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Hazardous Materials Investigations and Documentation

WSDOT must prepare a variety of documentation related to hazardous materials in order to meet regulatory and project requirements. HazMat investigations support the conclusions made in these documents. The investigations are often complex and must take into account project and site-specific details. WSDOT has HazMat Specialists (pdf 138 kb) or On-Call Consultants complete this work.

HazMat Section of the ERS or ECS

The Environmental Review Summary (ERS) and Environmental Classification Summary (ECS) are a part of WSDOT project scoping (pdf 328 kb) . Completing the HazMat Section of the ERS or ECS involves an informal review of known and potentially contaminated sites within or near the project area. This review helps identify what HazMat investigation (e.g., HazMat Discipline Report) must be done for the project and by when. The review also helps staff assess and document potential project impacts, mitigations, and required permits or approvals. If staff determines that no documentation is required based on project specifics, they justify the decision on the ERS or ECS.

Available Guidance Documents

HazMat ERS/ECS Guidance for WSDOT Projects (pdf 37 kb)

Additional References

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HazMat Discipline Report

The purpose of a Hazardous Materials Discipline Report is to assess the sites along the project corridor for the potential presence of contamination. The report must be project specific and identify and evaluate known or potentially contaminated sites that may:

  1. Affect the environment during construction.
  2. Create significant construction impacts.
  3. Incur cleanup liability to the department.

A HazMat Discipline Report is prepared to support NEPA/SEPA documentation, project design, and construction. HazMat Discipline Reports document:

  • Selection of project alternatives.
  • Mitigation measures for identified impacts.
  • Early coordination needed with regulatory agencies.
  • Significant, unavoidable, adverse impacts that cannot reasonably be mitigated.
  • Site-specific recommendations when additional investigation is needed prior to acquisition and construction.
  • Approximate site-specific cost estimates for additional investigations.

The cost for and time required to prepare a HazMat Discipline Report depends on the complexity of the report. Generally the cost for a full-scale report for a one-mile corridor is $15,000 to $25,000. These reports take approximately 170 to 190 hours to complete.

Not all projects need a full-scale report.  Factors such as project size and type of construction activities, past and current land use in an area, and acquisition plans help WSDOT staff determine the best report size. WSDOT provides Right Size guidance that describes three levels of reports as well as situations where no documentation may be required. WSDOT also offers guidance on a Two-Step Approach for preparing reports to help projects in the early phase of development when the level of detail needed for a report is uncertain and many elements (i.e., design and acquisition plans) are subject to change.

Available Guidance Documents

Guidance & Standard Methodology for WSDOT Hazardous Materials Discipline Reports  (pdf 288 kb)

Additional References

Phase I Environmental Site Assessment

The purpose of a Phase I Environmental Site Assessment (Phase I ESA) is to evaluate the potential for contamination to be present on or adjacent to a single property. WSDOT completes a Phase I ESA prior to acquisition in order to meet “All Appropriate Inquiry” as defined by the EPA and qualify for one of the CERCLA defenses to limit cleanup liability and potentially recover future cleanup costs. Phase I ESA Reports follow the American Society for Testing and Materials (ASTM) E 1527-05 Standard Practice to the extent practical. Per the ASTM standard, an Environmental Professional (pdf 88 kb) should complete the assessment.

Since WSDOT routinely uses HazMat Discipline Reports to identify potentially contaminated properties, WSDOT does not automatically complete Phase I ESAs for all individual sites.

Staff should consult a WSDOT HazMat Specialists to see if a property warrants a Phase I ESA and the level of investigation that is necessary.

A Phase I ESA in full compliance with the ASTM standard should only be conducted for properties that may be substantially contaminated and require WSDOT acquisition. Depending on project needs, WSDOT may decide to omit some portions of the Phase I ESA and thereby produce what WSDOT terms a Limited Phase I ESA Report. Such a report must meet the minimum requirements listed below.

