NDOT Hazardous Materials Review 201: Section 1

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01/17/2020 Added

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This is the 2nd video in a series of 4. This 2nd section has 2 videos. Section 1, and Section 2 thru 5.

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[00:00:01.030]Welcome to Nebraska
[00:00:02.310]Department of Transportation's Hazardous Material
[00:00:04.930]Review Course 201
[00:00:07.320]titled The Hazardous Material Review Process.
[00:00:11.350]This course should take you
[00:00:12.270]approximately 60 to 90 minutes to complete.
[00:00:16.130]There are five lessons with a few questions to answer
[00:00:19.300]at the end of each lesson.
[00:00:21.670]Please retrieve your 2018 HMR Guidance Manual,
[00:00:25.760]and refer to it as needed.
[00:00:28.010]The slides will contain chapter and section as a footnote
[00:00:31.530]referencing the information's location in the manual.
[00:00:36.480]Before completing Course 201, have you completed Course 101,
[00:00:41.410]The Purpose of Conducting a Hazardous Materials Review?
[00:00:44.930]If you have not completed Course 101, please do so now
[00:00:47.860]prior to beginning Course 201.
[00:00:50.270]Do not take Course 201 unless you have taken Course 101.
[00:00:56.320]The objective of Course 201 is to provide participants
[00:00:59.560]with a more comprehensive presentation
[00:01:02.180]of the approved NDOT HMR Guidance,
[00:01:05.120]and specifics on what comprises an HMR.
[00:01:09.220]This course will provide participants details
[00:01:11.580]about the different types of HMRs
[00:01:13.920]and how to determine level of review.
[00:01:16.850]It will describe how to complete the database review,
[00:01:19.800]visual reconnaissance form and photo log.
[00:01:24.540]HMRs are intended to help NDOT staff
[00:01:27.530]identify potential existing hazardous materials concerns
[00:01:31.320]as an integral step of the advanced planning
[00:01:34.100]and environmental documentation stages
[00:01:36.600]of project development, and when applicable,
[00:01:40.390]to facilitate project alternative selection.
[00:01:44.690]The purpose of conducting HMRs is to evaluate each project
[00:01:47.970]for potential impacts from hazardous material sites
[00:01:51.310]on construction or vice versa, the impacts construction
[00:01:55.500]might have on a hazardous material site.
[00:01:58.220]Over the past several years, HMRs have become more in-depth
[00:02:01.770]and NDOT has worked to make the HMR process more consistent.
[00:02:06.160]The approved guidance manual
[00:02:07.500]has been in place since August 2015
[00:02:10.540]and was updated in 2018.
[00:02:14.850]The objective of lesson one is for participants
[00:02:17.220]to learn the initial phases of conducting an HMR.
[00:02:21.330]NDOT defines the HMR process as the activities required
[00:02:25.650]to identify the presence or likely presence
[00:02:28.510]of any hazardous material within the HMR Study Area.
[00:02:33.000]As previously mentioned, HMRs are intended to help NDOT
[00:02:37.120]identify potential hazardous materials concerns
[00:02:39.640]during the advanced planning
[00:02:41.040]and environmental documentation stages
[00:02:43.380]of project development, and when applicable
[00:02:46.660]to facilitate project alternative selection.
[00:02:50.590]HMRs for site-specific projects are used
[00:02:53.060]to identify the potential
[00:02:55.150]for encountering contamination during construction
[00:02:58.400]and whether materials management
[00:02:59.940]and work health and safety are impacted.
[00:03:04.690]What is a hazardous material?
[00:03:07.130]For the purposes of completing an HMR,
[00:03:09.780]NDOT defines hazardous materials
[00:03:12.470]as a broad category of materials
[00:03:15.410]that because of their quantity, concentration,
[00:03:18.050]or physical or chemical characteristics
[00:03:20.550]pose a significant present or potential hazard
[00:03:23.280]to human health and safety
[00:03:25.220]or to the environment if released into the environment.
[00:03:30.930]Hazardous materials include but are not limited to:
[00:03:35.260]materials that are regulated as solid waste,
[00:03:37.970]hazardous waste, or other wastes contaminated
[00:03:41.700]with hazardous substances, radioactive materials,
[00:03:46.080]petroleum fuels, toxic substances and pollutants.
[00:03:52.370]A hazardous materials review is completed
[00:03:54.730]to determine if the project will impact a HazMat site,
[00:03:59.130]or if a HazMat site will impact the project.
[00:04:03.320]There are three conclusions or findings
[00:04:06.350]which can be reached through the HMR process
[00:04:09.150]indicating low, medium or high potential
[00:04:13.300]for impacts related to hazardous materials
[00:04:16.190]in the construction of the project.
[00:04:19.350]For a low potential site, through investigation
[00:04:23.130]it's determined unlikely
[00:04:25.200]contamination would be encountered during construction.
[00:04:28.780]For example, a leaking underground storage tank site
[00:04:31.730]would be considered a low potential site
[00:04:34.440]when through review contamination was determined
[00:04:37.670]not to be within the project footprint.
