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Work Plan

Section 17 - Final Environmental Cleanup Plan for AOCs and SWMUs (CDRL A005), December 2003

Section 1 - Introduction

1.1   Project Objectives

1.2   Scope of Work

1.3   Organization of the Environmental Cleanup Plan

Section 2 - Background

Section 3 - Site Activities

3.1   Site Control Activities Prior to Excavation

3.2   Remediation of Affected Soils

3.3   Demobilization and Closure

Section 4 - Scheduling and Time Management

4.1   Resources Management

4.2   Schedule Constraints

4.3   Milestones and Other Measures of Performance

Section 5 - Recordkeeping and Reporting

Acronyms and Abbreviations

Section 1 - Introduction

1.1   Project Objectives

The objectives of this project are to close or conduct investigations at 23 areas of concern (AOCs) and solid waste management units (SWMUs) located at Camp Stanley Storage Activity (CSSA), Boerne, Texas.  This Environmental Cleanup Plan (ECP) describes the procedures that will be implemented for the investigation, remediation, and closure of the AOC and SWMU sites.  Based on the data currently available, it is anticipated that 18 sites will be closed, and investigations will be conducted at 5 sites.

Waste and contaminated soil will be removed and properly disposed.  The medium of concern at these SWMUs and AOCs is soil.  Closure of these sites is for the soil medium only.  There are two areas of groundwater contamination at CSSA, and the source areas are SWMUs B‑3 and O-1 in the central portion of the camp and AOC 65 in the southwest corner of the camp.  The groundwater operable unit, which includes groundwater and bedrock, is currently being evaluated as part of the groundwater monitoring and well installation program.  A map showing all sites that will undergo removal actions or investigations during his project is provided in Figure 1.1.

1.1.1   Data Quality Objectives

The overall data quality goal for this project is to gather sufficient information to close the 18 SWMU and AOC sites under Risk Reduction Standard 1 (RRS1) per 30 Texas Administrative Code (TAC) 335 Subchapter S.  For the five sites undergoing investigation, the goal is to define the nature and extent of contamination, if any, at the site.  Data quality is defined by its representativeness, precision, comparability, and completeness.  Representativeness of the data is dependent on site selection and the number of samples taken, which are easily addressed in the sampling plan design.  The requirements for precision, comparability, and completeness of the data vary between data types but all are enhanced by the use of standardized sampling and analysis protocols and standardized reporting procedures.  Data quality objectives (DQOs) are continually being updated as the project progresses and data is generated. 

1.1.2   Residual and Waste Management Objectives

For each of the 18 SWMU and AOC sites to be closed, field investigations have been conducted to identify the nature and extent of contamination.  Based upon the data collected, the volume of waste and waste residue at each site have been estimated.  For each site, the affected soils and/or debris will be removed so that the analytical results for the confirmation samples are below the background levels established in the Second Revision, Evaluation of Background Metals Concentrations in Soils and Bedrock at Camp Stanley Storage Activity dated February 2002.  All soils transported off-site will meet the landfill criteria for Total Petroleum Hydrocarbon  (TPH) and the Toxicity Characteristic Leaching Procedure (TCLP) for eleven metals including antimony, arsenic, barium, beryllium, cadmium, chromium, lead, mercury, nickel, selenium, and silver.  If soils anticipated for off-site disposal do not meet the Texas nonhazardous disposal criteria (State of Texas hazardous waste classification standards specified in 30 TAC 335 Subchapter R), then the soils may be stabilized by the addition of a solidification agent such as flyash, Portland Cement or a chemical binding agent such as phosphate-induced metals stabilization (PIMS™).

1.2 - Scope of Work

The scope of work as detailed in the task order authorizing this project includes the preparation of project and/or site-specific addenda to the planning documents to be incorporated into CSSA’s Environmental Encyclopedia.  The primary objective is to remove waste and waste residue from each of the sites so that the analytical results for confirmation samples are below the background levels established in the Second Revision, Evaluation of Background Metals Concentrations in Soils and Bedrock at Camp Stanley Storage Activity dated February 2002 for closure under RRS1.

1.3 - Organization of the Environmental Cleanup Plan

This ECP is based on the format (CDRL A005) required by the Air Force Center for Environmental Excellence (AFCEE) in the statement of work (SOW) for this project.  Project objectives are presented in Section 1.  Section 2 includes relevant information (historical activities, previous site investigations and a summary of previous analytical results) for each of the subject SWMU and AOC sites addressed by this ECP.  Section 3 includes the plans required for the preparation and removal of the affected soils at the SWMU and AOC sites.  The items addressed are:

  1. Site Security Plan

  2. Excavation Plan

  3. Spill and Discharge Control Plan 

  4. Benchscale Test Plan

  5. Erosion Control Plan

  6. Remediation Management Plan

  7. Site Preparation Plan

  8. Demobilization and Closure Plan

Section 4 includes a discussion of scheduling and time management to be implemented throughout the duration of the project.  A discussion of record-keeping and data management is presented in Section 5.          

