rJUN ·1 - hwbdocuments.env.nm.gov Bliss/1995-06-21_Permit.pdf · The New Mexico Environment...

$: rJUN ·1 - hwbdocuments.env.nm.gov Bliss/1995-06-21_Permit.pdf · The New Mexico Environment Department (NMED) and the f \ Environmental Protection Agency (EPA) have ... CERCLA Comprehensive$
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS

1445 ROSS AVENUE, SUITE 1200 DALLAS, TX 75202-2733

rJUN 2 ·1 1995

CERTIFIED MAIL: RETURN RECEIPT REQUESTED

Major General James J. Cravens, Jr., Commander US Army Air Defense Artillery Center

and Fort Bliss Building 2, Wing A, Room 336 Fort Bliss, TX 79916-0058

RE: u.s. Army Air Defense Artillery Center and Fort Bliss EPA I.D. No. NM4213720101

Dear General Cravens:

Enclosed is a copy of your permit to operate a hazardous waste facility, under the Hazardous and Solid Waste Amendments of 1984 (HSWA).

The New Mexico Environment Department (NMED) and the f \ Environmental Protection Agency (EPA) have entered into a joint ¢' j permitting agreement, whereby permits may be issued in New ·Mexico

in accordance with the New Mexico Hazardous Waste Management Act, as well as the Resource Conservation and Recovery Act (RCRA).

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The agreement .. will-remain_ effective until the.~_State_hazardous wa-ste program recei-ves---authorfzatloli~ :g:na~.i'=:-_g(;.RA. :to. adiiiiriTsbir HSWA. In order for an applicant to have a fully effective -permit, both NMED and EPA must issue the permit.

This letter transmits a copy of your HSWA permit with the necessary signature for EPA approval for permit issuance. The RCRA part of the full permit will be sent to you by NMED. The permit will become effective on the date indicated.

Procedures for requesting the EPA Administrator to review permit decisions are detailed at 40 CFR Part 124.19. Effective March 1, 1992, jurisdiction over petitio_n~_for_review was changed from the Administrator to the Environmental Appeals Board. If you petition the Environmental Appeals Board for such a review, please send a copy of your petition to the Region 6 office.

Recycled/Recydable • PrlntJd with Vegetable 017 Based Inks on 100% Recyc/Bd Paper {40% Postoonsumer}

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The filing for appeals should be sent to the address listed below:

u.s. Environmental Protection Agency Office of the Administrator 401 M Street SW Room 1145 (West Tower) Washington, DC 20460

If you have any questions, please contact Mr. James Harris of my staff at (214) 665-6785.

Sincerely yours,

Allyn M. Davis, Director Hazardous Waste Management Division

Enclosures

cc: Mr. Ed Kelley New Mexico Environment Department

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LIST OF FIGURES AND MAPS Figure/Map Description Page A-1 Waste Analysis Plan Flow Scheme 29 G-1 Reservation Map, Fort Bliss, Texas 3 G-2 Fort Bliss McGregor Camp 4 G-3 Fort Bliss - Generalized Cross-Section 5 H-1 Hospital Routing Map, Fort Bliss, Texas 5 J-1 Well Locations and Water Table Contours, Fort Bliss, Texas 11 J-2 Simplified Geologic Map, Fort Bliss, Texas 13 J-3 Ft. Bliss/McGregor Range OB/OD Treat- ment Unit Schematic Diagram of Sampling Locations 15 J-4 Waste Analysis Plan Flow Scheme 20 J-5 Chain-of-Custody Form: Custody Transfer Record/Lab Work Request 30a O-1 Fort Bliss area Map 1 O-2 Fort Bliss area Contour Map 2 O-3 Unit Contour Map 3

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LIST OF ACRONYMS ADR Ammunition and Deposition Request AR Army Regulation BAT Ballistic Aerial Test BC Type of Fire Extinguisher Rating C-2...C-4 Military Explosive Paraffin Base CERCLA Comprehensive Emergency Response, and Liability Act CFR Code of Federal Regulations CLP Contract Laboratory Program CPR Cardio-Pulmonary Resuscitation DOT U.S. Department of Transportation DPT Department of Plans and Training EOD Explosive Ordnance Disposal EPA U.S. Environmental Protection Agency FAW Forward Area Weapons GPM Gallons Per Minute HAZMAT Hazardous Materials HSWA Hazardous and Solid Waste Amendments of 1984 HWMR New Mexico Hazardous Waste Management Regulations M32/MK1 Electric Cap Blasting Machine M700 Time Fuse M60 Time Fuse Igniter

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M122 Radio Wave Firing Device LIST OF ACRONYMS (Continued) MEDEVAC Medical Evacuation MS Matrix Spike MSD Matrix Spike Duplicate NBS National Bureau of Standards NEW Net Explosive Weight NMED New Mexico Environment Department OB/OD Open Burn/Open Detonation OIC Officer in Charge OSWER Office of Solid Waste Emergency Response PCB Polychlorinated Biphenyls PEP Pyrotechnics, Explosives and Propellants QAPMP Quality Assurance Project Management Plan QA/QC Quality Assurance/Quality Control RCRA Resource Conservation and Recovery Act RTO Radio Transmit Operator SOP Standard Operating Procedures TA312 Telephone Set TM Technical Manual USAADACENFB U.S. Army Air Defense Artillery Center and Fort Bliss UXO Unexploded Ordnance

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MODULE I Page 1 of 12

MODULE I - GENERAL PERMIT CONDITIONS A. EFFECT OF PERMIT The Permittee is allowed to treat on-site1 hazardous waste in accordance with the conditions of this Permit as specified in Module III, Permit Condition B, in compliance with HWMR-7, Part V, 40 CFR §264, Subpart I through O. Any treatment of hazardous waste requiring a permit under the New Mexico Hazardous Waste Management Regulations HWMR-7, Part V and not specifically authorized in this Permit is prohibited. Subject to HWMR-7, Part IX, § 270.4, compliance with this Permit generally constitutes compliance, for purposes of enforcement, with the New Mexico Hazardous Waste Act (§§ 74-4-1 et seq. NMSA 1978) and HWMR-7, Parts I,II, III, and IV to the extent the requirement of those Parts are applicable. The Permittee must also comply with all applicable self-implementing provisions imposed by the Resource Conservation and Recovery Act (RCRA) or HWMR-7, Part VIII. A complete (RCRA) permit consists of this Permit and a U.S. EPA Permit issued under the provisions of the Hazardous and Solid Waste Amendment of 1984 (HSWA) which addresses the portion of the RCRA program for which the State is not authorized. Issuance of this Permit does not convey any property rights of any sort or any exclusive privilege; nor does it authorize any injury to persons or property, any invasion of other private rights, or any infringement of state or local laws or regulations. Compliance with the terms of this Permit does not constitute a defense to any order issued or any action brought under Sections 3008(a), 3008(h), 3013, or 7003 of RCRA; Sections 106(a), 104 or 107 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. 9601 et seq., commonly known as CERCLA), or any other law providing for protection of public health or the environment. [HWMR-7, Part IX, §§ 270.4 and 270.30(g)] B. PERMIT ACTIONS B.1.Permit Modification, Revocation and Reissuance, and

Termination This Permit may be modified, revoked and reissued, or terminated 1 See definition on page 3.

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for cause, as specified in HWMR-7, Part IX, §§ 270.41, 270.42, and 270.43. The filing of a request for a permit modification, revocation and reissuance, or termination, or the notification of planned changes or anticipated noncompliance on the part of the Permittee, does not stay the applicability or enforceability of any permit condition. [HWMR-7, Part IX, §§ 270.4(a) and 270.30(f)].

B.2.Permit Renewal B.2.a. This Permit may be renewed as specified in HWMR-7, Part IX, §270.30(b) and Permit Condition E.2. Review of any application for a Permit renewal shall consider improvements in the state of control and measurement technology, as well as changes in applicable regulations. [HWMR-7, §270.30(b). B.2.b. This Permit shall be reviewed by the

Secretary five years after Permit issuance for any unit having land disposal aspects. Modifications shall be made by the Permittee as required by the Secretary and in accordance with HWMR-7, Part IX, §270.50 (d).

C. SEVERABILITY The provisions of this Permit are severable, and if any provision of this Permit, or the application of any provision of this Permit to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this Permit shall not be affected thereby [HWMR-7, Part X, §1004]. D. DEFINITIONS For purposes of this Permit, terms used herein are defined for each module. Terms found in Module I shall have the same meaning as those in HWMR-7 Part I, §260.2, unless this Permit specifically provides otherwise. Terms found in Module II shall have the meaning defined in HWMR-7, Part I, §260.10, unless the Permit specifically provides otherwise. Where terms are not defined in the regulations or the Permit, the meaning associated

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with such terms shall be defined by a standard dictionary reference or the generally accepted scientific or industrial meaning of the term. "Secretary" means the Secretary of the New Mexico Environment Department (NMED), a designee or authorized representative. "Regional Administrator" means the Regional Administrator of the U.S. Environmental Protection Agency (U.S. EPA), Region 6, or a designee authorized representative (the Secretary of the NMED). "Permittee" means the U.S. Army Air Defense Artillery Center and Fort Bliss (USAADACENFB), McGregor Range, Otero County, New Mexico, EPA I.D. Number NM4213720101. D.1 Facility Whenever the word "facility" is used anywhere in the Permit

text, such usage shall connote the entire complex comprising all contiguous land, and structures, other appurtenances, and improvements on the Permittee's land, used for treatment of hazardous waste munitions, as per HWMR-7, Part I, 40 CFR §260.10.

D.2. Foreign Source Whenever the words "foreign source" are used in the permit text,

it is to be understood to mean hazardous waste generated outside the United States.

D.3. Off-site source "Off-site source" refers to wastes generated outside the

Permittee's facility. D.4.On-site Whenever the words "on-site" are used it is to be understood to

mean on the same or geographically contiguous property as defined in 40 CFR §260.10.

D.5. Open Detonation Whenever the words "open detonation" are used it should be

understood to mean the disposal of explosives or munitions by propagating a detonation from a disposal charge to the explosives or explosive contained in the munition under destruction.

D.6.Treatment Unit

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Whenever the words "treatment unit" are used in the text, it

should be understood to be the approximately 500 feet (152.4 meters) by 200 feet (61 meters) generally rectangular portion of the Permittee's facility (shown on the topographic maps of Permit Attachment O), where explosive ordnance disposal of waste munitions will be conducted.

E.DUTIES AND REQUIREMENTS E.1.Duty to Comply The Permittee shall comply with all conditions of this Permit,

except to the extent and for the duration such noncompliance is authorized by an emergency Permit. Any Permit noncompliance, other than noncompliance authorized by an emergency Permit, constitutes a violation of RCRA and is grounds for enforcement action; for Permit termination, revocation and reissuance, or modification; or for denial of a Permit renewal application [HWMR-7, Part IX, §270.30(a)].

E.2.Duty to Reapply If the Permittee wishes to continue an activity allowed by this

Permit after the expiration date of this Permit, the Permittee shall submit a complete application for a new Permit at least 180 days prior to Permit expiration. [HWMR-7, Part IX, §§270.10(h), 270.30(b)].

E.3.Permit Expiration Pursuant to HWMR-7, Part IX, §270.50, this Permit shall be

effective for a fixed term not to exceed ten years. As long as NMED is the Permit-issuing authority, this Permit and all conditions herein will remain in effect beyond the Permit's expiration date, if the Permittee has submitted a timely, complete application (see HWMR-7, Part IX, §§270.10, 270.13 through 270.29) and, through no fault of the Permittee, the Secretary has not issued a new Permit (HWMR-7, Part IX, §270.51).

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E.4. Need to Halt or Reduce Activity Not a Defense It shall not be a defense for the Permittee, in an enforcement

action that it would have been necessary, to halt or reduce the Permitted activity in order to maintain compliance with the conditions of this Permit [HWMR-7, Part IX, §270.30(c)].

E.5. Duty to Mitigate In the event of noncompliance with this Permit, the Permittee

shall take all reasonable steps to minimize releases to the environment and shall carry out such measures, as are reasonable, to prevent significant adverse impacts on human health or the environment. [HWMR-7, Part IX, § 270.30(d)]

E.6. Proper Operation and Maintenance The Permittee shall at all times properly operate and maintain

the OD treatment unit and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this Permit. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance/quality control procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of this Permit [HWMR-7, Part IX, §270.30(e)].

E.7. Duty to Provide Information The Permittee shall furnish to the Secretary, within a

reasonable time, any relevant information which the Secretary may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this Permit, or to determine compliance with this Permit. The Permittee shall also furnish to the Secretary, upon request, copies of records required to be

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kept by this Permit [HWMR-7, Part V, §264.74(a), and Part IX, §270.30(h)].

E.8. Inspection and Entry Pursuant to HWMR-7, Part IX, §270.30(i), the Permittee shall

allow the Secretary, or an authorized representative, upon the presentation of credentials and other documents, as may be required by law, inspection and entry privileges authorized by Permit Conditions from E.8.a. through E.8.d.

E.8.a.Enter at reasonable times upon the Permittee's

premises where the regulated OD treatment unit or activity is located or conducted, or where records must be kept under the conditions of this Permit;

E.8.b.Have access to and copy, at reasonable times, any

records that must be kept under the conditions of this Permit;

E.8.c.Inspect at reasonable times any unit, equipment

(including monitoring and control equipment), practices, or operations regulated or required under this Permit.

E.8.d.Sample or monitor, at reasonable times, for the

purposes of assuring Permit compliance or as otherwise authorized by RCRA, any substances or parameters at any location. The Permittee shall be provided the opportunity to obtain split or duplicate samples.

E.9. Monitoring and Records E.9.a.Samples and measurements taken for the purpose of

monitoring shall be representative of the monitored activity. The method used to obtain a representative sample of the waste to be analyzed must be described in Permit Attachment A, the Waste Analysis Plan or be approved by the Secretary. Analytical methods must be those specified in Test Methods for Evaluating Solid Waste:

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Physical/Chemical Methods SW-846, Standard Methods of Wastewater Analysis, or an equivalent method, as specified in Permit Attachment A or approved by the Secretary [HWMR-7, Part IX, §270.30(j)(1)].

E.9.b.The Permittee shall retain records of all monitoring

information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports and records required by this Permit, the certification required by HWMR-7, Part IX, §264.73(b)(9), and records of all data used to complete the application for this Permit for a period of at least 3 years from the date of the sample, measurement, report, record, certification, or application. These periods may be extended by request of the Secretary at any time and are automatically extended during the course of any unresolved enforcement action regarding this facility. [HWMR-7, Part IX, §270.30(j)(2)].

E.9.c.Pursuant to HWMR-7, Part IX, §270.30(j)(3), records

of monitoring information shall specify: i.The dates, exact place, and times of sampling or measurements; ii.The individuals who performed the sampling or measurements; iii. The dates analyses were performed; iv. The individuals who performed the analyses; v. The analytical techniques or methods used; and vi. The results of such analyses. E.10. Reporting Planned Changes The Permittee shall give notice to the Secretary, as soon as

possible, of any planned physical alterations or additions to the Permitted OD treatment unit. [HWMR-7, Part IX, §270.30(l)(1)].

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E.11. Reporting Anticipated Noncompliance The Permittee shall give advance notice to the Secretary of any

planned physical changes in the permitted OD treatment unit or activity which may result in noncompliance with permit requirements. [HWMR-7, Part IX, §270.30(l)(2)].

E.12. Certification of Construction or Modification The Permittee may not commence treatment of hazardous waste at

the OD treatment unit until the Permittee has submitted to the Secretary, by certified mail or hand delivery, a letter signed by the Permittee and a New Mexico registered professional engineer stating that the OD treatment unit has been constructed or modified in compliance with the Permit; and

E.12.a.The Secretary has inspected the modified or newly

constructed OD treatment unit and finds it is in compliance with the conditions of the Permit;

or E.12.b.The Secretary has either waived the inspection or has not

within 15 days notified the Permittee of his intent to inspect. [HWMR-7, Part IX, §270.30(1)(2)].

E.13.Transfer of Permits This Permit is not transferable to any person, except after

notice to the Secretary. The Secretary may require modification or revocation and reissuance of the Permit pursuant to HWMR-7, Part IX, §270.40. Before transferring ownership or operation of the OD treatment unit during its operating life, the Permittee shall notify the new owner or operator in writing in accordance with the requirements of HWMR-7, Part IX, §270.30(l)(3), and Part V, §264.12(c).

E.14.Twenty-Four Hour and Subsequent Reporting

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E.14.a.The Permittee shall report to the Secretary any noncompliance which may endanger health or the environment. Any such information shall be reported orally within 24 hours from the time the Permittee becomes aware of the circumstances. The report shall include the following:

i.Information concerning release of any hazardous waste that may

cause an endangerment to public drinking water supplies.

ii.Any information of a release or discharge of hazardous waste,

or of a fire or accidental explosion at the hazardous waste management OD treatment unit which could threaten the environment or human health outside the hazardous waste management unit.

E.14.b.The description of the occurrence and its cause shall

include: i.Name, address, and telephone number of the owner or operator; ii.Name, address, and telephone number of the facility; iii.Date, time, and type of incident; iv.Name and quantity of materials involved; v.The extent of injuries, if any; vi.An assessment of actual or potential hazards to the

environment and human health outside the facility, where this is applicable; and

vii.Estimated quantity and disposition of recovered material

that resulted from the incident. E.14.c.A written submission shall also be provided within

five days of the time the Permittee becomes aware of the circumstances. The written submission shall contain a description of the noncompliance and

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its cause; the period(s) of the occurrence including exact dates and times; and, if the noncompliance has not been corrected; the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance. The Secretary may waive the five-day written notice requirement in favor of a written report within 15 days. [HWMR-7, Part IX, §270.30(l)(6)].

E.14.d.If the Contingency Plan is implemented, the

Permittee must comply with the reporting requirements listed in the Contingency Plan.

E.15.Other Noncompliance The Permittee shall report all other instances of noncompliance

not otherwise required to be reported above, Permit Conditions E.10. through E.15., at the time monitoring reports are submitted. The reports shall contain the information listed in Permit Condition E.14 [HWMR-7, Part IX, §270.30(l)(10)]

E.16.Other Information Whenever the Permittee becomes aware that it failed to submit

any relevant facts in the Permit application, or submitted incorrect information in a Permit application or in any report to the Secretary, the Permittee shall promptly submit such facts or information. [HWMR-7, Part IX, §270.30(l)(11)].

F. SIGNATORY REQUIREMENT All applications, reports, or information submitted to or requested by the Secretary, a designee, or authorized representative, shall be signed and certified in accordance with HWMR-7, Part IX, §270.11 and 270.30(k).

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G.REPORTS, NOTIFICATIONS, AND SUBMISSIONS TO THE SECRETARY All reports, notifications, or other submissions which are required by this Permit to be sent or given to the Secretary or should be sent by certified mail or given to: RCRA Permits Program Manager Hazardous and Radioactive Materials Bureau New Mexico Environment Department 525 Camino de los Marquez P.O. Box 26110 Santa Fe, New Mexico 87502 Telephone Number: (505) 827-4308 Facsimile Number: (505) 827-4361 H. CONFIDENTIAL INFORMATION In accordance with HWMR-7, Part IX, §270.12, the Permittee may claim confidential any information required to be submitted by this Permit. I. DOCUMENTS TO BE MAINTAINED AT THE FACILITY The Permittee shall maintain a written operating record of OD activities and laboratory results at the Davis Dome facility at the McGregor Range in compliance with HWMR-7, Part V, 264.73, until closure is completed and certified by an independent, New Mexico registered professional engineer, the following documents and all amendments, revisions and modifications to these documents: 1.Waste Analysis Plan, as required by HWMR-7, Part V, §264.13

and this Permit. 2.Inspection schedules, as required by HWMR-7, Part V,

§264.15(b)(2) and this Permit. 3.Personnel training documents and records, as required by HWMR-

7, Part V, §264.16(d) and this Permit. 4.Contingency Plan, as required by HWMR-7, Part V, §264.53(a)

and this Permit.

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5.Operating record, as required by HWMR-7, Part V, §264.73 and

this Permit. 6.Closure Plan, as required by HWMR-7, Part V, §264.112(a) and

this Permit. 7.Contingency Post-Closure Plan as per HWMR-7, Part V, §264.310

and this Permit, in case the Permittee is unable to demonstrate clean closure.

8.Procedures for Limiting air Emissions, as required by HWMR-7,

Part V, §264.601(c); and Part IX, §270.23(c) and this Permit.

J. PERMIT CONSTRUCTION J.1. Citations Whenever paragraphs of this Permit or of the Hazardous Waste Management Regulations are cited, such citations include all subordinate sections of the cited paragraph. When subordinate sections are cited, such citations include all subsections of the cited paragraphs. All such citations shall be considered an inclusion by reference to this Permit in accordance with HWMR-7, Part IX. J.2. Gender Whenever the pronoun "he" is used in reference to the Secretary

of the New Mexico Environment Department or the Permittee, it is to be read as "she" in any instance where the person of the reference is female.

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MODULE II Page 1 of 7

MODULE II - GENERAL FACILITY CONDITIONS A. DESIGN AND OPERATION OF OD TREATMENT UNIT The Permittee shall construct, maintain, and operate the OD treatment unit to minimize the possibility of a fire, explosion, or any unplanned, sudden or nonsudden release of hazardous waste to air, soil, or surface water which could threaten human health or the environment, as described in Permit Attachment G, in accordance with the requirements of HWMR-7, Part V, §264.31. B. REQUIRED NOTICES B.1.Hazardous Waste Imports This permit does not allow the Permittee to accept wastes

from a foreign source. If the Permittee is to receive hazardous waste from a foreign source, he shall apply and receive a permit modification in accordance with HWMR-7, Part IX, §270.41 or § 270.42 prior to accepting such waste.

B.2.Hazardous Waste from Off-Site Sources "Off-site source" refers to wastes generated by sources other

than the Permittee or its contractor(s) operating on-site. When the permittee is to receive hazardous waste from an off-site source (except when the Permittee is also the generator), he must inform the generator in writing that he has the appropriate Permits, and will accept the waste the generator is shipping. The Permittee must keep a copy of this written notice as part of the operating record. [HWMR-7, Part V, §264.12(b)].

C. GENERAL WASTE ANALYSIS The Permittee shall follow the waste analysis procedures required by HWMR-7, Part V, §264.13, as described in the Waste Analysis Plan, Permit Attachment A. In addition to the proposed soil sampling within and near the OD treatment unit (described in Permit Attachments A and J), the Permittee shall sample to at

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least 100 feet in radius and to a depth of 10 feet from the perimeter of the OD treatment unit during initial soil sampling. This sampling activity shall be coordinated with selection of the three background samples proposed by the Permittee. This will assist in characterizing the OD treatment unit and its proximity. The first soil sampling event shall be conducted within 180 days of the effective date of this permit. The Permittee shall verify the analysis of each waste stream annually as part of its quality assurance program, in accordance with Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, EPA Publication SW-846, or equivalent methods approved by the Secretary. At a minimum, the Permittee shall maintain proper functional instruments, use approved sampling and analytical methods, verify the validity of sampling and analytical procedures, and perform correct calculations. If the Permittee uses a contract laboratory to perform analyses, then the Permittee shall inform the laboratory in writing that it must operate under the waste analysis conditions set forth in this Permit. D. SECURITY PLAN The Permittee shall comply with the security provisions of HWMR-7, Part V, §264.14(b) and §264.14(c) as described in Permit Attachment B. Barriers and Means to control Entry The Permittee shall maintain a barrier and a means to control entry in compliance with HWMR-7, Pt. V, §264.14(b)(2). A three-strand barbed-wire fence shall be built around the OD area. The roadway barrier (i.e., a lockable gate at the entrance road) to the OD area shall be kept locked except when Ordnance Disposal personnel enter the area for inspections or treatment operations. Access to the open detonation area shall be only through one gate, which is to be kept locked at all times. Warning Signs Warning signs, for example: " Danger—Explosive Disposal Range—Keep Out" shall be posted at the road entry point and where the perimeter approaches roads or active areas. The signs must be

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written in English and Spanish and must be legible from a distance of 25 feet (8 meters) and shall also be seen from any approach to the facility. In addition, the warning signs shall be posted at 300-foot (91-meter) intervals around the OD Range perimeter in accordance with HWMR-7, Part V, § 264.14(c). E. GENERAL INSPECTION REQUIREMENTS The Permittee shall follow the inspection schedule set out in Permit Attachment C. The Permittee shall remedy any deterioration or malfunction discovered by an inspection, as required by HWMR-7, Part V, §264.15(c). Records of inspection shall be kept, as required by HWMR-7, Part V, §264.15(d). F. PERSONNEL TRAINING The Permittee shall conduct personnel training, as required by HWMR-7, Part V, §264.16. This training program shall follow the attached outline, Permit Attachment D. The Permittee shall maintain training documents and records, as required by HWMR-7, Part V, §264.16(d) and (e). G.SPECIAL PROVISIONS FOR IGNITABLE, REACTIVE, OR INCOMPATIBLE

WASTE G.1. Handling of Reactive Waste The Permittee shall comply with the requirements of HWMR-7, Part

V, §264.17(a). The Permittee shall also follow the procedures for handling ignitable, reactive, and incompatible wastes set forth in applicable parts of HWMR-7, Part V §264, Subpart I, and the procedures specified in Permit Attachments H and I.

G.2.Container Management The Permittee shall not place hazardous waste in unwashed

containers that previously held incompatible waste or material in accordance with HWMR-7, Part V §264.177(b).

G.3. Hazardous Waste Storage The Permittee shall follow the procedures for assuring that

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pyrotechnics, explosives, and propellant materials subject to treatment at the OD unit are not stored for greater than 90 days in compliance with HWMR-7, Part III, §262.34, and the procedures specified in Permit Attachment A.

H. PREPAREDNESS AND PREVENTION H.1. Required Equipment At a minimum, the Permittee shall maintain at the facility the

equipment set forth in the Contingency Plan, Permit Attachment E, as required by HWMR-7, Part V, §264.32.

H.2. Testing and Maintenance of Equipment The Permittee shall test and maintain the equipment specified in

Permit Condition H.1, as necessary, to assure its proper operation in time of emergency, as required by §264.33.

H.3. Access to Communications or Alarm System The Permittee shall maintain access to the communications or

alarm system, as required by HWMR-7, Part V, §264.34. H.4. Time to Conduct Open Detonation The Permittee shall conduct Open Burn/Open detonation activities

only between the hours of 7:00 am and 5:00 pm. No OD operations shall be conducted at night.

H.5. Weather Conditions The Permittee shall not carry out OD operations when the wind

speed exceeds 15 miles per hour (24 kilometers per hour). In addition, No OD activities shall be permitted if an electric storm is within 10 miles of the OD treatment unit.

H.6. Arrangements with Local Authorities The Permittee shall maintain arrangements with state and local

authorities, as required by HWMR-7 Part V, §264.37.

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If state or local officials refuse to enter into preparedness and prevention arrangements with the Permittee, the Permittee must document this refusal in the operating record.

H.7.Hazardous Waste Inventory The Permittee will maintain, in an accessible location, a

current inventory showing type, location, and quantity of all hazardous waste in storage that will be subject to treatment within 90 days. NMED does have a need and right to know the type, location and quantity of all Explosive/Reactive Hazardous waste.

H.8.Use of Grandstands The Permittee shall ensure that all grandstands are closed to

both members of the public and military personnel during open detonation activities.

I. CONTINGENCY PLAN I.1. Implementation of Plan The Permittee shall immediately carry out the provisions of the

Contingency Plan, Permit Attachment E, whenever there is a fire, explosion, or release of hazardous waste or constituents which could threaten human health or the environment in accordance with HWMR-7, Part V, §264.51.

I.2. Copies of Plan The Permittee shall maintain and distribute copies of the

Contingency Plan in accordance with the requirements of HWMR-7, Part V, §264.53.

I.3. Amendments to Plan The Permittee shall review and immediately amend, if necessary,

the Contingency Plan, as required by HWMR-7, Part V, §264.54.

I.4. Emergency Coordinator A trained emergency coordinator shall be available at all times

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in case of an emergency, in compliance with HWMR-7, Part V, §264.55. He must implement the requirements of HWMR-7, Part V,§264.56.

J. RECORDKEEPING AND REPORTING In addition to the recordkeeping and reporting requirements specified elsewhere in this Permit, the Permittee shall do the following: J.1. Operating Record The Permittee shall maintain a written operating record of OD

activities at the Davis Dome facility at the McGregor Range in accordance with HWMR-7, Part V, §264.73.

J.2. Biennial Report The Permittee shall comply with the biennial reporting

requirements of HWMR-7, Part V, §264.75. J.3. Personnel and Telephone Number Changes The Permittee shall inform the NMED Secretary of changes in

their management personnel, when a new officer replaces the current contact person. In addition, the Permittee shall keep the Secretary informed about any changes in its telephone numbers within 10 calendar days of the change in numbers.

K. GENERAL CLOSURE REQUIREMENTS K.1. Performance Standard K.1.a. The Permittee shall close the OD treatment unit as

required by HWMR-7, Part V, §264.111 and in accordance with the Closure Plan, Permit Attachment F.

K.1.b. The Permittee shall cease to conduct all open

detonation activities at the OD unit and shall close the OD unit in accordance with the Closure Plan, Permit Attachment F, if Congress decommissions McGregor Range.

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K.2. Amendment to Closure Plan The Permittee shall amend the Closure Plan, in accordance with

HWMR-7, Part V, §264.112(c), whenever necessary. K.3. Notification of Closure The Permittee shall notify the Secretary in writing at least 60

days prior to the date on which he expects to begin closure of the OD treatment unit or final closure of the OD treatment unit, as required by HWMR-7, Part V, §264.112(d).

K.4. Time Allowed For Closure After receiving the final volume of hazardous waste, the

Permittee shall treat, remove from the unit and dispose of at a permitted site all hazardous waste and shall complete closure activities, in accordance with §264.113 and the schedules specified in the Closure Plan, Permit Attachment F or as amended by the requirement of Permit Condition L.2.

K.5.Disposal or Decontamination of Equipment, Structures, and

Soils The Permittee shall decontaminate or dispose of all contaminated

equipment, structures, and soils, as required by HWMR-7, Part V, §264.114 and the Closure Plan, Permit Attachment F.

