Lead in Sediment Next to California Freeways,

Identification and Waste Management Options

Lead in Sediment Next to California Freeways,

Identification and Waste Management Options

Based on a presentation originally prepared by Julia Turney and

Marge Rouch

UPDATED 4/2007 KC

Does This Look Like a Hazardous Waste Site to You?

Does This Look Like a Hazardous Waste Site to You?

Topics of DiscussionTopics of Discussion

Where lead comes from and how lead levels Where lead comes from and how lead levels are identified are identified

Characteristics of lead next to freewaysCharacteristics of lead next to freeways Regulatory requirementsRegulatory requirements VarianceVariance Designing for leadDesigning for lead

Where Lead Comes FromWhere Lead Comes From Leaded Gasoline Leaded Gasoline Lead in yellow traffic paint and sand blast Lead in yellow traffic paint and sand blast

wastewaste Urban industry Urban industry Tire balance weights Tire balance weights Imported candy wrappersImported candy wrappers PesticidesPesticides

Lead DiscoveryLead Discovery Interstate 80 in EmeryvilleInterstate 80 in Emeryville

Project to add traffic lanes to freewayProject to add traffic lanes to freeway Excess material relinquished to the contractor Excess material relinquished to the contractor

and sent as clean fill to Chevronand sent as clean fill to Chevron Rejected as Calif. Hazardous WasteRejected as Calif. Hazardous Waste

Route 101 in Los AngelesRoute 101 in Los Angeles Soundwall Project near downtownSoundwall Project near downtown Excess material relinquished to the contractor Excess material relinquished to the contractor

and sent as clean fill to private land ownerand sent as clean fill to private land owner

Characteristics of Lead in SedimentCharacteristics of Lead in Sediment High total lead at surface next to edge of High total lead at surface next to edge of

the pavement, generally decreasing with the pavement, generally decreasing with depth and distance from the roaddepth and distance from the road

Highest levels of lead associated with Highest levels of lead associated with older roads with high traffic volume but older roads with high traffic volume but many variables affect depositionmany variables affect deposition

Lead Sample Concentration, 6 in.Lead Sample Concentration, 6 in.

6 INCH TOTAL LEAD LEVELS

21

14

18

11

37

37

3 3

10

0

5

10

15

20

25

0-

100

100-

200

200-

300

300-

400

400-

500

500-

600

600-

700

700-

800

800-

900

900-

1000

>100

0

Total Lead Levels ppm

Perc

enta

ge o

f 1300

Sam

ple

s

Lead Sample Concentration, 12 in.Lead Sample Concentration, 12 in.

12 INCH TOTAL LEAD LEVELS

54

10 104 7

04 4

0 07

0

10

20

30

40

50

60

0-10

0

100- 200

200- 300

300- 400

400- 500

500- 600

600- 700

700- 800

800- 900

900-

1000

>100

0

Total Lead ppm

Perc

enta

ge o

f 100

0 Sa

mpl

es

Lead Sample Concentration, 24 in.Lead Sample Concentration, 24 in.

24 INCH TOTAL LEAD LEVELS

84

40

40

4 40 0 0 0

0

10

20

30

40

50

60

70

80

90

0-100

100-200

200-300

300-400

400-500

500-600

600-700

700-800

800-900

900-1000

>1000

Total Lead ppm

Perc

enta

ge o

f 700 S

am

ple

s

Regulatory RequirementsRegulatory Requirements Title 22 CCR defines a waste is a material Title 22 CCR defines a waste is a material

that is discarded or relinquished or treated that is discarded or relinquished or treated in a manner constituting disposalin a manner constituting disposal

Title 23 CCR regulates placement of waste Title 23 CCR regulates placement of waste in landfillsin landfills

Regulatory Requirements cont’Regulatory Requirements cont’

Waste is Hazardous by Ca law if total lead Waste is Hazardous by Ca law if total lead levels are greater than 1000mg/kg or levels are greater than 1000mg/kg or soluble lead by Waste Extraction Test is soluble lead by Waste Extraction Test is greater than 5mg/l. A fed waste is greater greater than 5mg/l. A fed waste is greater than 5mg/l soluble by the TCLP test.than 5mg/l soluble by the TCLP test.

