Environmental Challenges in Utility Work January 18, 2012

1. Environmental Challenges in Utility WorkJanuary 18, 2012 Jennifer Grandmaison Sr. Environmental Engineer DTE Energy- Distribution Operations

2. Utilities and the Environment • Contaminated Soils • Generator Responsibilities • Dewatering Manholes • Soil Erosion and Sedimentation Control • plans • Abandoning Cable and Gas Pipelines • Training Requirements

3. Contaminated Soils • Project manager must perform Due Diligence during planning stages – waiting to “discover” contamination = Time and Money • The “Generator” of the waste must be determined. This is typically the owner/operator of the property. • Construction contractors must have proper equipment and Personal Protective Equipment to work in and Excavate, Store, and Transport contaminated soils. • In most cases, soils and ground water samples and sometimes monitoring must be performed. This may take weeks. • A Safety Plan must be written and on-site when working in contaminated areas. • Contractor must have sufficient training, licenses, • or permits • Environmental and/or Safety supervisors may have to • be on-site

4. Where is the contamination from? • Soil contamination or soil pollution is caused by the presence of xenobiotic (human-made) chemicals or other alteration in the natural soil environment. • This type of contamination typically arises from the failure caused by corrosion of underground storage tanks (including piping used to transmit the contents), application of pesticides, percolation of contaminated surface water to subsurface strata, oil and fuel dumping, disposal of coal ash, leaching of wastes from landfills or direct discharge of industrial wastes to the soil. The most common chemicals involved are petroleum hydrocarbons, lead, polynuclear aromatic hydrocarbons (such as naphthalene and benzo(a)pyrene), solvents, pesticides, polychlorinated biphenys (PCB) and other heavy metals. This occurrence of this phenomenon is correlated with the degree of industrialization and intensities of chemical usage.

5. Generator Responsibilities • Owner/Operator of property should supply any documentation of known contamination prior to breaking ground. • Must ensure that any contaminated soils are managed in accordance with the Regulations and classifications made by EPA. • Must ensure that Part A of the transport certificate has been completed correctly and that an approved EPA transporter carries the waste to a licensed facility. • Usually the generator is also responsible for paying all associated costs. Sometimes these costs are shared but, this must be negotiated, if at all possible before the excavation begins.

6. Dewatering Manholes • Prior to discharging water a visual inspection must be performed • No sheen, no odor, no turbidity, no discoloration and no know previous contamination • Water must be containerized and disposed of at an approved disposal facility • In some case, manholes must be decontaminated prior to working • Each individual community has unique guidelines for discharging water into the environment • In the City of Detroit, DWSD footprint, a special permit may be obtained to discharge water through specially designated filter socks • In some cases, PILC cable must be tested for Polychlorinated Biphenyls (PCB’s) prior to pulling out of ducts.

7. SESC, Natural, Wetland or Stream Crossing Permits • The Soil Erosion and Sedimentation Control Program was implemented to regulate the pollution of Michigan waters by improper construction site management practices.  Special provisions for all development sites where there will be a disruption in the site land cover is required. • Disturb more than 1 acre (43,560 sq. ft) of soil or take place within 500 feet of a river, stream, lake or regulated county drain? • Cross any rivers, streams, creeks or regulated county drains? Affect any wetlands? Floodplain? Shoreline? • Impact Endangered Species? Invasive • Species? National Parks or Wilderness? • Cultural or Historical site? • Some counties or municipalities may • even have permits for cutting trees

8. Abandoning Cable and Gas Pipelines • Has subsidence been considered for pipelines having a diameter greater than 323.9 mm (12 inches)? • 2. Has the pipeline company notified the landowners and proper authorities (municipalities, MOE, MTO, • MNR, etc.) of the abandonment? • 3. Have abandonment procedures for crossings been agreed upon by utilities (road, railway, pipelines, • etc.) and authorities responsible for rivers and streams crossed by the pipeline? • 4. Has consideration been given to the effect of drainage in the area surrounding the abandoned pipeline , • which may act as a conduit for ground water after the pipe is perforated by corrosion? • 5. Has consideration been given to the removal of all the aboveground facilities? • 6. Has consideration been given to any hazards posed to people, equipment, wildlife or livestock by any apparatus left in place above or underground?

9. Training Requirements • 40 Hazwoper Requirements • Soil Erosion – Construction Inspector Training • Right- to –Know • Asbestos Awareness ( or higher level) • Lead Awareness (or higher level) • PCB Awareness is suggested, not mandated