K.6. Certification of Closure The Permittee shall certify that the OD treatment unit has been

closed in accordance with the specifications in the Closure Plan, as required by HWMR-7, Part V, §264.115.

MODULE III Page 1 of 7

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MODULE III-TREATMENT OF ENERGETIC WASTES A. MODULE HIGHLIGHTS This module contains a general description of the permitted and prohibited waste identification, the design plan of the open detonation treatment unit, and the standard operating procedures. Also included are a description of the amount of waste munitions allowed to be treated, how the wastes are to be handled prior to OD activities, the sampling and analysis plan for the potentially contaminated soil and ash/residues following OD operations, and the procedures for limiting air emissions. Further, the climatic conditions, risk assessment, and methods of protecting the environmental media are presented. B. PERMITTED AND PROHIBITED WASTE IDENTIFICATION B.1.The Permittee may open detonate only the wastes listed

in Permit Attachment M (Permitted Waste Codes and Maximum Treatment Quantities) and in Tables A-2 through A-6. The Permittee is prohibited from treating Radioactive Nuclear Waste, Mixed Waste, and Polychlorinated Biphenyls (PCBs). All treatment shall consist of explosive open detonation only.

B.2.The Permittee is prohibited from treating hazardous

waste that is not identified in Permit Condition B.1. above, including shipping and storage containers for waste explosives. The amount of waste munitions to be open detonated shall not exceed 1372 pounds (623 kilograms) Net Explosive Weight (NEW) per calendar year or 13,720 pounds (6230 kilograms)(NEW) for the permitted life of the OD treatment unit.

B.3.The Permittee shall not open detonate more than 343 pounds

(156 kilograms) waste munitions per quarter, except in case of an emergency, after authorization by the Secretary.


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C. OPEN DETONATION ON THE GROUND: C.1.The Permittee shall construct, maintain and operate the OD

treatment unit to minimize the possibility of a fire, explosion, or any unplanned, sudden or nonsudden release of hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment, as required by HWMR-7, Part V, § 264.31 and §264.601. The Permittee shall maintain the structures and equipment and follow the design plan described in Permit Attachment G, with provisions for a cover for a pit that may result from continual OD operations during the permitted life of the OD unit.

C.2.The Permittee shall operate and maintain the open

detonation areas in accordance with the operating procedures contained in Permit Attachment I.

C.3.The Permittee shall (design, construct) operate and

maintain the open detonation area in order to minimize air emissions or exposure of people (onsite or offsite) to toxic or hazardous emissions in accordance with Permit Attachment I.

C.4.The Permittee shall (design, construct) operate and

maintain the open detonation area in order to minimize noise in accordance with Permit Attachment I.

C.5.Ash/residues from the open detonation area shall be

managed in accordance with Permit Attachment J. C.6.The Permittee shall (design, construct) operate and

maintain runon control system in accordance with the design plans, specifications, and operating practices contained in Permit Attachments G, and I, in compliance with the requirements of HWMR-7, Part V, §264.601(a)(1)(3)(4); (b)(2)(3)(4) and (c)(4).


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C.7. The Permittee shall (design, construct) operate and

maintain a runoff control system in accordance with the design plans, specifications, and operating practices contained in permit attachments G and I.

C.8. The protective berm described in Attachment G shall be

maintained in such a way that surface drainage will be eliminated from entering the active portion of the OD pits in accordance with (HWMR-7, §264.301(g).

C.9.The Permittee shall not allow accumulated precipitation

in any portion of the OD pits. All standing water shall be removed within 24 hours after a precipitation event. The water thus removed shall be treated as a hazardous waste, if sampling and analysis shows that it contains contaminant constituents beyond the regulatory thresholds.

C.10.Bilingual (English and Spanish) Warning signs shall be

posted on all four sides of the Open Detonation Unit as specified in HWMR-7, Part V, §264.14(c).

D. WASTE ANALYSIS PLAN The Permittee shall carry out the Waste Analysis Plan for

ash/residues and soils as described in Permit Attachments A and J.

E. RISK ASSESSMENT The Permittee shall conduct Risk Assessment using either EPA

Region 3 Guidelines or the Permittee may calculate the action levels using EPA Subpart S Risk-Based Guidelines.

F.INSPECTION SCHEDULES AND PROCEDURES:


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The Permittee shall inspect the OD treatment unit in accordance with the inspection schedule described in Permit Attachment C. These inspections shall also include search for, and the collection of any unexploded ordnance (UXO), metal casings, and related "kickouts". All UXOs, metal casings and fragments shall be placed in appropriate containers, handled and disposed of as RCRA hazardous waste.

G.SPECIAL PROVISIONS FOR HANDLING IGNITABLE, REACTIVE, OR

INCOMPATIBLE WASTE The Permittee shall follow the special procedures for handling

ignitable, reactive, and incompatible wastes set forth in Permit Attachment H in compliance with the requirements of HWMR-7, Part V, §264.17(a).

H. STANDARD OPERATING PROCEDURES H.1.The Permittee shall operate and maintain the OD treatment

unit in accordance with the operating procedures contained in Permit Attachment I.

H.2.The Permittee shall conduct OD activities only between the

hours of 7:00 am and 5:00 pm from Monday through Sunday during any week, except in case of an emergency.

H.3.Under no circumstances shall OD operations be conducted after sunset, or between the hours of 5: pm and 7:00 am during any day of the week.

H.4.The Permittee must ensure that not less that two

persons are present at the OD unit during any OD operations. No one shall be allowed to conduct OD operations alone.

H.5.The Permittee must carry out OD activities in compliance

with the safety precautions contained in the Standard Operating Procedures, Permit Attachment I.

H.6.The Permittee shall not conduct OD activities at the

treatment unit until an approved pre-operation soil sampling and analysis plan has been submitted to NMED.


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H.7.The Permittee is prohibited from conducting military

training at the OD treatment unit. I. SAMPLING AND ANALYSIS FOR AIR AND SOIL MONITORING I.1.The Permittee shall conduct soil sampling and analysis

program as described in Permit Attachment J in accordance with the requirements of HWMR-7, Part V, 40 CFR §264.278 and §264.601(b)(1)(8)(11).

In addition to the hazardous constituents listed in Table A-8,

Permit Attachment A, the Permittee must also analyze for polychlorinated biphenyls (PCBs), and dioxins since these are known to be by-products of open detonation events.

I.2.The Permittee shall carry out semi-annual soil sampling

within 24 hours after the last semi-annual open detonation event. The soil sampling shall be preceded by an inspection of the OD unit and removal of any unexploded ordnance by trained Ordnance Disposal personnel.

I.3.Frequency of Sampling: The Permittee shall implement a semi-annual soil sampling and

analysis program as described in Permit Attachment J. I.4.The Quality Assurance/Quality Control program to be

implemented shall be as presented in Permit Attachment J, which is included herein.

J.CLIMATIC CHARACTERISTICS OF THE OD AREA AND PROCEDURES FOR

PROTECTION OF HUMAN HEALTH AND ENVIRONMENTAL MEDIA. J.1.The Permittee shall evaluate the potential impact of the air

pollutants on human health before, during, and after OD operations by screening and assessment as per S.S. Army Environmental Hygiene Agency publication and/or U.S. EPA approved models.


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J.2.The Permittee shall not carry out open detonation operations when there is unauthorized personnel on the OD treatment unit.

J.3.The Permittee shall not carry out open detonation activities

on any day when a thunderstorm is imminent or is within ten (10) (16 km) miles of the treatment unit.

J.4.The Permittee shall not conduct open detonation activities

during a snowstorm. J.5.The Permittee shall not conduct open detonation

practices during a duststorm or sandstorm. J.6.The Permittee shall not conduct open detonation when

there is a range fire. K. RECORDKEEPING The Permittee shall develop and maintain all records required to comply with HWMR-7, Part V, §264.73, and §264.602, and Permit Attachment L. L. ASH MANAGEMENT PROCEDURES L.1.The Permittee shall manage ash/residues from the open

detonation treatment unit as described in Permit Attachment J.

L.2.Within 24 hours after each treatment event, Ordnance

Disposal personnel shall police the cleared area within the fence for fragments of waste (including metal casings) originating from treatment operations, and "kickouts". This shall be done only after it has been established that it is safe for personnel to reenter the active portion of the OD unit. If waste fragments, metal casings and kickouts are found, they shall be handled accordingly as described in Permit Condition G above.

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M. GROUND WATER MONITORING The Permittee shall conduct ground water monitoring if soil

sampling indicates contamination, in accordance with HWMR-7, Part V, §264 Subpart F.

N. AIR MODELING AND MONITORING The Permittee shall conduct air modeling prior to the

commencement of the OD operations. Air Monitoring shall be conducted at each detonation henceforth when soil sampling results indicate the potential for ground water contamination. This is in compliance with environmental protection requirements of HWMR-7, Part V, §264.601(c).

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PERMIT ATTACHMENT A Page 1 of 33

PERMIT ATTACHMENT A WASTE ANALYSIS PLAN The following information describes the measures that will be taken to assure that the wastes treated at the Open Detonation (OD) treatment unit by the U.S. Army Air Defense Artillery Center and Fort Bliss (USAADACENFB) are in accordance with the requirements of HWMR-7, Part. V, § 264.13, and the unit-specific requirements of HWMR-7, Part. V, § 264, Subpart X. The OD unit is a thermal treatment unit owned by the United States Government and operated by USAADACENFB. The hazardous wastes to be treated at the OD unit include propellants, explosives, and pyrotechnics (PEP), in the form of pure substances and contaminated solid wastes. The waste materials subject to treatment result from demilitarization of existing stockpiles and off specification materials. When records indicate that PEP materials have reduced military use due to age, the materials are segregated, designated "waste material", and they are transported to the OD treatment unit for demolition by EOD personnel. USAADACENFB plans to detonate up to 1372 pounds (623 kilograms) of hazardous waste munitions per calendar year or 343 pounds (156 kilograms) per quarter. Tables A-2 through A-7 are a list of the waste munitions that will be treated at the OD unit. WASTE CHARACTERISTICS The chemical and physical characteristics of waste thermally treated at the OD treatment unit are described in this section along with a waste analysis plan for sampling, testing, and evaluating the waste. Table A-1 is an example of generator supplied information that will be obtained from the explosives manufacturers and used together with the Materials Safety Data Sheet and equivalent technical information to characterize the waste munitions, since by their nature the subject waste munitions are too dangerous to characterize by chemical

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analysis. CHEMICAL AND PHYSICAL ANALYSES [HWMR-7, Part IX, §270.14 (b) (2) and 264.13(a)] For the vast majority of the wastes thermally treated at the OD unit, the physical and chemical characteristics required to prove that adequate treatment of the waste will occur during the open detonation process has been well documented by Department of Defense personnel. The formulations of some Department of Defense waste ordnance, propellants, explosives, and pyrotechnics (PEP) may be classified (i.e., secret or top secret) information (RCRA Part B Permit Writers' guidance manual for Department of Defense OD Detonation Units). The sensitive nature of this information is much different from that addressed in HWMR-7, Part IX, §270.12, i.e. Confidentiality of Information. USAADACENFB, will not provide analytical data which would jeopardize national security. Delays in the disposal of products that have been determined to be wastes, can lead to potentially severe safety problems. The inherent instability of these products greatly increases with time. Therefore, delays caused by requirements to perform time-consuming sampling and analysis may be counterproductive. Additional physical and chemical data will be worthless if the reactive waste detonated or ignited prematurely while sampling the product, or at a storage facility awaiting results of these analyses. Physical and Chemical Characteristics of Wastes and Residues Because the sampling and chemical analysis of PEP waste entering the unit is impractical for safety reasons, and because the materials treated may have changed over the years (e.g., initiators changed from black powder to C-4), direct waste characterization will not be done. Instead generator supplied information and process knowledge as well as unclassified literature will be used to document the general contents of the PEP prior to OD activities. Soil sampling will be used to determine what constituents may remain in the OD treatment unit.

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Two types of sampling are proposed. These include initial site characterization sampling, and closure sampling. The first, initial site characterization sampling is discussed below in the Section titled " Waste Analysis Plan". Closure sampling is presented in the Closure Plan, Permit Attachment F. Based on the information in Tables A-3, through A-7, all of the waste accepted for thermal treatment will be considered hazardous prior to treatment because of its explosive or reactive nature. Full hazardous characteristics analyses will not be performed prior to OD in order to avoid the danger associated with excessive handling of such materials and to eliminate costly and potentially dangerous time delays. The waste will be visually inspected prior to treatment to ensure that only appropriate wastes are subjected to thermal treatment, and to ensure that the PEP arriving at the OD treatment unit matches the waste identity designated on the accompanying manifest(s). Waste Container Management "Containers" are the shipping containers used to transport PEP from the manufacturer to bunker storage, to the practice range or battlefield for use, or to the OD unit for treatment. Containers are designed for safety and endurance, and are reusable. Therefore, they are reused or recycled after they are used to transport PEP to the OD treatment unit. The procedures for assuring that pyrotechnics, explosives, and propellant (PEP) materials subject to treatment at the OD unit are not stored for greater than 90 days are: 1.When records indicate that PEP materials in stockpile

have reduced military use due to age, the materials are segregated.

2.Segregated materials may be used for testing until they

are designated "waste material". 3.Once materials are designated "waste" they are

transported to the OD unit for treatment. The period

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between being designated waste and treatment does not exceed 90 days in compliance with HWMR-7, Part III, §262.34.

4.The "waste" is not stored at the OD treatment unit. WASTE ANALYSIS PLAN [ HWMR-7, Part IX, §270.14(b)(3), Part V, §264.13(b) and (c)] Tables A-2 through A-6 provide a list of PEP formulations that will be thermally treated at the OD treatment unit. Table A-7 contains the physical characteristics of PEP materials that will be demilitarized at this site. Analysis of the waste received will not be conducted prior to detonation because: 1.Its reactive nature is known to be hazardous, and

suitable for thermal treatment. 2.It would be dangerous to sample the waste PEP, and to

delay treatment pending laboratory analyses. 3.The constituents of the PEP are very well documented, and

unknown PEP wastes are not accepted for treatment. Documentation of the amount and type of PEP waste treated in the past two years is maintained by the 41st Explosive OD unit at Ft. Bliss (i.e. USAADACENFB). To determine potential impacts to human health and the environment, soils in and around the treatment unit will be sampled. If contaminants are released to the air the resulting particulate will settle near the source and be detected by soil sampling. Similarly, if groundwater is impacted it will be by leaching of contaminants through the soil and, therefore, soil sampling will indicate the impact. Surface water runoff is not anticipated, but soil sampling will indicate any potential runoff contamination. Therefore, the waste analysis plan will be focused on intensive soil sampling as presented below in the Section titled "Sampling Methods".

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•Parameters and Rationale [HWMR-7, Part V, §264.13(b)(1)] The configuration of the OD treatment unit is such that there is a large containment excavation in which all OD activities are conducted. The EOD team enters the excavation and selects a relatively flat area to place the waste munitions. The waste munitions are packed with an appropriate amount of explosives. The EOD team retreats to a safe distance from the detonation site, then detonates the materials. This process generates a pit from the explosion. There are currently two pits within the OD unit that are representative of any pits that would be formed as a result of OD operations. If waste residues (ash) are found in these areas they will be tested for RCRA hazardous waste characteristics (ignitability, reactivity, corrosivity and metals toxicity). The residue will be subjected to the reactivity tests (Gap Test and Deflagration/Detonation Transition Test) to determine if hazardous quantities of the PEP material remain. The residues will also be tested for explosive residues using an EPA approved Method SW 846 8330. These tests will serve as a measure of the effectiveness of thermal treatment for this waste. The RCRA toxicity characteristics test for metals will be done on the ash after negative results are obtained from the reactivity tests. The rationale for this is to minimize the potential for laboratory hazards associated with testing an explosive sample. The metals analysis will be performed because several heavy metals are used in PEP formulations. • SAMPLING METHODS [HWMR-7, Part V, §264.13(b)(3) & Part II, §261, Appendix I] Because of the inherent hazardous nature of the PEP materials and the potential for unexploded ordnance (UXO), no sampling will be done at the site until a sweep has been conducted for UXO. The UXO sweep will be done by a 41st Explosive OD

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specialist using established procedures. Discreet soil samples will be collected from the OD unit. All samples will be taken using a non-sparking (plastic or brass) scoop or other sampling device if so directed by the OD Ordnance Officer. Sampling personnel under the supervision of Fort Bliss Directorate of Environment personnel will record the location of each sample with respect to permanent stations, the date, names of sampling personnel, and other pertinent information. Permit Attachment J presents the Quality Assurance Project Management Plan. Soil samples will be collected from a depth between 6 in (15.2 cm) and 1 ft (0.3 m) at the following locations: •1 discreet sample at the bottom of each of the two OD pits in

the excavation, •3 discreet samples from the sides of each of the two OD

pits (6 total), •4 discreet samples around the perimeter of of each of the

OD pits (outside of the pits) to evaluate the effect of kickout (8 total),

•3 discreet background samples (in triangular form) from an area

of the OD treatment unit ( at least 50-100 feet away) that has not been impacted by operation of the OD.

Soil samples will be collected from a depth of surface to 6 in (15.2 cm), and 6 in (15.2 cm) to 1 ft (0.3 m) at the following locations: •8 discreet random samples in the bottom of the OD treatment

unit (but not in the pits). This is surface material from the flat excavated area that surrounds the pits of interest.

•8 discreet random samples from the perimeter (outside of

the treatment OD unit), and

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In addition, soil samples will be taken on 5 ft (1.5 m) intervals from a 50 ft (15.2 m) boring place approximately in the middle of the OD treatment unit. This will produce 10 samples. All samples will be examined for physical evidence of UXO or unburned materials. The samples will then be subjected to the reactivity tests (Gap Test and Deflagration/Detonation Transition Test). Upon completion of these tests, each individual soil sample will be placed into a cleaned mixing bowl, mixed thoroughly and placed into its appropriate sample container. The purpose of mixing each sample is to homogenize each individual discreet sample. There will be no sample compositing. Sample containers will be placed into a cooler with ice. When sampling is completed for the day, all samples will be shipped by overnight courier to a qualified laboratory, under appropriate chain-of-custody procedures, for analysis. During the initial site characterization sampling, only one boring in the OD treatment unit will be made to determine if downward migration of PEP materials has occurred. It will be made after the soil samples have been taken and analyzed in order to avoid placing it in an area of surface contamination that may be carried downward with the boring. Samples will be taken at 5 ft (1.5 m) intervals for logging (visual classification) and chemical analysis down to a depth of 50 ft (15.2 m). Quality Assurance/Quality Control and decontamination procedures are discussed in the Quality Assurance Project Management Plan (QAPMP) in Permit Attachment J. •ANALYTICAL METHODS [HWMR-7, Part V, §264.13(b)(2)] The test procedures that will be applied in this section are listed in Table A-8. These include analytical method numbers, detection limits, and sample volume requirements. All methods referenced are from Test Methods for Evaluating Solid Waste,

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Physical/Chemical Methods, (EPA, 1986) unless otherwise noted. The laboratory performing these analyses will operate in accordance with the Quality Assurance Project Management Plan (QAPMP) presented in Permit Attachment J. •Frequency of Analysis [HWMR-7, Part V, §264.13(b)(4)] Initial site characterization sampling will be conducted semi-annually and will begin within six months of permit issuance. The biannual sampling and analysis results will be reported to HRMB following each second and fourth quarterly sampling and analysis event. Monitoring Non-Reactive Waste Wastes that are not destroyed by OD treatment will remain in the soil and be discovered by the proposed sampling. Location of Plan and Responsible Position The soil sampling plan will reside with and be updated by: Director of Environment Directorate of Environment USAADACENFB Attn: ATZC-DOE Ft. Bliss, TX 79916-6816 In addition Fort Bliss must have a copy of the analytical results in the permit kept at Davis Dome in accordance with HWMR-7, Part V, §264.73(b)(3). •Additional Requirements for Waste Generated Off-Site [40 CFR

264.13(c)] No waste generated off of Ft. Bliss is accepted for treatment at

the OD treatment unit and will not be accepted without first informing and getting permission from NMED.

•Additional Requirements for Ignitable, Reactive, or

Incompatible Wastes [40 CFR 64.13(b)(6), 264.17] The PEP materials treated are known to be ignitable and/or

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reactive without testing. Therefore special requirements are directed to safety and they are summarized in the OD operating procedures in Permit Attachment I. For example, potentially hazardous substances are transported directly to the OD treatment unit; smoking is expressly forbidden and sources of ignition are eliminated; and emergency equipment is maintained on the transport vehicle.

Waste materials treated by OD at this unit are treated in lots

of similar materials. Therefore, incompatible wastes do not mix. Figure A-1 is a general waste analysis plan flow scheme for the proposed waste munitions/explosive contaminated materials.

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╔═══════════════════════════════════════════════════════════════╗ ║ Table A-1 Generator Supplied Information ║ ╚═══════════════════════════════════════════════════════════════╝ Parameters Rationale Method Physical Used to determine the general N/A Descriptionphysical characteristics of the waste; facilitates comparisons with subsequent samples of waste; changes in color, number of phases, clarity, etc., may be indicative of changes in the waste stream Flash Point Used to determine if waste displays SW-846 ignitable characteristic defined by 1010 HWMR-7, Part II, § 261.21 pH Used to determine if waste is a SW-846 corrosive waste as defined by HWMR-7, 9040 Part II, § 261.22; significant changes could be indicative of changes in waste characteristics and composition GeneratingUsed to determine if waste is a listed N/A Process hazardous waste as defined by HWMR-7, Part II, § 261 Specific Used because significant changes can be ASTM** Gravity indicative of changes in waste character- D891

istics and composition -86 * US EPA document, Test Methods for Evaluating Solid Waste, Physical and Chemical Methods ** American Society of Testing materials Updates of generator information are required when: 1) change occurs in the process generating the waste; 2) change occurs in the materials used in the process generating the waste stream.

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TABLE A-8 SOIL SAMPLE ANALYSES EXPLOSIVES ORDNANCE DEMOLITION AREA FORT BLISS, MCGREGOR RANGE OTERO COUNTY, NEW MEXICO

ANALYTE ANALYTICAL METHOD1 SAMPLE VOLUME

pH SW846 9040 10g

Reactivity GAP Test - Appendix III

10g

Reactivity Deflagra-tion/Detonation Test - Appendix III

20g

Nitrate/Nitrite (as N)

EPA 353.3 10g

METALS:

Arsenic SW846 7060 100-500g

Barium SW846 7080 100-500g

Beryllium SW846 6010 100-500g

Cadmium SW846 7130 100-500g

Chromium SW846 7190 100-500g

Lead SW846 7421 100-500g

Mercury SW846 7471 100-500g

Selenium SW846 7740 100-500g

Silver SW846 7760 100-500g

ORGANICS:

Picric Acid SW846 8270 100-500g

HMX SW846 8330 100-500g

RDX SW846 8330 100-500g

2,4,6-Trinitro-toluene

SW846 8330 100-500g

2,4-Dinitrotoluene

SW846 8330 100-500g

2,6-Dinitrotoluene

SW846 8330 100-500g

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Nitroglycerine SW846 8332 100-500g

1SW846 = "Test Methods for Evaluating Solid Waste - Physical/Chemical Methods,"

Environmental Protection Agency, SW846. EPA = "Methods for Chemical Analyses of Water and Wastes," Environmental

Protection Agency, 1979, Revised 1983.

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TABLE A-2 TYPICAL REACTIVE WASTES TO BE OPEN BURNED/OPEN DETONATED

TYPE OF WASTE

CONSTITUENTS

GENERAL OR TYPICAL CONCENTRATION OR

AMOUNT

75 mm Cartridge (Armor Piercing)

PEP

Nitroguanidine 50%

Nitroglycerin 20%

Nitrocellulose 20%

Ethyl Centralite Trace

Potassium Nitrate Trace

Charcoal Trace

Cryolite Trace

Sulfur Trace

Barium Peroxide Trace

Strontium Nitrate Trace

Lead Sulfocyanate Trace

Antimony Sulfide Trace

Potassium Chlorate Trace

TNT Trace

DNT Trace

Calcium Resinate Trace

Graphite Trace

Polyvinyl Chloride Trace

Aluminum Powder Trace

Casing and Body

Forged steel body and head

Brass booster cup

Waste MZ

Propellant Nitrocellulose 75-80%

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Nitroglycerin 17-22%

Ethyl Centralite Trace

Barium Nitrate Trace

Potassium Nitrate Trace

Graphite Trace

Off-Spec TNT 2,4,6-TNT 90-98%

Various isomers of TNT Trace

Isomers of DNT Trace

Other various compounds Trace

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TABLE A-3 SPECIFICATION REFERENCES FOR PROPELLANTS

TITLE NUMBER

Propellant Artillery MIL-P-270A

Propellant Charge Assy for Rocket, Practice, 35MM Subcaliber, M73 MIL-P-50981A(1)

Propellant Charge Assy Rocket, HE, 66MM, M72A1, w/coupler MIL-P-60009A

Propellant Charge Nuclear Component MIL-P-48194

Propellant Charge, Nuclear Component, Tng MIL-P-50838

Propellant Charge, Rocket, M180 MIL-P-50202A(4)

Propellant CTBN 23-17 MIL-P-85364

Propellant Double Base Sheet, XM36 MIL-P-48357A(1)

Propellant Feed System, Rocket Propulsion, General Specification For

MIL-P-27409(1)

Propellant For Small Arms Ammunition MIL-P-3984G(3)

Propellant for 20MM Aircraft Gun Mark 12 MIL-P-18942A(3) NOTICE (1)

Propellant for 20MM Ammunition MIL-P-81994

Propellant Grain M753 for 8" Projectile MIL-P-63159

Propellant Grain, Cylindrical, for Rocket Motors MIL-P-18906(1)

Propellant Grain, MK 43, Mod 1 MIL-P-18811A(2)

Propellant Grain, M28 MIL-P-6007A(1)

Propellant Grain Igniter MIL-P-82691

Propellant M1 for Use in Charge, Propelling, XM164 MIL-P-43848

Propellant M1 Type II (Master Lot) for Use in Charge XM72 MIL-P-14768(1)

Propellant M1 for Use in Charge, Propelling, M4A2 MIL-P-60397B

Propellant M1 for Use in Charge, Propelling, 155 MM, M3A1 for 155 MM Howitzer Cannon

MIL-P-60416A(1)

TABLE II.A-2 SPECIFICATION REFERENCES FOR PROPELLANTS (Continued)


TITLE NUMBER

Propellant M1 for Use in 90 MM Cartridges MIL-P-48759

Propellant M10 for Use in Cartridges, for 57 MM Rifle, M18 and M18A1

MIL-P-48051A

Propellant M10 for 81MM Mortar Propelling Charges MIL-P-48130A(1)

Propellant M14 for Use in Cartridge 105 MM TP-T M490E1 MIL-P-63517

Propellant M26 (T28) for Use in Increment XM90E1 for 81MM Mortar

MIL-P-46993

Propellant M26 for Use in Cartridge, Antipersonnel XM581 for 106MM Rifle M40A1

MIL-P-60375

Propellant M26A1 for Use in Charge Propelling M189 MIL-P-50472A

Propellant M30 for Use in Cartridge 105MM, APFSDS-T M833 MIL-P-63515A

Propellant M30 for Use in Cartridge 105MM APFSDS-T, M735 M735A1 and XM774

MIL-P-63105B(1)

Propellant M30 for Use in Cartridge 105MM HEAT-T M456A1, HEAT-T-MP M456A1E2 and TP-T,M490.