Phase I ESAs usually take 4-8 weeks to complete and cost between $3,000 and $8,000. The cost for a Phase I ESA depends on factors such as site history, how quickly a project office needs the report, and whether a WSDOT HazMat Specialist or a consultant completes the work.

WSDOT’s minimum requirements for a Limited Phase I include

A Scope of Services section at the beginning of the report documenting what information was not included in the limited report.

Historical & Land Use Evaluation

Maps such as Kroll Maps, Sanborn Fire Insurance Maps, USGS topographic maps

  • Aerial and still Photographs

Environmental Records Review (per Section 8 of ASTM 1527)

  • Regulatory database records search
  • Review of regulatory files

Site Reconnaissance

  • Field verification of sites identified through maps & aerials
  • Review adjacent properties

The conclusion of the Phase I ESA report should include recommendations about whether or not additional investigation is necessary prior to acquisition or construction.

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Phase II Environmental Site Assessment

The purpose of a Phase II ESA is to further investigate sites that may have contamination based on the findings of a HazMat Discipline Report or a Phase I ESA. A Phase II ESA is a limited field investigation to characterize the nature and extent of any contamination prior to acquisition and construction. WSDOT staff should consult a HazMat Specialist to see if a specific property warrants a Phase II ESA. Often a Phase II ESA is not necessary when site-specific documentation exists in Ecology files for the planned acquisition or construction areas.

Identifying the extent of contamination through a Phase II ESA helps WSDOT:

  • Select project alternatives and/or mitigation options.
  • Prepare real estate transactions and determine fair market property value.
  • Determine appropriate property management options.
  • Identify construction impacts and associated costs for mitigation and/or disposal of material.
  • Consider Worker Health and Safety needs.

WSDOT's policy is to follow the American Society for Testing and Materials (ASTM) E 1903-11 Standard Practice to the extent practical. Per the ASTM standard, field sampling and report writing should be performed only by or under the direct guidance of an Environmental Professional (pdf 88 kb) .

Field Sampling Expectations

Information from previous reports and acquisition and construction plans serve as the basis for field sampling activities. A clear Statement of Objectives based on the needs of the WSDOT project guides the data collection. WSDOT expects field samplers to follow the standards for collecting soil or water samples.

Report Expectations

The Phase II ESA report should summarize Recognized Environmental Conditions (RECs) contained in the Phase I ESA report. WSDOT’s minimum requirements for a Phase II ESA report include:

  • Explanation of the physical environment and how it may influence the potential types, location, and extent of contamination.
  • Selection of sampling techniques and the rationale for the type of sampling.
  • Discussion of the laboratory analysis performed.
  • Summary tables of the analytical results. Include electronic copies of raw laboratory data with QA/QC methods and verification as an appendix to the report.
  • Conclusions and recommendations including the nature and extent of any contamination found and a remediation strategy.

Depending on the results of the Phase II ESA as well as project details, additional assessment may be necessary. A site may require more extensive sampling or perhaps long term monitoring. The remediation strategies outlined in a Phase II ESA are preliminary but provide a basis for making decisions about property acquisitions or design modifications.

A typical Phase II ESA takes 8-12 weeks to complete and costs $15,000-$30,000. The cost for a Phase II ESA depends on factors such as the extent of sampling at a site, how quickly WSDOT needs the report, and whether a WSDOT HazMat Specialists or a consultant completes the work.

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Asbestos Surveys

WSDOT performs asbestos surveys of buildings, bridges, and other structures that may have asbestos-containing materials (ACM). These surveys follow the guidelines of the local Clean Air Agency or Ecology Regional Office with jurisdiction. WSDOT performs the surveys prior to placing a contract on Ad for bidding so that contractors are aware of the job hazards (WAC 296-62-07721). Depending on availability, WSDOT HazMat Specialists who are Asbestos Hazard Emergency Response Act (AHERA) Building Inspectors complete the surveys for WSDOT projects. Otherwise, WSDOT hires another state agency or a consultant. Asbestos surveys typically cost from $2500 to $6000.

