Appendix E CPL Protocol for Contaminated Soil

of 4 Chevron Pipe Line Company Protocol for Management of Hydrocarbon Contaminated Soil Encountered During Construction 1. Introduction: There is the potential to encounter petroleum-contaminated soil during pipeline construction projects. This Hydrocarbon Contaminated Soil Management Plan describes the procedures which must be followed upon encountering contaminated soil during pipeline construction. It is the intent of this plan to ensure the safe handling of contaminated soils to prevent impacts to human health and the environment. Since the potential exists to encounter contaminated soil on property that CPL does not own in fee it may be necessary to engage landowers to determine the responsible partyfor proper soil disposal. CPL will take prudent measures to identify the party responsible after the soil have been excavated per this management plan. The intent of this plan is to control handling of contaminted soil during construction to minimize construction delays. 2. Identification of Petroleum-Contaminated Soil: Petroleum-contaminated soil can be identified by the visual presence of oil or oil staining and/or a petroleum odor. Contaminated soil is defined as soil having an organic content exceeding 50 ppmw (based on laboratory analysis) or which registers greater than 50 ppmv when measured 3-inches from the soil surface with an organic vapor analyzer ( OVA ). A Phase I environmental assessment will be conducted on the right-of-way where the pipeline will be installed. The Phase I will include a file search of known data bases that contain information about potential environmental contamination. If the Phase I indicates a potential for contaminated soil to exist, then a Phase II soil investigation may be necessary to identify potential impacted soil prior to construction. 3. Contacts: CPL HES Environmental Specialist (Name and Phone Number) CPL HES Remediation Specialist (Name and Phone Number) CPL Construction Manager (Name and Phone number) 4. Definitions: Important definitions for the purposes of this guidance: Contaminated Soil Storage Pile Soil which has an organic content exceeding 50 ppmw (based on laboratory analysis) or which registers greater than 50 ppmv when measured with an OVA. A pile of excavated contaminated soil located above the existing grade level.

of 4 Active Storage Pile Backfill Emergency Excavation An above grade storage pile to which contaminated soil is currently being added to or removed from. Activity must have occurred within one (1) hour to be considered current/active. Replacement of contaminated soil to an excavated pit below existing grade. (Note that in some cases, contaminated soil may, with regulatory agency approval, be placed back into the original excavation or other approved location). Excavation of contaminated soil carried out pursuant to state or local government agency order. 5. Exclusions: The following scenarios are excluded from this guidance: Soil with an organic content 50 ppmw or 50 ppmv Excavation of contaminated soil 1 cubic yard Soil contaminated by accidental spillage of 5 gallons of liquid organic compounds. 6. Notification: Project personnel must notify the HES Environmental Specialist immediately upon discovery of suspected soil contamination. The following information will be required: Name of person responsible for excavation (Company representative coordinating work) Location of excavation Date of excavation Estimated quantity of soil to be excavated, if possible Estimated average organic content of soil Purpose of excavation (i.e. pipeline installation, over excavation for foundations, etc.) Precautionary storage measures (stored in covered bins, covered with tarp in place, etc.) The CPL HES Environmental Specialist will determine and make the necessary notifications to property owners and regulatory agencies. 7. Requirements for Handling Contaminated Soil : During excavation: Contaminated soil that is excavated during construction shall be placed on continuous heavy duty plastic sheeting. The covering must be in good condition, joined at the seams (overlapped 18-24 inches and held down with sand bags or other weights), and securely anchored to minimize headspace where vapors may accumulate. Additionally, the excavated soil shall be covered with continuous heavy duty plastic sheeting. Special care should be given to minimize the generation of dust and to mininize the handling or movement of the soil. Active storage piles of contaminated soil will have a maximum of 6000 square feet uncovered surface area with all additional surface area covered with a continuous heavy-duty plastic sheeting.

of 4 8. Characterization Sampling: Inactive storage piles of contaminated soil must be covered with a continuous heavy-duty plastic sheeting during periods of inactivity longer than one hour. Within 30 days of any excavation of contaminated soil, one of the following must occur: all contaminated soil must be disposed of at an approved waste disposal facility, or: all contaminated soil must be backfilled and covered with at least 6 inches of uncontaminated soil (with prior CPL HES approval only, or: other site specific arrangements may be made through the CPL HES Remediation Specialist Soil deemed to have a beneficial reuse as backfill material: Soil that is placed back in the excavation and has exposed surfaces shall becovered with a continuous heavyduty plastic sheeting. Also, during periods of inactivity longer than 12 hours, backfilled contaminated soil must be covered with at least 6 inches of uncontaminated soil or covered with continuous heavy duty plastic sheeting Organic concentration of soil should be confirmed using an OVA before samples are collected for lab analysis. (OVA must comply with EPA Method 21). The soil surface may be disturbed to expose soil approximately 6 inches below the surface to obtain a measurement. A. Soil Disposal Sampling: Composite samples are to be taken and analyzed when necessary tocharacterize the soil to determine the appropropriate dispositon for the soil.. A site-specific compostie sampling plan will be developed and it shall include a sampling frequency of at least two composite samples for every 100 cubic yards or other suitable ratio. Each pile requiring sampling must be divided into equal sectors. One sample must be taken from the center of each sector using: a driven-tube sampler, capped and sealed with inert materials, extruded in the laboratory; or a clean brass tube (12-inches long min.), driven into the soil. The ends must be covered with aluminum foil, then plastic end caps and tape. Samples should be placed on ice for transport. B. For purposes of waste characterization, contaminant content of soil must be determined using: EPA Methods 8015B and 8021B. Title 17 TTLC (Total Threshold Limit Concentration Metals). Consult the CPL HES representative to confirm characterization requirements of the chosen waste facility.

of 4 9. Confirmation Sampling: Discrete soil samples shall be taken and analyzed when necessary for confirmation of excavation boundaries. Samples should be taken from the bottom and sides of the excavation at a frequency appropriate with the size of the excavation to adequately verify that all potential contaminated soil has been removed. For confirmation of clean excavation boundaries, organic content of soil must be determined using: EPA Methods 8015B and 8021B. 10. Reporting: Based on information provided by project personnel, the HES Environmental Specialist will notify authorities as required. Written verification should follow no later than 30 working days after excavation and disposition of soil is complete. 10. Recordkeeping: The HES Environmental Specialist must keep records and the soil excavation reports andcorrespondence that is submitted to regulatory agencies.