MIL-P-46458F

Propellant M30A1 for Use in 155MM Propelling Charges MIL-P-48349

Propellant M30 for Use in Cartridge, 150MM, APDS-T, M728 MIL-P-48266A

Propellant M30 for Use in Cartridge, 105MM, TPDS-T, M724A1 MIL-P-48154B

Propellant M30 for Use in Cartridge, 90MM, Anti-personnel, XM580 for Guns M36 and M41

MIL-P-60382(1)

Propellant M30 for Use in 105MM Cartridge HEAT-T, M622 MIL-P-63301

Propellant M30 for Use in Cartridges, TP-T M353A1 and AP-T M318A1E1 and 90MM Guns

MIL-P-46999B

Propellant M30 Type 1 for Use in Charge, XM72, Zone III MIL-P-14769

Propellant M30 for Use in Cartridge, HEAT-T M431 for 90MM Guns

MIL-P-46600C

Propellant, M30A1 (M30E1) for Use in Charge, Propelling, 105MM, XM176, for Cartridge, HE, XM548 for Howitzers M101, M102 and M108

MIL-P-60422(1)



TITLE NUMBER

Propellant, M30A1 for Use in Charge Propelling M203 MIL-P-48367(B)

Propellant M30A1 for Use in Charge, Propelling XM201E2 MIL-P-48366(1)

Propellent M30A1 for Use in Charge, Propelling XM203 for 155MM Projectile, Rocket-assisted, M549

MIL-P-48257

Propellant M30A1 for Use in Charge, Propelling XM201E1 for 155MM Projectile, Rocket-assisted M549

MIL-P-48256

Propellant M30A2 for Use in Charge, Propelling, M188 and M188E1 for 8 Inch Projectiles

MIL-P-48181C

Propellant M30E1 for Use in Propelling Charge M85 and XM121 for 105MM Howitzer

MIL-P-46651B(1)

Propellant M31E1 for Use in Charge Propellant M188E2 for 8 Inch Projectiles

MIL-P-63341A

Propellant M5 for Use in Charge, Propelling, XM178 for 90MM Recoilless Rifle

MIL-P-60358(1)

Propellant M6 for Use in Cartridge 105MM HEP-T, M327 MIL-P-48058

Propellant M6 for Use in Cartridge, 105MM APERS-T M494 MIL-P-48231

Propellant M6 for Use in Cartridge, 76MM, HEAT-T, M496 MIL-P-46484A

Propellant M6 for Use in Cartridge, 90MM, APERS, XM580E1 for Guns M36 and M41

MIL-P-60417

Propellant M6 for Use in Cartridge, 90MM, Canister, M377 MIL-P-60465

Propellant M6 for Use in Cartridge, 90MM, TP-T, M353 MIL-P-60359

Propellant M6 for Use in Charge, Propelling, M119, 155MM MIL-P-1494OB(1)

Propellant M6 for Use in Charge Propelling 175MM, M199 and M86A2B1

MIL-P-46230C

Propellant M6 for Use in Charge Propelling 155MM, M119A2 MIL-P-63404

Propellant, M6 for Use in Charge, Propelling, (Green Bag) 175MM, XM124

MIL-P-60384(2)

Propellant M9 for Use in Charge, Propelling, M36A2 MIL-P-48127



TITLE NUMBER

Propellant M9 for Use in Increments M90 and M90A1 for 81MM Mortar

MIL-P-60029B(1)

Propellant M9, Flake (For Use in Ignition Cartridges) MIL-P-60398A(1)

Propellant M9, Flake (For Use in 40 MM Cartridges) MIL-P-50206(2)

Propellant Powder (For Use in Base Grain OGK) MIL-P-604638B

Propellant Pressurizing Agent, Helium MIL-P-27407A

Propellant Pressurizing Agent, Nitrogen MIL-P-27401C

Propellant, Ammonia MIL-P-27406

Propellant, Ball Powder for Cartridge, 105MM, HE, XM710 MIL-P-63084

Propellant, Booster, Grain-Ignition (For Torpedo Mk 46 Mod 0) MIL-P-81095 NOTICE 1

Propellant, Cannon, Naco MIL-P-19264A NOTICE 1

Propellant, Chlorine Pentafluoride MIL-P-27413

Propellant, Chlorine Trifluoride MIL-P-81399A

Propellant, Double Base Sheet M36 MIL-P-483457A

Propellant, Double Base Sheet N5 MIL-P-17689

Propellant, Composite ADC-109 MIL-P-83405

Propellant, Double Base, Type N-2 (JPN) MIL-P-18617

Propellant, Ethylene Oxide (Asg) MIL-P-8845A

Propellant, Fluoride MIL-P-27405(2)

Propellant, Foam (For Torpedo Mk 46 Mod 0) MIL-P-81069(1)

Propellant, Furfuryl Alcohol MIL-P-45702B

Propellant, Grain, Inhibited MIL-P-60852A

Propellant, High Density Synthetic Hydrocarbon Type, Grade JP-9 and JP-10

MIL-P-87107B(1)



TITLE NUMBER

Propellant, Hydrazine MIL-P-26536C(2)

Propellant, Hydrazine - UNS-DIMETHYLHYDRAZINE (50 Percent N2H4 - 50 Percent Udmh)

MIL-P-27402B

Propellant, Hydrogen MIL-P-27201B

Propellant, Hydrogen Peroxide MIL-P-16005E

Propellant, H8 MIL-P-23929A

Propellant, Kerosene MIL-P-25576C(2)

Propellant, Igniter X-62 MIL-P-85489

Propellant, M1 for Use in Charge Propelling for 75MM How M1A1 and M3

MIL-P-46990

Propellant, Mixed Amine Fuel, MAF-1 MIL-P-23741A(1)

Propellant, Mixed Amine Fuel, MAF-3 MIL-P-23686A(1)

Propellant, Mixed Oxides of Nitrogen MIL-P-27408A

Propellant, Monomethylhydrazine MIL-P-27404B

Propellant, M1 for Use in Charge Propelling M2 (White Bag) for 8 Inch Howitzer)

MIL-P-46699B

Propellant, M1 for Use in Charge, Propelling, M67 for 105MM Howitzer

MIL-P-60318B

Propellant, M1 for Use in 105MM Cartridges MIL-P-46252C

Propellant, M1, for Use in Charge Propelling M1 (Green Bag for 8 Inch Howitzer)

MIL-P-46698

Propellant, M1 for Use in Charge, Propelling, 155MM, M3 MIL-P-46913

Propellant, M10 (For Use in Special Applications) MIL-P-48099A

Propellant M10 for 60MM Mortar M204 Propelling Charge MIL-P-63194A

Propellant, M15 and M17 MIL-P-668A

Propellant, M17, for Use in Cartridge, 76MM, AP-T, M33, and 76MM TP-T, M340A1

MIL-P-46522(1)



TITLE NUMBER

Propellant, M2 and M5 MIL-P-323A

Propellant, M2 and M5 Subsystem Ammunition MIL-P-60989A(1)

Propellant, M2 for Use in 165MM Cartridges MIL-P-60045A

Propellant, M2, for Cartridge, 37MM, TP, M63 Mod 1 MIL-P-46663

Propellant, M26 (T28) for Use in Cartridges M344 and M346, in 105MM Rifles

MIL-P-46235A

Propellant, M26A1, for Use in Charge Propelling XM189 and XM190

MIL-P-50472(A)

Propellant, M30 (T36), for Use in Cartridge, 105MM HEAT-T, M456A1 and TP-T M490

MIL-P-46458F(1)

Propellant, M30 for Use in Cartridge 105MM APFSDS-T, M735 MIL-P-63105B(1)

Propellant, M30 for Use in Cartridge, 105MM, APDS-T, M392A2 MIL-P-46489C(1)

Propellant, M30 for Use in Cartridges 76MM, AP-T, M339 and TP-T, M340A1

MIL-P-60389A

Propellant M30A1 for Use in Charge, Proof, 155MM PXR-6255 MIL-P-48372

Propellant M30A1 for Use in Charge, Proof, 155MM PXR-6297 MIL-P-63387

Propellant, M31 (T34), for Use in Charge Propelling, M45 for Projectiles M365 and M367, for 120MM Gun, M58

MIL-P-46683A(1)

Propellant, M5 (For Use in Special Applications) MIL-P-48089(1)

Propellant, M5 for Use in Cartridge, 90MM, HEAT, M371 and M371E1

MIL-P-46426A

Propellant, M6 for Use in Cartridge, Canister, 76MM, M363 MIL-P-60098

Propellant, M7 MIL-P-14737(2)

Propellant, M9 (For Use in Base Charge Assemblies) MIL-P-60363A

Propellant, M9 (For Use in M19A2 Signal) MIL-P-60354(1)

Propellant, M9, for Use in Increment, M185 for 81MM Mortar MIL-P-50418

Propellant, M9 for Use in Increment, M5 for 81MM Mortar MIL-P-50425



TITLE NUMBER

Propellant, M9 for Use with Charge, Propelling M36A1 for 4.2 Inch Mortar

MIL-P-60019A(3)

Propellant, M9 for use in Cartridge, Ignition XM702E1 MIL-P-63195(1)

Propellant, Nitric Acid MIL-P-7245F(2)

Propellant, Nitrogen Tetroxide MIL-P-26539C(2)

Propellant, Oxygen MIL-P-25508E(3)

Propellant, Pressurizing Agent, Argon MIL-P-27415

Propellant, Pyrocellulose MIL-P-231A(2)

Propellant, Rocket Motor, Rocket, High Explosive, 345MM XM130 MIL-P-53028

Propellant, T36E1, for Use in Charge, Propelling, 155MM, XM119 (Supercharge)

MIL-STD-2100

Propellant Solid for Cannon Requirements and Packing MIL-STD-652D NOTICE 2 NOTICE 4

Propellant, Solventless Type 37 for Projectile 155MM, HE, Rocket Assisted, M549 and M549A1

MIL-P-63201

Propellant, Solid, Gas Generator MIL-P-47144

Propellant, Solid, Sampling, Examination and Testing MIL-STD-286B NOTICE 4

Propellant, Spheroidal Ball Powder MIL-P-48335

Propellant, T2 MIL-P-45460A

Propellant, T36E1, for Use in Charge, Propelling, 155MM, XM119 (Supercharge)

MIL-P-60033B

Propellant, T36E1, for Use in Charge, Propelling, 155MM, M51 MIL-P-46902

Propellant, T36E1 for Use in Charge, Propelling, 155MM, XM115 (White Bag)

MIL-P-46953(2)

Propellant, U.S. Navy Guns, Ballistic Appendix MIL-P-22314(3)

Propellant, Uns-dimenthylhydrazine - Jet Fuel MIL-P-26694B(2)



TITLE NUMBER

Propellant, Uns-demethylhydrazine MIL-P-25604D(1)

Propellant, M6 for Use in Charges, Propelling, 175MM, M199 and M86A2B1

MIL-P-46230C

NOTE: THESE SPECIFICATIONS WERE OBTAINED FROM THE DEPARTMENT OF DEFENSE INDEX OF SPECIFICATIONS AND STANDARDS (DODISS) CURRENT AS OF THE DATE OF HANDOUT PUBLICATION. THE DODISS SHOULD BE CONSULTED WHEN COMPLETE, UP-TO-DATE INFORMATION IS DESIRED.


TABLE II.A-3 GENERAL CHEMICAL COMPOSITION OF PEP ITEMS

NAME

CHEMICAL FORMULA

HAZARDOUS WASTE

ID NUMBER

Propellants

Nitrocellulose C12H14(ONO2)6O4 D003

Nitroglycerin C3H5(ONO2)3 D003

Nitroguanidine H2NC(NH)NHNO2 D003

These three primary constituents can be used singularly or in various combinations along with metals, metallic salts, and organic polymer binders.

Primary Explosives

Lead azide Pb(N3)2 (71% Pb) D003, D008

Mercury Fulminate HgC2N2O2 (7.055 Hg)

D003, D009

Diazodinitrophenol (DDNP) HOC6H3(NO2)2N(:N) D003

Lead styphnate C6H(NO2)3(O2Pb) (44.2% Pb)

D003, D008

Tetracene C18H12 D003

Potassium Dinitrobenzofuroxane (KDNBF)

C6H2N4O6K D003

Lead Mononitroresorcinate (LMNR)

C6H3NO2Pb (57.5% Pb)

D003, D008

Primary Compositions - mixtures of primary explosives, fuels, oxidizers and binders.

Fuel - Lead Pb(SCN)2 (64% Pb) D008

TABLE II.A-3 GENERAL CHEMICAL COMPOSITION OF PEP ITEMS (Continued)


NAME

CHEMICAL FORMULA

HAZARDOUS WASTE

ID NUMBER

thiocyanate

Antimony sulfide Sb2S5 D003

Calcium silicide CaSi2 D003, D001

Oxidizers - Potassium chlorate KCl03 D003

Ammonium Perchlorate NH4ClO4 D003

Barium nitrate Ba(NO3)2 D003, D005

Aliphatic Nitrate Esters

1,2,4-Butanetriol Trinitrate (BTN)

C4H7N3O9 D003

Diethyleneglycol Dinitrate (DEGN)

C4H8O3(NO2)2 D003

Nitroglycerine (NG) C3H5(ONO2)3 D003

Nitrostarch (NS) C12H12(NO2)8O10 D003

Pentaerythyritol Tetranitrate (PETN)

C(CH2NO3)4 D003

Triethylene Glycoldinitrate (TEGN)

C6H12O4 2NO2 D003

1,1,1-Trimethylolethane Trinitrate (TMETN)

C5H9O9N3 D003

Nitrocellulose (NC) C12H14(ONO2)6O4 D003

Nitramines

Cyclotetramethylene-tetranitramine (HMX)

C4H8N8O2 D003

Cyclotrimethylene-trinitramine (RDX)

C3H6N6O6 D003

Ethylendiamine Dinitrate C2H6N4O4 D003



NAME

CHEMICAL FORMULA

HAZARDOUS WASTE

ID NUMBER

(EDDN Haleite)

Nitroguanidine (NQ) H2NC(NH)NHNO2 D003

2,4,6-Trinitrophenyl-methylnitramine (Tetryl)

(NO2)3C6H2N(NO2)CH3 D003

Nitroaromatics

Ammonium picrate (Explosive D)

NH4C6H2N3O7 D003

1,3-Diamino-2,4,6-Trinitrobenzene (DATB)

C6H4N6O6 D003

2,2'4,4'6,6'-Hexani-troazobenzene (HNAB)

C12N8O12 D003

Hexnitrostilbene (HNS) C14H2N6O12 D003

1,3,5-Triamino-2,4,6-Trinitrobenzene (TATB)

C6H6N6O6 D003

2,4,6-Trinitrotoluene (TNT) (NO2)3C6H2CH3 D003

Ammonium Nitrate NH4NO3 D003

Compositions

Mixtures of the above

Plastic Bonded Explosive (PBX)

Explosives (see above) and polymer binder, plasticizer, and fuel (Aluminum or Iron)

Pyrotechnics

Combination of:

Oxidizer - oxygen or fluorine

Fuel - powdered Aluminum or Magnesium



NAME

CHEMICAL FORMULA

HAZARDOUS WASTE

ID NUMBER

Binding Agents - resins, waxes, plastics, oils, retardants, waterproofing, color intensifier


TABLE II.A-4 PROPELLENT COMPOSITIONS TREATED IN OB AREA The information contained in this chart is an approximation only. Specific information regarding percentages and tolerances of components should be obtained from appropriate specifications and standards. In addition, these sources may provide information about perforation and web thickness applicable to a particular weapon or round of ammunition. Numbers within chart are percentages by weight.

PROPELLANT MODEL DESIGNATION COMPONENT

M1

M2

M5

M6

M7

M8

M9

M10

M12

M13

M14

M15

M17

Nitrocellulose 85.0 77.45 81.95 87.0 54.6 52.15 57.75 98.00 97.70 57.30 90.00 20.0 22.0

Nitroglycerin 19.50 15.00 35.5 43.00 40.00 40.00 19.0 21.5

Nitroguanidine 54.7 54.7

Dinitrotoluene 10.0 10.0 Coating 8.00

Dibutylphthalate 225.0 3.0 2.00

Diethylphthalate 3.00

Diphenylamine 1.0* 1.0* 1.0 0.80 0.20 1.00*

Ethyl Centralite 0.60 0.60 0.9 0.60 0.75 1.00 6.0 1.5

Barium Nitrate 1.40 1.40

Potassium Nitrate 0.75 0.75 1.25 1.50

Potassium Perchlorate 7.8

Lead Carbonate 1.0**

Potassium Sulfate 1.0** 1.0* 1.0 0.75 1.50

Tin 0.75

TABLE II.A-4 PROPELLENT COMPOSITIONS TREATED IN OB AREA (Continued)



M1

M2

M5

M6

M7

M8

M9

M10

M12

M13

M14

M15

M17

Carbon black 1.2 0.05*

Graphite 0.30 0.30 Glaze 0.1

Glaze 0.1

Cryolite 0.3 0.3

*Added basis**When specified, added basis.

TABLE II.A-4 PROPELLENT COMPOSITIONS TREATED IN OB AREA (Continued)



M26

M26 E1

M30

M30 A1

M31

T2

M18

IMR

M30 A2

M31 A1

Nitrocellulose 67.25 68.70 28.00 28.00 20.00 57.50 80.00 100.00 27.00 20.00

Nitroglycerin 25.00 25.00 22.50 22.50 19.00 30.00 10.00 22.50 19.00

Nitroguanidine 47.70 47.00 54.70 46.25 54.00

Dinitrotoluene 2.50 8.00

Dibutylphthalate 4.50 9.00 4.5

Ethyl Centralite 6.00 6.00 1.50 1.50 8.00 1.5

Barium Nitrate 0.75

Potassium Nitrate 0.70 2.75

Carbon black 0.02*

Graphite 0.30 0.30 Glaze 0.10

Cryolite 0.30 0.30

Lead Stearate 0.50

2-Dinitrodiphenyldiamine 1.50

Potassium Sulfate 1.00 1.50 *1.00 1.5

Diphenylamine 1.00 .70 1.00

*Added basis


TABLE II.A-5 WASTES TREATED IN OD AREA

PROPELLANT TYPE CHEMICAL MAKE-UP

1.Black Powder Potassium Nitrate 74.0% Charcoal 15.6% Sulfur 10.4%

2.TNT Trinitrotoluene

3.Composition B 60/40 Cyclotol RDX 60% TNT 39% WAX 17%

4.PETN Pentaerythrite Tetranitrate Chemical Formula Carbon 19.0% Hydrogen 2.5% Nitrogen 17.7% Oxygen 60.8%

5.Photoflash Laminac 96.8% Lupersol, DDM 3.0% Iron Oxide .2%

6.Composition C4 RDX 91.0% Polysobutylene 2.1% Motor Oil 1.6% Di-(2-Ethylhexyl) Sebacate 5.3%

7.RDX (Cylclonite) (Cyclotrimethylene-Trinitramine) Chemical Formula Carbon 16.3% Hydrogen 2.7% Nitrogen 37.8% Oxygen 43.2%

TABLE II.A-5 WASTES TREATED IN OD AREA (Continued)


8.Tetryl Trinitro-Phenylmethyl-Nitramine Chemical Formula Carbon 29.3% Hydrogen 1.7% Nitrogen 24.4% Oxygen 44.6%

9.TPA Incendiary Triethylaluminum

10.HMX (Homecyclonite) (Cycloteramamethylene Tetranitramine) Chemical Formula Carbon 16.2% Hydrogen 2.7% Nitrogen 37.9% Oxygen 43.2%

11.Lead Azide Chemical Formula Nitrogen 28.8% Lead 71.2%

12.Lead Styphnate Chemical Formula Carbon 15.4% Hydrogen .65% Nitrogen 9.0% Oxygen 30.8% Lead 44.2%

13.Amatol Ammonium Nitrate TNT

14.Ammonium Nitrate Chemical Formula Nitrogen 35% Hydrogen 5% Oxygen 60%

15.Composition A3 RDX 91% WAX 9%



16.Explosive A4 RDX 97% WAX 3%

17.Explosive D Ammonium Picrate Chemical Formula Carbon 29.3% Hydrogen 2.4% Nitrogen 22.7% Oxygen 45.6%

18.Haleite (EDNA) (Ethylene-Dinitramine) Chemical Formula Carbon 16.0% Hydrogen 4.0% Nitrogen 37.3% Oxygen 42.7%

19.HBX-1, 3 & 6 RDX 39.6% TNT 37.8% Aluminum 17.1% Densitizer (Comp D2) 5.0% CACL .5%

20.Octol HMX 75% TNT 25%

21.PBX RDX Polystyrene Diocylphthalate

22.Pentolite 50/50 PETN 50% TNT 50%

23.Pentolite 10/90 PETN 10% TNT 90%

24.Picratol Explosive D 52% TNT 48%

25.Tetrytol Tetryl



TNT

26.Torpex RDX 42% TNT 40% Aluminum 18%

27.Tritonal Aluminum TNT

28.Nitroglycerin Chemical Formula Carbon 15.9% Hydrogen 2.2% Nitrogen 18.5% Oxygen 63.4%

29.Nitroguanidine (Picrate) Picrate Chemical Formula Carbon 11.5% Hydrogen 3.9% Nitrogen 53.8% Oxygen 30.8%

30.Military Dynamite - Medium Velocity RDX 75% TNT 15% Starch 5% SAE No. 10 Oil 4% Polysobutylene 1%

31.Military Dynamite - Low Velocity RDX/DYE* 17.5% TNT 67.8% Tripentaery-Thritol 8.6% Binder** 4.1% Cellulose Acetate 2.0%

*The dye is 96% pure 1 - Methylamino - Anthraquinone (1-MA) used in the amount of .5% of the

RDX mixture. **The binder is vistac No. 1 consisting of polybutene and Diotyseabacate.


TABLE II.A-6 THERMOCHEMICAL CHARACTERISTICS OR EXPLOSIVES

PRODUCTS OF EXPLOSION

MATERIAL

HEAT OF COMBUSTION,

CALORIES PER GRAM AT

CONSTANT PRESSURE

HEAT OF FORMATION,

KILOGRAM CALORIES PER

MOLE

HEAT CALORIES PER GRAM

(H2O) GAS

GAS, MILLIMETERS PER GRAM

Primary explosives

Lead azide

Mercury fulminate

Diazodinitrophenol

Lead styphnate

Tetracene

---

938

---

1,251

---

-112 to -126.3

-221 to -228

956

92.3

270

367

427

820

460

658

308

315

440

1,190

Aliphatic nitrate esters

BTN

DEGN

Nitrocellulose

Pyroxlyn (12% N)

Guncotton (13.35%)

High nitrogen (14.14% N)

Nitroglycerin

PETN

TEGN

TMETN

2,167

2,792

---

2,313

---

1,603

1,957

3,428

2,642

368

-99.4

-216

-200

-191

-90.8

-128.7

-603.7

-422

1,458

1,161

1,020

1,020

1,810

1,486

1,510

750

---

---

---

---

883.2

---

715

790

---

---

Nitramines

HMX

RDX

EDDN

Haleite

Nitroguanidine

Tetryl

2,231 to 2,253

2,259 to 2,264

2,013

2,477

2,021

2,914

11.3 to 17.93

14.71

156.1

20.11

20.29

4.67 to 7.8

1,480

1,480

128 to 159

1,278

880

1,450

---

908

---

908

1,077

760

Nitroaromatics

Ammonium picrate

DATB

2,745

---

95.82

-97.1 to -119

800

910

---

---


HNAB

HNS

TATB

TNT

---

3,451

2,850

3,563 to 3,598

-58 to -67.9

-13.9 to 1.87

-33.46 to -36.85

-10 to -19.99

1,420

1,360

1,018

1,290

---

---

---

730

Ammonium nitrate --- 88.6 381 980

US Army Fort Bliss


NMED Control Copy

PERMIT ATTACHMENT B Page 1 of 3

PERMIT ATTACHMENT B SECURITY PLAN SECURITY PROCEDURES The OD treatment unit which is located within the McGregor Range Military Reservation will have a 24-hour surveillance system. This means surveillance by USAADACENFB Security Police, who will continuously monitor and control entry inside the USAADACENFB perimeter, including the OD unit. USAADACENFB security will conduct patrols according to a 24-hour, seven-days-a-week schedule. The major duties of USAADACENFB security personnel will be to control personnel, vehicle, and material access in accordance with procedures to assure the integrity, maintenance, and safe operation of the OD unit and its proximity. During nonwork hours, USAADACENFB security will conduct documented security patrols of the USAADACENFB perimeter fence. Barriers and Means to control Entry USAADACENFB will raise a barrier and a means to control entry to the OD unit in compliance with HWMR-7, Pt. V, §264.14(b)(2). A three-strand barbed-wire fence will be built around the OD unit. The roadway barrier (i.e., a lockable gate at the entrance road) to the OD unit will be kept locked except when OD personnel enter the unit for inspections or treatment operations. Access to the OD will be only through one gate, which is to be kept locked at all times. Physical access controls are the unit's remoteness, the Hueco Mountains to the south and east and the monitoring provided at Davis Dome (Map 1/Exhibit 1, Permit Attachment O). Davis Dome is manned on a 24-hr basis and monitoring includes visual inspection of the Range supplemented with helicopter fly-overs, usually two per day. The military reservation boundary (Map 1

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/Exhibit 1, Permit Attachment O) and the lack of public roads make the potential access for hikers and 4-wheel drive very difficult. This is by design and is a requirement for the firing ranges. Illegal immigrants moving north from Mexico would have to cross about 40 miles (64.4 km) of desert to reach this site. If they did reach the area, Range Control should spot and arrest them. If that failed, there is no reason for them to stop at the unit (i.e., no water, shade, or other comforts). If for some reason illegal immigrants or others were in the unit, the OD Ordnance Disposal team would discover them during the placement of the PEP and they would be arrested. If all of these controls failed, the soil in the unit is not expected to be hazardous due to contact or dust inhalation. This will be determined during planned soil sampling and analysis to be implemented according to the plan presented in Permit Attachment J. Entrance to USAADACENFB, whether by personnel or vehicles, will only be through the controlled gates. USAADACENFB access control procedures must be designed to ensure that only properly identified and authorized persons, vehicles, and property are allowed entrance to and exit from the OD unit. A personnel identification and access control system will be maintained at the OD treatment unit. Employees will identify themselves when entering or leaving the premises. USAADACENFB OD personnel will escort all visitors to the OD unit. The protective force will be on duty 24 hours a day, 365 days per year, including those times when explosive detonation operations will be conducted. The active portion of the OD site does not contain any waste, structures, or equipment which could injure unknowing or unauthorized persons or livestock. The OD site consists of a large pit with gradual sloping sides (See Permit Attachment G). No equipment or structures are maintained within the OD site. During non-use periods, the OD site will be left empty and free of all obstacles. During disposal operations of hazardous waste munitions, a thorough examination of the OD site will be made prior to detonation to insure that there are no unauthorized personnel or livestock in the vicinity of the site. The check is also designed to make sure the area is free of vegetation

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B-3

and/or anything else that may cause a fire. Hazardous waste munitions are only brought to the site immediately prior to detonation and are not stored at the site itself. After detonation, the senior EOD technician inspects the site to confirm the destruction of all hazardous waste munitions and to ensure that no fires were started. Warning Signs Four warning signs will be maintained within 100 feet (30.5m) of the perimeter of the OD unit. These are printed in both English and Spanish to read as follows: "DANGER, NO UNAUTHORIZED PERSONNEL, KEEP OUT", AND "PELIGRO, NO PERMITIDA LA ENTRADA SIN AUTHORIZACION." These signs will be posted at the road entry point and where the perimeter approaches roads or active areas. The signs will be written in English and Spanish and will be legible from a distance of 25 feet (8 meters) and should also be seen from any approach to the treatment unit. In addition, the warning signs will be posted at 300-foot (91-meter) intervals around the OD unit perimeter in accordance with HWMR-7, Part V, § 264.14(c). Any illegal immigrants who enter the active portion of the OD treatment unit during the disposal of hazardous waste munitions would be detected by the disposal ordnance team and escorted off the premises. During non use periods, the OD treatment unit contains no material or objects that pose a threat to human life or livestock.

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PERMIT ATTACHMENT C Page 1 of 3

PERMIT ATTACHMENT C INSPECTION SCHEDULE All OD operators will follow all the general safe practices for handling (Permit Attachment H) and transporting explosives in order to prevent the accidental reaction of ignitable, reactive or incompatible waste as described in Technical Manual (TM) 9-1300-200, and TM 9-1300-206 "Ammunition and Explosive Standards." The operator will conduct inspections according to the General Inspection Schedule and logs will be kept for a period of at least three years. Corrective action will be initiated immediately upon the detection of a deficiency. Operations will cease if communication systems or safety equipment show deteriorations or malfunctions. Table C-1 presents the General Inspection schedule for inspecting safety and emergency equipment, security devices, operating equipment, communication equipment, and mobile equipment. There are two categories of items to inspect, the treatment unit and the equipment transported to the unit by the 41st EOD for each OD operation. The integrity of the treatment unit will be inspected before each operation (usually 2 to 3 times per quarter), as will the transported equipment listed in Table C-1. Additionally, the transported equipment will be inspected during routine and surprise military inspections. Inspection records will be kept by the 41st Ordnance Detachment or responsible military command. Most of the equipment which would be used at this unit in an emergency is maintained and inspected for military operations in general, not specifically for this treatment unit. For example, Ft. Bliss has a fully equipped Fire Department, hospital (William Beaumont Medical Center), air evacuation unit, etc. The inspections of these functions will be conducted and records

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will be kept by the responsible military commands. Prevention of injuries during OD treatment will be accomplished by taking great care during placement of the material to be treated, and retreating a safe distance from the unit before treatment. The EOD specialists will retreat on the access to at least the distances prescribed in Table C-2.

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TABLE C-1 GENERAL INSPECTION SCHEDULE MCGREGOR RANGE OD, OTERO COUNTY, NEW MEXICO

PORTABLE EQUIPMENT

MAINTENANCE

FREQUENCY

ITEMS CHECKED/MAINTAI

NED

Extinguisher, fire (ABC Multipurpose)

Before each OD operation

Pressure of contents Hose condition Safety pin in place Canister condition

Kit, First Aid (25 man with blood borne pathogen equipment)


Contents Complete Contents expiration dates Clasp secure Properly located

Telephone Set, TA 312/PT Before each OD operation

Equipment complete Batteries charged Equipment functional

FACILITIES

Berms Before each OD operation

Breaches, eroded section

Flammable materials within the unit.


Dry vegetation that may be ignited and escape the unit.

Reduced depth of pits or trench Before each OD operation

Settled material that requires removal

Warning signs Before each OD operation

Standing and legible

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PERMIT ATTACHMENT D Page 1 of 3

PERMIT ATTACHMENT D PERSONNEL TRAINING Introduction Destruction of ammunition will not be attempted by inexperienced or untrained personnel. All personnel will have successfully completed the Department of Navy, six month, EOD Training Course before engaging in such operation (as described below). The course is based at the U.S. Naval School, EOD Detachment, Indian Head, Maryland. TRAINING OUTLINE One of the primary objectives of the Ordnance Disposal training program is to prepare personnel to operate the Open Detonation unit in a safe and environmentally sound manner. To achieve this objective, the program provides all personnel with training relevant to their positions. Every Ordnance Disposal technician/specialist completes initial training within six months of employment or assignment to the OD unit. Ordnance Disposal personnel are given, at a minimum, a basic understanding of the regulatory requirements of hazardous waste management and emergency response procedures. Ordnance Disposal personnel receive additional classroom and on-the-job training designed specifically to teach them how to perform their duties safely and in conformance with regulatory requirements. Ordnance Disposal personnel receive the required training before being allowed to work unsupervised. This training includes: o Applied physical principles o Chemical procedures o Explosive ordnance identification and hazards o EOD tools and equipment o Basic demolition tools and techniques o EOD reconnaissance and locating surface and buried explosive ordnance oU.S. and foreign ordnance identification, render safe

procedures, and disposal procedures for: - ground ordnance - air ordnance - improvised explosive devices - U.S. nuclear weapons

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o Associated protective equipment Responsibilities: a.Detachment Commander: The Detachment Commander is responsible to insure all EOD personnel

assigned to this unit read, understand, and adhere to the procedures outlined in the Standard Operating Procedures (SOP) described in Permit Attachment I.

b.Detachment Noncommissioned Officer: (1)Insures SOP is updated as required. (2)Assumes responsibility of commander in his absence. c.Senior EOD person present during demolitions/disposal

operations: (1)Insures that personnel are briefed on the safety aspects

of the operation that will take place. (2)Insures that personnel comply with provisions outlined

in the SOP. d.Assigned or attached EOD personnel: The assigned or attached EOD personnel will read and comply with

the provisions outlined in the SOP. OD Treatment Unit Soil Sampler Job Description Job Title: Soil Sampler Duties: oCollects soil samples using proper sampling techniques for sample

collection, proper containers and/or preservatives, and maintains proper field documentation, labeling, packaging and method of shipment.