Section 2 - Background

An overview of the sites to be closed or investigated during this project is provided behind the site-specific tabs in Volume 1-2 and Volume 1-3 of the Environmental Encyclopedia.  In addition to a site description and history for each of the sites, a summary of previous investigations and sampling results is also provided.  A brief summary of the information provided in this section is depicted in Table 2.1.  For each of the SWMUs and AOCs described in this section, a site-specific work plan and additional background information can be found in the Environmental Encyclopedia (Volume 1-2 and Volume 1-3). 

The following 23 sites are included in this project:

  1. SWMU B-2

  2. SWMU B-8

  3. SWMU B-11

  4. SWMU B-12

  5. SWMU B-23

  6. SWMU B-23A

  7. SWMU B-25

  8. SWMU B-26

  9. SWMU B-29

  10. SWMU B-30

  11. SWMU B-33

  12. SWMU B-34

  13. SWMU Building 43

  14. SWMU Demolition Dud Area

  15. AOC-37

  16. AOC-38

  17. AOC-41

  18. AOC-48

  19. AOC-50

  20. AOC-54

  21. AOC-56

  22. AOC-66

  23. AOC-67

Section 3 - Site Activities

3.1   Site Control Activities Prior to Excavation

3.1.1   Site Security   Security Operating Procedures

Security involves the full-time deterrence of unauthorized, unknowing, or accidental entry of personnel or vehicles onto the CSSA facility and into areas being remediated.   The CSSA installation is within a fence, and entry and access to the installation are controlled through a series of perimeter gates.  The installation is frequently patrolled by the security police.  Furthermore, all remedial activities and areas are under control of authorized personnel.  Security personnel from CSSA will address any security violations associated with the CSSA perimeter fence line. 

Parsons along with the excavation subcontractor will be responsible for reducing the potential for unauthorized entry by personnel into the individual SWMUs/AOCs being remediated.   Due to the open excavations that will be created during this remedial program, entry into such areas could potentially result in the endangerment of health.  Perimeter fencing, on-site personnel and warning signs will all be used as a part of site security at each of the SWMU and AOC sites.   Use and Maintenance of Security Equipment

The security equipment that will be used at each of the sites being remediated will include signs, barricades, and perimeter fencing and flagging.  If an excavation is to be left open at the end of the day, then construction personnel will place and/or check the perimeter fencing and flagging to make sure the flagging or fencing is adequate for reducing the potential for unauthorized entry by personnel.  The CSSA Environmental Office and Security Force should also be notified of the excavation hazard.   Standard Security Measures

Security guards from CSSA will implement the standard procedures for authorizing entry into the CSSA facility.  Relative to security at the individual SWMU and AOC sites, personnel from both Parsons and the excavation contractor will take the same precautions for small excavations as for large excavations.   Procedures for Detecting Security Violations

Contracted personnel who enter the CSSA facility, must sign-in at the CSSA main gate.  Individuals who are not pre-registered for entry onto the site, will not be allowed to enter the site.   Since the entire CSSA facility is surrounded by a security fence, any unauthorized personnel will be identified and addressed at the main gate.   Personnel Responses to Security Violations

Security violations will be addressed by CSSA security personnel on a case by case basis.  If security violations occur at an individual SWMU or AOC site, then these violations will be reported to CSSA security.

3.1.2   Spill and Discharge Control

For the current list of sites to be remediated at CSSA under this ECP, the method of remediation entails the removal of affected soils.  There are currently no plans to consider a method of remediation that entails the storage of liquid hazardous materials or wastes at the site. The subcontractor will put fuel into the earth moving equipment from a supply tank located on a support vehicle and will not locate fuel storage tanks onto the CSSA facility for providing fuel to the equipment.  Since diesel is anticipated to be the only characteristically hazardous material (as defined by Texas Department of Transportation) that will be used at the site during the remediation of the sites, this section will provide the necessary procedures for controlling an accidental diesel fuel release. 

