Guzziwest Inspection And Consulting

A Detailed Overview of the Caltrans Hazardous Waste & Contracting Process

Guzi-West was recently certified as a small business in the State of California. This means that Guzi-West: 

  • now receives a 5-percent bid preference on State solicitations; 
  • can contract more easily with State agencies through a direct contracting process; and 
  • this allows a non-small business prime contractor, who uses certified small business/micro business subcontractors for at least 25 percent of its net bid price, to be eligible for a bid preference of 5-percent of the lowest responsible bid. 

How is Caltrans Divided?

Caltrans is divided into 12 Districts. For example, District 2 covers Shasta, Lassen, Modoc, parts of Trinity, Butte, Tehama, and Siskiyou counties and is headquartered out of Redding. The regions were created to avoid the redundancy of various functional units from district to district. Not all districts were regionalized. District 4 – the San Francisco Bay Area district and District 7 – Los Angeles and Ventura Counties – employ thousands and would equal many other states’ entire transportation departments.    

The Caltrans Headquarters departments, which oversee the districts and regions, are mostly centered in and around Sacramento.  

How is Caltrans Managed?

Caltrans environmental work is managed by the Division of Environmental Analysis (DEA). They’re responsible for everything, including Environmental Management, CEQA and NEPA studies, Air Quality, Coastal Permitting, Biology, Noise, Cultural Studies, Storm Water, and Hazardous Waste. This Department assures compliance with Federal and State Hazardous Waste laws and regulations, sets policy, controls funding, provides training and support to the regions and districts, and prepares and manages numerous contracts, many of which are on-call Architect and Engineering Contracts- A&E contracts. There are A&E contracts for studies ranging from archaeology, storm water studies, noise studies, wildlife, and hazardous waste studies. Caltrans Right-of-Way (R/W) and Legal branches are also often involved.

The North Region Environmental Branch conducts all environmental work in the North Region - Districts 1, 2, and 3 including all of Northern California, north of Sacramento. This department includes staff specializing in transportation planning, CEQA/NEPA studies and documents, biological, archaeologic, noise studies, Army Corps permits, storm water and hazardous waste (H/W).

Each district has an assigned Hazardous Waste Coordinator. Some of the more populated and urbanized districts – like the Bay Area – have multiple coordinators on staff, usually overseen by a Senior Environmental Engineer or Senior Engineering Geologist.  

There are several phases in the life of a Caltrans project. The process can take years and not all projects are built for a number of reasons. For this discussion, there are 3 important phases - Project Approval and Environmental Documents (PA&ED), Project Plans and Specification (PS&E), and Construction Support. Most projects have a Project Manager who manages the project throughout from inception to construction.

Project Approval and Environmental Documents Phase

During the PA&ED phase, a request is made to the District Hazardous Waste (H/W) Coordinator for an Initial Site Assessment (ISA). This request may include maps, preliminary plans, and potential R/W acquisitions. The ISA is basically the ASTM 1527 Phase 1 Site Assessment report. The ISA identifies any potential H/W issues that may impact the project and will identify whether additional studies and investigations are necessary. This could include contaminated properties, underground tanks - both current and abandoned, landfills, industrial sites, dry cleaners, adjacent properties with issues, junkyards, buildings and bridges with asbestos and lead paint issues, naturally occurring asbestos, and aerially deposited lead. A review is done of CAL-EPA agencies including RWQCB & DTSC records, EPA files, county and city records, old Sanborn Insurance maps, and aerial photos. A field site inspection is often conducted and a review of the Hazardous Waste and Substances Sites (Cortese) List is done. The Cortese List is a planning document used by state, local agencies, and developers to comply with the California Environmental Quality Act requirements, providing information about the location of hazardous materials release sites. Cortese sites add significant legal, environmental delays to a project. The ISA may be conducted by either Caltrans staff or a Contractor.  

Caltrans has a written policy to avoid gaining R/W within contaminated sites due to concerns regarding Responsible Party liabilities. This may not be always feasible. There are situations where a contaminated property must be acquired in order for a project to proceed. In these cases, acquisition of contaminated property may occur only after an adequate site investigation of the property has been conducted and the cost of the remediation has been considered in the appraisal and acquisition process. When a contaminated property must be purchased for the completion of a transportation project, the Project Manager, in coordination with district hazardous waste, right-of-way, project delivery, and legal staff submits an Exception Request for Headquarters’ approval.   Every effort is made to avoid acceptance of legal liability and responsibility for the cost of cleanup.

Project Plans and Specification & Construction Support Phase

If a Site Investigation (SI) - a Phase 2 ASTM 1903-97 Site Environmental Assessment- is warranted, the H/W Coordinator will prepare a task order under an A&E on-call Hazardous Waste and Design Contract, which is overseen by DEA HQ H/W group. There are numerous contracts at any given time throughout the State for various Districts and Regions, and while they’re essentially the same contract, each is bid and awarded separately. They generally run for 3 years and are valued at roughly 1-5 million depending on the District/Region and anticipated needs.  

The bidding process for these contracts is quite complex. There’s a Request for Proposals, Statement of Qualifications, and interviews by a panel. There are hundreds of bid items, including licensed and staff engineer/geologist hourly rates, travel time hourly rates, report prep rates, CAD hourly rates, every possible kind of sampling and lab analysis including all inorganic and organic methods, sample preparation, every kind of drilling and soil and groundwater sampling technique- ranging from hand augers, to hollow stem auger, truck mounted hydraulic push rigs- bid by per/ft, monitoring well installation, geophysical investigations, industrial hygienists, asbestos and lead paint consultants and technicians, and so on. These contracts are not always awarded on just low bid but on the availability, quality, and experience of the bidding company’s staff.  

The District Coordinator prepares a task order request using a complex spreadsheet for each bid item he or she estimates and submits to the DEA HQ H/W unit for approval.  A draft task order is sent to the contractor- sometimes they come back with revised estimates. All task orders are approved and invoiced out of that DEA HQ H/W. For instance, an ADL study might include senior management and staff hours, travel time hours, vehicle and drill rig hours, number of borings and samples (which can be hundreds), traffic control, lab analysis for metal, organic solvents, hydrocarbons, statistical analysis reports, and CAD hours. Another example might include - a known Leaking Underground Fuel Tanks near but outside the Project Limits, based on research on the State of California - Water Quality Control Board’s database GEOTRACKER it’s suspected the fuel contaminants have migrated into Caltrans Right-of-Way. That task order might include all the staff time, sampling and lab analysis for fuel contaminants and hollow stem auger drilling to sample groundwater. Sometimes you’ll have to install monitoring wells to get valid data. This would be equivalent to a Phase II Environmental Site Assessment- ASTM E1903II.

Once the investigations are completed, the results and recommendations are incorporated into the PS&E and may change the scope of the project or even kill it. All reports and data are provided to prospective project bidders - in what are called information handouts.

If H/W issues are discovered during construction, a similar contract called the Construction Emergency H/W contract is used. An example might be when the Contractor on a Highway Improvement Project finds unknown tanks half full of product. Not all highway construction contractors would be certified for H/W work. This contract brings in the right contractor. This contract would sample soil and groundwater remove and dispose of tank(s) and contaminated soils, and obtain regulatory approval.  

Hazardous Material Experience You Need & Trust!

The Guzi-West team has 30+ years of experience in hazardous material consulting. We’re well positioned to assist contractors with: Naturally Occurring Asbestos, Aerially-Deposited Lead, Asbestos, Lead-Based Paint, Mold, Methamphetamine, and Bacteria survey and consulting services. Contact us today to speak to one of our experts! (888) 351-8189

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