Closure Work Plan, July 2000

Introduction

This document is the work plan for the closure of the Building 40 container storage area (Texas Natural Resource Conservation Commission (TNRCC) 001)), at Camp Stanley Storage Activity (CSSA) in Boerne, Texas (EPA identification number TX2210020739, Texas solid waste registration 69026).

This work plan has been prepared to comply with all appropriate regulatory requirements of 30 Texas Administrative Code (TAC) §335 for clean closure under Risk Reduction Standard Number 1 (RRS1). This plan describes the procedures that will be implemented during closure activities to satisfy regulatory requirements.

Container Storage Area System Description

The Building 40 container storage area, is a 12- by 20-foot building located in the inner cantonment as illustrated in figure 1. The container storage area was used for the collection of hazardous wastes from operations at the installation prior to transfer to another Army agency or contractor for appropriate disposal.

The Building 40 container storage area was operated as a less-than-90-day container storage area, and is therefore exempt from regulation under 40 CFR §264 and §265 through 40 CFR §262.34.

The wastes previously managed in this area are described in Table 1. The EPA hazardous characteristics of each waste are also listed.

Closure Performance Standard

This work plan is designed to (a) minimize the need for further maintenance; (b) control, minimize, or eliminate, to the extent necessary to protect human health and the environment, postclosure emission of hazardous constituents, leachate, contaminated runoff, or hazardous waste decomposition products to soils, surface waters, or to the atmosphere; and (c) to ensure compliance with the specific closure requirements established for this unit.

Table 1 - Hazardous Wastes Potentially Managed at the Building 40 Container Storage Area (TNRCC 001)

In accordance with 30 TAC §335.554, all contaminated components will be properly disposed of or decontaminated to cleanup levels specified under Risk Reduction Standard 1. There is no record of any spills of stored material and the building is assumed clean. To demonstrate compliance with (RRS1), sampling will be performed in accordance with the following procedures.

CSSA will achieve this performance standard through the procedures specified herein. In general, the standard will be achieved by:

Procedures for Closure Activities

The following section describes the steps necessary to properly provide documentation that the container storage area does not have waste residues. This procedure assumes that all waste containers were sent to either proper disposal or Building 86 (the active container storage area).

Procedure

The number of samples required to evaluate contamination of a suspect surface is dependent of the size of the potential spill containment area and the degree of certainty desired. Based on the history of this facility, one discreet wipe per 25 square feet (ft²) of exposed surface will be adequate to characterize the area, for a minimum of ten samples. If other areas suspected of being contaminated are observed, additional samples will be collected. At least two field blanks should be taken for quality control measures.

Wipe Area

Establishing a known area that will provide sufficient loading without exceeding the absorptive capacity of the wipe material is the key to proper surface evaluation. As a general practice, a 10-centimeter (cm) x 10-cm area is evaluated as a discrete sample.

Field efforts can be simplified by developing templates using inert materials, such as posterboard, plastic, or other material (dependent on the nature of the contaminant of concern). The template is usually an 8.5 inch (in.) x 11 in. piece of the inert material with a 10 cm "hole" cut away that will leave the target surface exposed for the wiping process.

The sample grid will include the floor only (no wall or ceiling samples).

Wipe Materials

In general, the wipe materials will be comprised of an inert, absorptive material wetted with an appropriate solvent to enhance absorption/dissolution from the surface to be evaluated. The wipes are typically 10 cm x 10 gauze or "Techni-cloth" wetted with minimal solvent and contained within a small jar.

Wipe Process

1. Wiper is removed from the jar.

2. Excess solvent is squeezed from the wipe.

3. Sweep the surface from left to right with the wiper.

4. Fold the wiper, and make an additional surface sweep from bottom to top.

5. Place the wipe back into the original jar.

6. Ensure that the jar is appropriately labeled and that the surface area of the wipe is recorded.

Typical wipe kits consist of the following:

During the closure period, use the checklist in Table 2 to document closure activities for the purpose of closure certification. Photos should be taken during closure activities.

Personal protective equipment will be provided for the cleaning crew during decontamination and sampling operations in accordance with CSSA health and safety procedures or other appropriate procedures. This equipment may include waterproof steel-toed boots, safety glasses, and waste-resistant gloves.

After closure activities are completed, the building structure may be removed to an authorized waste landfill.

Constituents of Concern and Analytical Methods

In accordance with 30 TAC §335 Subchapter S, for closure under Risk Reduction Standard 1, cleanup levels shall be attained using analytical procedures taken from one of the following sources: Test Methods for Evaluating Solid Waste, EPA, SW-846, September 1994; Methods for the Chemical Analysis of Water and Wastes, EPA, March 1983; or Standard Methods for the Examination of Water and Wastewater, American Public Health Association, 1995. O’Brien and Gere Laboratory of Syracuse, New York, will conduct the sample analyses.

Table 2 - Checklist of Closure Procedures Building 40 Container Storage Area (TNRCC 001)

This building closure was prepared in accordance with this checklist.

Performed By:________________________________________

Parsons ES Field Personnel

The contaminants of concern, semivolatile organic compounds (SVOCs), cadmium, lead, and pesticides, will be analyzed for according to the methods listed in Table 3. Laboratory results, including PQLs, need to be reported. Complete laboratory quality assurance/quality control should be kept on file in the event of a request for more information from TNRCC.

Table 3 - Constituents of Concern and Methods of Analysis