In the case of an accidental diesel fuel release in the State of Texas, an amount greater than 25 gallons is reportable to the TCEQ as well as any amount creating a sheen on the surface of a water body.  If a SWMU or AOC is near a flowing stream or a pond, the soil removal subcontractor will be required to have an approved emergency spill response kit containing at a minimum Kenaf 2000® or equivalent (absorbent for spills onto soil or a water surface), absorbent socks and shovels.  In the case of a reportable spill, the CSSA Environmental Office will be notified.  CSSA Environmental will then contact the following agencies as needed:

TCEQ – 512-463-7727

TX Emergency Response Center – 800-832-8224

National Response Center – 800-424-8802

EPA, Region VI – 214-655-2222    Types of Hazardous Materials and Wastes

The excavation equipment used at the site will use diesel fuel.  At the end of each day, the excavation subcontractor will check fuel levels on the equipment to make sure the equipment has enough fuel for operations to resume the next day.  The current remedial method to be implemented at the site, removal of affected soils, does not require the use of hazardous materials and the only wastes to be generated will be the affected soils that will be excavated and transported to Waste Management’s Covel Gardens Landfill.   Categories of Spill and Discharge Amounts

The excavation equipment will be refueled at the end of each day from a tank located on the back of the subcontractor’s support truck.  Since there will be no diesel fuel storage tanks at the site, the source of any diesel fuel spills would be from the fuel tanks on the equipment or on the support vehicles.  Any size leak or spill that occurs from the diesel tank will be quickly cleaned and removed from the site surface, and if the spill is greater than 25 gallons or occurs on a water body as defined by TAC 30 Part 1 Chapter 327, the spill is considered reportable.   Control Procedures and Protective Measures

Leaks and spills that occur during the day-to-day operation of the equipment will be addressed similarly no matter the size with the only exception being those spills that are classified as reportable.   If a spill occurs, the affected soils will be excavated, removed from the site and managed in an appropriate manner (e.g.; characterized and transported to an approved off-post landfill).    Regulatory and Base Spill Response Plans

Since liquid hazardous materials or wastes will not be stored on the site for this project, a response plan is not necessary.  There is a possibility that the analytical results for soil samples collected from in-place or stockpiled soils may exceed the hazardous criteria for toxicity as established by 40 CFR 261.24.  As mentioned earlier, special precautions will be taken to help reduce the potential for the affected soils from migrating away from the stockpile area and these precautions and methods for reducing the potential for off-site migration will be discussed under erosion control.

3.1.3   Erosion Control

Excavation and surface soil modification activities can increase erosion rates from pre-removal conditions.  Because of the accelerated erosion, clay and silt particles may be are carried away from the site and into Salado Creek during severe storm events.  The resulting increased turbidity of the waters as well as the accumulation of layers of silt and clay (and possibly waste materials) on the bottoms of streams and eventually lakes can have deleterious effects on both plant and animal life in the affected waters.  Thus, the primary objective for erosion control is to minimize the erosional effects due to storm water run-off.  In addition, storm water run-on and run-off controls will be implemented so that storm water does not collect at the SWMU or AOC sites.

There are three primary goals for control of sediment and erosion:

  1. Divert upgradient storm water around the remediation site;

  2. Minimize the duration of exposure at disturbed areas and unvegetated areas; and

  3. Control/remove sediment before it is eroded from the site.   Future Site Use

There are currently no plans for future development at any of the SWMU and AOC sites being remediated as a part of this ECP.   Erosion Potential and Estimated Rate of Erosion

The SWMU and AOC sites being remediated as a part of this ECP are located on either flat or gently sloping terrain.  Once the surface vegetation is removed a site, the soils will be more susceptible to erosion and precautions will be taken to reduce the potential for the erosion of surface soils.   Control Methods

The methods for reducing the erosional effects of higher velocity run-on and run-off water during rain events include several techniques.  During the soil removal activities at the various sites, stormwater will be managed to prevent undue releases of material into Salado Creek.  In the event of a major storm event, diversion dikes may be constructed upgradient of all construction zones and diversion ditches may be constructed in order to minimize the amount of stormwater infiltrating the site.  Silt fences (geotextile fabrics), strawbale barriers, sediment traps and other similar controls may be installed along sideslope and downslope boundaries as needed, to remove sediments from stormwater run-off and to divert run-on that would otherwise leave the site through natural drainage pathways.  These devices prevent large quantities of silt and clay from entering waterways, but they will also need periodic maintenance to repair dislocated or damaged devices so that the devices remain effective.