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Required Skills, Experience and Qualifications: oTwo years experience with soil sample collection Required Education: oBachelor's degree in a relevant science or engineering field. An annual review of the initial training or refresher training is required for all personnel that continue in EOD assigned duties. In addition to the aforementioned formal training, EOD personnel receive unit training that integrates individual training with crew drills and other collective training in accordance with STP 9-55D14-SM-TG Soldier's Manual/Trainer's Guide Explosive Ordnance Disposal Specialist. Emergency response training is accomplished in unit training. TRAINING RECORDS Records of personnel training in the unit are and will be documented using DA Form 4164-R (Hands-On Evaluation) and kept on file with the 41st EOD. IMPLEMENTATION Daily safety meetings will be conducted to assure that training is implemented during activities and during the daily operations.

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PERMIT ATTACHMENT E Page 1 of 7

PERMIT ATTACHMENT E CONTINGENCY PLAN The provisions of this plan will be carried out immediately whenever there is a fire, unplanned explosion, or release of hazardous waste constituents which could threaten human health or the environment in accordance with the requirements of [20 NMAC 4.1, Subpart V, §§264.52, 264.53, 264.56, and Subpart IX, 270.14(b)(7)]. 1. In case of an emergency, Range Control will be notified

immediately. 2.In case of injuries, aeromedical evacuation from range

location to William Beaumont Army Medical Center will be available on a continuous basis. Request for aeromedical evacuation from the range is to be relayed to Range Control who in turn will contact the 2nd Platoon, 507th Medical Company (AA). An area will be cleared immediately of all hazardous materials and marked for landing. To establish adequate preparation for the evacuation the following is required:

a.Pick up location and destination b.Number of patients c.Urgency of mission d.Brief description of patients' condition e.Call sign and frequency at pick up point f.Special equipment necessary 3.In case of a hazardous material/hazardous waste release

which could threaten human life or the environment, the Fire Department will be notified immediately, the Fire Department in turn will notify the On-scene Coordinator. Persons qualified to act as the On-scene Coordinator are listed below.

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The reporter will be prepare to provide the following information: a.Name of reporter b.Exact location of incident c.Time and type of incident d.Name and quantity of material e.Action being taken LOCATION OF CONTINGENCY PLAN The original copy and revisions will be maintained in the office of the Directorate of Environment at Fort Bliss. A copy of this contingency plan and all revisions to this plan will be maintained at Range Control and submitted to William Beaumont Army Medical Center, the Military Police, and the Ft. Bliss Fire Department (which also provides the emergency response team). ON-SCENE COORDINATOR AND EMERGENCY EQUIPMENT At all times, there will be an On-scene Coordinator (or alternate) either on base or on call (i.e., available to respond to an emergency by reaching the area within a short period of time) with the responsibility for coordinating all emergency response measures. This On-scene Coordinator will be familiar with all aspects of this plan, all burn/detonation operations and activities in the area of operations, the location and characteristics of waste handled, and the location of all related records. The On-scene Coordinator and alternates are as follows:

TITLE OFFICE PHONE NO.

Primary Staff Duty Officer McGregor Range Command

(915) 569-9505/9519

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Alternate Staff Duty Officer Ft. Bliss

(915) 568-1501 evenings and weekends

Alternate Director, Directorate of Environment

(915) 568-1385/1064

(This list of telephone numbers is used for official government purposes only. The list will not be provided to outside parties. Such release will be a violation of the Privacy Act.) The On-scene Coordinator, or alternate, has the responsibility and authority to commit the resources needed to carry out the contingency plan for emergency response. The emergency equipment available to the On-scene Coordinator includes the following: •Fire fighting equipment and personnel. •Medical air evacuation by helicopter •Fully equipped hospital (William Beaumont Army Medical Center) •HAZMAT Unit (Ft. Bliss Fire Department) PLANS TO IDENTIFY THE CHARACTER, SOURCE AND EXTENT OF AN UNPLANNED EXPLOSION Policies and procedures for minimizing the threat of fires, unplanned explosions, and/or releases of hazardous materials/hazardous waste during normal handling, shipping, and storing of explosive ordnance materials are included in the Department of the Army 41st Ordnance Detachment (EOD) FORSCOM

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(Forces Command) Field Operation Activity's Standard Operating Procedures (SOP), Permit Attachment I. In the event of an unplanned explosion, the On-scene Coordinator will determine the source of the explosion and assess the extent of the impact of the explosion. The On-scene Coordinator will review the available records on materials in the explosion area to determine what may have exploded, the amount of material that could have been involved, and the potential for subsequent detonations. A visual inspection of the incident site may be performed, if safe to do so. ASSESSMENT OF HAZARD POTENTIAL RESULTING FROM AN UNPLANNED EXPLOSION After determining source and extent of an unplanned explosion, the On-scene Coordinator will assess the hazard potential for impacts to human health and the environment. Based on the amount of material involved in the unplanned explosion and a review of the hazards of the exploded material, the On-scene Coordinator will determine what possible direct and indirect effects of the unplanned explosion, if any, have resulted. If the On-scene Coordinator determines that an unplanned explosion has occurred, he will notify the National Response Center and the New Mexico Environment Department of the event. The report will include his name, the name and location of the unplanned explosion, site telephone number, type and time of the incident, name and quantity of materials involved, extent of any injuries, and any possible hazards to human health or the environment outside the facility as a result of the unplanned explosion.

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EMERGENCY PROCEDURES This section addresses medical emergencies; fire, explosion, or release; and site excavation. Medical Emergencies In the case of a medical emergency requiring more than minor first aid, the following procedure will be implemented: 1)Call Range Control - Identify location (include grid coordinates). - Request medical assistance. - Identify number of patients. - Identify urgency of mission (see Table E-1) - Provide brief description of patient(s) condition. - Call sign and frequency at pick up point. - Special equipment necessary. 2)A first aid/CPR trained person will provide first

aid until medical personnel arrive. A first aid kit will be located on the vehicle.

3)Range Control will contact the 2nd Platoon, 507th

Medical Company for aeromedical evacuation from the range.

4)An area will be cleared immediately of all hazardous

materials and marked for landing. 5)Injured person(s) will be evacuated to William

Beaumont Army Medical Center, Ft. Bliss. Fires, Explosion, or Release In cases of a fire, unplanned explosion, or a hazardous material/hazardous waste release, the following procedure will be implemented:

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1)Call Range Control. Range control in turn will notify the Fire Department and the On-scene Coordinator.

- Identify location (include grid coordinates). - Give time and type of incident. - Name and quantity of material. - Action being taken. 2)Providing it can be done safely, site personnel will

use the fire extinguishers located in the vehicles to control or extinguish a small fire. Because of the relatively barren surrounding area, a large fire is not anticipated.

3)Remove or isolate flammable or other hazardous

materials that may contribute to the fire. 4)Begin containment and recover any spilled materials. 5)In the event of an unplanned explosion, DA Form

3265-R (Explosive Ordnance Incident Report) will be filled out in accordance with Appendix C of FM 9-15 Explosive Ordnance Disposal Service and Unit Operations.

6)The On-scene Coordinator, upon arrival, will assess

possible hazards to human health or the environment that may have resulted from the release, fire, or unplanned explosion. This assessment will consider both direct and indirect effects of the release, fire, or unplanned explosion.

Immediately after the emergency, the On-scene Coordinator must

provide for treating, storing, or disposing of recovered waste.

7)All emergency equipment will be clean and fit for

its intended use before operations are resumed.

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Site Evacuation Plan During the operation of the thermal treatment unit, only EOD personnel shall be present at the site. EOD personnel are trained to manage the detonation operation and to respond to potential emergencies related to the operation. No site evacuation plan is required for this site since EOD personnel would be involved in any required emergency response. SCHEDULE OF REMEDIAL ACTION The On-scene Coordinator will assess the site as soon as possible after an incident. The Coordinator will determine the appropriate action, then determine if NMED should be informed before action is taken. When appropriate, action will be taken as soon as possible to reduce impact on human health and the environment. TABLE E-1 MEDICAL EVACUATION (MEDEVAC)

PRECEDENCE ACTION REQUIRED

URGENT Evacuation is required as soon as possible but not later than two hours to save life, limb, or eyesight.

PRIORITY Evacuation is required within four hours if the patient's medical condition could deteriorate to an URGENT precedence.

ROUTINE Evacuation is required within 24 hours.

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PERMIT ATTACHMENT F Page 1 of 17

PERMIT ATTACHMENT F CLOSURE PLAN This chapter contains the closure plan that describes the activities necessary to close the U.S. Army Air Defense Artillery Center and Fort Bliss (USAADACENFB) Open Detonation (OD) thermal treatment unit. This plan has been submitted to the New Mexico Environment Department (NMED) in accordance with the requirements of HWMR-7, Part IX, §270.14(b)(13). Closure of the OD treatment unit must include decontamination and decommissioning of all OD structures and equipment. Until final closure of the OD thermal treatment unit is complete and has been certified in accordance with HWMR-7, Part V, §264.115, a copy of the approved plan and all approved revisions will be on file at the USAADACENFB Directorate of the Environment (DOE) Office and available to the Secretary of the NMED or the EPA Regional Administrator upon request. Closure performance Standard: The OD treatment unit is intended to be clean closed. To meet the requirements of "clean closure," all wastes and waste residues will be removed from the OD treatment unit and associated structures. Soil contaminated with hazardous constituents will be excavated and removed. There should be no post-closure migration of hazardous waste, hazardous waste constituents, or hazardous waste decomposition products to ground or surface waters or the atmosphere. Decontamination activities will help to ensure the removal of waste residues to levels acceptable to the EPA, and further maintenance or post-closure care should not be necessary. The contaminated soil thus removed will be transported to a RCRA permitted disposal site. Partial Closure and Final Closure Activities Notice of intent to close

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USAADACENFB will notify the Secretary of the NMED, in writing, at least 90 days before the date on which partial or final closure of the OD treatment unit will commence, pursuant to HWMR-7, Part. V, §264.112(a). Partial closure of the OD unit will not occur. Final Closure: Final closure activities for the OD treatment unit is scheduled for the year 2090 and will consist of (1) decontaminating and decommissioning all structures and equipment used for hazardous waste treatment; (2) decontaminating the area within the OD treatment unit; and (3) removing any hazardous waste residues to a permitted treatment, storage, or disposal facility. Final closure of the OD treatment unit will be complete when (1) all hazardous waste and hazardous waste residues have been removed from the OD unit to a permitted TSD facility for proper management; and (2) all structures, equipment, and surrounding areas have been decontaminated. Maximum Extent of Operations The maximum extent of operations that will be open during the term of this permit includes the Open Detonation unit. Maximum Waste Inventory: The maximum inventory of waste expected to be in treatment at the OD unit at anytime during the life of the unit will not exceed 343 pounds (156 kilograms) Net Explosive Weight(NEW) of munitions per quarter of explosive-contaminated material. No more than 1372 pounds (623 kilograms) NEW of materials will be detonated in a year. Therefore, the expected waste inventory for the permitted life of the open detonation treatment unit is 13,720 pounds (6230 kilograms) of waste munitions. Schedule for Closure OD cleaning, sampling, and analytical activities are expected to take 180 days. Closure will proceed by the following schedule:

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Closure Schedule: Activity Maximum Time Required Notify NMED of intent to Close 0 Days Process final volumes of wastes 30 Days Completion of site characterization 60 Days Completion of remediation 165 Days Certification of closure by independent professional engineer 175 Days Notification of completion of closure to NMED 180 Days The 41st EOD conducts explosives demolitions at the OD treatment unit approximately 2 to 3 times per quarter. Explosives are blown with C-4 in existing demolition pits, which are visually inspected following each blow. Amendment of the Closure Plan: If it becomes necessary to amend the Closure Plan for the OD treatment unit; USAADACENFB will submit a written notification or request for a permit modification describing any change in operation or facility design which affects the Closure Plan in accordance with HWMR-7, Part V, §264.112(c). The written notification or request will include a copy of the amended closure plan for approval by the NMED. USAADACENFB will submit a written notification of, or request for, a permit modification to authorize a change in the current plan if: •There are changes in operating plans, waste management

design, or waste types to be treated that affect the Closure Plan

•There is a change in the expected year of closure •Unexpected events occur during closure that require

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modification of the current Closure Plan •Changes in state or federal laws affect the Closure

Plan.

USAADACENFB will submit a written request, pursuant to HWMR-7, Part V, §264.112(c), for a permit modification with a copy of the amended closure plan at least 60 days prior to the proposed change in facility design or operation, or within 60 days of the occurrence of an unexpected event that affects the closure plan. If the unexpected event occurs during final closure, the permit modification will be requested within 30 days of the occurrence. If the Secretary of the NMED requests a modification of the closure plan, a plan modified in accordance with the request will be submitted within 60 days of notification, or within 30 days if a change in facility condition occurs during final closure. The OD Detachment Commander, or designee, shall be responsible for storing and updating the facility copy of the closure plan and distribution of amended/updated copies of the closure plan to the OD unit office, the USAADACENFB Environmental Management (EM) office and the NMED. Closure Procedures When the decision is made to close the OD treatment unit, all hazardous waste present at the site will be treated or removed before closure activities commence. To the extent possible, all contaminated structures and equipment will be decontaminated and removed. Any structures and equipment that cannot be decontaminated shall be dismantled, placed into containers, and managed as hazardous waste. The first phase of closure will consist of a hazards survey of the OD treatment unit conducted by USAADACENFB EM health physics and industrial hygiene personnel. The purpose of the survey will be to identify potential contamination concerns that may

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present hazards to workers during the closure activities and to specify any control measures necessary to reduce worker risk. This survey will provide the information necessary for health physics and industrial hygiene personnel to identify worker qualifications, personal protective equipment (PPE), safety awareness, work permits, exposure control programs, and emergency coordination that will be required to perform closure. All workers involved in the closure activities will be required to have training and medical monitoring as required by applicable regulations. Personnel performing closure activities will be required to wear PPE as specified by health physics and industrial hygiene personnel. Open Detonation Pits. Following completion of the health and safety survey, the detonation pit and the OD treatment unit will be decontaminated. Soil sampling of the OD treatment unit will follow the procedures described below. The contaminated soil in the OD treatment unit will be sampled as described below, and subsequently analyzed for the parameters listed in Table F-1. MAXIMUM EXTENT OF UNCLOSED PORTION The treatment unit will remain open until complete closure. It is not anticipated that any area within the OD treatment unit will be closed separately. However, if the soil sampling proposed herein indicates that a particular operation or area is a threat to human health and the environment, USAADACENFB may opt to amend the closure plan in order to reduce the threat. This may require closure of part of the treatment unit. Appropriate regulatory approvals will be obtained if this option is necessary. REMOVAL OF WASTE/RESIDUE/CONTAMINATED SOIL Waste, residue, or soil will not be removed from the treatment

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unit during the active period of the OD events. If the results of the soil sampling proposed herein indicate that human health and the environment are threatened by these materials, and removal is the most cost-effective corrective measure, then the necessary regulatory approvals will be sought from NMED. YEAR OF CLOSURE The treatment unit capacity is not being physically consumed at a measurable rate (i.e., it is not fill up). Therefore, no operationally required closure is anticipated and there is no anticipated limit to Ft. Bliss/McGregor Range operations (e.g., base closure) which would necessitate closure. Therefore, the year 2090 was selected arbitrarily as a potential closure date. CLOSURE SITE ACTIVITIES USAADACENFB will ensure that the OD treatment unit will be closed in a manner the will minimize or eliminate any potential adverse impact to human health or the environment. USAADACENFB will also eliminate or minimize the potential for the escape of hazardous wastes, hazardous constituents, leachate, contaminated run-off, or hazardous waste decomposition products to groundwater, surface water, or to the air upon closure. Since it is anticipated that the unit will be 100 percent in use during the life of the unit, there will be no partial closure of this thermal treatment unit and only the complete closure of this facility will be addressed. Closure of the OD area thermal treatment unit will be conducted in three phases: • Phase 1 - Site Characterization • Phase 2 - Remedial Action, if needed • Phase 3 - Post-closure Care, if needed

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PHASE 1 - SITE CHARACTERIZATION The wastes handled in the OD unit are propellants, explosives, and pyrotechnics (PEP). During previous OD activities, the maximum amount of PEP wastes on site at any time during the facility's operation to date was approximately 2,000 lbs. (900 kg). To minimize the need of further maintenance of the OD treatment unit all visible evidence of the PEP treatment will be removed. This evidence will include, but is not limited to, discolored soils, metal fragments, and any other remnants of the detonated munitions. Additionally, the detonation area and the surrounding areas within the unit, and areas to which a fragment could be expected to be blown to by a maximum explosion will be swept with metal detecting equipment. This equipment will be used to detect any metal debris beneath the surface and to ensure that there are no Unexploded Ordnance (UXO) residues in the surface soils. Any fragments or residues detected with this equipment will be removed. All metal fragments, residues, soils, and other wastes removed from the unit will be characterized for hazardous waste constituents and characteristics and properly disposed of in accordance with HWMR-7, Part V, §264.111. Site Sampling In addition to the removal of visible remnants of the PEP destruction, surface soils from the detonation and surrounding areas will be collected. Sampling and analysis will be conducted in accordance with EPA established protocols. Discreet soil samples will be collected from the OD unit. All samples will be taken using a non-sparking (plastic or brass) scoop or other sampling device if so directed by the OD. Sampling personnel will record the location of each sample with respect to permanent stations, the date, names of sampling

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F-8

personnel, and other pertinent information. Permit Attachment A (Waste Analysis Plan) presents the Quality Assurance Project Management plan. Soil samples will be collected from a depth between 6 in. (15.2 cm) and 1 ft. (0.3m) at the following locations: •1 discreet sample at the bottom of each of the two pits in the

OD excavation, •3 discreet samples from the sides of each of the two OD pits (6

total), •4 discreet samples around the perimeter of the two OD pits

(outside of the pits) to evaluate the effect of kickout (8 total),

•3 discreet background samples from an area of the site that has

not been impacted by operation of the OD. Soil samples will be collected from a depth of surface to 6 in. (15.2 cm), and 6 in. (15.2 cm) to 1 ft. (0.3m), i.e. two samples per location, at the following locations: •8 discreet random samples in the bottom of the treatment unit

(but not in the pits, 16 total), •8 discreet samples from the perimeter (outside of the treatment

unit, 16 total), and In addition, soil samples will be taken on 5 ft. (1.5 m.) intervals from a 50 ft. (15.2 m) boring placed approximately in the middle of the treatment unit. This will produce 10 samples. All samples will be examined for physical evidence of UXO or unburned materials. The samples will then be subjected to the reactivity tests (Gap Test and Deflagration/Detonation Transition Test). Upon completion of these tests, the soils will be placed into the appropriate sample containers.

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Sample containers will be placed into a cooler with ice. When sampling is completed for the day, all samples will be shipped by overnight courier to a qualified laboratory, under appropriate chain-of-custody procedures, for analysis. Analyses will be conducted using the methods presented in Tables F-1 and F-2. Quality assurance and decontamination procedures are discussed in the Quality Assurance Project Management Plan (QAPMP) in the Permit Attachment A.

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TABLE F-1 SOIL SAMPLE ANALYSES

ANALYTE ANALYTICAL METHOD/OD1 SAMPLE VOLUME

INORGANICS:

Free Liquids SW846 9095 100g

Ignitability SW846 1010 10g

pH SW846 9040 10g

Reactivity GAP Test - Appendix III 10g

Reactivity Deflagration/Detonation Test - Appendix III

20g


EPA 353.3 10g

METALS:

Antimony Arsenic

SW846 7040 SW846 7060

100-500g 100-500g

Barium SW846 7080 100-500g

Beryllium SW846 6010 100-500g

Cadmium SW846 7130 100-500g

Cobalt Copper Chromium

SW846 7201 SW846 7210 SW846 7190

100-500g 100-500g 100-500g

Iron Lead

SW846 7380 SW846 7421

100-500g 100-500g

Mercury SW846 7471 100-500g

Potassium Selenium

SW846 7610 SW846 7740

100-500g 100-500g

Silver Strontium Zinc

SW846 7760 SW846 7780 SW846 7950

199-500g 100-500g 100-500g

ORGANICS:

Picric Acid SW846 8270 100-500g

HMX SW846 8330 100-500g

RDX SW846 8330 100-500g

2,4,6-Trinitro-toluene

SW846 8330 100-500g

2,4-Dinitrotoluene SW846 8330 100-500g

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2,6-Dinitrotoluene SW846 8330 100-500g

Nitroglycerine SW846 8332 100-500g

1SW846 ="Test Methods for Evaluating Solid Waste - Physical/Chemical Methods," Environmental Protection Agency, SW846. EPA = "Methods for Chemical Analyses of Water and Wastes," Environmental Protection Agency, 1979, Revised 1983.

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Sampling Equipment Decontamination Procedures All sampling equipment that must be reused will be decontaminated by the following process as specified in the QAPMP and summarized below: 1)All surfaces of the equipment that contact the sample will

be washed with a Liquinox/water wash, using a scrub brush to remove any remaining soils from the previous sample.

2)After washing, the equipment will be rinsed with distilled

water. 3)Following, the distilled water rinse, the equipment will

be spray-rinsed with ethanol or isopropyl alcohol to remove any traces of the soap.

4)A final rinse of distilled water will complete the

decontamination procedure. All decontamination liquids will be sampled upon the completion of the sampling event and characterized for disposal. These liquids will be properly disposed of during the remediation of the site. Sampling Quality Assurance/Quality Control (QA/QC) To ensure that the data received from the sampling event is representative of the site, quality assurance/quality control samples will be collected as specified in the QAPMP (included with Permit Attachment A). These samples include: 1) Duplicate Samples 2) Matrix Spike/Matrix Spike Duplicate Samples 3) Equipment Rinsate Blank Samples 4) Trip Blank Samples (for water only) The required samples, waste constituents and frequency of

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analysis are summarized in Table F-2. PHASE 2 - REMEDIAL ACTION When the analytical data has been reviewed, the extent and nature of contamination of the thermal treatment unit will be assessed. It is not anticipated that significant amounts of contamination will be reported in the soils collected from the site. However, in the event that detectable levels of contamination are reported at the site, the following activities will be conducted. TABLE F-2 QUALITY ASSURANCE/QUALITY CONTROL SAMPLES

SAMPLE TYPE FREQUENCY ANALYSES

Duplicate 5% Metals, Organics, NO2-NO3

Matrix Spike/Matrix Spike Duplicate

5% Metals, Organics, NO2-NO3

Rinsate Blank 5% Metals, Organics, NO2-NO3

Trip Blank 1 per day Organics

Establishment of Clean-up Levels Appropriate clean-up levels will be determined for the OD treatment unit at the time of closure, based on the nature of reported contamination at the site, the potential land use for the site, and the surrounding land use. Currently, the area surrounding the unit is uninhabited and not being used for agricultural purposes or otherwise developed. At the time of the unit closure, USAADACENFB shall incorporate the status of the area into the determination of the appropriate clean-up levels for the unit and will control,

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minimize, or eliminate, post closure escape of hazardous waste, hazardous constituents, leachate, or hazardous waste decomposition products to the ground or to the atmosphere for the protection of human health and the environment. Site Remediation Based on the analytical results from the soil sampling event and the determination of the appropriate clean-up levels, the site will be remediated, if required. Potential remediation activities may include soil excavation, in situ treatment, or other appropriate technologies. Once a technology for remediation is selected, a plan for the completion of the site remediation will be prepared and submitted to the New Mexico Environment Department for review and approval. Any wastes generated during the remediation will be disposed in accordance with all applicable regulations during the site remediation. These wastes may include excavated soils, decontamination liquids from the sampling event, metal fragments removed from the soils, and any other waste materials on-site. Site Restoration When remediation of the unit has been completed the site will be returned to as near natural grade as the available soil stock piles allow, and sloped to drain. If a waste-in- place closure is selected, the site will be fenced and warning signs will be posted on all approaches to the site. These warning signs will be in both Spanish and English. Due to the arid climate at the site, no vegetation will be planted on the remediated area. Rather, the vegetation will be allowed to reestablish itself. Deed Recordation Upon closure of this OD treatment unit, if it is determined that reactive, toxic, or hazardous materials remain on-site, Fort Bliss will, within 60 days of completion of the closure

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activities, complete the following actions. •Fort Bliss will submit a record of the type, location,

and quantity of materials remaining on-site to the NMED, the EPA Regional Administrator, and the local authority with jurisdiction over land use for the site.

•Fort Bliss will add a statement restricting the use of the

property to the deed of the facility or other instrument normally examined during title search. This statement will remain in the property description in perpetuity to notify any potential purchaser or user that hazardous wastes remain on-site.

PHASE 3 - POST CLOSURE CARE If clean closure is not practical, post-closure care will be conducted. The geology in the vicinity of the site may minimize the potential for groundwater contamination from activities at the site. Also, the groundwater level is approximately 600 ft. (182.9 m) below the surface in this area. Based upon the geology and the depth to groundwater, no groundwater monitoring is anticipated at this site. Soil analyses will be used to make the determination. If a clean closure is not achieved, fences, containment systems around the site, and warning signs will be used and inspected at least once every six months. Any deficiencies will be corrected as soon as possible, and within no more than 30 days from the date of discovery of the deficiency. All records for the facility during the post closure care period will be maintained by the Directorate of Environment. Any inquiries relating the closure of this unit and post closure care should be directed to: The Director, Directorate of Environment Fort Bliss, Texas 79916

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(915) 568-1385/1064 SUMMARY The following steps provide a summary of the potential closure process for this OD treatment unit. (1)If the analytical results indicate that there is no

residual contamination on the property, the site will be returned to approximately natural contours as the available soil stockpiles allow, using earth moving equipment (i.e. bulldozers). No decontamination of the equipment will be required.

(2)If the analytical data indicates that residual

contamination is present at the time of closure, the property will be deed recorded and the site will be returned to approximately natural contours using earth moving equipment (i.e. bulldozers). The entire site will be graded at the time of closure; no partial closure is anticipated.

(3)There are no permanent structures or equipment at the OD

unit to be decontaminated. The only decontamination potentially required will be the earth moving equipment. If necessary, the equipment will be washed over an impervious surface with pressurized water to remove any traces of potentially contaminated soils. Water will be collected, sampled for hazardous waste characteristics, and properly disposed of. It is not anticipated that removal of contaminated soils or additional sampling or testing of soils will be required.

LOCATION OF PLAN The Closure Plan will be kept in the Directorate of Environment, Fort Bliss, Texas. RESPONSIBILITY FOR PLAN UPDATE

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The Director, Directorate of Environment will be responsible for updating the Closure Plan.

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PERMIT ATTACHMENT G Page 1 of 5

PERMIT ATTACHMENT G DESIGN PLAN AND SPECIFICATIONS Introduction: The OD unit is used to thermally treat pyrotechnics, explosives, and propellants (PEP) that result from demilitarization of existing stockpiles and off specification material. The operation was begun in 1965, but records are only maintained by the 41st EOD for two years. Using the estimate of 1984 lbs (900 kg) per quarter, the total PEP destroyed at the site is approximately 207,232 lbs (94,000 kg) through 2nd quarter 1993. Currently, the PEP materials treated at this site are large caliber (non-handheld) munitions, and rocket propellants. Pyrotechnics are rarely treated here. C-4 is used as an initiator. Black powder is no longer used. The EOD has historically been responsible for ordnance and explosives found off of Ft. Bliss property in New Mexico and west Texas. However, every effort is made to detonate such off-site material where it is located and the current EOD officer has no recollection of off-site materials being treated at the unit. It is the intent of the 41st EOD to continue the policy of not treating off-Ft. Bliss waste munitions at this time. However, if the need arises, NMED will be contacted and a variance will be requested for the specific waste involved. Unit Location and Description: As illustrated in Figure G-1, the OD treatment unit is located in the northern portion of Ft. Bliss Military Reservation on McGregor Range. Exhibits 1,2, and 3 (map pockets, Permit Attachment O) contain details of the area and the treatment unit which is located about 10 mi (16.1 km) east of U.S. Hwy 54 at latitude 32o05'15" North, and longitude 106o04'45" West. As shown on Figure G-2, the unit is on an active portion of McGregor Guided Missile Range within the impact area for ballistic aerial targets (BATs), and the large caliber munitions

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and guided rockets which are used to destroy the BATs. EOD operations at the unit only occur when McGregor Range is inactive. The surrounding area is owned by the US government. A minimum of 5.5 mi (8.9 km) radius in any direction, is uninhabited desert, which is used as a firing range, and is secured by Range Control at Davis Dome. Access is from Hwy 54, through McGregor Camp, past Davis Dome. The unit is about 4 mi (6.4 km) east of Davis Dome at the foothills of the Hueco Mountains. All PEP materials to be treated come from bunkers on the Military Reservation and are only transported on military roads. General Dimensions The OD treatment unit is a manmade excavation with a roughly oval shape. As shown on Exhibit 3, Permit Attachment O, the dimensions are approximately 500 ft (152.4 m) x 200 ft (61 m) and 20 ft (6.1 m) deep. Within this excavation there are two pits (Pit A and Pit B) which are used for explosive Open Detonation (OD). The dimensions of the two pits are 6 to 7 ft (1.8 to 2.1 m) deep and 40 ft (12.2 m) in diameter of the top lip. All structures at the unit are earthen. The closest non-earthen structure is a viewing stand (covered bleachers) 2.5 miles (4 km) to the west which is occasionally used when dignitaries are invited to view missile launch operations. Because the site is on the target range, OD operations cannot occur when the range is active. Therefore, no non-EOD personnel will be in the viewing stand or on the range during OD operations. The closest authorized non-EOD personnel during OD operations will be at Davis Dome, 4 mi (6.4 km) west of the site (Figure G-2). Access to the site from McGregor Camp (Figure G-2) is by asphalt road about 3 miles (4.8 km), to the check-in at Range Control at Davis Dome,and about 3 miles (4.8 km) of asphalt road and about 4 miles (6.4 km) of one lane unpaved road to the unit. Entry to the unit to place the waste in the appropriate OD pit is by an earthen ramp at the south side of the excavation. The waste material is placed in the pit in conformance with EOD

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G-3

procedures; the EOD personnel retreat to a safe distance, and the material is detonated. Engineering Controls/Drawings All control structures are earthen. Within this excavation are several pits which are the result of OD operations. Also located in this excavation are the two OD pits that are the subject of this permit. Exhibit 3, Permit Attachment O, is a Site Contour Map that illustrates the engineered controls. A generalized cross-section of the OD treatment unit is provided as Figure G-3.