[00:04:42.490]For a medium potential site, during investigation
[00:04:46.070]it's unclear whether contamination is located
[00:04:50.010]in the project footprint.
[00:04:52.520]A subsurface investigation or further coordination
[00:04:55.680]with regulatory agencies determines it is unlikely
[00:04:59.600]contamination would be located in the project footprint.
[00:05:04.070]On a case-by-case basis,
[00:05:05.920]a commitment to the contractor and NDOT project manager
[00:05:09.720]to look for signs of contamination in specific areas
[00:05:13.260]can be included in the HMR
[00:05:15.700]rather than proceeding with a subsurface investigation.
[00:05:19.750]For example, it may be unlikely contamination is present
[00:05:23.430]in the project footprint after additional investigations,
[00:05:27.810]but a project scope change
[00:05:29.280]adjacent to a medium potential site
[00:05:31.800]could result in a change in conclusion to high potential.
[00:05:36.140]For instance, an example of where a medium potential site
[00:05:39.660]is the conclusion occurred during the Fairbury West project.
[00:05:44.800]There was a release in 2015 from a tank overspill incident,
[00:05:49.280]and leaks in the tank fuel-line were discovered.
[00:05:52.260]The tank is located at the back of the property.
[00:05:54.970]The site has poor housekeeping practices,
[00:05:57.730]and the project scope of work
[00:05:59.070]was for minor shallow excavations.
[00:06:02.470]Due to the close proximity to the project
[00:06:05.100]and the visual reconnaissance observations of the facility,
[00:06:09.140]the site was listed as medium potential
[00:06:11.660]because of the proposed scope of work.
[00:06:14.470]However, if the proposed scope of work were to change
[00:06:18.780]and the excavation encounters groundwater
[00:06:20.850]or extends into the property for right-of-way acquisition,
[00:06:25.100]the facility may be changed to high potential to impact.
[00:06:29.260]Otherwise, as a medium potential to impact,
[00:06:32.660]the recommendation was a stronger mitigation measure
[00:06:35.840]in addition to the unexpected waste mitigation measure.
[00:06:41.290]For a high potential site,
[00:06:43.620]through file review or subsurface investigation,
[00:06:46.610]it's been determined contamination
[00:06:48.520]would likely be encountered during construction.
[00:06:51.940]An example would be a grain elevator with a shop building
[00:06:55.210]which has historically been located
[00:06:56.840]near the project footprint and was in operation
[00:06:59.730]during the 1940s through the 1960s
[00:07:02.930]when the use of carbon tetrachloride was common.
[00:07:06.470]The site is sampled for volatile organic compounds or VOCs,
[00:07:11.000]and petroleum products.
[00:07:13.420]Soil and groundwater contamination is found at levels
[00:07:16.480]high enough to be a human health and safety concern.
[00:07:22.210]The level of effort required for conducting an HMR
[00:07:25.000]is based on several factors:
[00:07:27.610]the level of environmental NEPA documentation,
[00:07:30.690]categorical exclusion versus environmental assessment
[00:07:33.640]or environmental impact statement,
[00:07:36.930]the potential impacts to construction,
[00:07:38.940]materials management, human health and safety,
[00:07:42.900]site-specific projects,
[00:07:45.700]alternatives analysis projects.
[00:07:48.970]Lastly, consult with NDOT
[00:07:51.350]HazMat Professionally Qualified Staff or PQS
[00:07:55.640]on the level of effort for the HMR.
[00:07:58.960]A reminder, the majority of HMRs
[00:08:01.340]are for site-specific projects.
[00:08:05.430]The HMRs are either for site-specific projects
[00:08:09.150]or for projects with in-depth alternatives analysis.
[00:08:14.670]The majority of HMRs are for site-specific projects.
[00:08:18.940]The details of HMRs for projects
[00:08:21.060]with in-depth alternatives analyses
[00:08:24.210]are covered in a more advanced course.
[00:08:27.530]The top image is a site-specific project,
[00:08:30.610]a bridge replacement.
[00:08:32.350]The only alternatives are build and no-build.
[00:08:37.120]The bottom image is a project with three alternatives:
[00:08:40.720]no-build, alternative one, and alternative two.
[00:08:49.470]NDOTs Hazardous Materials Review Guidance Manual
[00:08:53.170]originally published in 2015 and updated in 2018
[00:08:57.950]includes the HMR flowchart.
[00:09:00.550]Please see page 4-2
[00:09:03.092]of the 2018 HMR Guidance Manual.
[00:09:07.330]Each time there's a black hexagon,
[00:09:09.480]a decision needs to be made.
[00:09:11.570]Sometimes the decisions can be made
[00:09:13.360]with your own professional judgment,
[00:09:15.460]and other times it is to make a recommendation
[00:09:18.540]for next steps in consultation
[00:09:20.630]with NDOT HazMat PQS before proceeding to the next step.
[00:09:26.850]Brown boxes are process points,
[00:09:29.550]things the practitioner will need to complete
[00:09:32.050]in order to progress through the flowchart.
[00:09:35.800]Yellow boxes are major steps in the process
[00:09:38.660]such as approval points or deliverables.
[00:09:42.600]Blue boxes identify when the HMR process
[00:09:45.480]is considered complete.