3.1.4   Site Preparation

Prior to the start of field activities, a sequence of which sites to remediate first, second, etc. will be determined by personnel from CSSA, Parsons and the subcontractor.  The most suitable routes will be established for the haul trucks to use within CSSA when transporting the affected soils from the SWMU or AOC site to the off-site disposal facility.  Within several days prior to the removal of affected soils from a SWMU or AOC site, surface vegetation will be removed from the area and any large debris will also be removed from the site.  Precaution will be taken for those sites that are known to have UXO.   Site Clearance Procedures

Prior to soil removal activities at a SWMU or AOC site, any high grass, bushes or small trees that could potentially interfere with the excavation activities will be removed from the site by the excavation contractor.  If UXO is encountered, the UXO team will be mobilized to the site and site activities will not resume until the area has been cleared by the UXO team.   The UXO clearance team will be mobilized to those sites that are known to have UXO prior to any excavation activities.   Site Ground Preparation

After site clearance activities have been conducted at a site, the site will be ready for the soil removal activities.  Excavation will be initiated at those areas that are known to have debris or affected soils based on previous investigation activities.  If a trench is excavated to a depth greater than four feet, then the sides will be sloped at an angle of approximately 3:1 (three feet of run per one foot of rise) and the soils will be sampled and stockpiled for potential future backfill into the excavation.   Site Utility Requirements

The excavation subcontractor and the UXO clearance team contractor from Parsons will be able to perform their required activities without the utilities being located to the SWMU or AOC site, and therefore utilities are not necessary at each site for the anticipated remedial activities.  CSSA personnel will be responsible for identifying all known utilities at each SWMU and AOC site.  The excavation subcontractor will take the necessary precautions so as not to damage any active utility lines during the soil removal process.   Availability of Contaminated Material Handling Facilities

Prior to the soil removal contractor arriving at the SWMU or AOC, the site will be sampled in-situ for waste characterization purposes.  The site will be divided into estimated 1000 CY lots and one composite sample will be collected from each 1000 CY lot.  The samples will be analyzed for waste characterization criteria (TPH and TCLP Metals Sb, As, Ba, Be, Cd, Cr, Pb, Hg, Ni, Se and Ag).  If the results for a 1000 CY lot are reported below the criteria accepted by the landfill, the soils from that lot will be identified as acceptable for excavation and direct placement into haul trucks for immediate transport to the approved off-site landfill at Covel Gardens.  If the soils do not meet the accepted criteria, the soil lot will be combined with a stabilizing agent, mixed in-situ and resampled.  Additional details will be described in the section pertaining to stabilization.  It is anticipated that material handling facilities or containers will not be required in order to treat contaminated material from a site.

3.2   Remediation of Affected Soils

3.2.1   Remediation Management   Establishment of Cleanup Goals

As described in Section 4.3 of the Risk Assessment Technical Approach Document (Volume 1-6), CSSA has opted to pursue, when feasible, closure of the SWMU and AOC sites under the Risk Reduction Rule (RRR) (30 Texas Administrative Code [TAC] §335).  After all visibly affected soils and debris have been removed from a site, confirmation samples will be collected and analyzed for the specific COCs predetermined during the RI for the site.  If the site concentrations do not exceed background, then the site will be closed using Risk Reduction Standard 1 (RRS1).  Since the contaminants of concern (COCs) can be VOCs, SVOCs, metals, and explosives, the RRS1 standards are the reporting limits (RLs) for VOCs, SVOCs, and explosives, and the soil or rock background values for metals.  Background metals levels were statistically calculated for CSSA soils and the Glen Rose Limestone, and are reported in the Second Revision to the Evaluation of Background Metals Concentrations in Soil Types (Parsons, February 2002).  TCEQ approved the background evaluation on April 23, 2002.

 If the site exceeds background, then a determination will be made regarding the feasibility of removing additional soils to meet background concentrations.  If the decision is made to clean the site to background, closure under RRS1 will be sought.  However, if it is determined that the site cannot be closed to meet background concentrations under this current project, then the soil removal contractor will demobilize from the site and the site will be closed later under the Texas Risk Reduction Program (TRRP).  A notification of intent to close sites in accordance with the former RRR was sent to the TCEQ on July 12, 1999.  TCEQ acceptance of this notification was received on October 5, 1999.

RRS1 requires that the site be closed following removal or decontamination of waste, waste residues, and contaminated operation system components; and demonstration of attainment of cleanup levels (30 TAC §335.554).  If closure requirements under RRS1 are attained and approved by the TCEQ Executive Director, then the owner is released from the deed recordation requirement.3   Applicable Site Agreements and Decrees

The site agreements include the Agreed Order dated May 1999 and the Second Revision to the Evaluation of Background Metals Concentrations in Soil Types (Parsons, February 2002).   Involvement of Regulatory Agencies

The TCEQ has been notified of the schedule for remediating the subject SWMU and AOC sites included under this ECP.  After the affected soils have been removed from a site and the analytical results for confirmation samples indicate the remaining soils are below background levels for metals and RLs for VOCs, SVOCs and explosives, then a closure report will be prepared for the site and submitted to CSSA for review.  After the report has been finalized, the report will be certified by an engineer licensed in the State of Texas and the report will be submitted to the TCEQ for their approval.   Subcontractor Activities

There will be two subcontractors working at each of the sites.  The soil removal contractor will be responsible for excavating the affected soils along with any debris and placing the materials into haul trucks.  Any metal material that can be recycled will be placed into a roll-off container for later transport to the Newell Recycling facility in San Antonio.   A second subcontractor will be responsible for transporting the affected soils to Covel Gardens landfill.  After the affected soils have been unloaded at the landfill, the transport truck may obtain an equivalent volume of clean “borrow” soil from the landfill area and haul the clean soil back to the site.  The clean soil will have verification documentation for use as backfill.