Regulatory Requirements cont.Regulatory Requirements cont.

Cal OSHA (Title 8 CCR) and Fed OSHA Cal OSHA (Title 8 CCR) and Fed OSHA regulate Lead in Construction regulate Lead in Construction

Adding traffic lanes usually involves Adding traffic lanes usually involves excavating about 2 feet of sediment for the excavating about 2 feet of sediment for the new pavement section. Soundwalls require new pavement section. Soundwalls require excavation for foundationsexcavation for foundations

VarianceVariance

Caltrans applied for and received a Caltrans applied for and received a Variance from Title 22 regulations to allow Variance from Title 22 regulations to allow stockpiling, transporting, and reuse of stockpiling, transporting, and reuse of sediment with hazardous levels of lead for sediment with hazardous levels of lead for seven Caltrans Districts (4,6,7,8,10,11,12)seven Caltrans Districts (4,6,7,8,10,11,12)

The Variance allows reuse under certain The Variance allows reuse under certain conditions:conditions:

Variance cont.Variance cont.

Less then 50 mg/l soluble lead (DI WET) & Less then 50 mg/l soluble lead (DI WET) & Less then 3397 mg/kg total leadLess then 3397 mg/kg total lead

5 feet above groundwater5 feet above groundwater Use of non-hazardous cover soil or pavementUse of non-hazardous cover soil or pavement Use of special provisions to direct and control Use of special provisions to direct and control

the contractorthe contractor Notification and inspection by Dept. of Toxic Notification and inspection by Dept. of Toxic

Substances ControlSubstances Control Out of 100 year flood plainsOut of 100 year flood plains

Variance: To Reuse Lead Soils as Fill MaterialsVariance: To Reuse Lead Soils as Fill Materials Existing variances are in effect until June Existing variances are in effect until June

30, 2008. 30, 2008. Notification to regional water quality Notification to regional water quality

control board 30 days prior to advertisement control board 30 days prior to advertisement is required.is required.

RWQCB can take 180 days to issue WDR RWQCB can take 180 days to issue WDR when they determine they are necessary.when they determine they are necessary.

Variance cont.Variance cont.

Placement on other projects in corridors. Placement on other projects in corridors. The regulatory definition of “corridors” is The regulatory definition of “corridors” is DIFFERENT from traditional Caltrans DIFFERENT from traditional Caltrans definition of a highway corridordefinition of a highway corridor

Major Conditions of Variance Use: Major Conditions of Variance Use:

Hazardous waste soils not addressed under Hazardous waste soils not addressed under variance are to be handled as a hazardous wastevariance are to be handled as a hazardous waste

Manage soils based on lead levelsManage soils based on lead levels One foot non-hazardous coverOne foot non-hazardous cover Under hard (asphalt) coverUnder hard (asphalt) cover Implement Health and Safety procedures to Implement Health and Safety procedures to

protect workers and public to eliminate or protect workers and public to eliminate or minimize exposureminimize exposure

Conditions of Variance Use cont.Conditions of Variance Use cont. Hazardous waste soils must stay within designated Hazardous waste soils must stay within designated

right of way corridor, stockpiling included. right of way corridor, stockpiling included. Reasonable allowances for transportationReasonable allowances for transportation

Soils not buried not allowed to be in contact with Soils not buried not allowed to be in contact with groundwater, within 10 feet of culverts, stored in low groundwater, within 10 feet of culverts, stored in low areas subject to flooding, and protected from runoff areas subject to flooding, and protected from runoff to storm drainsto storm drains

Changes in placement, quantities or protection Changes in placement, quantities or protection measures (field changes) from plans noted in RE log measures (field changes) from plans noted in RE log within 5 days of field changewithin 5 days of field change

Reuse Based on Total and Extractable Lead

Reuse Based on Total and Extractable Lead

Hazardous Waste>1000 mg/kg Total

or> 5.0 mg/l Soluble

Reusable Soil>1000 mg/kg Total>5mg/l Soluble

Surplus Soil>1000 mg/kg Total >5 mg/l Soluble

1’Cover with Non-HazSoil, 5’ Above groundwaterUnder pavement if DI WET is high.