[00:09:50.580]Now let's briefly walk through each of the steps
[00:09:53.530]of the HMR process.
[00:09:55.470]These steps will be covered in-depth
[00:09:57.320]through the rest of this 201 course.
[00:10:02.370]Step one, if the project is exempt, document it,
[00:10:06.330]and save for the administrative record.
[00:10:09.410]It's important to keep in mind
[00:10:11.220]that an environmental contract with NDOT
[00:10:13.910]may include the completion of an HMR.
[00:10:16.570]However, there may not be project information at the time
[00:10:20.040]to know whether the project is exempt from an HMR.
[00:10:24.020]Please consult with the NDOT HazMat PQS
[00:10:27.630]to determine if a project is exempt
[00:10:29.870]and does not require an HMR.
[00:10:35.020]Step two, if the project is not exempt,
[00:10:38.640]ask if project excavations will be to a depth
[00:10:41.540]to encounter groundwater.
[00:10:45.670]Step three, is a visual reconnaissance warranted?
[00:10:49.330]Usually yes, but in some instances it may not be.
[00:10:53.460]Consult with NDOT during contract scoping
[00:10:56.200]or prior to going out to the site for HMR purposes.
[00:11:02.510]Step four, if excavations will encounter groundwater,
[00:11:06.660]identify all HazMat sites within the HMR Study Area
[00:11:10.840]and any facility beyond where contamination
[00:11:13.760]may have migrated
[00:11:15.250]to within one tenth of a mile through groundwater.
[00:11:19.040]It's important to determine
[00:11:20.410]if groundwater might be encountered
[00:11:22.490]due to potential impacts to exposure pathways,
[00:11:25.650]including the potential to exacerbate
[00:11:27.960]the spread of contamination through groundwater.
[00:11:34.950]Step five, if no excavation will encounter groundwater,
[00:11:39.200]identify all HazMat sites within the HMR Study Area.
[00:11:43.300]Possibly conduct visual reconnaissance
[00:11:45.700]and additional analysis.
[00:11:50.370]Step six, upon review of the regulated sites,
[00:11:54.010]if all sites are considered low potential
[00:11:56.240]to impact the project, the HMR can be completed,
[00:11:59.750]findings summarized, and mitigation measures identified.
[00:12:03.870]If regulated sites require additional information
[00:12:06.610]to determine the potential for impact,
[00:12:08.880]a regulatory file review may be necessary.
[00:12:12.690]If after the regulatory file review,
[00:12:14.900]it's determined that all sites are considered low potential
[00:12:18.050]to impact the project, then the HMR can be completed,
[00:12:21.650]findings summarized, and mitigation measures identified.
[00:12:26.480]Step seven, if one HazMat site has medium or high potential,
[00:12:31.700]consult NDOT HazMat PQS.
[00:12:37.050]Step eight, consultation with NDOT HazMat PQS
[00:12:41.550]and regulatory authorities will determine
[00:12:43.900]if a subsurface investigation is or is not necessary.
[00:12:50.160]Step nine, if the subsurface investigation
[00:12:53.050]reveals no contamination, then the HMR may be completed,
[00:12:57.200]findings summarized, and mitigation measures identified.
[00:13:02.700]Step 10, if the subsurface investigation
[00:13:06.170]does reveal contamination, consult with NDOT HazMat PQS.
[00:13:11.680]Consultation with Nebraska Department of Environment
[00:13:14.210]and Energy and/or other agencies may be required.
[00:13:20.480]Step 11, upon completion of the subsurface investigation
[00:13:24.610]and agency coordination if required,
[00:13:27.540]identify any project-specific health and safety measures
[00:13:31.310]and commitments to be documented in the HMR report.
[00:13:37.050]Step 12, complete the HMR report,
[00:13:41.060]summarize the findings and mitigation measures
[00:13:43.380]for the project, and attach figures,
[00:13:45.640]project descriptions and any pertinent regulatory files
[00:13:49.330]that would aid NDOT in their review.
[00:13:52.480]Upon NDOT's review, address comments
[00:13:55.730]and revise the report if necessary for the PQS approval.
[00:14:02.570]Step 13, the final step,
[00:14:05.130]after the PQS has approved the HMR report
[00:14:08.990]is to summarize the findings in the NEPA document
[00:14:12.250]and carry forward commitments
[00:14:14.070]in the NEPA documentation and Green Sheets.
[00:14:17.710]Additionally, the PQS memo
[00:14:20.070]should be attached to the NEPA documentation.
[00:14:25.660]Databases are searched for sites
[00:14:27.550]within a specific distance beyond the project area,
[00:14:30.300]approximately 1/10 of a mile and ranging up to one mile
[00:14:33.960]for active regulatory cleanup sites
[00:14:36.540]such as voluntary cleanup program or Superfund sites.
[00:14:41.040]This is referred to as the HMR Study Area.
[00:14:45.460]For linear transportation projects, the distance
[00:14:47.690]is generally from the existing or proposed right-of-way,
[00:14:51.780]temporary or permanent if known.