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PERMIT ATTACHMENT H Page 1 of 4

PERMIT ATTACHMENT H GENERAL PROCEDURES FOR HANDLING IGNITABLE, REACTIVE, OR INCOMPATIBLE WASTES Engineering Precautions to Prevent Reactions Wastes are never stored at the USAADACEFB OD treatment unit prior to treatment. Reactive explosives and energetic waste (being sensitive to impact, heat, shock, and light) are immediately treated upon transport from the bunker to the OD unit. The reactive waste is protected from open flames. Smoking, matches, and lighters are not permitted at any time. The grounds near the OD unit are generally clear of weeds and brush, which helps to prevent accidental brush fires at and around the OD pits. General Precautions for Handling Incompatible Reactive Waste The munitions to be destroyed are not incompatible because waste materials treated by OD at this unit are treated in lots of similar materials. Therefore, incompatible wastes do not mix. A more detailed description of the inventory, loading, transportation, unloading, and management as well as safety measures to be taken during waste handling has been provided in Permit Attachment I, Standard Operating Procedures. Prevention of injuries during OD treatment is accomplished by taking great care during placement of the hazardous waste to be treated at the OD pits, and retreating a safe distance from the unit before treatment. The EOD specialists retreat on the access road to at least the distances prescribed in Table H-1. Internal Communication/Instructions All personnel engaged either directly or indirectly in open detonation operations will notify Range Control and obtain clearance. Range Division or Range Command is located at Ft. Bliss. Range Control is located at Davis Dome at the McGregor Demolition Range. Prior to departing to the unit area the following will be accomplished: 1)Communications check with range Division.

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2)Vehicles will be inspected and meet the criteria outlined in Permit Attachment I, Standard Operating Procedures.

3)At least two persons will be dispatched in designated vehicles

to pick up required explosives from the EOD Bunker. 4)The following items will be placed in the vehicle prior to

departure: a)Telephone set, TA 312/PT, with batteries; b) First Aid Kit, with bloodborne pathogens protective equipment; c) Fire Fighting Equipment; d) Other equipment as required Upon arrival at McGregor Range, establish communication with Range Control. If communications cannot be established with Range Control or if during operations communications is lost, demolition operations will cease. The primary means of communication with Range Control will be a telephone set, TA 312/PT, in an electrical firing system operation. However, two-way radios may be used in an electric environment if the minimum safe distance for transmission, listed in Table H-1, is observed. Two-way radios or vehicle transmitters can be used in a nonelectric environment. Communication checks with Range Control will be made at least once an hour. Access to Communications Equipment As noted above either a telephone set or two-way radio is to be in any vehicle in use at the EOD during operations. Telephones and two-way radios will also be available in Range Control at Davis Dome. Communications are to be maintained between field vehicles and Range Control, as specified above, during EOD operations. Loss of communications will require that all EOD operations cease immediately and may not resume until communications are reestablished. Fire Control Ft. Bliss has extensive fire fighting facilities and one unit is located at McGregor Camp. The total fire fighting force is 61 persons and they operate 12 pieces of major equipment including:

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•1,000 gallons per minute (gpm) Structural Pumper Truck •1,200 gpm Crash (P-19) Fire Rescue Truck •Fully Equipped Personnel Rescue Unit •Fully Equipped HAZMAT Unit •Various Tank Trucks, for Water Transport The McGregor Camp unit is typically assigned one pumper and one tank truck and the unit is staffed on a 24-hour basis. A full compliment of hand held equipment and personal protective equipment is provided for use by the McGregor Camp Fire Fighters. Emergency Equipment - Testing and Maintenance All emergency equipment will be inspected and, if applicable, tested prior to departing to the OD area of operations. The following first echelon maintenance schedule is provided in Table H-1. Arrangements All emergency response personnel equipment and facilities are located on the base. Because the base facilities are adequate for emergency response, no arrangements for outside assistance are required. The Ft. Bliss emergency response contacts are listed below. Police - Military Police Officer In Charge 568-2404, 568-2651, 568-2114, 568-2117. Fire Department - Fire Chief 568-8887 or 568-8401 Directorate of Environment - 568-7930 Emergency Response Team Fire Chief - 568-8887 or 568-8401 Local Hospital - Emergency Room 569-2201 Map to William Beaumont Army Medical Center - Figure H-1. All information relevant to emergency response at the OD

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treatment unit will be provided to these emergency response departments. The information provided includes OD operating procedures, copies of emergency response plans and any other pertinent information.

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PERMIT ATTACHMENT I Page 1 of 20

PERMIT ATTACHMENT I STANDARD OPERATING PROCEDURES Introduction: The following is a description of the Standard Operating Procedures (SOP) that will be implemented by all Explosive Ordnance Disposal (EOD) personnel of the U.S. Army Air Defense Artillery Center and Fort Bliss. These procedures include the inspection of vehicles that will be used in transporting waste munitions to the OD unit, transportation of the inspected vehicles to the OD unit, and unloading of waste munitions brought by those vehicles. After unloading the waste munitions, the hazardous waste munitions will be subjected to open detonation. Safety criteria are also presented, and the meteorologic conditions under which OD operations will be allowed. Further, medical evacuation of OD personnel accidentally injured during Ordnance Demolition activities is outlined. Personnel and Explosives limits: All waste demolition/disposal operations will be analyzed with a view toward reducing personnel and quantity of explosives that could be subjected to an incident. Personnel limits: A minimum of two EOD qualified personnel will be exposed for a minimum time to the smallest quantity of explosives consistent with safety requirements and efficiency. One person will be available near the hazard area during explosive operations to give warning and assist in rescue activities in the event of an accident. The safe area will be determined by the senior EOD persons present. Trucks transporting explosive material to demolition site shall meet the U.S. department of transportation (DOT) requirements. Not more than two persons will ride in the cab. Explosive limits: Explosive limits will be established for each disposal operation so that each EOD Team Leader will be charged with the responsibility

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of not exceeding the established limit of 343 pounds (156 kilograms) per quarter. Procedures Prior to Departure: Prior to departing the bunker area to the OD unit, trained OD personnel will inspect the vehicles that will be transporting the waste munitions to the OD unit as follows: Inspection of Vehicles before Loading: All vehicles will be inspected before loading for compliance with safety regulations prescribed by transportation regulatory bodies and the U.S. Department of Defense. Only vehicles against which no unsatisfactory conditions are noted will be accepted for loading. Vehicles will not be rejected, however, if deficiencies are corrected before loading. Inspection will be made to determine that: (1)Fire extinguishers are serviceable. (2)Electric wiring is in good condition and properly

attached. (3)Brakes, steering, and other equipment are in good

condition. (4)The exhaust system is not exposed to accumulations of

grease, oil, gasoline or other fuels and has ample clearance from fuel lines and other combustible materials.

TRAFFIC PATTERNS: Traffic inside and around the Explosive Ordnance Disposal Demolition unit is limited to Explosive Ordnance Detachment (EOD) personnel. EOD personnel will maintain all approaching roads in serviceable condition. Materials destined for OD treatment unit will be removed from the McGregor Range storage bunkers and hauled entirely on military roads on the Military Reservation. Trucks moving PEP waste travel east of McGregor Camp using the road to Davis Dome which is maintained

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and cleared. Trucks moving PEP waste travel east of McGregor Camp using the road to Davis Dome which is asphalt, two lane, and very well maintained. Progressing further eastward toward the treatment unit, there are one and two lane asphalt roads to the various launch areas, one of which leads to the viewing stand and the treatment unit. Nearer to the site, in the impact area of the range, the road becomes unpaved, but well cleared. There is a single road into the site which leads to the ramp which is used to enter the OD excavation. East of Davis Dome during OD operations there is no reason for traffic except EOD personnel. The EOD unit establishes its base of operation on the unpaved entry road during treatment operations so as to stop any traffic approaching the treatment unit.

Number and Type of Vehicles The only vehicles on the dirt roads between the viewing stands and the treatment unit during OD operations are carrier trucks appropriate for transport of the waste in its containers, and lighter trucks for personnel transport. There should not be more than four such vehicles in the area at any one time. During range operations, (i.e., target practice) there will not be any vehicles east of the viewing stands. Any other vehicle movement in the area of the treatment unit (i.e., when there are no OD operations and no Range operations) will be Range personnel conducting maintenance operations or, potentially, reclamation of target materials.

Transfer and Pick-Up Stations Pickup is at the PEP bunkers on McGregor Range. When loaded the waste materials will be transported directly to the OD unit, without being transferred to another vehicle. Quantity of Waste Per Movement The weight of PEP waste per movement, including shipping containers, will not exceed the load limit of the vehicle. However, practically the loads are much less and are not expected to exceed 343 pounds

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(156 kg) per load. Route Capacities The road surface design loads are not known, however, the asphalt roads have supported the trucks transporting PEP, as well as missile carriers and other heavy military equipment, since 1965 with normal maintenance and resurfacing. The unpaved roads are on a very hard base (usually rock) and have previously supported the vehicles involved in treatment operations for many years. Loading/Unloading: Inspection before unloading: All vehicles will be inspected before unloading. Deficiencies will be corrected at the time of inspection, if such correction is considered necessary for safe delivery to the unloading point. During loading or unloading of vehicles, the brakes must be set and if the vehicle is on a grade, at least one wheel must be chocked. No explosives or ammunition will be loaded into or unloaded from vehicles while the motor is running unless the motor is required to provide power to vehicle accessories, such as mechanical handling equipment utilized in the loading and unloading of the vehicle. After vehicle inspection, the following will be accomplished: (1)Department of plans and Training (DPT) Range Division will

be notified and clearance obtained. (2)Communications check, with the unit and Range Division. (3)Vehicles will be inspected and meet the criteria outlined

above. (4)Two persons will be dispatched in designated vehicles to

pick up required explosives from the EOD bunker. (5)The following items will be placed in the vehicle prior to

departure:

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(a)Telephone Set, TX 312 (with batteries). (b)First Aid Kit. (c)Fire Fighting Equipment. (d)Other equipment as required. Handling and Preserving Explosives: a.Improper, rough, and careless handling of explosives may result in undue accidents which could result in loss of life, injury or property damage. The history of accidents which have occurred in the use, handling, shipping, and storing of ammunition shows that in many instances where the cause was determined, the accidents have been due to human error and circumstances which were avoidable. b.If hazardous conditions present immediate danger to life and

property, operations will not be continued until the hazard has been removed.

c.Explosives and ammunition will be handled and transported

carefully. Containers will not be tumbled, dragged, thrown, dropped on each other, rolled, walked over or dropped from tailboards of trucks.

d.Explosive containers should not be opened unnecessarily and

should remain sealed until needed. Transportation of Explosives: a.All ammunition and explosives will be secured in such a

manner as to prevent any movement. Dunnage, blocking and tie down straps will be used as required.

b.Vehicles transporting explosives will have the appropriate

"EXPLOSIVES" placards showing on the front, rear, and on each side. Signs will be covered when not carrying

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explosives. c.Vehicles hauling ammunition and explosives will be equipped

with two 5 pound ABC-type fire extinguishers in operational condition. This requirement can be satisfied by carrying two portable fire extinguishers.

Arrival at McGregor OD Treatment Unit: Upon arrival at the demolition site, trucks may distribute explosive containers or explosive items to be destroyed. As soon as all items have been removed, trucks shall be withdrawn from the detonation area to a safe location until waste destruction is completed. Containers of explosives will not be opened until the trucks have been withdrawn. Removal of Explosive Waste Munitions from Containers/Boxes: Containers of explosives or ammunition items to be detonated at the destruction site will be spotted and opened at least ten feet from each other and from explosive material previously laid for destruction to prevent rapid transmission of fire in an event of premature ignition. Empty containers will be closed and moved away. Empty containers will be picked up by truck on the return trip after delivery of the next quantity to be destroyed. Empty containers will be recycled. Communication between Range Control and the OD unit: If communication cannot be established between the Range Control and the OD unit or if during operations communication is lost, all demolition/disposal operations will cease immediately until contact is made. The following information will be required by Range Control from the senior EOD person present: (a)Unit (Open Detonation); (b)RTO and OICs name and grade;

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(c)Number of personnel involved in the operation; (d)Actual time of check in and check out with Range

Control; (e)Type of weapon (i.e., TNT, unserviceable

ammunition, etc.); (f)Explosive weight of each detonation; (g)Number of explosions; (h)Fire fighting equipment will be placed in a safe

area. Actions during operations: (1)Vehicles will be inspected before unloading. (2)Vehicle will be unloaded and withdrawn to the safe

area (this area will be selected by the senior EOD person present).

DESTRUCTION OF WASTE MUNITIONS: Methods: Destruction of ammunition and explosive material will be accomplished by open detonation.

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Open Detonation: Use of the two open detonation pits will only be during daylight hours and during favorable weather conditions. The acceptable conditions for explosive open detonation operations, permissible munitions for destruction, safety precautions, and detailed operational steps to be adhered to, are as specified above and as described in SOP AN-0000-G-026, "Detonation of H.E. Load Items, Pyrotechnics and Ammo Components." Prior to any explosives being transported to the detonation site, the demolition area will be inspected. The PEP will then be delivered to the pit areas by an enclosed truck and placed in the excavation. Initiating explosives will then be placed on the ground at least 25 ft (7.6 m) from the carrier truck and at least 10 ft (3 m) from the demolition site. Packing material from unpacking initiating and PEP explosives is then loaded on the carrier truck and, after the carrier truck has moved away, the initiating explosive is placed on the item to be destroyed. Detonating cords are then prepared and the blasting caps are wired into firing wire circuits and connected to the remote detonating cords. After all personnel are clear of the area the charges are detonated. After detonation is complete, the area will be inspected for unexploded ordnace. Items that are determined to be safe to handle, such as lumps of explosive and unfused projectiles, will be picked up and prepared for the next detonation. If the material is not safe to handle, the unexploded items will be destroyed by placing a demolition charge adjacent to, but not in contact with the item in accordance with SOP-0000-K-036. No remnants will be left untreated at the end of the day. Actions During OD Operations: (1)Vehicles will be inspected before unloading. After

unloading, they will be withdrawn to the safe area. (2)Safety precautions outlined below will be observed. (3)Electric and nonelectric capping procedures will be

performed as outlined below. (4)Fires will be fought as they occur.

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(5)Range explosive limits will not be exceeded. (6)All scraps and kickouts will be destroyed. Completion of operations: Upon completion of the OD event the following safety measures will be taken within 24 hours: (1)As some types of ammunition are comparatively difficult to

explode, a search of the surrounding area will be made after each blast and any material which has been thrown from the pit and not detonated will be collected and included with the next charge to be destroyed. Some items of ammunition that have been subjected to an explosion may be hazardous to handle. When such items are encountered, they will be handled accordingly.

(2)The area will be checked for fires. (3)The area will be policed for all trash. (4)Range Control will be contacted and informed of the range area

to be cleared. SAFETY PROCEDURES AT THE OD TREATMENT UNIT 1.General. All personnel engaged either directly or indirectly in operations

in which ammunition, explosives and hazardous material is involved will be thoroughly trained in explosive safety. They shall be capable of recognizing hazardous situations and of taking prompt and effective corrective action. Thinking safety and working safely must be a firmly established habit when working with or in the vicinity of items which are potentially dangerous by reason of their explosive, flammable, or toxic characteristics.

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2.Safety criteria: a.Prompt action will be taken to control any hazard. If an

immediate dangerous situation is encountered, all operations in the vicinity will be shut down and personnel evacuated to a safe location. EOD qualified personnel will then proceed to eliminate the hazard. Operations in the area will not resume until the hazard has been eliminated.

b.EOD operations will be conducted under the supervision and

control of the senior EOD technician present. c.Disposal/demolition operations will be restricted to

daylight hours. Under no circumstances will operations be performed during the hours of darkness.

d.No less than two qualified personnel will be present on the

Demolition Range during operations involving explosives. e.Operations will immediately cease upon discovery of any

unsafe situation which include the following: (1) Range Fire. (2)Unauthorized personnel in the demolition area. (3)Aircraft in dangerous proximity to the demolition

area. (4)Electrical storm within ten miles. (5) Snow, sand, or duststorm (6)Loss of communication with Range Control or Unit. f.Caps and explosives will be separated by at least twenty-

five feet. g.Firing trains will be prepared at least twenty-five feet from

explosives charges. h.There will be no running on the unit.

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i.Smoking will not be permitted in the OD area. j.There will be no "horseplay" on the unit at any time. k.Objects found on the unit will be left alone. l.Non-EOD personnel finding any object on the unit will point

the item out to an EOD Technician. m.The last person to leave the open detonation pit after

ignition of the time fuse has taken place will be an EOD Technician.

n.No person will be closer to the pit than the established safe

distance for the amount of explosives being disposed of. o.Any unsafe act detected by the EOD personnel present will be

brought to the attention of the individual concerned and the OIC.

p.Any person found in violation of the above safety rules will

be evicted from the unit and reported in writing to their commander/supervisor.

q.Improvising: The use of improvised methods of detonating blasting caps is

prohibited. r.Use of Trained Personnel. Destruction of ammunition will never be attempted by inexperienced

or untrained personnel. The number of trained and experienced personnel engaged in such operations will be kept to a minimum of two, consistent with safety, but no person will be permitted to engage in such operations alone.

s.Guarding Demolition Area: Guards, safety signals, and warning signals will be used as required

to keep unauthorized personnel from danger areas during OD waste destruction operations.

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t.No OD operations will be conducted at any time when the wind speed is more than 15 miles per hour (24 kilometers per hour). The army uses a variety of wind speed indicators as part of the usual missile range operations. EOD personnel will consult the operators of wind speed measuring equipment at Davis Dome, or carry portable devices to ensure that wind speeds are less than 15 miles per hour prior to conducting OD operations.

RANGE PROCEDURES FOR THE PREPARATION OF NONELECTRIC AND ELECTRIC PRIMING 1.Purpose: To establish procedures for the preparation of nonelectric and

electric priming. 2.Applicability: This section is applicable to all EOD personnel assigned or attached

to the 41st Ordnance Disposal Range. It also applies to personnel undergoing demolition procedures training provided by the 41st Ordnance Detachment.

3.Preparation and priming, nonelectric. A nonelectric system is one in which an explosive charge is prepared

for detonation by means of a nonelectric blasting cap. The basic priming materials consist of a nonelectric blasting cap which provides the shock adequate to detonate the explosive and the safety fuse which transmits the flame that fires the blasting cap. If more than one charge must be detonated simultaneously, the nonelectric system must be combined with a detonating cord to insure simultaneous firing.

a.Procedure: (1)Cut and discard approximately a 6 inch length from

free end of safety fuse to prevent a misfire caused by exposed powder absorbing moisture from air. Cut off a 3 foot length of safety fuse to check burning rate.

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(2)Ignite fuse and note the time required for fuse to burn. Compute the burning rate per foot by dividing the time in seconds by the length of safety fuse in feet.

NOTE A. All fuses in the same roll should burn at the same rate. In older types of fuse coils, the rate should be approximately 30 to 45 seconds per foot. New safety fuses (M700) should burn uniformly at 40 seconds per foot. (3)Cut the fuse long enough to permit the person

detonating the charge to reach a safe distance by walking at a normal pace before the explosion. Use a minimum of 6 feet under normal conditions. This cut should be made squarely across the fuse.

NOTE B. Ensure that the safety fuse is cut smoothly and squarely before inserting it into a blasting cap. If a clean-cutting crimper is not available, use a sharp knife, taking care to insure a square end cut by cutting against a smooth, hard, wooden surface. A jagged or rough cut may cause a misfire. (4)Attach M60 waterproof fuse igniter. (5)If primer adapter is used, pass the end of the safety

fuse through the priming adapter. The fuse should move through the adapter easily.

(6)Take one blasting cap from cap box and inspect it by

looking into its open end. If any foreign matter or dirt is present, hold it with the open end down and shake it gently, or lightly bump hand holding it against other hand. If foreign matter does not come out, discard the cap.

(7)Hold the safety fuse vertically with square cut end up

and slip the blasting cap gently down over it so that the flash charge is in contact with the end of the fuse; if not in contact it may misfire. If the fuse end is flattened or is too large to enter the blasting cap freely, roll it between the thumb and fingers until the size is reduced to permit free entry of the fuse.

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(8)After the blasting cap has been seated, hold cap firmly against fuse.

(9)Slide the second finger down the outer edge of the

blasting cap to guide crimpers and thus obtain accurate crimping.

(10)Crimp blasting cap at a point approximately 1/8 to

1/4 inch from the open end. Complete crimping while holding the cap. Then pull the cap into the adapter, if used, until it stops.

NOTE: No EOD operations will be conducted during inclement weather. b.Nonelectric misfires. (1)Prevention. A misfire should be extremely rare if the

following procedures are followed carefully: (a)Prepare all primers properly. (b)Load charges carefully. (c)Place primers properly. (d)Perform any tamping operation with care to avoid

damage to an otherwise carefully prepared charge.

(e)Fine charge according to proper technique. (f)If possible, use dual firing systems. If both

systems are properly assembled, the possibility of a misfire will be reduced to a minimum.

(g)Do not use blasting caps underground; use a

detonating cord. 4.Clearing Nonelectric Misfires. For charges primed with nonelectric blasting caps and safety fuse, the procedure is as follows:

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a.Allow a minimum of 30 minutes to elapse after maximum delay predicted for any part of disposal shot has passed before starting to investigate.

b.When practical, insert a new fused blasting cap into the

charge if this can be done without disturbing old blasting cap or prime and place new charge close enough to original charge to insure detonation of both. When necessary, a misfire blasting cap may be removed and a new fused blasting cap inserted.

5.Preparation and priming, electric. An electric firing system is

one in which electricity is used to fire the primary initiating element. An electric impulse supplied from the power source, usually on electric blasting machine, travels through the firing wire and cap lead wires to fire an electric blasting cap. The chief components of the system are the electric blasting cap/electric squib, firing wire and the blasting machine. The preparation of the explosive charge for detonation by electric means is called electric priming. The proper methods and sequence of operations of electric priming are described below.

NOTE: These procedures, pertaining to the preparation and priming of high explosives with electric blasting caps, also pertain to the preparation and priming of low explosives with electric blasting squibs. A.Procedures. (1)Placing charges. Prepare and place all explosive

charges as prescribed for appropriate type or types of charges.

(2)Lay out the firing wire. (a)After locating a firing position a safe distance

away from the charges, lay out the firing wire. (b)Test the firing wire. (c)Twist the free ends of the firing wire together

to prevent an electric charge from building up

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in the firing wire. (3)Testing blasting the caps. (a)Test each blasting cap to be used in electric

firing system. (b)After each cap has been tested, twist the free

ends of cap lead wires together to prevent an electric charge from building up in the cap lead wires.

(4)Connecting the circuit. (a)If two or more electric blasting caps are used,

connect their lead wires into one of the circuits described in paragraph 3-3c, TM 60A-1-1-31.

NOTE: At the firing position, keep the free ends of the firing wire twisted together until ready to connect the blasting machine. A continuity check may be made of the firing wire and blasting cap circuit before inserting caps into the charges. (b)Splice free cap lead wires to the firing wire. (5)Inserting caps into charges. Place blasting caps into charges and fasten the caps securely to

the charge. (6)Testing the entire circuit. (a)Move to firing position and test the entire firing

circuit with the galvanometer or test set. (b)Twist the free ends of the firing wire together. (7)Exercise the blasting machine. Test blasting machine by actuating it several times with nothing

attached to terminals. Self test M32/Mk1 Mod 1/M34 machine by observing the area between the terminals after actuating several times. Thje indicator lamp

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should glow. If it does not glow, reject and replace the blasting machine.

(8)Connecting blasting machine. Untwist ends of firing

wire and fasten them to two posts of the blasting machine.

(a)Release blasting machine handle by rotating the

D-ring until handle springs outward from the body of the blasting machine.

(b)Hold machine in upright position (terminals up)

in either hand, so that the plunger end of handle rests under the base of thumb and fingers grasp machine body.

(c)Squeeze the hand sharply several times in

succession until the charge fires. B.Electric Misfires. (1)Prevention of electric misfires. In order to prevent

misfires ensure that: (a)All blasting caps are included in the firing

circuit. (b)All connections between the blasting caps and

firing wires, connecting wires, and firing wires are properly made.

(c)Short circuits are avoided. (d)Grounds are avoided. (e)The number of blasting caps in any circuit does

not exceed the rate capacity of power source at hand.

(2)Cause of electric misfires. Common specific causes of

electric misfires include:

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(a)Inoperative or weak blasting machine or power

source. (b)Improperly operated blasting machine or power

source. (c)Defective and damaged connections, causing either

a short circuit, a break in the circuit or high resistance with resulting low current.

(d)Faulty blasting caps. (e)The use in the same circuit of blasting caps

(other than M6) made by different design. (f)The use of more blasting caps other than power

source rating permits. (3)Clearing electric misfires. If charge is primed

electrically, proceed as follows: (a)Make several successive attempts to fire. (b)Check firing wire connections to blasting machine

terminals to be sure that contacts are good. (c)Make two or three more attempts to fire charge. (d)Disconnect blasting machine and short firing

wire. (e)Allow a minimum of 30 minutes to elapse before

starting to investigate. NOTE: Wait for at leasst 30 minutes, unless it can be ascertained that the blasting cap failure is strictly electrical. A malfunctioned cap may have initiated a burning explosive charge. If the misfire is strictly electrical in nature, corrective action may be taken immediately. (f)Test the firing circuit with circuit tester for

breaks and short circuits and correct any defects discovered.

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(g)Remove and disconnect old blasting cap(s) to

firing circuit and reprime charge. (h)Reconnect firing wire ends to blasting machine

and fire the charge(s). MEDICAL EVACUATION (MEDEVAC) IN CASE OF EMERGENCY DURING OD PROCEDURES: ACCIDENTS: In case of an accident, Range Control will be notified immediately. When MEDEVAC Helicopter is airborne, one radio will be placed in direct radio communications with the pilot. An area will be cleared of all hazardous materials immediately and marked for landing. MEDEVAC procedures are covered below: 1.Purpose: To establish procedures concerning the evacuation of

injured personnel by Helicopter Ambulance from McGregor OD Demolition Site.

2.Procedures. a.A qualified medical technician, with ambulance, will be

available through Range Control during inclement weather or when the 507th Medical Company (AA) is not on strip alert. Unit will transport personnel to a pickup point designated by Range Control when ambulance support is requested. When checking into the range, the unit should check with Range Control as to air evacuation status.

b.For emergencies, aeromedical evacuation from range location

to Beaumont Army Hospital Medical Center will be available on a continuous basis. Requests for aeromedical evacuation from the range will be relayed to Range Control who in turn will contact the 2nd Platoon, 507th Medical Company (AA). To establish adequate preparation for the evacuation the following is required:

(1)Pick up location and destination (grid coordinates

with common name should be given, if available).

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(2)Number of patients. (3)Urgency of mission. (Care should be employed in

determining the urgency. Routine or nonemergency cases should utilize ground ambulance or organic transportation.)

(4)Brief description of patients condition to include

whether he/she is a litter or an ambulatory patient. (5)Call sign and frequency at the pick up point, if radio

is available or name of person to contact in the event the aircraft is met.

(6)Any special equipment necessary. c.Unit will select a helicopter landing zone (LZ) as follows: (1)LZ should be away from overhead powerlines, trees,

high bushes and boulders. (2)LZ should be as flat as possible and free of

depressions and ditches. (3)Any obstacle should be observable from the air. (If

panel markers or other day or nighttime site identification device are available, they should be utilized and well staked down.)

(4)LZ will be free of all loose objects which could be

blown up into the helicopter rotor blades. SAMPLING AND ANALYSIS PLAN Within 6 months of issuance of the operating Permit, thereafter biannually, and at closure, sampling and analysis of the OD treatment unit soils and/or ash residues will be conducted as described in Permit Attachment J.