Class 1 Disposal

Variance NotificationVariance Notification

Information availability:Information availability: Current fact sheets placed in the Caltrans RE Current fact sheets placed in the Caltrans RE

Office/District OfficesOffice/District Offices If additional projects are identified that are not If additional projects are identified that are not

in initial public notification - District must in initial public notification - District must notify public via a notice in newspapernotify public via a notice in newspaper

Variance Notification cont.Variance Notification cont. Comply with all applicable State policies for Comply with all applicable State policies for

SWRCB, RWQCB related to waste discharges to SWRCB, RWQCB related to waste discharges to landland

Dust must be controlledDust must be controlled NOTIFICATION (project specific) to DTSC at NOTIFICATION (project specific) to DTSC at

least 5 days prior to constructionleast 5 days prior to construction NOTIFICATION (project specific) to NOTIFICATION (project specific) to

RWQCB at least 30 days prior to RWQCB at least 30 days prior to advertisementadvertisement

Variance Notification cont. Variance Notification cont. Plan drawing designating limits of the corridor Plan drawing designating limits of the corridor

where lead-contaminated soils will be where lead-contaminated soils will be excavated, stockpiled, buried and coveredexcavated, stockpiled, buried and covered

Name and telephone number of project resident Name and telephone number of project resident engineer(s)engineer(s)

Summarize excavation quantitiesSummarize excavation quantities Special Provisions for project specific area, soil Special Provisions for project specific area, soil

excavation, transport and placementexcavation, transport and placement

Variance Notification cont.Variance Notification cont.

List of Caltrans contractors (general) for each List of Caltrans contractors (general) for each Caltrans project conducting any phase of work Caltrans project conducting any phase of work under the varianceunder the variance

Duration of corridor constructionDuration of corridor construction Location of sampling/analytical data is located Location of sampling/analytical data is located

( e.g. particular project file)( e.g. particular project file)

New Variance Notification RequirementNew Variance Notification Requirement Type of environmental document for each Type of environmental document for each

project, date of adoption,document project, date of adoption,document title,Clearing House number and where the title,Clearing House number and where the document is available for review. A copy document is available for review. A copy of the Notice of Exemption for any project of the Notice of Exemption for any project shall be sent with the notification.shall be sent with the notification.

Special ProvisionsSpecial Provisions Major areas of importance:Major areas of importance: Health and Safety Plan (Lead Compliance Plan)Health and Safety Plan (Lead Compliance Plan) Work Plan for handling and stockpiling materials Work Plan for handling and stockpiling materials

with hazardous levels of leadwith hazardous levels of lead No visible dust, water truck available at all times No visible dust, water truck available at all times

while performing earthwork, excavation or while performing earthwork, excavation or grubbing in lead areasgrubbing in lead areas

Bill of LadingBill of Lading

Additional Public Notice - Suggested by DTSCAdditional Public Notice - Suggested by DTSC

If residential area or areas of potential If residential area or areas of potential public relations problems - additional public public relations problems - additional public notice is advised; District’s callnotice is advised; District’s call

DTSC Role:DTSC Role:

Tracking of materialsTracking of materials Enforcement requests for inspection from Enforcement requests for inspection from

DTSC headquartersDTSC headquarters Inspections by Regional DTSC officesInspections by Regional DTSC offices

Some Basic Concepts of Handling/Placement: Some Basic Concepts of Handling/Placement: If at all possible reuse soils on the project, If at all possible reuse soils on the project,

surplus can be a major problem surplus can be a major problem Separate layers of materials to alter volumes Separate layers of materials to alter volumes

and/or make non-hazardous and/or make non-hazardous Embankment fill, contouring- fill-in areas, Embankment fill, contouring- fill-in areas,

creating mounds etc.creating mounds etc. Roadbase fill, excavate clean and replace Roadbase fill, excavate clean and replace

with contaminatedwith contaminated

Some Basic Concepts of Handling/Placement cont.Some Basic Concepts of Handling/Placement cont. Raise grades, e.g. Park and Ride lotsRaise grades, e.g. Park and Ride lots Behind retaining wallsBehind retaining walls Surcharge for future sites, i.e. on other Surcharge for future sites, i.e. on other

projectsprojects