[00:14:54.460]Otherwise, the distance is from the project center line
[00:14:57.590]or edge of pavement.
[00:14:59.580]For bridge projects, the distance
[00:15:01.580]is generally from the center of the bridge
[00:15:04.030]or bridge footprint.
[00:15:06.650]The minimum distances may be extended
[00:15:08.760]at the discretion of the environmental professional
[00:15:10.900]completing the review, particularly if there is potential
[00:15:14.340]for contamination to have migrated
[00:15:16.200]into the project footprint
[00:15:17.940]from a source outside of the 1/10 mile search radius.
[00:15:22.400]For example, if the project scope of work
[00:15:24.500]involves excavation to groundwater, there may be potential
[00:15:27.800]for contaminant plume migration to impact construction.
[00:15:31.620]For instance, some contamination plumes
[00:15:34.040]are more than one mile long, especially in the case
[00:15:37.280]of large-scale volatile organic compounds or VOCs,
[00:15:42.120]or semi-volatile organic compound contamination.
[00:15:45.800]Grand Island, Hastings, and Mead Department of Defense sites
[00:15:49.210]are all good examples.
[00:15:52.410]The approximate minimum distance
[00:15:54.330]should include any right-of-way, temporary or permanent,
[00:15:57.930]that may be needed for construction
[00:15:59.960]and should be sufficient to evaluate minor scope changes,
[00:16:03.160]minor shifts in the alignments,
[00:16:05.240]and other possible redesign options
[00:16:07.170]to avoid hazardous material involvement.
[00:16:10.080]For projects with alternatives analysis,
[00:16:12.780]the approximate minimum search distance
[00:16:15.340]should be sufficient to evaluate the potential alternative
[00:16:19.000]for hazardous materials concern.
[00:16:21.430]Here are some example HMR location maps NDOT has approved.
[00:16:27.110]An urban area showing the one-mile HMR Study Area,
[00:16:31.380]note that there are three Superfund sites
[00:16:33.620]within the one mile radius.
[00:16:36.930]Here's an example of an HMR location map
[00:16:39.710]in a more rural setting.
[00:16:42.000]Note the importance of showing the location
[00:16:44.180]of regulated sites relative to the project alignments.
[00:16:49.780]When a site is identified
[00:16:51.060]that might have the potential to impact the project,
[00:16:54.160]it may be beneficial to create another figure
[00:16:57.010]zooming in on the site.
[00:16:58.940]In this example,
[00:16:59.800]a former atlas missile silo site was identified
[00:17:03.950]and a zoomed-in map was provided in the HMR
[00:17:07.420]showing the site on an aerial photograph.
[00:17:10.770]The missile silo, a Superfund site, had a contaminant plume
[00:17:15.140]which went underneath the proposed project location.
[00:17:18.530]However, it was not considered within the project footprint
[00:17:22.310]because excavation was not going to be deep enough
[00:17:25.710]to encounter groundwater.
[00:17:28.600]Assessing the physical setting of the project is imperative
[00:17:32.440]because if a HazMat site exists,
[00:17:34.750]you need to know how the potential contamination
[00:17:37.370]may have migrated from the site.
[00:17:39.690]Some questions to be answered include,
[00:17:43.100]is the project in a rural or urban location?
[00:17:47.140]Is the topography flat, sloping or rolling?
[00:17:51.510]What is the surface hydrology of the site?
[00:17:54.150]Which direction does the surface water drain?
[00:17:57.620]Is the area covered with vegetation
[00:17:59.720]or is it a paved surface?
[00:18:02.560]What is the depth to groundwater or the static water level?
[00:18:07.000]Which direction does the groundwater flow?
[00:18:10.070]All of these physical setting attributes play a role
[00:18:13.250]in the ultimate determination of low, medium,
[00:18:16.290]or high potential impacts for any project.
[00:18:21.160]Groundwater flow direction can be determined by looking
[00:18:24.210]at United States Geological Survey topographic maps,
[00:18:28.130]and Nebraska Department of Natural Resources elevation data.
[00:18:32.570]Groundwater and surface water
[00:18:34.420]do not always mirror each other,
[00:18:36.730]so a general understanding of the physical setting
[00:18:39.260]is important to evaluating for potential impacts.
[00:18:43.440]The most reliable source for depths
[00:18:45.690]come from NDEE regulatory files for a site.
[00:18:50.420]Groundwater usually flows downhill
[00:18:53.080]from higher elevations to lower elevations.
[00:18:56.250]This is also referred to as topographic gradient.
[00:19:00.240]Site locations may be referred to as up-gradient,
[00:19:03.930]cross-gradient, or down-gradient from the project area.
[00:19:10.240]A site is considered topographically up-gradient
[00:19:14.030]from the project area when based on topographic relief,
[00:19:18.200]it is higher in elevation than the project
[00:19:21.310]and upstream from the project area
[00:19:23.320]in regard to drainage and groundwater flow direction.
[00:19:29.200]A site is considered topographically down-gradient
[00:19:32.080]from the project area when based on topographic relief,
[00:19:36.010]it is lower in elevation than the project area
[00:19:39.180]and downstream from the project area
[00:19:41.620]in regard to drainage and groundwater flow direction.
