November 6, 2020
How to Create a Soil Management Plan
Soil management and soil excavation planning can be a complex topic with much to remember. In this blog post, we’ll answer the questions, what is a soil management plan and how are soil management plans created.
What Is A Soil Management Plan?
Soil management, also known as soil excavation, involves the planning and execution of soil testing and the removal of contaminated soil from a construction site. Soil Management Plans are documents created by environmental professionals in order to make sure all safety protocols and permitting procedures required by various regulatory agencies are met on job sites with potential contamination issues. The main goal of a Soil Management Plan is to meet all required Environmental Screening Levels (ESLs). ESLs can be applied to a range of concerns and mediums, from soil to air, and were created as standards for the highest allowable amount of pollutant that can be mixed in with said medium. “Meeting” an ESL means that some pollutant has been released, but not enough to be a hazard to humans and the environment, according to the EPA.
History Of Soil Management Plans
Soil management planning became an important topic beginning in 1976 when the United States passed the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). RCRA was passed in 1976 to mandate safe handling, storage, and removal of toxic chemicals. CERCLA, on the other hand, was passed in 1980 and gives the EPA authority to seek out and clean up past hazardous waste sites around the United States. RCRA and CERCLA are meant to uphold healthy environmental standards that keep people and the planet safe from toxic contaminants. However, meeting all guidelines can be a bit tricky because there are a number of regulatory agencies involved in the due diligence process.
For a more comprehensive look at soil management for construction projects and real estate developers, check out our Guide to Dirty Dirt:
How Do You Create A Soil Management Plan For Your Site?
Examine historical documents The first step of soil management planning is to take a look at historical documents for evidence of contamination. Historical documentation includes Phase I ESAs, Phase II ESAs, and Geophysical surveys, all of which are commonly conducted when properties change hands. Phase I Site Assessments, in particular, should include historical documentation regarding previous uses of the property, previous uses of adjacent properties, and previous contamination on the property that has already been cleaned up. Evidence of potential contamination includes:
- Underground Storage Tanks (USTs) on the property in question or adjacent properties,
- The property used to be home to a dry cleaning business
- The property is adjacent to a property with evidence of contamination
If evidence of soil contamination is found within historical records, further testing is warranted.
Create a plan for soil remediation.
Once contamination is confirmed on the property, the next logical step in the soil management process is to create a plan for soil remediation. Soil remediation is a two-step process that includes:
- Creating a plan for the removal of contaminated soil
- Locating a landfill that will take contaminated soil
Locating a landfill that will take contaminated soil is more complicated than it might appear, as many landfills won’t take contaminated soil or other hazardous wastes. Therefore, it’s important to locate and connect with a landfill that does accept contaminated soil as soon as possible. Starting the remediation process six months before ground is broken on a construction site is ideal. For soil disposal in the Bay Area, the Altamont Landfill in Livermore, CA does take contaminated soil. For those located in California, here is a list of landfills you can review to determine if they currently take Class II contaminated soil. To create a plan for the removal of contaminated soil, check in with your certified environmental professional. They’ll likely be able to develop a plan that meets your timeline, budget, and remediation needs.
Obtain the right permits
Another aspect of soil management planning is completing the often complex permit process. Your environmental professional will be able to comply with all permitting requirements, but here is a list of common requirements:
- OSHA Trenching and Excavation Safety Guidelines for construction workers
- AQMD 1166 Plan
- Grading permit
Is it too late to test soil if I’ve already started construction?
No, it’s never too late to test for soil hazards, even if construction has already begun. Stockpiled soil can easily be tested, and an environmental professional can figure out how to remove soil from the site even if construction is already underway. Once the soil has been tested and a plan is in place for soil remediation, make sure to identify a landfill that can take contaminated soil on short notice.
How Essel Can Help with Your Soil Remediation Process
Need an environmental professional to manage this process for you? Unlike other environmental consulting firms, Essel can create and execute comprehensive soil management planning from start to finish. This includes:
- Creating a soil management planning document
- Completing all required permits
- Conducting necessary testing, including:
- Phase I Site Assessments
- Phase II ESAs
- Geophysical Surveys
- Soil Characterization
- Making contact with landfills and disposing of contaminated soil
For more information, contact us at 1-800-595-7616 with any questions or concerns, or click here to download the Ultimate Soil Due Diligence Checklist.