3.2.2   Excavation   Site Clearing and Preparation

Site clearing and preparation was discussed earlier in Section 3.1.4.  Parsons anticipates that all soil and potential UXO removal work can be performed in Level D personal protective equipment and will coordinate with CSSA operations so that most work is conducted during times when traffic through or adjacent to each site will be at a minimum.  The excavation equipment will remove the first two feet of soil at a SWMU or AOC and will proceed across the site until all material has been visually screened for ordnance/explosive (O/E) scrap and/or UXO material.   Soil Excavation, Hauling and Loading

After a site has been cleared of vegetation that may interfere with the soil removal process and all UXO visible at the surface has been removed or made inert, the soil removal contractor will mobilize a backhoe or equivalent for the sampling of soils from the site for waste characterization purposes.  Based upon initial affected soil volume estimates determined from the investigation results (see Table 2.1) and the known locations of anomalies, debris and any affected soils, the site will be divided into 1000 CY lots.  One composite sample will be collected from each of the pre-designated 1000 CY lots.  The samples will be sent to an analytical lab for analyses of TPH and TCLP Metals including: Sb, As, Ba, Be, Cd, Cr, Pb, Hg, Ni, Se and Ag.  If the analytical results are reported below the acceptable limits for the Covel Garden Landfill, then the soils from the lot with acceptable levels of TPH and the 11 metals will be excavated and placed into trucks for delivery to Covel Gardens.  If the soils within a specific lot are identified as characteristically hazardous (40 CFR 261.24), then the soils will be treated with the stabilization procedure detailed in Section 3.2.3 under Bench Scale Testing.  After the soils have been treated, a second composite sample will be collected and analyzed. 

As mentioned above, one sample for each 1000 CY of excavated material will be collected.  Sample methodology and quality control procedures are described in the Sampling and Analysis Plan (SAP) for Solid Waste Management Unit (SWMU) Closures at Camp Stanley Storage Activity (CSSA) (Environmental Encyclopedia Volume 1-4, Field Sampling and Analysis Plan tab and QAPP tab) and additional details are provided in the SAP Addendum.

During excavation of the SWMU or AOC, the contractor will adhere to the OSHA standards for open excavations.  For trenches that are excavated to a depth greater than five feet, the sides of the excavation will be properly sloped based on whether the soils are classified as A, B or C.  For A, B and C soil types, the sides are sloped at angles of 0.5 feet of run per one foot of rise, 0.75 feet of run per one foot of rise and 1.5 feet of run per one foot of rise, respectively.   

After the affected soils have been removed, confirmation samples will be collected from the base and side slopes of the excavation.  Samples will be collected at a frequency of one per 100 linear feet of sidewall, with a minimum of one sample per wall.  If the bottom of the excavation is bedrock, bottom samples will be collected at a frequency of one per 20,000 ft2 of bottom surface, with a minimum of two per excavation area.  If the bottom of the excavation is soil, bottom samples will be collected at a frequency of one per 100 feet (100-ft grids).  When the laboratory results have been received and there are no COC concentrations greater than the accepted background levels, the subcontractor will backfill the excavation with the clean soils and grade the remediation area to match the grade of the surrounding area. 

Investigation results from the trenching efforts and soil samples will be used to estimate the waste volume of fill material within each AOC or SWMU.  Using depth information from the excavation process and data from the earlier investigation, the volume of soil will be calculated.   Hauling Route Selection at CSSA and to the Landfill

The haul trucks will transport the affected soils to Covel Gardens landfill located in San Antonio, Texas.  The trucks will enter and egress CSSA through Gate 5 and onto Ralph Fair Road.  From Ralph Fair Road, the transport trucks will haul the soils to Covel Gardens Landfill located near the intersection of I35 and 410 on the southwest side of San Antonio.  The route from the SWMU or AOC to Gate 5 will follow along a set of roadways within CSSA predetermined by CSSA personnel, Parsons and the dirt hauling subcontractor.  The haul trucks will back haul an equivalent amount of clean soil from Covel Gardens and this soil will be stockpiled near the SWMU or AOC being remediated.  The stockpiled soil will later be used as backfill into the excavation at the site.   Soil Stockpiling