[00:19:46.700]A site is considered topographically cross-gradient
[00:19:50.100]from the project area when based on topographic relief,
[00:19:53.700]it is at the same elevation in relation to the project area
[00:19:57.930]and/or parallel to the project area
[00:20:01.110]in regard to drainage and groundwater flow direction.
[00:20:05.900]Determining the depth to groundwater
[00:20:07.810]within the HMR Study Area can be done
[00:20:10.620]by using the NDNR groundwater well database
[00:20:14.560]which catalogs registered wells.
[00:20:17.580]The NDNR's interactive map shows all registered wells
[00:20:21.230]within the state by well type and category.
[00:20:25.750]The type of well may be important
[00:20:27.310]depending on the overall review
[00:20:28.790]of the area and nearby sites.
[00:20:31.210]If multiple monitoring wells are shown
[00:20:34.060]which are yellow in color,
[00:20:35.930]it may indicate past or current contamination.
[00:20:39.720]Potential exposure pathways may also be identified
[00:20:42.940]using well type, such as domestic drinking water wells
[00:20:46.770]or commercial and industrial wells.
[00:20:51.720]Registered well information includes the static water level,
[00:20:55.880]and can be used to document
[00:20:57.260]the site characteristics at that location.
[00:21:00.120]It can also indicate red flags.
[00:21:02.610]For instance, a cluster of registered wells might indicate
[00:21:06.420]a mining operation or a remedial action site.
[00:21:10.790]The image on the right shows the wells
[00:21:12.780]associated with uranium mining east of Crawford, Nebraska
[00:21:17.440]which is no longer in operation.
[00:21:22.140]To find registered wells, type in DNR.Nebraska.gov.
[00:21:29.140]Click on Services in the top right-hand corner.
[00:21:35.460]Scroll down and click on Groundwater.
[00:21:41.220]Then scroll down and click on Interactive Maps.
[00:21:57.650]Next, zoom in on the map to your desired area
[00:22:01.830]until the wells are shown.
[00:22:25.490]Zoom in further for an aerial map,
[00:22:28.220]and then wells are shown in different colors
[00:22:30.580]depending on their use, commercial, monitoring, industrial.
[00:22:35.920]Click on an individual well.
[00:22:37.400]Then click on View Additional Details
[00:22:40.510]in the upper left-hand corner.
[00:22:46.800]We scroll down on the left to SWL
[00:22:51.090]or static water level.
[00:22:55.240]This determines our groundwater depth.
[00:23:01.360]The project footprint as it relates to hazardous materials
[00:23:04.350]is defined as the area on a project site
[00:23:07.460]where excavation or work occurs
[00:23:10.130]to construct the project improvements,
[00:23:12.320]including work on such features
[00:23:14.010]as the roadway and structures such as a bridge.
[00:23:17.880]The project footprint includes
[00:23:19.340]vertical and horizontal attributes
[00:23:22.150]of the project's construction activity,
[00:23:24.290]including depth of excavation.
[00:23:27.460]If there is contamination under the roadway
[00:23:29.870]but excavation is not to a depth where it will be reached,
[00:23:33.580]then the contamination is not within the project footprint.
[00:23:37.300]If contamination is under the roadway
[00:23:39.690]and excavation will reach it,
[00:23:42.110]it is within the project footprint.
[00:23:46.860]This figure from a remedial action plan
[00:23:49.410]shows the static water elevation at 75 feet
[00:23:53.430]or the blue line in the top figure.
[00:23:56.940]The red lines are the levels of contamination.
[00:24:00.340]ND means non-detect.
[00:24:03.430]Soil types are shown in green or sand and clay.
[00:24:07.860]If the project's excavation is 25 feet for utilities,
[00:24:12.220]then the existing contamination would not be impacted.
[00:24:15.710]Therefore, the existing contamination is considered
[00:24:18.710]not within the project footprint.
[00:24:21.960]If the project's excavation is 100 feet for bridge piers,
[00:24:26.850]then the existing contamination would be impacted,
[00:24:30.200]and further coordination with NDOT
[00:24:32.740]and NDEE would need to occur.
[00:24:37.870]Another figure from the same remedial action report
[00:24:40.780]showing the contamination plume,
[00:24:43.210]but knowing the depth of contamination
[00:24:45.560]and depth of excavation determines
[00:24:48.230]whether it's in the project footprint.
[00:24:51.180]The site may still be documented
[00:24:52.690]as a concern for the project,
[00:24:54.720]but would be considered a low potential
[00:24:57.120]to impact project construction activities,
[00:24:59.880]and the mitigation measure would be
[00:25:01.430]the standard unexpected waste mitigation measure.
[00:25:07.250]The purpose of conducting an environmental database review
[00:25:10.970]is to identify known contamination sources
[00:25:13.630]and regulated or registered sites.
[00:25:16.680]An agency environmental database review
[00:25:19.140]consists of a search of federal, state,
[00:25:21.390]and tribal environmental databases.
[00:25:24.380]These databases contain information for sites,
[00:25:27.420]i.e. properties with known contamination,
[00:25:30.430]or sites that generate, treat, store
[00:25:33.240]or dispose of hazardous materials
[00:25:35.610]that could have potential contamination concerns.