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PERMIT ATTACHMENT J Page 1 of 41

PERMIT ATTACHMENT J SAMPLING AND ANALYSIS PLAN Introduction The U.S Army Air Defense Artillery Center and Fort Bliss Open Detonation (OD) treatment unit is being permitted as a Subpart X Miscellaneous unit since this type of unit does not neatly fit into any one particular conventional unit type discussed in HWMR-7, 40 CFR, Part V, § 264, Subpart I through O. During its operational life, the unit will be operated as an OD treatment unit. At the end of its operational life, if the Permittee cannot close in accordance with 20 NMAC 4.1, §264 closure by removal standards, then the OD treatment unit will be subject to post-closure permitting requirements. SITE CHARACTERISTICS: A brief account of the topographic, meteorologic, surface water, ground water, geologic, and geomorphologic characteristics of the OD unit is presented in the following paragraphs. After characterization of the OD unit, the Sampling and Analysis Plan will be described. Topographic Map The topographic map for the OD unit is provided as Exhibit 3, Permit Attachment O. The 2 feet (0.6 meter) contour map is dated and orientation, surface waters, surrounding land uses, roads, and facilities are shown for the radius of 1,000 ft (304.8 m). Also, Exhibits 1 and 2, Permit Attachment O, provide similar information for a radius of approximately 50 miles (80.5 km) from the site and 5 miles (8 km) from the site, respectively. The topographic and structural description of the OD unit and its surroundings are presented below under "Geology". Meteorological characteristics: Regional Meteorology

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The climate in the OD unit region is typical of the arid to semi-arid regions of the southwestern United States. Table J-1 presents a summary of climatic information for the Alamogordo, Tularosa, Cloudcroft, El Paso, and Orogrande areas. Alamogordo, Tularosa, El Paso, and Orogrande are typical of the central portion of the basin and Cloudcroft is typical of the bordering mountains. The mean annual precipitation in the basin ranges from 8.8 in (22.4 cm) in the central portion of the basin at Orogrande to 25.4 in (64.5 cm) at Cloudcroft in the bordering mountains. Precipitation on the slopes of the surrounding mountains produces intermittent stream runoff that drains toward the center of the basin, or moves as groundwater flow through the alluvial fans as interflow. The intense summer thunderstorms produce high runoff of short duration, most of which flows into the playas or alkali flats and evaporates (New Mexico Water Resources Research Institute, 1976). Temperatures in the basin range from an annual average of about 61°F (16°C) in the central portion of the basin to about 45°F (7°C) in the bordering mountains (Table J-1). Recent meteorological data compiled by the National Weather Service for the El Paso International Airport (approximately 30 mi (48.3 km) south of the site) has been used to construct wind roses for the years 1988, 1989, 1990, 1991, and 1992. This information is graphically illustrated on Maps (entitled Exhibits) 2 and 3, in Permit Attachment O. LAND USE AND SURFACE WATER: There are no buildings on the OD unit. The nearest structure to the site is the viewing stand, located about 2.5 miles (4 km) west of the unit. The nearest occupied buildings are the Range Control facilities on Davis Dome, about 6 miles (9.7 km) west of the unit. There are no water wells near the unit. No monitoring wells, injection wells, or recovery wells have been constructed. There are no drinking water wells because the groundwater at the unit is not potable (See Section on "GROUND WATER" for explanation of why there is no potable water at the OD unit). The facilities at McGregor Camp and Davis Dome obtain water from the El Paso

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municipal system via a 12-inch (30.5 cm) diameter underground pipeline. Drainage away from the unit is natural and generally directed to the south, west, and north. The Unnamed Arroyo approximately 1,000 ft (304.8 m) north of site (Exhibit 3, Permit Attachment O) drains an area of the Hueco Mountains of about 40,000 acres (162 sq km), as discussed below in Section on "Discharge Calculation". Drainage to the west and south is by sheet flow and naturally eroded swales. It does not enter a well defined stream bed near the unit. Run-on will be diverted from the unit by berms (to be built). Run-off from the east from the unit does not occur because it is an excavation with no outlet. There are no homes in this area, therefore, no Federal Insurance Administration (FIA) floodplain maps have been developed. Calculations follow to predict the 100 year flood elevation. The dry Unnamed Arroyo north of the unit (Maps/Exhibits 2 and 3, Attachment O) is the only likely potential source of flood water and an estimated 100 year flood is determined for this arroyo using runoff and discharge equations as described in this section. The objective will be to predict a stream discharge (Q) for the arroyo adjacent to the unit, and calculate the stream capacity to determine if the resulting flood will reach the OD treatment unit. Discharge Calculation The design flood for the arroyo north of the unit was developed based on the intensity of the 30 minute 100 year rainfall. The assumptions are that the rain event occurs over the entire 40,000 acres (162 sq km) of the drainage basin at the rate of 5 in (12.7 cm) per hr. The other assumption is that the duration of the rain event is sufficiently long that runoff from the farthest upstream locations in the basin has time to flow to the point in the drainage way adjacent to the OD unit. Both of these assumptions result in a higher calculated maximum discharge adjacent to the unit than would result from a 100 yr flood. Based on the above assumptions, the design flood has a discharge rate of about 100,000 cubic feet per second (cfs) (2,832 cms) as

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calculated using the rational equation: Q = CIA where: C =Runoff Coefficient (assumed to be 0.5) I =Rainfall intensity (assumed to be 5 in per hr) A =Area of the basin (measured at approximately

40,000 acres) (Chow, 1964, p. 14-7) These assumptions result in a 100,000 cfs (2,832 cms) discharge rate from the basin. The drainage basin was also evaluated using the USDA equation for the southwest: Q =CM5/6 Where Q =Discharge in cfs C =Runoff Coefficient (different from that for the rational

equation and empirically developed for conditions in the southwest).

M = Drainage Basin Area in acres. (Davis, 1969, p. 39-8, 9) The runoff coefficient was estimated at 100. This is the average of the extreme values recommended for hilly areas. Much of the drainage area is relatively flat (slopes less than 5 percent) so this is a conservative runoff coefficient value. The calculation is: Q = 100 (40,000)5/6 = 685,000 cfs (19,399.2 cms) Because the southwest equation predicts more stream flow, it

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will be used. Available Stream Capacity Based on the Manning Equation for open channel flow (Chow, 1964,p. 7-24, 25), the discharge capacity of the arroyo and overbank areas north of the unit were calculated. Q = 1.49 AR_ S½ n where: Q= the flow in an open channel in cfs n= the Manning number (estimated at 0.025) A=Cross Sectional area of the channel R=Hydraulic Radius (approximately equal to the

mean channel depth) S=Slope of the Energy Gradient To determine the total drainage way discharge capacity two discharge rates have been calculated. The first (Q1) is that capacity when the arroyo channel is full. The second (Q2) is that capacity available when the arroyo overflows and water spreads out over the surface of the alluvial fan. The discharge capacity of the main channel of the arroyo (Q1) was calculated based on current mapping in the area of the unit (Map/Exhibit 3). The main channel is about 200 ft (61 m) wide and 2 ft (0.6 m) deep. Therefore: Q1 = 1.49 (360)(2)_(0.015)½ 0.025 = 4,162 cfs (117.9 cms) The discharge capacity of the overbank area (Q2) was calculated using topographic data from both current mapping (Map/Exhibit 3) and the published 1:24,000 scale map (Map/Exhibit 1).

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Based on current mapping, the lip of the treatment unit excavation is approximately 8 ft (2.4 m) higher than the bottom of the arroyo. Assuming a design flow depth is a total of 6 ft (1.8 m) (i.e. 2 ft (0.6 m) in the arroyo channel and 4 ft (1.2 m) in the floodplain), and assuming the floodplain extends to within 1,000 ft (304.8 m) of the adjacent (further north) arroyo the Q2 value can be calculated. The resulting 9,300 ft (2,834.6 m) floodplain is reasonable given the conservative values for rainfall intensity and the low probability of it occurring over more than one drainage basin at the same time. The overbank flow area discharge capacity (Q2) assuming 4 ft (1.2 m) of water over an area 9,300 ft (2,834.6 m) wide is: Q2 = 1.49 (37,200)(4)_(0.015)½ 0.25 = 681,631 cfs (19,303.8 cms) The total available discharge capacity (Q1 + Q2) is approximately 685,000 cfs (19,399.2 cms) with a design depth of 6 ft (1.8 m), 2 ft (0.6 m) below the elevation of the lip of the treatment unit. This approximately equals the maximum estimated flood discharge of 685,000 cfs (19,399.2 cms) Therefore, the conservatively derived 100 year storm is predicted to reach an elevation of about 4,326 ft (1,318.6 m) adjacent to the treatment unit. Because the lip of treatment unit is at about elevation 4,328 ft (1,319.2 m), there is approximately 2 ft (0.6 m) of free board under the assumed conditions. This is a conservative analysis and the probability that flood conditions will reach the calculated elevation adjacent to the treatment unit is low. Conclusion: Flood barriers at the OD treatment unit consist of natural vertical relief. The unit is above the estimated 100 yr. floodplain (FIA maps are not available for this area). Erosion and Soil Types at the OD Site: The morphology of the alluvial fan and ridges near the OD

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treatment unit suggest erosion of the arroyo into the unit will not occur. There is a ridge of rock east of the unit which marks the likely southwestern limit of the Unnamed Arroyo. If the arroyo migrates under extreme flood conditions it will likely migrate to the north, away from the treatment unit. Therefore, erosion of the treatment unit due to flooding by the arroyo is unlikely. The soil type at the OD site is the Mimbres-Tome Association (MTA) which consists of mixed silty calcareous alluvial sediments on broad flood plains. Figure J-1 and its accompanying Legend present a brief description of the subject soil Series/Group. GROUND WATER: Regional Hydrology: Groundwater resources on the eastern side of the Hueco Bolson are sparse and of generally poor quality when compared with those on the west side of the Hueco Bolson, from which the City of El Paso derives its drinking water. Bolson deposits are composed of deep alluvial accumulations washed into intermontane areas from the surrounding highlands. The water bearing sediments which form this aquifer are generally unconsolidated, alternating, and discontinuous beds of silt, clay, sand, gravel, and boulders with associated caliche, gypsum, conglomerate, volcanic ash, tuffs, and basalts (Taylor, 1981). Precipitation and, to a minor extent, infiltration from the Rio Grande and Pecos Rivers, are the principal sources of recharge to the alluvial and Bolson deposits. Groundwater movement in this area begins with recharge along the foothills of the mountains and plateaus where the sediments are coarse grained and permeable, and possibly along the channels of ephemeral streams in the basins. Generally, recharge does not occur unless precipitation is sufficient to cause surface flow through the foothill areas in the ephemeral streams, otherwise the water is either directly evaporated or lost from the shallow subsurface by evapotranspiration. Groundwater moves from recharge areas to discharge in the

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topographically lower parts of the basins. Fresh water is generally located in recharge areas that flank the topographically higher basin edge and may occur down gradient in distinct lenses intertongued with less permeable sediments which contain older, more saline waters. Total dissolved solids, chloride, and sulfate concentrations increase along the groundwater flow path by interaction with the rock matrix, dissolution of associated evaporite deposits, and/or evapotranspiration concentration. Basinward, slightly saline to saline groundwater may discharge naturally through evaporation, which can result in accumulation of salts on the land surface; may leave the topographically closed basin through the rocks that underlie the basin; or discharge directly to surface drainage such as the Rio Grande (Groundwater Availability in Texas). Currently, large amounts of groundwater are withdrawn for municipal and industrial use in the El Paso area from the Hueco and lower Mesilla Bolsons. Overproduction of groundwater may result in a rise in dissolved constituents due to mixing of fresh water with slightly saline to saline water withdrawn from the sediments which underlie, overlie, or adjoin the fresh-water bearing zones. The water table in the McGregor Range area is generally deep, greater than 230 ft (70 m) below ground surface. Available well data from the area (Table J-2) have been summarized, and used to construct a water table contour map, Figure J-2 (Taylor, 1981). The map shows a water table depression to the east and south of Davis Dome, on McGregor Range, encouraging an easterly movement of water into the northern Hueco Mountains, as compared with a westerly movement, away from the mountains in the south. The water flow in the central part of the Hueco Bolson is southward towards the Rio Grande. The difference in flow regime is probably due in part to a decrease in transmissibility of the Bolson sediments (an increase in clay content, for instance) to the immediate east of Davis Dome. The depth to groundwater in the immediate area of the OD treatment unit may be in excess of 600 ft (182.9 m). Some water quality data is variable for the area. Test holes drilled by the Army in 1956 to investigate the potential for drinking water beneath McGregor Camp found no water considered

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potable. In general the hot waters are highly mineralized, with up to 8,980 ppm total dissolved solids (TDS) being recorded, while the cold groundwater of the region has a lower salinity. The two adjacent wells (numbers 24 and 25 in Table J-2 and on Figure J-2) apparently display both types: the "Hot Well" encountering hot water (presumably originating at depth) at the water table, and the shallower well finding "normal" water in what appears to be a perched zone. Some shallow holes drilled for a geothermal project hit small amounts of water at this same level. A small playa lake located near the "Hot Well" could provide recharge for such a localized perched aquifer (Taylor, 1981). More generally, alluvial fans emanating from the Hueco Mountains are the probable source of the low salinity non-thermal waters. Flow data are almost non-existent for the eastern side of the Bolson. Alluvial deposits tend to be coarser-grained at greater depths allowing water movement, although the underlying lake-bed sediments are less permeable, having a considerable clay content. The limestone bedrock is generally fairly compact, often crystalline; and having a low porosity. However, many fractures and solution cavities have been reported by drillers, and this suggests a means by which water may move, especially from depth (Taylor, 1981). GEOLOGY: Regional Geology The OD treatment unit is located in the Hueco Bolson, a part of the transition-zone between the Basin and Range, and the Great Plains tectonic provinces in an area referred to as the Rio Grande Rift. The Rio Grande Rift is characterized by evidence of Quaternary faulting, high heat flow, Tertiary volcanic activity, and a minor number of earthquakes. The Hueco Bolson is a marginal Basin and Range structure, lying between the Franklin and Hueco Mountains and is the southernmost extension of the Tularosa Basin of New Mexico. It is a flat intermontane basin approximately 19 mi (30 km) in width, with an elevation of about 4,000 ft (1,220 m) at the base of the Franklin Mountains, rising eastward to about 4,430 ft (1,350 m)

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near the Hueco Mountains. Bolson sediments consist of late Cenozoic Camp Rice and Fort Hancock Formations (fluvial and lacustrine sands, gravels and clays), plus recent valley fill and eolian sand. The Franklins are a tilted fault-block sequence of Paleozoic rocks underlain by Precambrian granite, totalling approximately 8,000 feet (2,440 m) of section (Barrie, 1975). Their counterparts on the eastern side of the Bolson are the Hueco Mountains. The Hueco Mountains, located east of the treatment unit, are a range of hills, comprising mainly Paleozoic sedimentary rocks, which rise approximately 984 ft (300 m) above the floor of the Hueco Bolson. They form an impressive escarpment in their northern part. Small hills surrounded by alluvium to the west of the main mountain block would appear to be faulted-off outliers. A series of Tertiary igneous bodies have intruded the sediments around Hueco Tanks State Park. A simplified geologic map of the area is shown in Figure J-3. The OD treatment unit is located on alluvial deposits near the northern terminus of the Hueco Mountains. SAMPLING AND ANALYSIS PLAN: Sampling Methods Because of the inherent hazardous nature of the Pyrotechnics, Explosives, and Propellant (PEP) materials and the potential for unexploded ordnance (UXO), no sampling will be done at the site until a sweep has been conducted for UXO. The UXO sweep will be done by a 41st EOD specialist using established procedures within 24 hours of the detonation event. In order to collect samples the EOD personnel will have to inspect the unit and general area after the detonation and clear it for sampling. However, the contaminants of concern are generally not degradable and, if present, will be in the unit and protected from wind dispersion. Therefore, sampling should not be time critical. In fact OD operations are relatively rare

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(sometimes less than once a quarter), and scheduling sampling based on these operations may cause delays in data acquisition. Discreet soil samples will be collected from the OD treatment unit. All samples will be taken using a non-sparking (plastic or brass) scoop or other sampling device if so directed by the EOD. Sampling personnel will record the location of each sample with respect to permanent stations, the date, names of sampling personnel, and other pertinent information. The Quality Assurance Project Management Plan to be implemented is described below following this Sampling and Analysis Plan. Discreet soil samples will be collected from a depth of between 6 in (15.2 cm) and 1 ft (0.3 m) at the following locations which are shown on the schematic diagram, Figure J-4: •1 discrete sample at the bottom of each of the two OD pits, • 3 discrete samples from the sides of each pit (6 total), •4 discrete samples around the perimeter of each of the OD

pits (outside of the pits) to evaluate the effect of kickout (8 total),

•3 discrete background samples from an area of the site that has

not been impacted by operation of the EOD. Soil samples will also be collected from a depth of surface to 6 in (15.2 cm), and 6 in (15.2 cm) to 1 ft (0.3 m) at the following locations: •8 discrete random samples in the bottom of the treatment unit

(but not in the pits), •8 discrete samples from the perimeter (outside of the

treatment unit), and In addition, soil samples will be taken at 5 ft (1.5 m) intervals from a 50 ft (15 m) boring place approximately in the middle of the treatment unit. The analytical results will be evaluated to determine whether drilling to a depth greater than 50 feet is necessary.

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All samples will be examined for physical evidence of UXO. The samples will then be subjected to the reactivity tests (Gap Test and Deflagration/Detonation Transition Test). Trained Explosive Ordnance Disposal (EOD) experts will use visual inspection to determine that the soil samples taken following the open detonation episode are safe (i.e., non-explosive) for chemical analysis. Upon completion of these tests, each discreet soil sample will be placed into a cleaned mixing bowl, mixed thoroughly (to homogenize the sample) and then placed into its appropriate sample container. There will be no compositing of any samples. Sample containers will be placed into a cooler with ice. When sampling is completed for the day, all samples will be shipped by overnight courier to an EPA acceptable qualified laboratory, under appropriate chain-of-custody procedures, for analysis. During the Initial Unit Characterization Sampling, only one boring in the treatment unit will be made to determine if downward migration of PEP materials has occurred. It will be made after the soil samples have been taken and analyzed, in order to not place it in an area of surface contamination that may be carried downward with the boring. Samples will be taken on 5 ft (1.5 m) intervals for logging (visual classification) and chemical analysis for 50 ft (15.2 m). Quality assurance and decontamination procedures are discussed below in the Quality Assurance Project Management Plan (QAPMP). Frequency of Analysis Initial unit characterization and subsequent sampling will be conducted semi-annually. Results will be reported to NMED after each sampling event. Similar sampling will be conducted at closure. Soil Sample Analyses: The analytical methods to be used for the OD treatment unit potentially contaminated soils will be those listed in Table J-3.

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"Kick-Out" Residue This section addresses the concern that the PEP waste are ejected from the treatment unit and the fragments potentially result in environmental contamination. Open Detonation: Little, if any, ash is generated following an explosive open detonation. The residue following open detonation consists of metallic fragments and occasional pieces of PEP which were not thermally treated during the explosion. Following each detonation, and as soon as the site can be safely approached, typically within 24 hours of the detonation, the site will be closely inspected for metallic or PEP fragments. Metallic fragments that are obviously free of PEP will be collected and stored to be surplused. PEP fragments found will be detonated at the point they are found with no additional handling. Potential for Danger Waste PEP is not present at the OD treatment unit until immediately prior to being treated. During the treatment process, access to the site is controlled by Range Control and there is only one access road. There is, therefore, no significant potential for exposure of domestic animals, wildlife, crop, or vegetation during the OD treatment process. PEP is detonated in accordance with minimum safety distances detailed in 40 CFR 265.382. These safety distances refer to the distance from the open detonation unit to the property of others and are specified below in Table J-4.

TABLE J-4 MINIMUM SAFETY DISTANCES FOR OPEN DETONATION OPERATIONS

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Quantity of Waste Explosives

Minimum Distance from

Detonation to Property of Others

0 to 100 pounds (0 to 45.4 kg)

670 feet (204.2 m)

101 to 1,000 pounds (45.5 to 453.6 kg)

1,250 feet (381 m)

1,001 to 10,000 pounds (453.7 to 4,536 kg)

1,730 feet (527.3 m)

Unidentified Remnants Very small pieces of "kick out" which are not located and left in the soil will be characterized by soil sampling. Sampling will determine the impact of unrecovered residue. RESIDUE ANALYSIS PLAN The PEP materials treated since 1965 may have varied, and analysis of currently treated materials is unnecessary because the character is known and chemical analysis is impractical from a safety standpoint. Therefore, sampling and testing of soils and the residue that may be included with the soil will be the method of characterizing the unit and its potential impact on human health and the environment. Parameters and Rationale The configuration of the OD treatment unit is such that there is a large containment excavation that contains two pits. The pits are used for detonation. If waste residues (ash) are found in these areas they will be tested for RCRA hazardous waste characteristics (ignitability, reactivity, corrosivity and

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metals toxicity). The residue will be subjected to the reactivity tests (Gap Test and Deflagration/Detonation Transition Test) to determine if hazardous quantities of the PEP material remain. The residues will also be tested for explosive residues, method SW 846 8330. These tests will serve as a measure of the effectiveness of thermal treatment for this waste. The RCRA toxicity characteristics test for metals will be conducted on the ash residue found after negative results are obtained from the reactivity tests. The rationale for this is to minimize the potential for laboratory hazards associated with testing an explosive sample. The metals analysis will be performed because several heavy metals are used in PEP formulations. The waste analysis plan flow scheme is shown in Figure J-5. The test procedures described in this section are listed in Table J-3 along with analytical method numbers and sample volume requirements. All methods referenced are from Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, (EPA, 1986) unless otherwise noted. The laboratory performing these analyses is to operate in accordance with the Quality Assurance Project Management Plan (QAPMP) presented below. QUALITY ASSURANCE PROJECT MANAGEMENT PLAN INTRODUCTION The purpose of the Quality Assurance Project Management Plan (QAPMP) is to establish procedures for verifying the quality of work conducted for the Fort Bliss sampling and closure plans. The scope of this QAPMP includes field sampling, analytical testing, equipment maintenance, data reduction and reporting. This QAPMP is consistent with EPA's "Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans," QAMS 005/80, EPA's "Data Quality Objectives Manual for Remedial Response Activities," OSWER Directive 9355.D-7B, and EPA's

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22

"Characterization of Hazardous Waste Sites - A Methods Manual, Volumes I and II - Site Investigations." The Specific Goals of the QAPMP are to: •Verify that acceptable QA methods and protocols are in

place. •Verify that such protocols are actually applied. •Take corrective action, if procedures are found to be "out

of compliance." •Provide a framework for stepwise corrective action to

return procedures to compliance within stated limits. LABORATORY QA/QC OBJECTIVES FOR ANALYTICAL DATA OVERVIEW: Quality Assurance/Quality Control (QA/QC) objectives for the analytical data are a means of checking and controlling the sources of an error in analytical data results. These objectives are generally expressed in the following terms: Accuracy: Accuracy refers to the ability of the system to measure a sample's true value. Accuracy is expressed as a percent recovery equal to the difference between the average of the sample's true values and the average of the laboratory determined values. Because the sample's true value is relative to the sample collection procedures, inferences are drawn from the analysis of field and trip blanks and laboratory matrix-spiked samples. Precision: Precision measures the replicability and repeatability of the

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analytical results. Precision is generally monitored using the results of duplicate and spiked samples. Precision is expressed as the relative percent difference between the percent recovery of two individual sample values. Any variability of known or established precision limits may be a result of improper sampling, handling, or laboratory procedures. Representativeness: Representativeness is the degree to which a data set accurately reproduces the characteristics of the population samples within the subject matrix. Analytical data are considered representative of the sample matrix if results are statistically distributed within the defined limits of the compound's percent recovery and relative percent difference. Completeness: Completeness is a record of the amount of data collected, analyzed, and validated compared to the amount specified in the site specific sampling plan. Completeness is composed of field and laboratory activities. Field completeness is measured by the number of samples collected compared to the number specified in the sampling plan. Laboratory completeness is measured by the number of samples analytically validated compared to the number of samples received in the laboratory. Completeness will be measured by the ratio of validated samples compared to the number of samples planned, expressed as a percentage. Specific QA/QC procedures to be used for sampling, chain-of-custody, calibration, analytical methods, reporting, internal QC, audits, and preventative maintenance are described herein. ANALYTICAL LABORATORY QA OBJECTIVES The selected analytical laboratory's QA program must certify the precision and accuracy of their analytical data, and confirm by documentation all phases of sample handling, data acquisition and transfer, report preparation, and report review. In addition, the QA program will provide for storage and retrieval of samples and data.

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The laboratory's QA program will specify that detailed instructions be available for performing all activities affecting the quality of analytical data. ANALYTICAL PROCEDURES Laboratory procedures and methods to be used contain the following information: •Scope - A description of the scope of applicability of the

procedure. •Principal - A brief description of the steps to be taken and/or

the theory involved in the laboratory analysis. •Interference - A description of known interfering agents which

would cause difficulty in performing the laboratory analysis or would lead to erroneous results.

•Apparatus - A listing or description of equipment required to

perform the laboratory analysis. •Reagents - A listing of the reagents required, a description of

the steps involved in preparing the reagents, and instructions on storage requirements and retention times.

•Procedures (Instructions) - An enumeration of the sequence of

activities to be followed. The topics include sample preparation or pretreatment, sample storage requirements, instrument set-up, standardization or calibration, sample analysis, calculations, and glassware cleaning procedures. The procedure includes any precautions, explanation, or clarifications as needed to properly perform the analysis. These include safety precautions, the frequency of standardization required, the acceptance criteria or procedures for determining the acceptability of stan-dard curves, clarifications or special techniques critical to the analysis, and how the analyst

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determines the reliability of sample results based on the standard curves.

•Quality Control Requirements - A listing of the Quality Control

(QC) checks to be performed and the acceptance criteria used to evaluate the QC data.

•References - A listing of the publications from which the

information was derived in preparing the laboratory method. All references pertain to these documents. As a rule, laboratory methods are derived from the following publications:

-Standard Methods for the Examination of Water and Wastewater,

American Public Health Association. -Annual Book of Standards, American Society for Testing and

Materials. -Methods for Chemical Analysis of Water and Waste,

Environmental Protection Agency. -Test Methods for Evaluating Solid Waste, SW-846, Environmental

Protection Agency. Editions used are those currently specified in 40 CFR, as

updated. SAMPLING PROCEDURES SAMPLE COLLECTION Sample descriptions, including the number of samples and the rationale for sampling have been presented earlier above. Specifics regarding the sampling procedures are presented below. Efforts will be made to collect samples representative of the

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site and avoid contamination of samples during collection. To this end, the following procedures will be followed for all sampling: •Samplers will change gloves between sampling. •Clean, unused sample jars will be used to contain all

samples. •Sample jars will be labelled immediately prior to

collection. Samples will be assembled and catalogued prior to shipping.

•Sample jars will be immediately sealed in individual

ziploc bags, stored in a cooler with sufficient ice to maintain a temperature of 4°C or less.

•Sample points will be located by reference to a surveyed

grid datum, prominent site features, or from some stated reference point.

Access and Location Clearance All sampling activities will conform to 41st EOD operating procedures, which include: 1.Scheduling with Range Control, 2.Obtaining clearance from an EOD specialist at the

location of each sample. For drilling operations this may include frequent down-hole monitoring by EOD personnel.

3.Clearing each sample for shipment to the laboratory by an

EOD specialist, and 4.Checking out with Range Control. Surface Soil Sampling

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Sample locations will be staked and numbered. Samples will be collected by scraping aside loose debris, litter, etc., and collecting soil from the appropriate interval (i.e. 0-6 in. or 6 in.-12 in.). Samples will be obtained using brass or disposable plastic hand trowels, hand augers, or similar equipment. Non-sparking equipment will be used whenever indicated by EOD personnel. Reusable equipment will be decontaminated between sample locations. Samples for laboratory analyses will be placed in coolers with ice. Cuttings generated from each surface soil sampling location will be used to backfill the sample hole. Procedure for Completion of Boring and Subsurface Soil Sampling A single soil boring will be installed in the unit. Experience indicates that hollow stem auger techniques will not work in this geology; therefore, air or mud rotary techniques will be used. Samples will be collected using either thin-walled, split spoon samplers, or rock core barrels, as appropriate based on the soils encountered. The borings will be visually logged and measured using a photoionization detector (PID) for total organic vapors. (Flame ionization detectors will only be used if specifically approved by an EOD specialist.) For each sample, a core section, of not more than 6 inches in length will be placed in clean sample jars. The sample portion for laboratory analyses will be placed in a cooler with ice. Cuttings and drill mud will be retained pending results of soil analyses. The boring will not be converted to a monitoring well and, therefore, will be grouted from the bottom up with a cement/bentonite mixture. The mixture will consist of one 94 pound bag of cement to 5 pounds sodium-montmorillonite bentonite (granular or powdered) to approximately 7 to 8 gallons of water. QUALITY ASSURANCE/QUALITY CONTROL SAMPLING QA/QC Sample Definitions Quality Assurance/Quality Control (QA/QC) samples will be collected or prepared during the sampling. All QA/QC requirements will be met as per EPA SW-846. QA/QC samples may

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be of the following types: 1. Blanks a. Equipment or rinse blanks b. Trip blanks 2. Duplicates Equipment or rinse blanks: Equipment or rinse blanks will consist of distilled water poured over decontaminated equipment used in collecting samples. Equipment blanks are intended to identify sources of contamination from incomplete decontamination of equipment or from the decontamination solutions or procedures. Trip blanks: Trip blanks will consist of deionized water poured into vials in the laboratory, shipped to the field and handled with the shipping containers. Trip blanks are intended to identify sources of contamination from the sample jars or sample handling in the field and laboratory. It may also identify possible cross-contamination of samples during shipping. If water samples are not taken trip blanks will not be used. Duplicates: Duplicates will be collected from all the soil sample locations. These samples will be taken at the same soil sampling location and split from the sample using standard sample splitting techniques. These samples are intended to verify the contaminant concentration at the sampling points. QA/QC Sampling Procedures Reasonable effort will be made to collect samples representative of the site and to avoid contamination of samples during collection. To this end, the following procedures will be followed:

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•Samples will be collected with decontaminated equipment. •Samplers will change gloves between sampling locations. •Clean, unused sample jars will be used to contain all samples. •Sample jars will be labelled immediately after collection to

avoid confusion. •Samples will be assembled and catalogued prior to shipping. EQUIPMENT DECONTAMINATION PROCEDURES Sampling equipment will be decontaminated before use. Any equipment coming into direct contact with sample media will be decontaminated. The following decontamination procedure will be used for reusable sampling equipment: 1.Wash in phosphate free detergent (e.g., in Liquinox®)/potable

or distilled water solution to remove dirt. 2. Rinse with potable or distilled water. 3.Rinse with ethanol or isopropyl alcohol, 4. Rinse with distilled water. SAMPLE AMOUNT, PRESERVATION, CONTAINER, AND HOLD TIMES Samples will be kept on ice in coolers while at the site. The samples will be preserved (if necessary) and shipped by overnight courier to the designated laboratory. Samples will be

kept refrigerated at 4oC at the laboratory until analyzed. Samples subject to laboratory analyses will be prepared, containerized, and preserved according to the guidelines shown in Table J-5. DOCUMENTATION

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After collection and identification, samples will be maintained under chain-of-custody procedures. FIELD DOCUMENTATION All field activities will be recorded in a bound notebook with sequentially numbered pages. Entries will be made in blue or black ink, in chronological order. Errors to field documentation are to be deleted by marking through the incorrect entry with a single, horizontal line. The deletion will be initialled and dated by the person making the change. The minimum information to be included on each page of field notes will include: •Date of the field activities. •Time of each entry, in military time. •Name of scribe. •Identification of the project or field activities being

chronicled. •Scribe's signature at the end of each day's activities or when

scribe's duties change to another person. •Blanks at the end of lines and at the bottom of a page will be

marked through with a single line. All entries must be complete and legible. Entries will include the full names and affiliations of persons referenced. No entries will be made in the log book margins or between written lines. SAMPLE ACQUISITION, IDENTIFICATION, AND DOCUMENTATION Samples will be identified according to the following approach: DATE - LOCATION NUMBER For example, a sample collected from a surface soil sample

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location on 3 June 1995 would be labeled: 950603SS07 The following field custody procedures will be adhered to: •When collecting samples, as few people as possible should

handle the samples. •The field sampler is personally responsible for the care and

custody of the samples until they are transferred or properly dispatched to the laboratory.