Soils may be stockpiled at a SWMU or AOC for various reasons.  During excavation, the affected soils may have to be stockpiled if the haul trucks are not operating that day.  There may be cases where the sides have to be sloped in excavations greater than five feet deep.  If the soil that is excavated from the sides is unaffected, then the soil can be stockpiled for later use as backfill into the excavation.  In addition, soil that is back hauled from the landfill will be stockpiled near the excavation for later use as backfill in the excavation.   Dewatering Methods and Waste Water Management

During remediation, the excavation subcontractor will be responsible for maintaining a site where conditions for collection of rainwater in low areas are minimized.  If storm water does collect, the subcontractor will either remove any rain water that may collect in an open excavation or allow it to evaporate.  During this project, it is anticipated that ground water will not be encountered during excavation activities.   Backfilling Procedures

The soils that are stockpiled at each site will be used to backfill the excavation.   The soil excavation subcontractor will be responsible for placing the soils into the excavation and using an adequate amount of effort to compact the soils so that there is a minimal amount of surface settlement in the future.   Storm Water Management

During the site activities, the soil removal subcontractor will minimize the temporary presence of depressions and holes that may collect storm water during storm events.   If storm water does collect, the subcontractor is responsible for properly removing the water.   Restoration

Each site will be graded smooth and the natural vegetation will be allowed to redevelop across the site.

3.2.3   Bench Scale Testing   Objectives

The primary objective for the bench scale testing of stabilization and subsequent disposal work efforts for the solid waste management units addressed in this plan and other various SWMUs is to immobilize contaminated soils, scrap metal, and other contaminants of concern to nonhazardous class 2 levels as specified in 30 TAC 335 subchapter R.  Potentially hazardous and class 1 non-hazardous contaminated soils will be excavated, stabilized with an approximate 5% to 10% (by weight) of Apatite II, Phosphate-Induced Metal Stabilization (PIMS™) material.  Post-treatment sample analyses will be used to determine proper disposal methods for metal impacted soil media.  This approach describes the procedures that will be undertaken to provide sufficient information for accomplishing the bench scale testing of stabilization efforts for determining proper disposal efforts for the SWMUs addressed by this Task Order.   Technology Description

The PIMS™ technology is a stabilization or sequestration technology. Like PIMS™, many stabilization technologies use an additive to the contaminated soil that immobilizes the metal or renders it non-toxic, but does not change the basic nature of the soil, e.g., its permeability or porosity.  These technologies allow the soil to function in the future as a soil.  Solidification technologies, such as grouting or in situ vitrification, immobilize the metal by changing the basic nature of the soil, effectively rendering it a non-soil, which may or may not fit the desired future uses for the site.

PIMS™ uses a special reactive form of the mineral apatite, Apatite II™, which chemically binds soluble metals into new insoluble solid phases (Wright et al., 1995; Chen et al., 1997; Conca et al., 2000; Conca, 1997; Conca, 1998).  In this case, Apatite II™ binds lead into lead-pyromorphite, an insoluble phase that is stable over all environmental conditions for hundreds of millions of years (Wright, 1990).  Lead-pyromorphite has an extremely low solubility product, Ksp = 10-80, and will not dissolve under most environmental conditions.  The lead in lead-pyromorphite is also not bioavailable.  Apatite II™ will stabilize about 20 percent of its weight in lead.  Similar performance occurs with uranium, plutonium, and other metals.   Test Specifications and Procedures

The procedures described in this technical approach are designed to ensure compliance with 30 TAC 335 subchapter R requirements.  The expected soils included in the stabilization and disposal efforts are contaminated with lead, however other metals/contaminants may be present.  Results of ongoing investigations will be utilized in determining the contaminants of concern for all disposal efforts.  The anticipated disposal material will be sampled for proper waste characterization in accordance with TCEQ requirements. 

The general approach which will be taken for completing the stabilization and disposal task is described in detail below.

  1. SWMUs which have a requirement for treatment of impacted soil media for rendering the waste material to Class 2 Non-hazardous as specified in 30 TAC 335 Subchapter R will undergo benchscale treatment studies to determine appropriate mix ratios of the PIMS material.

  2. A composite sample of the impacted soil media from a SWMU addressed by this plan will be excavated and placed on plastic sheeting at an appropriate location within the SWMU’s boundary for determining appropriate management methods.  The material, as much as possible, will be located on level terrain which is easily accessible. 

After the composite sample of the impacted soil media have been excavated for a benchscale stabilization study, 5%, and 10% (by weight) of PIMS will be mixed in the composite sample (one each) and sent to an off-site laboratory for TCLP analysis.   Analyses and Use of Test Results

All material intended for disposal will be properly characterized, per 30 TAC 335 Subchapter R requirements, and previous investigation results will be used to determine the contaminants of concern (COC) at each SWMU.