[00:25:39.160]There are several ways
[00:25:40.250]to complete an agency database review.
[00:25:42.910]However, the suggested way includes
[00:25:45.620]starting with one, utilizing
[00:25:48.330]the Nebraska Department of Environment and Energy
[00:25:51.250]interactive web-based interpretive tool,
[00:25:54.660]Interactive Mapping System,
[00:25:57.590]and/or two, contracting a database search firm.
[00:26:03.890]Several existing databases also provide valuable information
[00:26:07.350]when further details are needed
[00:26:09.410]or when the first two searches
[00:26:11.480]do not provide enough information.
[00:26:13.960]These include the EPA's EnviroMapper tool,
[00:26:18.080]the National Response Center, and the Nebraska State
[00:26:21.330]Fire Marshal's registered tank databases.
[00:26:25.610]The NDEE IMS provides data
[00:26:29.550]on several programs relevant to hazardous materials analysis
[00:26:33.660]and provides links from the database
[00:26:35.620]to the online regulatory file records depository
[00:26:39.200]via the NDEE content management portal.
[00:26:43.940]Contracting a database search firm to conduct the agency
[00:26:47.270]environmental database search is a quick
[00:26:49.800]and typically cost-effective way to search the agency
[00:26:53.040]environmental databases for a specific project.
[00:26:59.970]The State Fire Marshal Tank Database
[00:27:03.200]is a good source for tank closure.
[00:27:06.570]Other contacts and resources are listed in Appendix B
[00:27:10.520]of the HMR Guidance Manual.
[00:27:14.300]The NDEE IMS should be used for all projects.
[00:27:19.810]Vendors like EDR could be used in areas
[00:27:23.320]where contamination is known to have occurred
[00:27:25.820]or there is a greater probability it has occurred,
[00:27:28.920]such as industrial, light industrial, developed areas,
[00:27:32.690]or other multi-tenant retail property areas
[00:27:36.070]such as dry cleaners or gas stations.
[00:27:39.590]Be sure to request permission from NDOT PQS
[00:27:43.450]prior to utilizing a vendor report.
[00:27:48.080]Conduct the database review
[00:27:49.700]once the project activities are known.
[00:27:53.420]Depth of excavation and groundwater depth information
[00:27:56.840]as previously discussed is needed to determine
[00:28:00.000]if groundwater will be encountered during construction.
[00:28:04.630]Please keep in mind NDOT activities
[00:28:07.450]more likely to have impacts to HazMat sites:
[00:28:11.360]projects with right-of-way acquisition,
[00:28:14.140]easements or displacements,
[00:28:16.920]projects with structure removal or modification,
[00:28:21.500]underground utility or pipeline work,
[00:28:25.020]installation of columns or piers,
[00:28:28.430]excavations greater than five feet deep,
[00:28:32.170]grading in urbanized areas,
[00:28:34.940]and construction of foundations
[00:28:36.460]for new or relocated lighting
[00:28:38.650]or traffic signals or overhead signs.
[00:28:43.520]There are also NDOT activities
[00:28:45.910]with fewer hazardous materials concerns.
[00:28:49.410]They include projects in rural areas
[00:28:52.500]with no evidence of previous contamination,
[00:28:55.930]projects involving no earthwork or trenching,
[00:28:59.830]and projects involving no new right-of-way.
[00:29:04.860]During the database review, some facilities
[00:29:06.930]to look for include: leaking underground
[00:29:10.120]and aboveground storage tanks, spills,
[00:29:14.170]dry cleaning facilities, Superfund sites,
[00:29:18.100]industrial sites, missile silos,
[00:29:22.010]USDA grain bins, asbestos,
[00:29:26.620]lead-based paint,
[00:29:28.770]release assessment sites and maintenance shops.
[00:29:35.480]If groundwater will be encountered during excavation,
[00:29:39.120]the search distance would be one mile
[00:29:41.900]to determine if contamination from a source has migrated.
[00:29:46.100]If groundwater will not be encountered
[00:29:48.150]or there is no excavation, the search distance will be less
[00:29:52.830]because contamination in the soil does not spread
[00:29:56.160]like contamination in the groundwater.
[00:29:59.960]If a detailed records review is conducted,
[00:30:02.860]all findings should be recorded in the HMR.
[00:30:06.420]Copies of pertinent regulatory files should be included
[00:30:10.020]in the HMR appendices.
[00:30:12.510]Pertinent files include: site maps, groundwater flow maps,
[00:30:18.100]closure assessments, NDEE correspondence,
[00:30:23.420]executive summaries of monitoring reports,
[00:30:26.240]and no further action letters.
[00:30:31.250]Updates may be warranted during construction
[00:30:33.640]to address changes in project scope, design,
[00:30:37.610]or length of time since last review.
[00:30:40.420]These changes need to be documented
[00:30:42.160]in a consultant or contractor change order.
[00:30:45.720]The shelf life of the HMR is one year
[00:30:48.750]from completion of the report.
