MAKING APPROPRIATE HMM IMPACT DETERMINATIONS FOR … · 2018. 10. 29. · Making Appropriate HMM Impact Determinations for TxDOT Projects September 2018 : EC Conference ISA Mechanics

Making Appropriate HMM Impact Determinations for TxDOT Projects September 2018 : EC Conference

MAKING APPROPRIATE HMM IMPACT DETERMINATIONS FOR TXDOT PROJECTS ENV, ERM

Hazardous Materials Management (HMM)

September 2018


Table of contents

2

7

8-13

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15

16

3-6 ISA Mechanics

Section 8 – HMM Concerns (Impact Determinations)

HMM Type of Concerns (directly from Section 8)

Summary of “Unresolved” Issues

Resolving HMM Issues

ENV HMM Contacts

1

2

3

4

5

6


ISA Mechanics – Sections 1-3

The Initial Site Assessment (ISA) is separated into 10 distinct sections.

– Sections 1-3: are the preliminary assessment tools

• Helps the ISA preparer gather all known (or past) hazardous materials

assessments in the area,

• Has an acknowledgment statement about asbestos and lead-in-paint,

and

• Allows for further project screening (opting out of the rest of the ISA)

– The first three sections of the ISA are not really part of the HMM

assessment, but tools to help prepare for the assessment.

3


ISA Mechanics – Sections 4-7

Sections 4-7 makeup the traditional industry-wide HMM assessment. This is

the investigative part of the ISA.

– Similar to the ASTM 1527-13 ESA

• Current and Past Land Use Information

• Regulatory Database Search

• Site Survey

• Interviews

4


ISA Mechanics – Section 8

Section 8 is designed to identify the potential for a project to impact

hazardous materials issues.

– For any knowledge level pertaining to HMM issues… basic construction

project knowledge

– Completion by consultants and by internal TxDOT personnel,

– Allows for the ISA process to come to a conclusion,

– HMM issues can be resolved during the ISA process and unresolved

issues can easily be carried over to an Issues Identification and Resolution

(IIR) Form in ECOS.

5


ISA Mechanics – Section 9 and 10

These sections help complete the form

– Reference Materials – Give the prepare a way to identify what tools they

used for their investigation and to remind them to attach the items to the

ISA, as well.

– Signature area for the ISA Preparer

6


Section 8 – HMM Concerns (Impact Determinations)

Section 8 - Allows the ISA preparer to make an impact determination based

on the information obtained during the investigative process (Sections 4-7)

The Issues identified will either need to be:

– Unresolved: A potential issue was identified or the preparer could not

determine a potential impact to the proposed project (not enough

information known about the project),

– Resolved: A potential issue was identified, but the preparer determined

that it would not impact the proposed project.

– No Issue: No potential issues were identified.

7


HMM Type of Concerns – First Three in Section 8.1

8

The first three Types of Concerns in Section 8.1 are directly connected

with Sections 4, 6, and 7 of the ISA.

• Were any issues identified?


HMM Type of Concerns - PSTs

Answer these questions first

– Are we acquiring a ROW parcel with a PST (Yes or No)

– Is there an unusual circumstance found with PSTs that should be

investigated further? (the “Other” question)

Make a selection here based on the initial questions

– If you selected “Yes” to a question, then you must select either

“Unresolved” or “Resolved” and provide an explanation here

– If you selected “No” to all questions than select “No Issues”

9


HMM Type of Concerns - LPSTs

Additional research is required on a suspect LPST site (judgement call)

Acquiring a parcel with an LPST

An LPST is adjacent (within .25 miles) of the project

Is there an unusual circumstance discovered about an LPSTs that would

require further investigation?

If you selected “Yes” to a question, then you must select either “Unresolved”

or “Resolved” and explain why the issue was resolved or is unresolved. You

can have unresolved and resolved issues under the same concern type.

10


HMM Type of Concerns – Oil and Gas

Additional research is required on a suspect Oil and Gas site (judgement call)

Is there a TRRC VCP within .5 miles of the project?

Will the project acquire oil and gas wells?

Are there spills or contamination (visible or in records) associated with

ancillary equipment or pipelines associated with oil and gas well production?

Is there an unusual circumstance found with an Oil and Gas site that should

be investigated further?

11


HMM Type of Concerns – Non-LPST

1) Answer the questions!

2) Select either Resolved or Unresolved or both if any are selected “Yes”, then

explain why.

12


HMM Type of Concerns – Landfills or Dump Sites

1) Answer the questions!

2) Select either Resolved or Unresolved or both if any are selected “Yes”, then

explain why.

13


Summary of “Unresolved” Issues

Section 8.3 just asks if any issues were identified as “Unresolved”.

14


ENV HMM Contacts

Rodney Concienne - 512-416-2634

Douglass Mack – (512) 416-2634

Terry Dempsey – (512) 416-3010

Jeff Richardson – (512) 416-2697

Mark Norman- (512) 416-2851

Jay Carsten – (512) 416-2474

David Morley – (512) 416-2607

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Documents

MAKING APPROPRIATE HMM IMPACT DETERMINATIONS FOR … · 2018. 10. 29. · Making Appropriate HMM Impact Determinations for TxDOT Projects September 2018 : EC Conference ISA Mechanics