Sample collection and handling techniques will follow the Sampling Analysis Plan (SAP) for SWMU Closures at Camp Stanley Storage Activity (Parsons ES, 1996) and specific addendum developed for this task order.  Analytical techniques will follow procedures described in Test Methods for Evaluating Solid Waste, U.S. Environmental Protection Agency, SW-846 and the CSSA Quality Assurance Project Plan (QAPP) (CSSA, 2003).   Quality Assurance Measures

As described in the Amendment to Project Plans for SWMU Closures (Parsons, 2003), four types of field quality control (QC) samples will be collected during the investigative effort.  QC samples to be collected include equipment blanks, field duplicate samples, and matrix spike/matrix spike duplicate (MS/MSD) samples.  Sample descriptions, identifications, and frequencies required are described in detail in the SAP (Parsons, 1996).   Location of Test Equipment and Materials

The equipment used to perform the in-situ mixing will be located at the site.  Depending on the depth of the mixing zone, samples will either be collected with a hand trowel or with a backhoe.  The samples will be sent to the same laboratory that conducted the initial analyses on the soils from the AOC or SWMU site.   Test Scheduling

The benchscale testing efforts will be accomplished when investigative and waste characterization data are received for site specific SWMUs or AOCs.  This data will be used to determine the need for in-situ treatment of the impacted soil media and waste for off-site disposal.   Recording and Reporting Test Results

The benchscale study results will determine the appropriate management method for the waste material and will be accomplished on an as-needed basis determined for each SWMU addressed under this task order.

A benchscale treatability section in the closure report will be included for each SWMU or AOC undergoing the benchscale testing procedure.  All pertinent data used in the decision making process will be reported (e.g.; results of analysis, resultant waste characterization profile, etc.).

3.3 - Demobilization and Closure

3.3.1   Certification of Site Closure

After the affected soils have been removed from a site and the analytical results for confirmation samples indicate the remaining soils are below background levels for metals and RLs for VOCs, SVOCs and explosives, then a closure report will be prepared for the site and submitted to CSSA for review.  After the report has been finalized, the report will be certified by an engineer licensed in the State of Texas and the report will be submitted to the TCEQ for their approval. 

3.3.2   Decontamination Procedures for All Equipment

The subcontractor will be responsible for removing all soils from the equipment prior to mobilizing to the next SWMU or AOC in order to reduce the potential for cross-contamination between the sites.  A combination of various hand tools and pressure washing will be used to remove the soils.

3.3.3   Post Closure Maintenance and Monitoring Requirements

After the closure plan for a site has been approved by the TCEQ, there will not be any further maintenance or monitoring associated with the affected soils that once existed at the former SWMU or AOC.  There are currently no plans to utilize the closed sites for any sort of structure or CSSA function.  In cases where a monitoring well or some other CSSA related monitoring device is located on the former SWMU or AOC, then monitoring will continue for the well or device until the particular monitoring program has been completed or adjusted so that access to the well or device is no longer necessary.

Section 4 - Scheduling and Time Management

4.1   Resources Management

This project will be managed by a Project Manager located in Austin, Texas, Julie Burdey.  The PM will be assisted by the project engineer, several geologists, and support staff located in Austin and San Antonio, Texas.  In addition, the data verification will be conducted in Austin.  The field coordinator and sample manager are located in San Antonio and will report to the Project Manager.  Additional staff from the Austin and San Antonio offices will support the project at CSSA whenever necessary.

Excavation and hauling will be conducted by Eagle Construction & Environmental Services, of San Antonio, Texas.  Waste will be disposed of at Covel Gardens Landfill in San Antonio, Texas, which is operated by Waste Management, Inc.  Sample analyses will be conducted by Agricultural and Priority Pollutants Laboratory (APPL), in Fresno, California. 

4.2   Schedule Constraints

The project entailing the remediation of the 21 SWMU and AOC sites was awarded on June 9, 2003.  A project schedule outlining the activities to be completed during the project is presented in Figure 4.1.  The amount of time to be spent in the field remediating the 21 sites is based upon the estimated volume of affected soils shown in Table 2.1.  If the field observations along with soil sampling at a site indicate a significant under estimation on the affected soil volume, then the schedule will have to be delayed or site personnel will need to review the possibility of delaying the removal action at the particular site and addressing the soil removal at an alternative site not included in the current list of 21 AOC or SWMU sites.  The current period of performance for this project is June 9, 2003 through July 2005.

