August Mack Newsletter | May, 2017

Understanding Soil Management Plans
by Charlie Gomez

Cleaning up contaminated properties can take a long time at great expense. In most cases, complete cleanup is not feasible and is cost prohibitive. As a result, residual contamination remains and environmental restrictions are applied to the property. These restrictions are used to manage risks and control completed or potentially completed exposure pathways. The increasing acceptance and use of environmental restrictions has allowed for flexibility with closures, thus facilitating redevelopment activities.  However, these environmental restrictions must be recognized prior to redevelopment or construction activities. A common environmental restriction is that soil disturbance cannot be performed without following an approved Soil Management Plan (SMP).  SMPs should be approved by a federal or state regulator, if not, it could lead to contaminant exposures, regulation violations, and potential fines.  Although SMPs are becoming a common restriction with risk based closures, there is currently no US EPA guidance on what constitutes an approved SMP. 

What Should an SMP Identify?

SMPs are necessary to control any potential exposure pathways at a Site where residual soil and groundwater contamination is present and allowed to remain in place.  Each SMP will be different because the SMP should be tailored to Site-specific conditions.  For an SMP to be approved by a regulator, it should, at a minimum, identify the following the information:

  • Define the area and extent of residual contamination left in place;
  • Outline the baseline health and safety provisions that are necessary to prevent potential exposure; and,
  • Provide plans to characterize, monitor, and manage any exposed impacts pursuant to Federal, State, and Local law.
     

What Should Be Included in an SMP?

The SMP needs to effectively communicate the above information to the contractors and site personnel prior to the soil disturbance/development activities begin.  Although there is no US EPA guidance on what needs to be included in an SMP, an SMP should contain the following to be approved by a regulator:

  • Site background information
  • Summary of proposed work
  • Remaining impacts left on-Site
  • Organizational structure and management responsibilities
  • Health and safety provisions
  • Excavation work plan activities
  • Dewatering activities, if shallow groundwater is present
  • Soil and groundwater screening/monitoring procedures
  • Stockpile management procedures
  • Decontamination plans for personnel and heavy equipment
  • Waste characterization, transport, and disposal protocol
  • Record keeping procedures
  • Other restrictive covenants
  • Odor control plan (if necessary)
  • Dust control and monitoring plan (if necessary)


 

Depending on Site–specific conditions, an SMP may include additional information and be more in-depth.  For instance, a Site located in a rural area where a heating oil tank spill occurred will have a different SMP than a Site where a former drycleaners operated in downtown New York City.  Although SMPs may vary, the most important objective is to prevent potential exposure of any on-Site workers, neighbors, and/or Site visitors during redevelopment activities, and ensure that current and future exposure pathways are controlled. 

When Should an SMP Be Prepared?

SMPs can be prepared during the Site closure process as part of an environmental restrictive covenant (ERC) on the property, or prior to redevelopment activities.  They are commonly produced before any construction occurs as part of the redevelopment process.  Therefore, the SMP can be written specifically for the proposed construction activities.  It is difficult to write an SMP during the closure process since future redevelopment activities may be unknown at that time.

Conclusion

With the increase in risk based closures, the use of ERCs on properties are becoming more common.  When residual soil and groundwater contamination is left in place, an ERC will typically require an approved SMP before any soil disturbance can be performed.  Although there is no US EPA guidance on what constitutes an SMP, it should include enough information to identify and manage the impacted areas in order to control the risks and prevent exposures.

To learn more about this topic, register to attend our free webinar, Soil Management Plans, on June 7, 2017 @ 3:00pm.


Charlie Gomez is a Project Manager/Geologist for closure services with August Mack Environmental, Inc. He has over 4 years of experience with knowledge regarding geological and hydrogeological investigations, State and Federal regulatory programs (e.g., CERCLA, RCRA, State Cleanup, Voluntary Remediation), soil and groundwater sampling, vapor intrusion evaluation and mitigation, remedial evaluation and regulatory coordination.  Charlie can be reached at 317.916.3141 or via e-mail at cgomez@augustmack.com.


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