[00:30:51.640]It's important updates occur
[00:30:53.260]in tangent with the project moving on in design
[00:30:56.760]such as final design,
[00:30:58.890]plans, specifications and estimates or PS&E,
[00:31:03.230]right-of-way, and right before the project
[00:31:05.900]is let for construction.
[00:31:09.290]If the scope of the project changes,
[00:31:11.650]the HMR should be reevaluated.
[00:31:14.970]If previous concerns or conclusions
[00:31:17.110]are affected due to the scope change,
[00:31:19.630]additional review such as but not limited
[00:31:22.710]to a regulatory file review may be required.
[00:31:27.240]If more than one year has passed
[00:31:29.210]since the original HMR was completed, a written reevaluation
[00:31:33.980]of the original findings may be required.
[00:31:38.730]Most projects require a visual reconnaissance,
[00:31:42.270]but in some cases such as when it's a rural setting
[00:31:46.090]and nothing has returned on the database search,
[00:31:48.800]a visual reconnaissance may not be required.
[00:31:52.220]If another technical resource is going to be onsite,
[00:31:55.060]ask them to take pictures of the project
[00:31:57.910]to be sure something isn't missed.
[00:32:01.190]The other time visual reconnaissance is not required
[00:32:04.460]is exempt projects.
[00:32:07.450]Generally, the visual reconnaissance is limited
[00:32:10.040]to areas visible from the public right-of-way
[00:32:12.920]and does not include access to fenced areas,
[00:32:15.840]interiors of buildings, rear lots,
[00:32:18.940]or alley-side portions of adjacent sites
[00:32:21.780]or areas not visible from the public right-of-way.
[00:32:25.730]Know the project footprint compared to the adjacent area.
[00:32:31.900]Look at the previous and current land uses for evidence
[00:32:35.280]of hazardous materials used, storage and disposal.
[00:32:40.280]The visual reconnaissance can also help verify
[00:32:42.960]building occupants, addresses, locations,
[00:32:46.950]and current property uses of sites
[00:32:49.420]identified in the agency environmental database review.
[00:32:53.420]The staff performing the visual reconnaissance
[00:32:56.050]should also look for visible evidence
[00:32:58.250]of hazardous materials concerns at sites identified
[00:33:01.730]in the agency environmental database search as necessary.
[00:33:07.030]Appendix C of the 2018 HMR Guidance Manual
[00:33:11.780]includes a description of reference items
[00:33:14.490]that may be identified during the visual reconnaissance.
[00:33:18.290]Visual recon if necessary is visiting the project footprint
[00:33:22.770]to physically look for sites.
[00:33:25.120]The NDEE IMS, and vendor report
[00:33:29.640]would have already taken place at this point,
[00:33:32.030]so you will have maps and an idea of what is in the area.
[00:33:37.767]NDOT requires the standard visual reconnaissance form
[00:33:41.700]be used to document the visual reconnaissance
[00:33:45.120]and be submitted to the project file.
[00:33:47.770]The form is completed for the entire HMR Study Area
[00:33:51.660]and within the HMR Study Area as described in Table 4.1.
[00:33:57.640]The standard visual reconnaissance form must be reviewed
[00:34:01.000]and signed by a qualified EP if the work is conducted
[00:34:05.920]by someone who does not meet the definition of an EP.
[00:34:11.050]Only check the impacts box if something was identified
[00:34:16.180]which could impact the project.
[00:34:18.860]Only check the recommendations
[00:34:21.360]if something was identified during the visual recon.
[00:34:27.540]Observations about the current use
[00:34:29.850]and current site conditions
[00:34:31.240]within and adjacent to the project area
[00:34:34.200]should be recorded on the visual reconnaissance form
[00:34:37.280]in the findings and conclusions section.
[00:34:40.450]This information is also to be included in the photo log.
[00:34:44.840]Also, limitations such as snow cover preventing observations
[00:34:50.230]of ground conditions should be documented.
[00:34:53.870]The facility names and addresses of adjacent properties
[00:34:57.120]and observations concerning these properties
[00:34:59.610]should also be included.
[00:35:01.810]Observations of water wells
[00:35:04.070]including monitoring wells in particular
[00:35:06.750]should be noted and their locations identified.
[00:35:11.080]Reviewing the physical setting is particularly important
[00:35:14.510]when it is suspected contamination could migrate
[00:35:17.800]from a nearby site into the project area,
[00:35:20.700]or existing contamination in the project area
[00:35:23.640]has the potential to affect soil and groundwater
[00:35:26.870]and could affect the project
[00:35:28.240]in terms of materials management
[00:35:30.470]and/or worker health and safety.
[00:35:33.690]The standard visual reconnaissance form
[00:35:35.690]contains a checklist of items
[00:35:37.230]commonly associated with hazardous materials
[00:35:40.140]use, storage, and disposal
[00:35:42.740]to be looked for during the visual reconnaissance.
[00:35:47.440]The photo on the right shows a grain elevator
[00:35:49.870]in the background and a former service station
[00:35:53.060]that's now a liquor store.