4.3   Milestones and Other Measures of Performance

The project will consist of several key activities.  The initial field efforts will occur in September 2003 and will last three to four months depending on the accuracy of the volume estimates depicted in Table 2.1.  It is anticipated that the first few draft closure reports will be submitted in February 2004 and that all 21 closure reports will be finalized by January 2005.

Section 5 - Record Keeping and Reporting

5.1   Field Logbooks

Field logbooks will be used to record daily field activities and field observations.  Daily entries into the logbook may include work hours, field personnel, weather information, sampling times, and observations.  Logbook entries will be handwritten using permanent ink.  A new page will be started each day of field activities and entries will continue onto successive pages as necessary.  At the end of each day, the field team leader will sign the field logbook and unused portions of the last page will be marked through to prevent further entries.

The team leader, or his designee, will electronically scan that day’s entry into the field logbook.  The pages will be scanned to create a graphics format electronic file (JPEG or similar) using the electronic scanner in the CSSA environmental office.  The hard copy of the field notes will be stored in Parsons field and project files.

5.2   Submittal Requirements

5.2.1   Plans and Reports

Deliverables to be submitted prior to, during and after the remediation of the subject SWMU and AOC sites include:


This Environmental Cleanup Plan and associated addenda;

Environmental Construction Quality Plan which will contain a project organizational chart, inspection activities, record keeping, monitoring tests and construction quality sampling requirements;

Health and Safety Plan along with an Explosive Safety Plan for addressing potential unexploded ordnance (UXO) that may be encountered at some of the subject sites;

Sampling and Analysis Plan (SAP), an addendum to the existing SAP for CSSA, will be prepared for removal of affected soils, and environmental sampling necessary to characterize the excavated waste materials and to confirm contaminant concentrations have been reduced to levels for meeting site closure;

Standard Operating Procedures for Managing Hazardous Media, a plan detailing the standard operating procedures for handling hazardous media that may be encountered at the 16 subject sites;


Work Breakdown Structure (CDRL B001);

Project schedule in Microsoft Project format;


Technical Interchange Meeting (TIM) Minutes which will summarize the items discussed during the TIMs and will include a list of attendees, agenda discussed, decisions made, and outstanding issues;

Excavation and Removal Report which will present a summary of the soil excavation activities including the areas excavated, the volume of soil removed, results of the confirmation soil sampling, and site restoration activities;

Report on Production or Delivery Problems;

Hazardous Material and Hazardous Waste Disposal Report for the 21 SWMU and AOC sites;

Contractor’s Progress, Status, and Management Report which will be prepared monthly and will present a summary of the activities completed for each task, activities for the next reporting period, status of deliverables, and any problems encountered; 

Submittal of Analytical Data Report Package properly validated by a Parsons scientist and Environmental Restoration Program Information Management System (ERPIMS) data files; and

Closure/investigation reports for each of the 23 sites along with photographs documenting field activities. 

Each draft closure report will be prepared and submitted electronically for review and comment by the Base POC and AFCEE ERDB.  Draft documents will be submitted in both Microsoft Word and Adobe PDF format.  Submittals will not be forwarded to regulatory agencies until CSSA/AFCEE comments are incorporated and finalized.  Copies will be prepared for all final submittals for inclusion into the CSSA Environmental Encyclopedia.  Final copies of the deliverables will also be added electronically to the CSSA Environmental Encyclopedia.  The planned submittal schedule for these deliverables was provided in Section 4.

5.2.2   Electronic Data   CHERP Data

The CHERP’s database application is currently designed to generate COCs and labels for samples submitted for laboratory analyses.  Based upon the anticipated number of samples shown in Table 2.1, this information will be used as input into the CHERP program.  The database ensures that all required information for delivery of Environmental Resources Program Information Management System (ERPIMS) data is entered.  The field screening data collected on a daily basis will be incorporated with the daily logs to provide efficient and expedient review of data.  The electronic database application is set up to allow synchronization between networks at CSSA and Parsons.  This will allow review and observations of daily field activities by CSSA and Parsons Managers.   GIS Data

Data and other relevant field information will be incorporated into the CSSA geographic information system (GIS) in Spatial Data Systems (SDS) format to include GPS surveyed sample locations and surveys of excavation areas.  Also, if “hot-spots” are visually identified during initial sampling, characterization, excavation efforts they should be surveyed. 

5.3   Meetings

Project meetings to be conducted during the progress of the remediation of the subject 21 AOC and SWMU sites include: a kickoff meeting and five progress meetings.  The Parsons Principal Project Manager, Project Manager, Project Engineer and senior project engineer (field task manger) will attend the kickoff meeting and the initial site visit.  The Parsons Project Manager and Project Engineer will attend the progress meetings.  As mentioned above, a set of meeting minutes will be prepared after each meeting.