Additional information about how WSDOT handles ACM.

HazMat Special Provisions & Standard Specifications

WSDOT may need to have a contractor handle and manage issues such as contaminated soil or water, underground storage tanks, asbestos-containing materials or spills during construction. WSDOT communicates this information in the construction contract through the use of Standard Specifications, a General Special Provision, or a Project-Specific Special Provision. The WSDOT Construction Specifications, Amendments, GSPs FAQ web page describes the differences between these contracting terms.

Below is a listing of WSDOT Standard Specifications and General Special Provisions that cover the following HazMat related topics:

For complex issues, WSDOT HazMat Specialists assist with writing or reviewing HazMat Project-Specific Special Provisions. Often these provisions define areas with differing types or depths of contaminated soil or water. The Project-Specific Special Provision describes how the Contractor will handle and manage the material, including stockpiling. Information about how WSDOT will characterize the material for disposal is also often included.

Contractor Health and Safety
Standard Specification

  • Section 1-07.1 Laws to be Observed
  • Section 1-07.4(2) Health Hazards

General Special Provision
Lead Health Protection Program

  • 1-07.1.OPT2.FR1 (January 5, 2004)

Spill Prevention
Standard Specification

  • Section 1-07.5(1) General
  • Section 1-07.5(3) State Department of Ecology
  • Section 1-07.15(1) Spill Prevention, Control and Countermeasures Plan

Asbestos-Containing Materials
General Special Provision
Asbestos Handling and Removal - Use when asbestos removal is required.

  • 2-02.1.OPT2.FR2 (March 3, 1995)
  • 2-02.3.OPT5.GR2 (September 30, 1996)
  • 2-02.5.OPT11.GR2 (September 30, 1996)

Asbestos Handling and Removal - Use when there is reason to suspect asbestos may be encountered.

  • 2-02.1.OPT4.GR2 (September 30, 1996)
  • 2-02.3.OPT4.GR2 (September 30, 1996)
  • 2-02.5.OPT14.GR2 (September 30, 1996)

Hazardous Materials Removal and Disposal
Standard Specification

  • Section 2-03.3(7)C Contractor-Provided Disposal Site

General Special Provision
Removal and Disposal of Hazardous Materials

  • 2-02.3.OPT3.FR2 (August 1, 2005)
  • 2-02.4.OPT1.GR2 (December 4, 2006)
  • 2-02.5.OPT7.GR2 (December 4, 2006)

Lead-Based Paint
Standard Specification

  • Section 6-07.3(2) Painting Submittals
    • see “D” for Hazardous Waste Containment, Collection, Testing, and Disposal Submittal Component
  • 6-07.3(10) Painting Existing Steel Structures
    • see “A” for Containment
    • see “F” for Collecting, Testing, and Disposal of Containment Waste
  • Section 9-08.4(2) Lead Abatement Additive

Toxicity Testing for Recycled Materials in Aggregates
Standard Specification

  • Section 9-03.21 Recycled Material in Aggregates

Treated Wood Disposal
General Special Provision
Treated Wood Disposal

  • 1-07.5.OPT1(W).GR1 (August 3, 2009) 

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HazMat Management Plans

When a WSDOT contractor must handle and manage HazMat during construction, WSDOT usually includes a General Special Provision or a Project-Specific Special Provision in the construction contract. In rare cases, a WSDOT HazMat Specialist may prepare a Hazardous Materials Management Plan (HMMP) for a project.

A Hazardous Materials Management Plan:

  • Supplements a HazMat Special Provision.
  • Guides contractors on projects that have wide spread contamination or unique conditions such as dangerous waste.
  • Outlines a specific sequence of activities that will take place during construction.
  • Minimizes schedule delays and excess costs for known contamination.
  • May also be called a Soil Management Plan if only soils are involved.

In order to prepare a HMMP, WSDOT must thoroughly characterize the contamination prior to construction.

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