•Sample tags or labels will be completed for each sample using

waterproof ink, or covered by transparent waterproof tape.

Information included on the sample tags or labels will be: •Sample Identification Number, •Date and Time, •Type of Laboratory Analysis Required, •Preservation Required, •Collector's Initials, and •Other Remarks. In addition to the above, a chain-of-custody record as shown in Figure J-6, will be completed each time a group of samples is prepared for shipment to the laboratory. The record will repeat the information on each of the sample labels, and will serve as documentation of handling during shipment. A copy of this record will remain with the shipped samples at all times, and another copy will be retained by the member of the sampling team who originally relinquished the samples. Samples relinquished to the laboratory will be subject to the following procedures for transfer of custody and shipment: •Samples will be accompanied by the chain-of-custody record.

When transferring the possession of samples, the individuals relinquishing and receiving will sign, date, and

note the time on the record. This record documents

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transfer of sample custody from the sampler to another person or to the laboratory.

•Samples will be properly packed for shipment and dispatched to

the appropriate laboratory for analysis, with a separate signed custody record enclosed in each sample box or cooler. Shipping containers will be custody-sealed for shipment to the laboratory.

•Whenever samples are split with a facility or government

agency, a separate chain-of-custody record will be prepared for those samples and marked to indicate with whom the samples are being split.

•All packages will be accompanied by the chain-of-custody record

showing identification of the contents. The original record will accompany the shipment, and a copy will be retained by the sampler.

•If sent by common carrier, a bill of lading will be used. LABORATORY OPERATIONS The analytical laboratory assumes the responsibility for the integrity and security of the samples after proper custody transfer is completed. The laboratory will implement the following steps to maintain integrity of samples:

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TABLE J-5 SAMPLE AMOUNT, CONTAINER, PRESERVATION, AND MAXIMUM ALLOWABLE SAMPLE HOLDING TIMES FORT BLISS

PARAMETER

MATRIX

MINIMUM REQUIRED AMOUNT

NO. OF CONTAINERS

CONTAINER

PRESERVATION1

MAXIMUM ALLOWABLE HOLDING TIME2

Metals

Total Soil 500 g 1 500 ml Amber, wide-mouth Glass Teflon lined cap

Cool, 4oC 6 months

Organics

Volatile Organic Compounds Soil 200 g 1 120 ml (4 oz.) Glass, wide-mouth Jar Teflon lined cap

Cool, 4oC 14 days

Semivolatile Organic Compounds

Soil 500 g 1 250 ml (8 oz.) Amber, wide-mouth Glass Bottle Teflon lined cap

Cool, 4oC 14 days extraction 40 days analysis after extraction

1Sample preservation should be performed shortly after sample collection. 2The periods listed are the maximum times that samples may be held before analysis and still be

considered valid.

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•Log-in personnel will receive the samples and provide a sample

tracking number for each sample received. Then they will log samples into a hard bound sample log book or other appropriate document by recording the appropriate information.

•An internal chain-of-custody for samples will be maintained by

the laboratory on the custody record. Internal chain-of-custody for sample extracts and digestates should be maintained in the laboratory. All samples and extracts should be signed for by the person retaining custody of these items. On completion of all analyses, these custody sheets will be placed in the file.

•All samples will be held until the results have been reported

and accepted by the client. •When samples are transferred from the lab to any other

destination, chain-of-custody protocols will be followed.

•The laboratory will maintain documentation procedures for the

preparation of reagents and supplies which become an integral part of the sample.

FIELD AND LABORATORY CALIBRATION PROCEDURES AND FREQUENCY FIELD EQUIPMENT CALIBRATION PIDs (and flame ionization detectors, FIDs, if EOD approved) will be calibrated in accordance with manufacturer's directions. Various calibration standards may be used to calibrate these instruments, depending on the site and constituents of concern. Any additional equipment or instrumentation utilized in the field will be calibrated at least daily. Calibrations will be

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performed in accordance with the manufacturer's instructions. Calibration of field equipment will be documented in the field logbook and maintained in the project files.

LABORATORY EQUIPMENT CALIBRATION

Laboratory equipment calibration will be in accordance with the most currently accepted versions of the following: Statement of Work for Organic Analysis, Multi-Media Multi-

Concentration. Office of Solid Waste and Emergency Response. U.S. Environmental Protection Agency. Washington, D.C.

Statement of Work for Inorganic Analysis, Multi-Media Multi-

Concentration. Office of Solid Waste and Emergency Response. U.S. Environmental Protection Agency. Washington, D.C.

SUPPLEMENTAL LABORATORY PROCEDURES Reference Materials Whenever possible, primary reference materials will be obtained from the National Bureau of Standards (NBS) or the U.S. Environ-mental Protection Agency (EPA). In the absence of available reference materials from these organizations, other reliable sources will be sought. These reference materials will be used for instrument calibration, quality control spikes, and/or performance evaluations. Secondary reference materials may be used for these functions provided that they are traceable to an NBS standard or have been compared to an NBS standard within the laboratory.

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Reagents Laboratory reagents will be of a quality to minimize or eliminate background concentrations of the analyte to be measured. Reagents must not contain other contaminants that will interfere with the analyte of concern. Corrective Action An analysis or analytical system is considered to be out-of-control when it does not conform to the conditions specified by the method or standard operating procedures which apply. To confirm that an analysis or analytical system is in-control, the laboratory routinely performs instrument calibration checks, analysis of method blanks and method blank spikes, and compares the results of quality control samples to laboratory control charts or analytical protocol criteria. When an analysis or analytical system is determined to be out-of-control, the person who identifies that there is a problem is responsible for documenting the occurrence and notifying their Analyst and/or Laboratory Manager. The analyst, working with their supervisor or Laboratory Manager, will attempt to determine the cause of the problem and take appropriate corrective action. Analysis may not resume until the problem has been corrected and it is determined that the analysis is back in control. Demonstration of the restoration of analytical control will normally be accomplished by generating satisfactory calibration and/or quality control sample data. This documentation will be maintained in the project files at the laboratory. Data generated concurrently with an out-of-control system will be evaluated for usability in light of the nature of the deficiency. If the deficiency does not impair the usability of the results (e.g., blank contaminated but all samples not detected), data will be reported and the deficiency noted in the case narrative. Where sample results are impaired, the appropriate corrective action is taken. This action may include repreparation and reanalysis of the affected samples.

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ANALYTICAL METHODS AND DATA COLLECTION Analytical methods will be performed in accordance with those listed earlier in this Attachment, Table J-3. DATA COLLECTION In addition to the data collected in the field and recorded on the chain-of-custody forms, data describing the processing of samples will be accumulated in the laboratory and recorded in laboratory notebooks. Laboratory notebooks will contain: •Date of processing, •Sample numbers, •Client (optional), •Analyses or operation performed, •Calibration data, •Quality control samples included, •Concentrations/dilutions required, •Instrument readings, •Special observations (optional), and •Analyst's signature. DATA REDUCTION Data reduction will be performed by the individual analyst and will consist of calculating concentrations in samples from the raw data obtained from the measuring instruments. The complexity of the data reduction will be dependent on the specific analytical method and the number of discrete operations (extractions, dilutions, and concentrations) involved in obtaining a sample that can be measured. For those methods utilizing a calibration curve, sample responses will be applied to the linear regression line to obtain an initial raw result which is then factored into equations to obtain the estimate of the concentration in the original sample. Rounding will not be performed until after the final result is obtained to minimize rounding errors, and

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results will not normally be expressed in more than two (2) significant figures. Copies of all raw data and the calculations used to generate the final results will be retained on file to allow reconstruction of the data reduction process at a later date, if required. DATA REVIEW AND VALIDATION System reviews will be performed at all levels. The individual analyst will review the quality of data through calibration checks, quality control sample results, and performance evaluation samples. These reviews will be performed prior to submission to the Analytical Project Manager. The Analytical Project Manager will review data for consistency and reasonableness with other generated data and determine if program requirements have been satisfied. Selected hard copy output of data (chromatograms, spectra, etc.) will be reviewed to ensure that results are interpreted correctly. Unusual or unexpected results will be reviewed, and a decision will be made as to whether the analysis should be repeated. In addition, the Analytical Project Manager will recalculate selected results to

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TABLE J-3 SOIL SAMPLE ANALYSES EXPLOSIVES ORDNANCE DEMOLITION AREA FORT BLISS, MCGREGOR RANGE OTERO COUNTY, NEW MEXICO

ANALYTE ANALYTICAL METHOD1

SAMPLE VOLUME (g)

METALS:

Arsenic SW846 7060 100-500

Barium SW846 6010 100-500

Beryllium SW846 6010 100-500

Cadmium SW846 6010 100-500

Chromium SW846 6010 100-500

Lead SW846 6010 100-500

Mercury SW846 7471 100-500

Selenium SW846 7740 100-500

Silver SW846 6010 100-500

ORGANICS:

Picric Acid SW846 8270 100-500

HMX SW846 8330 100-500

RDX SW846 8330 100-500

2,4,6-Trini-trotoluene

SW846 8330 100-500

2,4-Dinitrotoluene

SW846 8330 100-500

2,6-Dinitrotoluene

SW846 8330 100-500

Nitroglycerine SW846 8332 100-500

INORGANICS:


EPA 353.3 10

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1SW846 = "Test Methods for Evaluating Solid Waste - Physical/Chemical Methods," Environmental Protection Agency, SW846.

EPA = "Methods for Chemical Analyses of Water and Wastes,"

Environmental Protection Agency, 1979, Revised 1983.

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verify the calculation procedure. The final routine review will be performed by the Laboratory Manager prior to reporting the results to the client. DATA REPORTING Reporting will contain final results (uncorrected for blanks and recoveries), methods of analysis, levels of detection, surrogate recovery data, and method blanks data. In addition, special analytical problems, and/or any modifications to referenced methods will be noted. The number of significant figures re-ported will be consistent with the limits of uncertainty inherent in the analytical method. Consequently, most analytical results will be reported to no more than two (2) significant figures. Data will be reported in units commonly used for the analyses performed. Concentrations in liquids are expressed in terms of weight per unit volume (e.g., milligrams per liter). Concentrations in solid or semi-solid matrices are expressed in terms of weight per unit weight of sample (e.g., micrograms per kilogram). Reported detection limits will be the concentration in the original matrix corresponding to the low level instrument cali-bration standard after concentration, dilution, and/or extraction factors are accounted for. DATA ARCHIVING The laboratory will maintain on file all of the raw data, laboratory notebooks, and other documentation pertinent to the work on a given project. This file will be maintained for five (5) years from the date of invoice unless a written request is received for an extended retention time. Client confidentiality will be maintained for any retrieved data. Consequently, the laboratory will honor only those requests for data authorized by the original client. LABORATORY QUALITY CONTROL CHECKS The following analyses will be completed in the laboratory as measures of accuracy and precision of the analytical process.

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•Laboratory Duplicates - Laboratory duplicate samples will be analyzed to monitor for intralaboratory precision of data generated. These samples will be analyzed on no less than a 5% basis with at least one replicate if fewer than ten samples are analyzed for any particular parameter.

•Spiked Samples - will be analyzed to monitor for accuracy of

data due to interferences which may be present in the sample and thus influence the reported results. These spiked samples will be tested on no less than a 5% basis for any particular parameter. At least one spiked sample will be run if fewer than ten samples are analyzed.

•Control Charts - will be utilized to effectively monitor and

periodically review the accuracy of the data generated as a result of spike analyses. These charts also aid in observing trends in data so as to take corrective actions before data generated are out of control.

•Methods Blanks - Are accomplished by treating purified water or

ultra-cleaned sand in the same manner as samples to monitor potential contamination of samples due to contamination in solvents, reagents, glassware or laboratory equipment. Method blanks are included with each set of samples.

•Laboratory Equipment Blanks - will be analyzed to monitor

potential contamination of samples due to improper or ineffective cleaning of equipment.

•Quality Control Samples - will be analyzed to monitor for

accuracy of data generated. EPA check samples or samples purchased from a reputable independent source will be analyzed at the beginning of the project and also at regular intervals during the project.

•Surrogate Samples - will be analyzed in accordance with EPA

guidelines for GC/MS analysis. Deuterated standards will be utilized as a measure of the recovery of the target compounds (that may be similar to the compounds in the standards) during analyses.

•Reagent Checks - Are accomplished by treating known laboratory

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blanks in the same manner as samples and reviewing data to verify that contamination has not been introduced as a result of reagents.

•Internal Standards - Are prepared in the laboratory and are

referenced against known external standards to measure accuracy.

•Calibration Standards and Devices - will be utilized according

to the type and method of analysis. The laboratory should be certified by the U.S. Army Corps of Engineers, Missouri River Division. Laboratory duplicates for QA/QC will be at least 10%. PERFORMANCE SYSTEM AUDIT EXTERNAL AUDITS The results of audits performed by regulating agencies will be reviewed for the analytical laboratory selected to analyze samples from Fort Bliss. Documentation of satisfactory performance on such audits will be required prior to submitting samples for analysis. INTERNAL AUDITS The laboratory QA Coordinator will be responsible for monitoring the internal Quality Assurance/Quality Control program. The QA Coordinator, with assistance from support staff, will provide in-house audits, reviews and validate analytical data packages. The QA Coordinator will also be responsible for scheduling and coordinating external systems audits and reviewing data for performance samples received. The QA Coordinator will supply blind performance samples to the laboratory semi-annually. Also, the QA Coordinator will audit laboratory systems and procedures at least once annually. Unique client audit procedures and data requirements will be complied with as contractually specified. The internal audit will consist of a review of laboratory systems, procedures and documentation. Any deficiencies/deviations will be documented and a summary report prepared.

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LABORATORY PREVENTIVE MAINTENANCE LABORATORY MAINTENANCE The analytical laboratory will have in place a procedure which details the steps to be taken to calibrate and standardize instruments to ensure that analytical data produced are accurate. Records of all calibrations, preventative maintenance, and service calls will be readily available from the laboratory files. A procurement procedure which identifies the methods to be used to document and control the purchase of materials, parts, and services will be implemented by the laboratory. The procedure will include provisions for identifying the quality of laboratory chemicals and equipment, evidence of management approval of procedure items, inspection of shipments for compliance to requirements, and isolation of nonconforming items to be returned to vendors. This procurement procedure will serve to ensure the availability of any spare parts routinely required. The quality of all equipment must conform to the requirements specified in the latest edition of the EPA "Handbook of Analytical Quality Control in Water and Wastewater Laboratories," the Federal Register, or other regulatory agency publications. FIELD MAINTENANCE Field instruments, sampling equipment and machinery will be maintained in accordance with manufacturer's recommendations and normal field practice. All maintenance will be documented in permanent records by the individual responsible for each item. This will include routine, scheduled maintenance and unscheduled maintenance. PROCEDURES USED TO ASSESS DATA ACCURACY AND PRECISION The reliability and credibility of analytical laboratory results are established by the inclusion, as an integral part of any analytical procedure, of a program of randomly selected

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replicate analyses and analysis of standards or spiked samples. Precision of analytical results may be established as the stan-dard deviation from true values or from the mean of replicate analyses. Accuracy is reported as the percent recovery of a parameter from a sample of known value with a given analytical procedure. The procedure described herein is designed to give precise and accurate data for each analytical method. To ensure that reli-able data continue to be produced, systematic checks must show that test results remain reproducible and that the methodology is actually measuring the quantity in each sample. The following procedures will be used to evaluate data accuracy and precision for analyses by the laboratory. ACCURACY Acceptability of data as being accurate is based on intralaboratory limit of 95 percent recovery of spiked compounds. Accuracy calculation from spike recoveries is by:

S = Accuracy AT = Total amount found in spiked sample AO = Total amount found in unspiked sample AF = Amount of spike added to sample PRECISION Precision data are generated by the analysis of duplicate samples. Should the difference of the value of two duplicate samples exceed the method specified value, then the precision is judged to be out of control and the analyst will be responsible for confirming the source of the precision error. Once confirmed and remedied, the analysis will be rerun, and providing acceptable precision limits, the data will then be reported.

S=AT-AOAF

×100%

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•Relative percent difference (RPD) from pairs of duplicate measurements is calculated by:

where d1 - d2 is the difference in concentrations of the two

measurements. Relative percent difference can be calculated using duplicate

analyses when an analyte is detected above the reporting limits. RPD can also be calculated from the percent recoveries of the matrix spike (MS) and matrix spike duplicate (MSD). RPD's are set by the EPA's Contract Laboratory Program (CLP) protocols for target compounds.

•Standard deviation(s) from many measurements on one sample is

calculated by:

where x1 = the values of individual measurements x = the mean of

all the measurements; and N = the number of measurements.

The precision for organics is normally about +40%. If the precision is not on target, the sample may not be homogeneous (frequently true of soils). The precision of duplicates, MS/MSDs, and MS/MSD surrogate recoveries will be compared to determine the cause of the precision problem and to determine if the data is valid.

RPD = d1 - d2

½ (d1 + d2)

S = ∑ (x1 - x)

2

N - 1

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SURROGATE RECOVERIES Each organic sample will be spiked with surrogates, or deuterated compounds. Standards for surrogate recoveries are set by CLP. The QA/QC plan does not specify that these recoveries will be met. However, the recoveries will be used as another benchmark to evaluate the validity of the data. COMPLETENESS Completeness is a measure of the relative number of data points which are valid. It is usually a comparison of actual number of valid data points and expected number of valid data points, expressed as a percentage. Difficulties encountered during sample handling in the laboratory as well as unforeseen complications regarding analytical methods may affect completeness during sample analysis. For example, the analytical methods proposed for use (particularly for the organics analyses) are intended for analysis of "environmental samples" (low- and medium-level), and the applicability of these methods to unknown or high-level samples may result in poor method performance and have, therefore, an adverse impact on achieving the data completeness goal.

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PERMIT ATTACHMENT K Page 1 of 8

PERMIT ATTACHMENT K CLIMATIC CHARACTERISTICS OF THE OD TREATMENT UNIT AND PROCEDURES FOR PROTECTION OF ENVIRONMENTAL MEDIA: INTRODUCTION: A detailed description of the OD Site Characteristics has been presented in Permit Attachment J, Standard Operating Procedures, hence will not be reproduced here. AIR QUALITY ASSESSMENTS: Potential for Emission There is minimal potential for the release of any gases, aerosols, or particulates into the air that would adversely affect human health or the environment. There is at least a five mile (8 km) radius surrounding the OD treatment unit that is barren, undeveloped, and uninhabited. The primary concern is the impact of the waste constituents in soil around the treatment area. However, since minimal potential exists for particulates in soil to be released into the air, perimeter soil samples will be collected surrounding the area of operation, as described in Permit Attachment J (Sampling and Analysis Plan). If contaminant concentration levels above background are reported for soil samples, a risk assessment as described in Module III, Section E., page 3, will be completed air and ground water monitoring will be conducted. Air modeling will not be performed prior to the commencement of the proposed OD operations as demonstrated in Permit Attachment M. Justification for not doing Air Monitoring: The destruction of the explosive and propellant devices is nearly 100% because they are designed to explode or burn. Unlike other installations that treat explosive contaminated materials, for example, this unit treats only explosive and propellent products. Also, there are no receptors near the OD unit and it is in a secure, impact area. The nearest public

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highway is 10 miles (18 km) to the west. Davis Dome is the closest military occupation and it is 4 miles (6 km) to the west. The prevailing winds are north-south and potential receptors in these directions are even more distant. Effectiveness of Control Current control systems are conducted of OD operations within designated areas and the OD pits within the excavated treatment unit, and OD operations are conducted only during favorable wind conditions as described below. OD treatment efficiency is sufficient that these control systems should protect human health and the environment. To prove this the waste analysis plan described in Permit Attachments A and J, will be implemented to establish soil quality and the potential spread of contamination. Operational Conditions No treatment operation will be conducted during an electrical storm or when such a storm is approaching within 10 miles (16 km) of the OD unit. Additionally, disposal by detonation using an electrical firing system will not be conducted during sand, dust, or snow storms. It is recognized that weather factors are interdependent. Therefore, in order to evaluate the weather conditions for disposal operations, the weather factors must be considered collectively. The following will be observed: 1)Wind speed will not be less than 3 miles per hour and will not

exceed 15 miles per hour (5 km , and 24 km per hour respectively).

2)Cloud cover will not be greater than 50%. 3)Demilitarization operations should occur only during lapse

temperature gradient conditions. The temperature gradient is the difference obtained by subtracting the air temperature 1.6 ft (0.5 m) above ground from the air temperature 13.1 ft (4 m) above the ground. Estimation

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of temperature gradient is as follows: •Strong lapse conditions (temperature gradient -2° to -

3°F (-18.9° to -19.4°C)) will occur near midday when the sky is clear of clouds, the sun is bright, and the wind speed is low.

•Weak lapse conditions (temperature gradient 0° to -1°F

(-17.8° to -18.3°C)) will occur during midmorning and midafternoon provided that the sky is clear, the sun is bright, and the wind speed is low. They will also occur on partly cloudy days and when the wind speed is moderate.

•Neutral conditions (temperature gradient 0°F (-

17.8°C)) generally will occur at sunrise and sunset on clear days and will exist throughout the day whenever the sky is overcast or any time there are strong winds.

•Inversion conditions (temperature gradient 0°F to +3°F

(-17.8° to -16.1°C)) generally will occur throughout the night when the sky is clear and the wind speed is low.

Existing Air Quality/Other Sources/Receptors The current air quality in the vicinity of the Fort Bliss EOD is varied. The City of El Paso County, to the south is an air quality non-attainment area for ozone and is rated as serious. Additionally, an area in the City of El Paso is also a non-attainment area for particulate matter (PM-10) and carbon monoxide. This area is bounded on the north by Interstate Highway 10, on the south by the Rio Grande River, on the east by Avenue of the Americas, and on the west by Executive Center. PM-10 is rated as Class I non-attainment and the carbon monoxide level is rated as moderate. The air quality in Otero County, New Mexico where the site is located, is in compliance with air quality standards. There are no areas of non-attainment in Otero County and no major air emission sources. Operations at the OD treatment unit are not expected to

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adversely impact the air quality of Otero County, nor to contribute to the non-attainment areas in El Paso County. OD treatment is very efficient and, particularly at this remote site, are not expected to degrade air quality so as to impact the environment or human health. The potential public receptors in the area are far removed (at least 5 mi (8 km)) from the site. The 41st EOD team members who will conduct the treatment operations will be at the required distances for the EOD team. These distances are specified in Permit Attachment J. Vehicle traffic due to OD operations has negligible impact on air quality. Diesel truck traffic is estimated at less than 30 hauls per calendar quarter. Conclusion: In conclusion, OD operations are very efficient due to the reactive nature of the PEP materials, and there are no receptors in close proximity to the site. Current air quality is excellent and OD operations will not significantly impact it. POTENTIAL EXPOSURE PATHWAYS The public is denied access to the OD treatment unit by a number of mechanisms (e.g., Range Control, location in a firing range impact area, remoteness from human habitation). Access is only provided to 41st EOD personnel during OD operations. No one is allowed at the treatment unit during Range Operations, including target practice. Time Before Detonation PEP materials are not stored at the OD treatment unit. As described in Permit Attachment I (SOP), they are transported by truck through McGregor Camp to the floor of the treatment unit. Subsequently, the PEP materials are expeditiously placed in the appropriate treatment area (pit), initiation materials are applied, and after retreat to a specified safe distance, the ignition is accomplished. The precise times between PEP arrival and placement, initiator placement and ignition, vary. However, because no waste is stored at the unit all activities will occur between 7:00 am and 5:00 pm of the same day.

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Time After Detonation After the OD operation, EOD personnel will return to the treatment unit within 24 hours to inspect for UXO and kick-out, when it has been determined that it is safe to do so. This drive time and the required wind speed (greater than 3 knots (5.6 km per hr)) is considered sufficient by EOD procedures to protect the EOD specialists from any gases, vapors, or airborne particulates resulting from the OD operations. Management of Residues The treatment unit currently has no visual indication of ash or other chemical residue. There are a few metal fragments identifiable within the unit, and the impact area of the Range in general has remnants of Range operations (e.g., BATs, large caliber slugs). The above mentioned few metal fragments and remnants of Range operations will be collected after every treatment activity, placed into appropriate containers, and handled as RCRA hazardous waste. PROTECTION OF GROUNDWATER The subject McGregor range OD treatment unit is located just west of the Hueco Mountains on the Tularosa Basin. The basin-fill deposits consist predominantly of playa, lacustrine, and alluvial-fan sediments. The water table is at approximately 600 feet. The water encountered in this area is not potable. The water is highly mineralized with up to 9000 ppm total dissolved solids. The nearest well with drinking water quality is approximately 19 miles (30 km) away, in Dona Ana County. This well is pumping water from the Hueco Bolson. The Hueco Bolson and the Tularosa Basin are not hydraulically connected. The remaining residues contain no free liquids. This coupled with climatological and hydrologic conditions in the area, greatly reduces the wastes ability to migrate to the groundwater. The average annual precipitation in the area is 9 inches. The annual pan evaporation is 80 inches. Furthermore, minimum amounts of ash are generated following a detonation. The vast majority of the surface residues remaining after a detonation consist of metallic fragments and occasional

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pieces of PEP which were not thermally treated during the explosion. Therefore, if any subsurface contamination were to occur resulting from an OD event, the source of the contamination would be the metallic shard. Metallic fragments are removed after each detonation, thus reducing the potential for contamination from this source.

HYDROLOGY The hydrogeology of the Fort Bliss area including the OD treatment unit has been studied for other purposes (e.g., potential drinking water, geothermal energy, Taylor, 1981) and the following are reported: 1.The Hueco Bolson produces drinking water from the west side of

the Bolson, but not from this area on the east side. 2.Groundwater at the site is about 600 ft (183 m) from ground

surface. 3.The 600 ft (183 m) water is not potable due to Total Dissolved

Solids concentration of about 9,000 ppm. 4.There is potentially perched water in the area, but apparently

not at the treatment unit. 5.Evaporation limits, and may preclude, recharge from the

treatment unit area. Because the treatment unit is designed for containment and there is no runoff from the excavation, the potential migration pathway to groundwater is through the soil at the base of the OD unit. Groundwater at the treatment unit is expected to be 600 ft (182.9 m) deep and EOD operations cause seismic disturbance which preclude installation of monitoring wells. Therefore, the need for more aggressive groundwater protection will be assessed based on soil monitoring described in Permit Attachment J., and below. Soil Monitoring Two soil sampling programs are proposed as follows: •Characterization Sampling - to determine the results of past OD

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operations. •Closure Sampling - to determine the necessary closure

operations, and provide a record of "clean" or "waste-in-place" closure.

Sample Collection, Shipment, Etc. As described in Permit Attachment J, which includes the QA/QC Management Program, representative soil samples will be taken from within the two OD pits, the floor of the OD treatment unit, and outside the treatment unit (around the rim). Also, to monitor downward migration, a 50 ft (15.2 m) boring will be made in the treatment unit and samples taken at 5 ft (1.5 m) intervals. As described in Permit Attachment J, which includes the QA/QC Management Program, representative soil samples will be taken from within the two OD pits, the floor of the treatment unit, and outside the treatment unit (around the rim). These samples shall NOT be composited at any time Analytical Parameters and Methods Soil samples will be analyzed for the parameters discussed in Permit Attachment J, Table J-3. Background Values As described in Permit Attachment J, three background soil samples will be taken near the treatment unit in the Range impact area. Care will be taken to not sample near observed debris. Even so, Range operations may make establishment of background values difficult. Literature values are available for metals and these will be consulted if analytical results of background samples are inconclusive. Statistical Comparison Soil samples are non-homogenous and analytical values of potential constituents can vary greatly. Therefore, conventional statistical tests tend to fail with soil samples. This problem is compounded when naturally occurring constituents are involved (e.g., metals), and when other sources are possible


(e.g., BAT remains from target practice). Therefore, statistical comparisons will not be used. Instead direct comparison to the arithmetic mean will be used. A sample will not be considered contaminated unless the analytical value for any site-related constituent is at least three times the arithmetic mean of the background. For naturally occurring constituents, the background levels may range from below detection limit to several orders of magnitude higher than the detection limit. Naturally occurring constituents will be evaluated on an individual basis either in comparison with published background ranges, by comparison with risk-based levels, or statistically as the data permit. PROTECTION OF THREATENED OR ENDANGERED SPECIES Mr. Rafael Corral, botanist/dendrologist, Fort Bliss Directorate of Environment reports that the OD treatment unit and its surroundings are barren and do not provide good habitat for endangered species. There are no known endangered species on McGregor Range, where the OD treatment unit is located. The only known potential threatened species is the Dessert Night Blooming Cereus (considered a sensitive plant species). This plant is on the candidate list for threatened species, however, it primarily exists far west of the OD treatment unit area in the Oregon Mountains. Therefore this OD treatment unit does not impact threatened or endangered species.

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PERMIT ATTACHMENT L Page 1 of 2

PERMIT ATTACHMENT L RECORDKEEPING Operating Record: The U.S. Army Air Defense Artillery Center and Fort Bliss will keep a written open detonation operating record of OD activities at the Davis Dome facility at the McGregor Range. The following records will be maintained by the facility for the OD treatment unit: A description and the quantity of each hazardous waste received

listed in Tables A-2 through A-6, Permit Attachment A enclosed herein;

Operating log that describes the type and quantity of hazardous

waste treated in the OD treatment unit and the date the waste was detonated;

Records and results of waste analyses performed as specified in

HWMR-7, §264; Reports of any incidents that required the activation of the

contingency plan; Inspection logs for the last three years; Records of monitoring, testing, analytical data, and any

corrective actions taken to prevent or mitigate releases of hazardous waste to the environment;

Training records for EOD personnel; Disposal requests and Land Disposal Restriction Certifications

for hazardous waste transported to a permitted facility;

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PERMIT ATTACHMENT L Page 2 of 2

Correspondence and other documents from governmental agencies that affect the OD treatment unit.

