August Mack Newsletter | July, 2019

Understanding Soil Management Plans
by Bryant Hoffer

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 may remain and institutional controls, such as an environmental restrictive covenant (ERC) are applied to the property. These restrictions are used to manage risks and control potentially completed exposure pathways. The increasing acceptance and use of ERCs have allowed for flexibility with closures, thus facilitating redevelopment activities.  However, these environmental restrictions must be recognized prior to redevelopment or construction activities. A common restriction is that soil disturbance cannot be performed without following a site-specific Soil Management Plan (SMP).  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/or 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.  SMPs should, at a minimum, identify the following:

  • 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 a SMP?

SMPs need to effectively communicate the above information to the contractors and site personnel prior to the soil disturbance/development activities begin.  A SMP should contain the following to be approved by a regulator:

  • Site background information
  • Details on the remaining impacts left on-Site
  • Summary of proposed work
  • Organizational structure and management responsibilities
  • Health and safety provisions
  • Planned excavation 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)
 

Although SMPs will vary based on the site location and specific residual impacts, the most important objective is to prevent potential exposure to any on-Site workers, neighbors, and/or Site visitors during redevelopment activities.

When Should an SMP Be Prepared?

SMPs are commonly produced before any construction occurs as part of the redevelopment process.  As such, 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 is becoming commonplace.  When residual soil and groundwater contamination is left in place, an ERC will typically require a site-specific 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.


Bryant Hoffer is a senior manager for August Mack Environmental, Inc. in its Indianapolis, IN office. He has more than ten years of experience with extensive knowledge regarding geological and hydrogeological investigations, monitoring well installation and abandonment, soil and groundwater sampling, vapor intrusion evaluation and mitigation, tank management, and environmental site assessments. He graduated with a Bachelor of Arts degree in Geology from Indiana University – Purdue University. Bryant can be contacted at 317.916.3163 or via e-mail at bhoffer@augustmack.com.


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