[00:35:55.490]Both land uses should indicate to the HMR practitioner
[00:35:59.550]that a closer look such as additional regulatory file review
[00:36:04.840]is warranted based on associated activities
[00:36:08.230]with historically operated service stations
[00:36:10.870]and grain elevators.
[00:36:14.670]Please note if the bridges within the project footprint
[00:36:17.810]have paint on them.
[00:36:20.210]Please photograph the paint on the bridges
[00:36:23.380]and include these photos in the photo log.
[00:36:26.290]Most of the paint may be under the bridge.
[00:36:29.720]The left photo shows no paint on the side of the bridge.
[00:36:33.890]The right photo shows silver paint under the same bridge.
[00:36:38.580]For corridor-level and large linear projects,
[00:36:42.350]there may be numerous adjacent properties
[00:36:44.480]that need to be documented during the site reconnaissance.
[00:36:48.290]If necessary, prior to conducting the site visit,
[00:36:51.460]print additional pages of the visual reconnaissance form
[00:36:55.260]to record the adjacent property information
[00:36:58.190]or record information on a corridor-level map.
[00:37:03.920]During the visual reconnaissance, think outside the box.
[00:37:07.980]Think about unknown container contents,
[00:37:11.316]1996 tank regulations,
[00:37:14.660]buildings and structures historically used
[00:37:17.090]for activities associated with known concerns,
[00:37:20.810]industrial or manufacturing by-products,
[00:37:24.120]stockpiles, debris, et cetera
[00:37:26.670]which may appear harmless but could be treated or processed
[00:37:30.410]with hazardous substances or petroleum products.
[00:37:34.130]And remember, pre-1975 landfills
[00:37:37.950]may not be documented.
[00:37:42.540]Observations made during the visual reconnaissance
[00:37:45.010]should also be documented with photographs and field notes.
[00:37:49.580]Photographs should be documented in the photograph log
[00:37:53.180]with the date and time of the visual reconnaissance,
[00:37:56.580]compass orientations or directions of the photo,
[00:38:01.080]describe what is in the photo
[00:38:03.870]and why the photo is of interest to the HMR,
[00:38:07.800]including specific hazardous materials
[00:38:09.970]observations and concerns.
[00:38:12.760]Please try to be succinct.
[00:38:15.570]Field notes can be completed on maps such as corridor maps
[00:38:19.580]with aerial photography of the project area
[00:38:22.210]to identify the location of potential hazardous materials.
[00:38:27.960]During the visual reconnaissance, be on the lookout
[00:38:30.810]for old auto body or repair shops,
[00:38:35.330]aboveground storage tanks, dry cleaning facilities,
[00:38:40.040]service stations using gasoline or diesel fuel,
[00:38:44.080]old retired service stations,
[00:38:47.440]transfer stations or landfills,
[00:38:50.850]railyard and railroad tracks,
[00:38:54.020]transformer yards and electrical substations,
[00:38:57.880]grain elevators and cooperatives, scrapyards.
[00:39:02.840]If there's fencing or placards
[00:39:04.640]that might indicate a land use or hide a use,
[00:39:08.440]evaluate and use your professional judgment
[00:39:10.970]as to whether it contributes
[00:39:12.710]to a wider understanding of the property use.
[00:39:17.210]Think about what you're seeing
[00:39:19.060]and whether or not it's a relevant observation.
[00:39:23.150]Sites must have a justifiable reason
[00:39:25.400]to be considered unlikely to impact construction.
[00:39:29.280]One of the main purposes of visual reconnaissance
[00:39:32.470]is identifying existing or potential issues in the field,
[00:39:36.500]not making any final determinations
[00:39:39.690]which sites will or will not affect the project.
[00:39:43.720]State in the HMR if anything of concern was identified
[00:39:47.670]during the visual recon which would impact the project.
[00:39:52.930]Please refer to Appendix C of the HMR Guidance Manual
[00:39:57.780]for more photos and detailed descriptions
[00:40:00.470]of what to look for during the visual reconnaissance.
[00:40:05.060]Appendix A in the HMR Guidance Manual
[00:40:08.160]is the glossary of terms and list of acronyms.
[00:40:13.290]Please be consistent
[00:40:14.480]with ASTM 1527-13 terminology,
[00:40:20.360]but do not use recognized recognized environmental condition
[00:40:24.870]or REC unless you are writing an ASTM-compliant
[00:40:29.790]phase one ESA for NDOT
[00:40:33.550]as part of the right-of-way acquisition process.
[00:40:37.160]The use of historical REC or controlled REC
[00:40:41.560]are also not to be used for NDOT HMRs.
[00:40:47.090]Providing NDOT with ASTM-compliant
[00:40:50.770]phase one ESAs will be addressed in a future course
[00:40:55.600]for advanced practitioners.
[00:40:59.000]Wrapping up lesson one,
[00:41:00.900]we discussed the different types of HMRs,
[00:41:03.920]how to determine level of review,
[00:41:06.380]and many of the details for completing the database review
[00:41:09.340]and visual reconnaissance form
[00:41:12.230]including what to take pictures of while visiting
[00:41:14.880]the proposed project location,
[00:41:16.820]and what to document in the photo log.

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NDOT Hazardous Materials Review 201: Section 1

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