Waste Analysis Plan

1. Introduction

During the course of investigation activities at Camp Stanley Storage Activity (CSSA) solid waste management units (SWMUs), metals-contaminated soils from the SWMUs may be treated and disposed of off-site to facilitate further investigation. The treatment of the contaminated soils will be conducted in 20 cubic yard roll-off containers and will be conducted within a 90-day accumulation period from the time the waste is determined applicable for treatment. Treatment will occur within each SWMU boundary from which contaminated soils were generated. The best demonstrated available technology (BDAT) to treat metals contaminated soils is stabilization (McCoy and Assoc., 1992).

This waste analysis plan describes the procedures that will be undertaken to obtain sufficient information to characterize the waste. It also establishes the waste sampling and analysis procedures that will be conducted to ensure appropriate land disposal restrictions (LDR) treatment standards have been met based on previous investigative and analytical results. Finally, this plan provides information regarding how the stabilization will be achieved, and why it is a suitable technology.

This plan was prepared in accordance with the requirements of 40 Code of Federal Regulations (CFR) 268.7(a)(4) and follows the model outline for Waste Analysis Plans (WAPs) provided in Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Waste, A Guidance Manual (EPA, PB963603, OSWER 9938.4-03, 1994). To the greatest extent possible, information required in this WAP that has already been presented in CSSA�s Environmental Encyclopedia is provided here by reference only.

2. Facility Description

A general facility description is included in the Installation Description and History section of the Background Information Report.

1. Description of Solid Waste Management Units

The background of SWMUs B-20/21, B-32, and B-33, all units which may generate hazardous waste, can be found under their respective tabs in Volume 1-2 of the Environmental Encyclopedia. The general descriptions for these three sites provide information on the source of the waste and the constituents likely to be present in the waste.

Investigations at other SWMUs potentially contaminated with metals are ongoing and described under each site tab found in Volume 1-2 of the Environmental Encyclopedia. These investigations may indicate that stabilization and off-site disposal is the best demonstrated available technology (BDAT) to remediate metals-contaminated soils. Therefore, these SWMUs may also generate contaminated soils which may undergo stabilization treatment as necessary. These SWMUs may contain hazardous levels of barium, cadmium, chromium, as well as lead. In addition, contaminated soils may contain concentration levels of nickel and zinc for which treatment standards may be applicable.

2. Identification and Quantities of Hazardous Wastes Managed

When necessary, potentially hazardous heavy metal contaminated soils from CSSA SWMUs will be excavated, stabilized, and disposed off-site. The quantities of soils from each SWMU to be disposed will be determined during investigation of each site. Soils will be stabilized to nonhazardous levels, as specified in 30 Texas Administrative Code (TAC) 335 Subchapter R, via immobilization. This includes stabilization and subsequent disposal work efforts for the SWMUs at CSSA including B-20, B-21, B-32, B-33 and other various SWMUs. This WAP has been developed to ensure the stabilized waste is properly managed as specified in Waste Analysis at Facilities that Treat, Store, and Dispose of Hazardous Wastes (EPA, 1994).

3. Selecting Waste Analysis Parameters

1. Criteria and Rationale for Parameter Selection

The rationale for selection of the parameters for which waste from each SWMU will be analyzed is presented in this description. Analytical results of sampled hazardous wastes referred to in site descriptions are maintained at CSSA.

1. SWMUs B-20 and B-21

Previous investigation and analytical results (see B-20/21 Links) indicate that material from SWMUs B-20 and B-21 would be considered characteristically hazardous due to elevated lead concentrations. Stabilized and non-stabilized over-excavated soils removed from these SWMUs will be tested for lead according to the methodology and parameters listed in this document.

2. SWMU B-32

Previous investigation and analytical results (see B-32 Links) indicate that material from SWMU B-32 would be considered hazardous waste due to elevated lead concentrations. Stabilized and non-stabilized over-excavated soils removed from this SWMU will be tested for lead according to the methodology and parameters listed in this document.

3. SWMU B-33

Previous investigation and analytical results (see B-33 Links) indicate that material from SWMU B-33 would be considered hazardous waste due to elevated lead concentrations. Stabilized and non-stabilized over-excavated soils removed from this SWMU will be tested for lead according to the methodology and parameters listed in this document.

4. Other SWMUs

Other CSSA SWMUs may contain hazardous levels of barium, cadmium, chromium, as well as lead. In addition, contaminated soils may contain concentration levels of nickel and zinc for which treatment standards may be applicable.

4. Waste Management Activities

All wastes managed at CSSA were generated on-site. No off-site generated waste will be managed at CSSA. When suspected hazardous waste is ready for disposal, the Environmental Coordinator notes the date, the waste type and quantity, and its off-site destination. This information is then checked against the lists of authorized wastes and authorized management facilities to ensure that the disposal facility to receive the waste is authorized by the permit.

5. Waste Stabilization

The hazardous waste material will be stabilized with an approximate 14% (by weight) portland cement mixture prior to disposal, as specified in the standard operating procedures provided by the subcontractor in the Brief Work Plan (Eagle Construction and Environmental Services, Inc., 1997). Portland cement has been identified as the most appropriate solidification/stabilization (S/S) agent due to its ability to reduce leaching, its structural integrity, and material efficiency.

Portland cement is proven to significantly reduce the leachability of metals, in particular lead. A study prepared for the Environmental Protection Agency (EPA) performed a comparison of different techniques for the solidification/stabilization of contaminated soils. This study concluded that when the appropriate immobilization agent is used, "S/S can reduce the leachability of many metals to near the normal detection limits�as determined by the [toxicity characteristic leaching procedure] TCLP" (Acurex, Corp, 1989). An appropriate binding agent is chosen such that the hazardous waste and does not adversely affect setting, curing, or permanence of the matrix. Contaminants that interfere with any of these processes are considered contaminant restrictions. The S/S comparative study finds that there are very few contaminant restrictions for portland cement.

When compared to the other major S/S media, such as lime kiln dust and equal weight lime and fly ash, portland cement also tends to produce the most robust matrix while maintaining a high soil to cement ratio. The material strength of the resultant matrix is maintained for a variety of contaminants with differing water contents even at a high soil to cement ratio. Therefore, large quantities of soils and sludges may be solidified with little cement, while maintaining structural integrity.

Portland cement is the most widely used S/S agent used, and is especially suitable for immobilizing metals contaminated soils and sludges due to the pH of the cement mixture. As concluded by the EPA study, "The portland cement proved to be a superior binder by many criteria and appears to be the binder of choice of the [ones] evaluated here".

6. Waste Sampling and Analysis

In accordance with 40 CFR 268.7(a) all sampling and analytical methods employed are consistent with "Test Methods for Evaluating Solid Waste" (EPA SW-846) or equivalent. Analysis for waste characterization efforts will be conducted at a qualified independent commercial laboratory. Specific sampling procedures and analytical methods are addressed below.

The anticipated disposal material will be sampled for proper waste characterization in accordance with Texas Natural Resource Conservation Commission (TNRCC) requirements. Waste soils will be stabilized then analyzed using TCLP for the appropriate parameter(s) at an independent laboratory. A grab sample of the stabilized soils will be taken immediately upon completion of mixing efforts by hand trowel and placed into clean 8 ounce glass containers.

1. Parameters and Test Methods

As previously outlined, lead and other inorganic constituents have been identified as possible contaminants of concern for both stabilized and non-stabilized, over-excavated soils. Analytical methods identified in the table below will be used for the detection of other inorganic constituents. Since leachable constituents from waste or other materials are a concern for stabilized soils, all samples will be extracted using method SW1311, as required by 268.7(a). These analytical techniques will follow procedures described in "Test Methods for Evaluating Solid Waste", U.S. Environmental Protection Agency, SW-846 and the HQ AFCEE Quality Assurance Project Plan (QAPP) (AFCEE, 1998).

Although soils included in the stabilization and disposal efforts are contaminated with lead, other metals/contaminants may be present. Results of ongoing investigations will be utilized in determining the contaminants of concern for all disposal efforts.

2. Sampling Frequency

Soils that are stabilized will be sampled at a frequency of one per batch, approximately 20 yd³ per batch to verify the success of the treatment. Over-excavated soils which are intended for off-site disposal and are not stabilized will be sampled at a maximum frequency of one per 50 yd³.

Special Procedural Requirements

The stabilization treatment will be performed on applicable and appropriate soils in batch treatment operations. The treated waste streams will be stored on site until confirmation is received that the appropriate LDR treatment standards have been meet. In accordance with LDR regulations (40 CFR Part 268), all treated waste shipped off-site will be analyzed, to determine whether the waste meets applicable LDR treatment standards contained in 40 CFR ��268.41-48. All waste destined for off-site disposal will be tested for applicable parameters in 40 CFR ��268.41-48 to ensure that accurate LDR notifications and certifications are provided. All analytical results completed in support of LDR requirements will be retained within the facility operating record.

Wastes resulting from stabilization operations that exceed applicable LDR treatment standards will be either retreated until the LDR standards are met or sent off-site for further treatment to attain the numeric LDR standards. LDR notifications will be supplied with the shipment of waste with the information required under 40 CFR 268.7. In addition to the LDR notification, any additional data on the generated wastes will be provided to the subsequent permitted treatment, storage, or disposal facility (TSDF).

The treated waste can be disposed of in a Subtitle D landfill if they are determined after treatment to have attained the LDR treatment standards and no longer exhibit any hazardous waste characteristics.