Additional Reports: In compliance with HWMR-7, Pt. V, §264.56(j), and HWMR-7, Pt. VI, §265.56(j), any release, fire, explosion, or other unusual occurrence that results in implementation of the contingency plan will be noted in the OD treatment unit operating record and reported in writing within 15 days to the Secretary of the NMED. Biennial Report: In accordance with HWMR-7, Pt. V, §264.75, a biennial report on OD treatment activities will be prepared and submitted to the Secretary of the NMED. The report will be prepared and submitted to cover facility activities at the OD treatment unit during the previous calendar year. The EPA identification number, name, and address of the facility will be included in the report. A description and the quantity of each RCRA-regulated explosive hazardous wastes treated at the OD unit will be listed. The method of treatment and disposal for each RCRA-regulated explosive hazardous waste will be described.

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PERMIT ATTACHMENT M Page 1 of 5

PERMIT ATTACHMENT M AIR MODELING Introduction The New Mexico Environment Hazardous and Radioactive Materials Bureau (HRMB) strongly recommended that the US Army Fort Bliss should conduct air modeling prior to commencement of OD operations at the subject treatment unit. Fort Bliss conducted theoretical modeling of the air at the OD unit using the POLU10 model for the determination of soil contamination or the extent of particulate dispersion pattern. Calculations based upon this amount indicate that the amount of emissions shown in Tables M-1 and M-2 will be many orders below New Mexico and Federal regulatory standards. Fort Bliss used the above findings to demonstrate that air modeling is unnecessary for the OD treatment unit. NMED accepted the demonstration which is presented in this attachment as follows: PROCEDURES Fort Bliss plans to demolish 624 kilograms of waste munitions per calendar year. The detonation of PEP materials has been shown to be a very effective process for disposal of these materials. The Army Materials Command Handbook "Principles of Explosive Behavior" provides some information on the destructive efficiencies of open detonation for some of the explosives that will be handled at the OD treatment unit. These data are provided in Tables M-1 and M-2. Data on the open detonation efficiency of most military explosives are either not available in published literature, or are classified. Fort Bliss therefore cannot provide specific information on the generation of contaminants for all propellants, explosives, and pyrotechnics (PEP) agents detonated at the OD treatment unit. There are data available for the open detonation efficiencies

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for three of the more common PEP agents: pentolite (PETN), homecyclonite or cyclotetramamethylene tetranitramine (HMX), and trinitrotoluene (TNT). These were assumed to be representative of the detonation efficiencies of PEP agents during open detonation. INTERPRETATION Table M-1 shows the open detonation efficiencies of PETN, HMX, and TNT. Examination of the combustion products identified in Table M-1 shows the extremely small mass of product generated for each pound of original explosive material. For example, open detonation of one pound of PETN will generate only 0.0001 pound of ammonia. Table M-1 also clearly shows that, of the three PEP agents listed, TNT is the explosive that has the lowest destruction efficiency, and therefore generates the most combustion products. TNT would therefore represent a "worst case" scenario in terms of the mass of contaminants produced per pound of original explosive. This conservative scenario will be used to develop estimates of the contaminants developed as a result of the OD activities. The most detailed information currently available on emissions factors from explosives detonation were developed by the U.S. Army with assistance from the EPA. These emission factors were developed for TNT. The emission factors per pound of explosive are provided in Table M-2, Column 2. Ft. Bliss currently disposes of approximately 1,300 pounds of waste PEP agents per year, or approximately 325 pounds per quarter using the open detonation method. Using the emission factors for TNT and assuming the "worst case" scenario that all explosives are TNT, an emission rate of contaminants in pounds per year can be generated. It is obvious from Column 3 of Table M-2 that the mass of contaminants are extremely small even if it were assumed that all 1300 pounds of explosives were detonated at the same time, rather than

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quarterly. The Effect Screening Level (ESL), column 3, is based on toxicological data and is a concentration used by the Texas Natural Resource Conservation Commission to evaluate ambient impacts from emission sources. The ESL can be used in combination with the emission rate to calculate a relative measure of emission rate verses toxicity. This relative measure is shown in column 4 as Volume. The volume reported is the volume of air that the annual emissions of each pollutant would occupy at the ESL concentration, assuming all the emissions of that pollutant are present at one time, and the pollutant is evenly distributed over the volume. The highest "volume" numbers indicate those pollutants with the "worst-case" combination of high emission rate and high toxicity (low ESL). Table M-2 shows that the only materials of significance are Inhalable Particulate Matter(dust,PM10) and Barium. The table also indicates that the volatile and semi-volatile organic compounds are not emitted in sufficient quantity to be of concern. Conclusion In conclusion, based on the volume of PEP waste in individual detonations and the effectiveness of this disposal method, only de minimis emissions would occur. Operations at the OD treatment unit will not adversely impact the air quality of Dona Ana and Otero Counties in New Mexico, and the City of El Paso, Texas. There are no areas of non-attainment in Otero County and no major air emission sources. There are no human receptors in the immediate vicinity of the OD treatment unit and access by humans, livestock, and other potential environmental receptors is strictly controlled. The nearest permanently occupied facility is at Davis Dome, approximately 4 miles west of the OD unit. Therefore based upon the above findings, air modeling will not be conducted.

TO VIEW THE MAP AND/OR MAPS WITH THIS DOCUMENT,

PLEASE CALL THE HAZARDOUS WASTE BUREAU AT 505-476-6000 TO MAKE AN

APPOINTMENT

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PERMIT MODULE IV

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HSWA PERMIT CONDITIONS

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, REGION 6

HAZARDOUS WASTE PERMIT (HAZARDOUS AND SOLID WASTE AMENDMENTS, 1984)

PERMITTEE:

OWNER:

LOCATION:

I.D. NUMBER:

EFFECTIVE DATE:

EXPIRATION DATE:

U.S. Army Fort Bliss

U.S. Army Air Defense Artillery Center and Fort Bliss

Fort Bliss Military Reservation: Orogrande & Dona Ana Counties, NM and El Paso County, TX

NM4213720101

June 8 1995

June 8, 2005 @ Midnight

Pursuant to the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act (RCRA), as amended (42 u.s.c. 6901, et seq.) and the Hazardous and Solid Waste Amendments of 1984 (HSWA), a permit is issued to u.s. Army Fort Bliss (hereafter called the Permittee) to operate a hazardous waste disposal facility at the location stated above.

The Permittee must comply with all the terms and conditions of this permit. This per~it consists of the conditions contained herein (including the attachments). Said conditions are needed to ensure that the Permittee's hazardous waste management activities comply with all applicable Federal statutory and regulatory requirements. Applicable requirements are those which are found in, referenced in, or incorporated into that version of RCRA or the regulations promulgated pursuant to RCRA that are in effect on the date this permit is issued. (See 40 CFR 270.32 (c) • )

This permit is issued in part pursuant to the provisions of Section 201, 202, 203, 206, 207, 212, 215, and 224 of HSWA which modified Sections 3004 and 3005 of RCRA. These require corrective action for all releases of hazardous waste or hazardous constituents from any solid waste management unit at a treatment, storage, or disposal facility seeking a permit, regardless of the time at which the waste was placed in such unit and provides the authority to review and modify the permit at any time. The decision to issue this permit is based on the assumption that all information contained in the permit application is accurate and that the facility will be operated as specified in the permit application. Any inaccuracies found in the application may be grounds for termination or modification of this permit (see 40 CFR 270.41, 270.42 and 270.43) and potential enforcement action.

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Under Federal Law, this permit is effective on the effective date specified above unless a petition to the Administrator of the U.S. Environmental Protection Agency is filed in accordance with the requirements of 40 CFR 124.19.

Issued this ~J ltt-1!7 ~ 7- day

by Allyn M. Hazardou Division

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MODULE V. SPECIAL CONDITIONS PURSUANT TO THE 1984 HAZARDOUS AND SOLID WASTE AMENDMENTS (HSWA) TO RCRA FOR U.S. ARMY FORT BLISS EPA I.D. NUMBER NM421372010l

TABLE OF CONTENTS

A.

B.

c.

D.

E.

F.

G.

H.

I.

J.

K.

L.

M.

DEFINITIONS

STANDARD CONDITIONS 1. Waste Minimization ..• 2. Dust Suppression . . . . . ...•.•.••. 3. Permit Modification . . • • • • • • 4. Permit Review . . • . . . . . . • • . • . . . . 5. Compliance with Permit .....•......•. 6. Specific Waste Ban •••••• ~ 7. Information Submittal . . • • • • • . • . • 8. Plans and Schedules Incorporation Into Permit . 9. Data Retention .•.•...•••••••

SPECIFIC CONDITION - CLOSURE

SPECIFIC LANDFILLS

CONDITION SURFACE IMPOUNDMENTS AND . . . . . .. . . . . . . . . . . . . . . . . .

SPECIFIC CONDITION - INCINERATORS

SPECIAL CONDITIONS [RESERVED]

BIF RULE [RESERVED]

AA-BB AIR REGULATIONS . . . . . . -. . . . . CORRECTIVE ACTION • • • • • • • 1. Corrective Action for Releases 2. Releases Beyond Facility Boundary • 3. Financial Responsibility ..• 4. Dispute Resolution .••

REPORTING REQUIREMENTS .

NOTIFICATION REQUIREMENTS NEWLY-IDENTIFIED SWMUs . . .

FOR AND

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ASSESSMENT OF

NOTIFICATION REQUIREMENTS FOR NEWLY-DISCOVERED RELEASES AT SWMU(s) . . • • • ••••••••

INTERIM MEASURES • • • • . . . . • . • • • • • . . -.

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4 4 6 6 7 7 7 8 9 9

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12 12 12 13 13

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N. RFI WORKPLAN . . . . . . . . . . . . . . . . . . 16

o. RFI IMPLEMENTATION . . . . . . . . . . . . . . . . . 18 . .

P. RFI FINAL REPORT AND SUMMARY . . . . . . 18

Q. DETERMINATION OF NO FURTHER ACTION . . . 19

R. CMS PLAN . . . . . . . . . . . . . . . . . . . . 20

s. CMS IMPLEMENTATION . . . . . . . . . . . . . 21

T. CMS FINAL REPORT AND SUMMARY . . . . . . . . 21

u. CORRECTIVE MEASURE (REMEDY) SELECTION AND IMPLEMENTATION . . . . . . . . . . . . . . . . . . . . . 22

v. RFI SCOPE OF WORK . . . . . . . . . . . . . 22 1. Purpose . . . . . . . . . . . . . . . . 22 2. Scope . . . . . . . . . . . . . . . . . 22 3. Task I: RFI Workplan . . . . . . . . . . . . . 23 4. Task II: RCRA Facility Investigation . . . . . 34 5. Task III: RFI Final Report and Summary . . . . . . 35

( w. CMS SCOPE OF WORK 36 I'''" . . . . . . . . . . . . . . . . . 1. Purpose . . . . . . . . . . . . . . 36 2. Scope . . . . ... . . . . . . . . . . . 36 3. Task IV: CMS Plan . . . . . . . . . . . . . . 37 4. Task V: Corrective Measures study . . . . . . . 37 5. Task VI: CMS Final Report and summary . . . . . . 45

Table 1: RFI/CMS SUBMISSION SUMMARY . . . . . . . . . . . . 47

Table 2: SWMUs REQUIRING AN RFI . . . . . . . . . . . . 49

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A. DEFINITIONS

For purposes of these special conditions pursuant to the 1984 Hazardous and Solid W~ste Amendments to RCRA, the following definitions shall apply:

"Administrative Authority" means the New Mexico Environment Department, or his /her designee, or, in the case of HSWA provisions for which the State is not authorized, the United States Environmental Protection Agency {EPA}.

"Area of Concern" (AOC) means any discernable unit or area which, in the opinion of the Administrative Authority, may have received solid or hazardous waste or waste containing hazardous constituents at any time. The Administrative Authority may require investigation of the unit as if it were a SWMU. If shown to be a SWMU by the investigation, the AOC must be reported by the Permittee as a newly-identified SWMU. If the AOC is shown not to be a SWMU by the investigation, the Administrative Authority may determine that no further action is necessary and notify the Permittee in writing.

"CMS" means Corrective Measures Study.

"EPA" means the United States Environmental Protection Agency.

"Facility" means all contiguous property under the control of the owner or operator seeking a permit under subtitle c of RCRA.

"HSWA" means the 1984 Hazardous and Solid Waste Amendments to RCRA.

"Hazardous constituent" means any constituent ·identified in Appendix VIII of 40 CFR Part 261, or any constituent identified in Appendix IX of 40 CFR Part 264.

"Hazardous waste" means a solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or pose a substantial present or potential hazard to human health or the environment when improperly trea·ted, stored, transported, or disposed of, or otherwise managed. The term hazardous waste includes hazardous constituent.

"NMED" means the New Mexico Environment Department.

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"Permit" means the conditions embodied in these special conditions pursuant to the 1984 Hazardous and Solid Waste Amendments to RCRA.

"Permittee" means u.s. Army Fort Bliss, Fort Bliss, Texas 79916 EPA ID No. NM42113720101.

"RCRA" means the Resource Conservation and Recovery Act of 1980 as amended by HSWA in 1984.

"RCRA Permit" means the full permit, with RCRA and HSWA portions.

"RFA" means RCRA Facility Assessment.

"RFI" means RCRA Facility Investigation.

"Release" means any spilling, leaking, pouring, emitting, emptying, discharging, injecting, pumping, escaping, leaching, dumping, or disposing of hazardous wastes (including hazardous constituents) into the environment (including the abandonment or discarding of barrels, containers, and other closed receptacles containing hazardous wastes or hazardous constituents).

"Solid Waste Management unit" (SWMU) means any discernible unit at which solid. wastes have been placed at any time, irrespective of whether the unit was intended for the management of solid or hazardous waste. such units include any area at a facility at which solid wastes have been routinely and systematically released~

If, subsequent to the issuance of this permit, regulations are promulgated which redefine any of the above terms, the Administrative Authority may, at its discretion, apply the new definition to this permit.

B. STANDARD CONDITIONS

1. Waste Minimization

The·Permittee shall submit a certified plan according to 40 CFR 270.11 in writing annually, by December 1, for the previous year ending September 30, specifying that:

a. the Permittee has a program in place to reduce the volume and toxicity of all hazardous wastes which are generated by the facility's operation to the degree determined-to be economically practicable; and that the proposed method of treatment, storage, or disposal is the practicable method currently available to the Permittee which minimizes the present and future threat to human

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health and the environment. address the items below:

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This certified plan must

1) Any written policy or statement that outlines goals, objectives, and/or methods for source reduction and recycling of hazardous waste at the facility;

2} Any employee training or incentive programs designed to identify and implement source reduction and recycling opportunities;

3} Any source reduction and/ or recycling measures implemented in the last five years or planned for the near future;

4) An itemized list of the dollar amounts of capital expenditures (plant and equipment) and operating costs devoted to source reduction and recycling of hazardous waste;

5} Factors that have prevented implementation of source reduction and/or recycling;

6} Sources of information on source reduction and/or recycling received at the facility (e.g., local government, trade associations, suppliers, etc.);

7} An investigation of additional waste minimization efforts which could be implemented at the facility. This investigation shall analyze the potential for reducing the quantity and toxicity of each waste stream through production reformulation, recycling, and all other appropriate means. The analysis shall include an assessment of the technical feasibility, cost, and potential waste reduction for each option;

8} The Permittee shall submit a flow chart or matrix detailing all hazardous wastes it produces by quantity, type, and building/area;

9} The Permittee shall demonstrate the need to use those processes which produce a particular hazardous waste due to a lack of alternative processes or available technology that would produce less hazardous waste.

The Permittee shall include this certified plan in the operating record. This section applies to the RCRA Permit.

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2. Dust suppression

Pursuant to 40 CFR 266.23 (b), the Permittee shall not use waste or used oil or any other material which is contaminated with dioxin, polychlorinated biphenyls (PCBs), or any other hazardous waste (other than a waste identified solely on the basis of ignitability), for dust suppression or road treatment. This section applies to the RCRA Permit.

3. Permit Modification

a. If at any time for any of the reasons specified in 40 CFR 270.41, the Administrative Authority determines that modification of this Permit is necessary, the Administrative Authority may require the Permittee to request a permit modification per MODULE V.B.3.b or may initiate a modification according to 40 CFR 124.5, as follows:

1) Notify the Permittee in writing of the proposed modification and the date by which comments on the proposed modification must be received.

2) Publish a notice of the proposed modification in a locally distributed newspaper, broadcast the notice over a local radio station, mail a notic~ to all persons ~n the facility mailing list maintained according to 40 CFR 124.10(c) (1) (ix), and place a notice in the facility's information repository (a central source of all pertinent documents concerning the remedial action, usually maintained at the facility or some other public place in the vicinity of the permitted facility, such as a public library).

3) If the Administrative Authority receives no written comment on the proposed modification, the modification will become effective five (5) calendar days after the close of the comment period. The Administrative Authority will:

a) Notify the Permittee in writing of the final decision.

b) Notify individuals on the facility mailing list in writing that the modification has become effective and shall place a copy of the modified permit in the information repository, if a repository is required for the facility.

4) If the Administrative Authority receives written comment on the proposed modification, the Administrative

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Authority will make a final determination concerning the modification after the end of the comment period. The Administrative Authority will:

a) Notify the Permittee in writing of the final decision.

b) Provide notice of the final modification decision in a locally distributed newspaper and place a copy of the modified permit in the information repository, if a repository is required for the facility.

b. The Permittee may initiate permit modifications proceeding under 40 CFR 270.42. All applicable requirements and procedures as specified in 40 CFR 270.42 shall be followed.

c. Modifications of the Permit do not constitute a reissuance of the Permit.

Permit Review

This Permit may be reviewed by the Administrative Authority five years after the date of permit_ issuance and may be modified as necessary as provided for in MODULE V. B. 3. Nothing in this section shall preclude the Administrative Authority from reviewing and modifying the Permit at any time during its term. This section applies to the RCRA Permit.

Compliance with Permit

Compliance with this Permit during its term constitutes compliance, for the purposes of enforcement, with 40 CFR Parts 264 and 266 only for those management practices specifically authorized by this Permit. The Permittee is also required to comply with Parts 260, 261, 262, and 263 as applicable.

6. Specific Waste Ban

a. The Permittee shall not place in any land disposal unit the wastes specified in 40 CFR 268 after the effective date of the prohibition unless the Administrator has established disposal or treatment standards for the hazardous waste and the Permittee meets such standards and other applicable conditions of this Permit.

b. The Permittee may store wastes restricted under 40 CFR 268 solely for the purpose of accumulating quantities necessary to facilitate proper recovery, treatment, or

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disposal provided that it meets the requirements of 40 CFR 268.50(a) (2) including, but not limited to, clearly marking each tank or container.

c. The Permittee is required to comply with all requirements of 40 CFR 268.7 as amended. Changes to the waste analysis plan will be considered permit modifications at the request of the Permittee, pursuant to 40 CFR 270.42.

d. The Permittee shall perform a waste analysis at least annually or when a process changes, to determine whether the waste meets applicable treatment standards. Results shall be maintained in the operating record.

e. The Permittee must comply with requirements restricting placement of hazardous wastes in or on land which become effective by statute or promulgated under Part 268, regardless of requirements in the Permit. Failure to comply with the regulations may subject the Permittee to enforcement action under Section 3008 of RCRA.

This section applies to the RCRA Permit.

Information Submittal

Failure to comply with any condition of the Permit, including information submittal, constitutes a violation of the Permit and is grounds for enforcement action, permit amendment, termination, revocation, suspension, or denial of permit renewal application. Falsification of any submitted information is grounds for termination of this Permit (40 CFR 270.43).

The Permittee shall ensure that all plans, reports, notifications, and other submissions to the Administrative Authority required in this Permit are signed and certified in accordance with 40 CFR 270.11. A summary of the planned reporting requirements pursuant to this Permit is found in Table 1. Two (2) copies and one ( 1} · 3. 5" IBM compatible disk copy each of these plans, reports, notifications or other submissions shall be submitted to the Administrative Authority by Certified Mail or hand delivered to:

U.S. EPA, Region 6 Hazardous Waste Management Division 1445 Ross Avenue Dallas, Texas 75202-2733

and

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New Mexico Environment Department Hazardous and Radiation Waste Bureau P.O. Box 26110 Santa Fe, New Mexico 87502

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8. Plans and Schedules Incorporation Into Permit

9.

All plans and schedules required by this Permit are, upon approval by the Administrative Authority, incorporated into this Permit by reference and become an enforceable part of this Permit. Since required items are essential elements of this Permit, failure to submit any of the required items or submission of inadequate or insufficient information may subject the Permittee to enforcement action under Section 3008 of RCRA which may include fines, suspension, or revocation of the Permit.

Any noncompliance with approved plans and schedules shall be termed noncompliance with this Permit. Written requests for extensions of due dates for submittals may be granted by the Administrative Authority in accordance with MODULE V.B.3.

If the Administrative Authority determines that actions beyond those provided for, or.changes to what is stated herein, are warranted, the Administrative Authority may modify this Penni t according to procedures in MODULE V.B.3.

Data Retention

All raw data, such as laboratory reports, drilling logs, bench-scale or pilot-scale data, and other supporting information gathered or generated during activities undertaken pursuant to this Permit shall be maintained at the facility during the term of this Permit, including any reissued Permits.

C. SPECIFIC CONDITION - CLOSURE

Pursuant to Section 3005(j) (1) of the Hazardous and Solid Waste Amendments of 1984, the Permittee shall close the hazardous waste management units in accordance with the following provisions:

1. After closure the Permittee shall not place hazardous waste in the former waste management units;

2. The Permittee shall close the waste management units in accordance with the Closure Plan(s) as approved at the time of closure, and which meet ( s) all relevant state and Federal closure requirements at.the time of closure; and

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3. The Permittee shall notify EPA and the New Mexico Environment Department in writing at least 60 days prior to commencement of closure.

D. SPECIFIC CONDITION - SURFACE IMPOUNDMENTS AND LANDFILLS

1. Operation/Construction of Surface Impoundments and Landfills

The Permittee shall not place hazardous waste in any surface impoundment or landfill unless the unit meets the Minimum Technological Requirements outlined in 40 CFR 264.221{a) and 40 CFR 264.301(a). The Administrative Authority must approve plans and specifications for retrofitting or construction prior to commencement of construction by the Permittee.

2. Surface Impoundment and Landfill Specific Waste Ban

The Permittee shall not place hazardous waste prohibited by 40 CFR 268 in any surface impoundment or landfill unless:

a. The waste meets treatment standards specified in .40 CFR 268.40, .41, .42, and .43;

b. A variance ·from the treatment standards has been granted pursuant to 40 CFR 268.44;

c. A petition has been granted extension to the effective date, 268.5;

on a case-by-case pursuant to 40 CFR

d. A "no-migration" petition has been granted pursuant to 40 CFR 268.6; or

e. A surface impoundment is exempt under 40 CFR 268.4.

E. SPECIFIC CONDITION - INCINERATORS (RESERVED]

F.

G.

H.

SPECIAL CONDITIONS (RESERVED]

BIF RULE [RESERVED]

AA-BB AIR REGULATIONS

The Permittee must comply with the requirements of 40 CFR 264 subparts AA and BB, as applicable. Within 90 days of the effective date of this Permit, the Permittee shall submit to the Administrative Authority a report which must contain, at minimum, the following information:

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1. An equipment list which includes all the information required under 264.1064 (b) ( 1) for equipment that contains or contacts hazardous wastes with organic concentrations of at least 10 percent by weight, and a list of all process vents associated with distillation, fractionation, thin-filmevaporation, solventextraction, or air or steam stripping operations managing hazardous waste with organic concentrations of at least 10 percent by weight.

2. For the process vents listed above, the amount of vent emissions in lb/hr or kg/hr, and in lb/yr or kgjyr.

3. If the emissions in paragraph 2 of this section exceed the emission limits cited in 264.1032{a} (1), the report must detail the manner in which compliance will be obtained, i.e., by the reduction of total organic emissions to the limits in 264.1032(a) (1), or reduction by means of a control device per 264.1032{a) (2).

4. If a closed-vent system and control device is installed to comply with the requirements in 264.1032{a) {2), provide the following information:

a. An implementation schedule that includes dates by which the closed-vent system and control device will be installed and in· operation per 40 CFR 264.1033(a) {2).

b. The type of control device under 264.1033 to be installed (e.g. vapor recovery, flare, etc.).

5. If the Permittee feels any of the requirements of thi-s MODULE V.H., or of 40 CFR 264 Subparts AA and BB, are not applicable to this facility, the Permittee must provide justification for this decision as part of the report.

I. CORRECTIVE ACTION

1. Corrective Action for Releases: Sectiop 3004 (u) of RCRA, as amended by HSWA, and 40 CFR 264.101, require that permits issued after November 8, 1984, address corrective action for releases of hazardous waste including hazardous constituents from any SWMU at the facility, regardless of when the waste was placed in the unit.

2. Releases Beyond Facility Boundary

a. The Permittee shall notify the Administrative Authority verbally, within 24 hours of discovery, of any release of hazardous· waste or hazardous constituents that has the potential to migrate off-site.

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b. Section 3004 (v) of RCRA as amended by HSWA, and Federal regulations promulgated as 40 CFR 264.101 (c), require corrective actions beyond the facility property boundary, where ne·cessary to protect human health and the environment, unless the Permittee demonstrates that, despite the Permittee's best efforts, the Permittee was unable to obtain the necessary permission to undertake such actions. The Permittee is not relieved of all responsibility to clean up a release that has migrated beyond the facility boundary where offsite access is denied.

Financial Responsibility: Assurances of financial responsibility for corrective action shall be provided as specified in the Permit following major modification for remedy selection.

Dispute Resolution

a. The parties shall use their best efforts to informally and in good faith resolve all disputes or differences of opinion. If, however, disputes arise concerning the corrective action which the parties are unable to resolve informally, including but not limited to, disputes over implementation of workplans, approval of documents, scheduling of any work, selection, performance or completion of any corrective action, or any other obligation assumed hereunder, the Permittee shall present a written notice of such dispute and the basis for the objections to EPA withinten business days of the receipt of EPA's disapproval, decision or directive. The notice shall set forth the specific points of the dispute, the position the Permittee maintains should be adopted as consistent with the Permit's requirements, the basis therefore, and any matters.which it considers necessary for EPA's proper determination. EPA shall provide to the Permittee a written statement of its decision on the pending dispute, which shall be incorporated into the final Permit unless the Permittee requests an opportunity for a conference in accordance with MODULE V.I. 4. b. The existence of a dispute as defined herein, and the consideration of such matters which are placed into dispute shall not excuse, toll, or suspend any compliance obligation or deadline while the dispute resolution process is pending.

b. If the Permittee objects to any EPA determination regarding any requirement by EPA that the Permittee perform work, the Permittee shall, within ten days of its receipt of EPA's decision pursuant to MODULE V.I.4.a, notify EPA in writing of its objections, and may request that the Hazardous Waste Management Division Director

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convene an informal conference. The Director shall state in writing his decision regarding the factual issues in dispute. Such decision shall be the final resolution of the dispute and shall be implemented immediately by the Permittee according to the schedule contained therein.

J. REPORTING REQUIREMENTS

K.

1. The Permittee shall submit, in accordance with MODULE V.B.7, signed quarterly progress reports of all activities (i.e., RFI, CMS) conducted pursuant to the provisions of this Permit beginning no later than ninety (90) calendar days from the effective date of this Permit. These reports shall contain:

a. A description of the work completed and an estimate of the percentage of work completed;

b. Summaries of all· findings, including summaries of laboratory data;

c. summaries of all problems or potential problems encountered during the reporting period and actions taken to rectify problems;

d. Projected work for the next reporting period;

e. summaries of contacts pertaining to corrective action or environmental matters with representatives of the local community, public interest groups or state government during the reporting period; ·

f. Changes in key project personnel during the reporting period; and

g. summaries of all changes made in implementation during the reporting period.

2. Copies of other reports (e.g., inspection reports), drilling logs and laboratory data shall be made available to the Administrative Authority upon request.

3. In addition to the written reports, at the request of the Administrative Authority, the Permittee shall provide status review through semi-annual briefings with the Administrative Authority.

NOTIFICATION REQUIREMENTS FOR AND ASSESSMENT OF NEWLY-IDENTIFIED SWMUs

1. The Permittee shall notify the Administrative Authority, in writing, of any newly-identified SWMU(s) (i.e., a unit

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not specifically identified during the RFA), discovered in the course of ground water monitoring, field investigations, environmental audits, or other means, no later than thirty- (30) calendar days after discovery. The notification shall include the following items, to the extent available:

a. The location of the newly-identified SWMU in relation to other SWMUs;

b. The type and function of the unit;

c. The general dimensions, capacities, and structural description of the unit (supply any available drawings};

d. The period during which the unit was operated;

e. The specifics, to the extent available, on all wastes that have been or are being managed at the SWMU; and

f. Results of any sampling and analysis required for the purpose of determining whether releases of hazardous waste including hazardous constituents have occurred, are occurring, or are likely to occur from the unit.

2. Based on the results of this Notification, the Administrative Authority will determine the need for further investigations or corrective measures at any newly-identified SWMU(s). If . the Administrative Authority determines that such investigations are needed, the Administrative Authority may require the Permittee to prepare a plan for such investigations. This plan will be reviewed for approval as part of the RFI Workplan or a new RFI Workplan under MODULE V.N.3. The Permit will be modified according to MODULE V.B.3 to incorporate the investigation requirements for the newly-identified SWMU(s), if required.

L. NOTIFICATION REQUIREMENTS FOR NEWLY-DISCOVERED RELEASES AT SWMU(s}

The permittee shall notify the Administrative Authority in writing, no later than fifteen ( 15) calendar days after discovery, of any release(s} of hazardous waste or hazardous constituents discovered during the course of ground water monitoring, fieid investigation, environmental auditing, or other means. Such newly-discovered releases may be from newly-identified units or from units for which, based on the findings of the RFA, the Administrative Authority had previously determined no further investigation was necessary. The Administrative Authority may require further investigation and/or interim measures for the newly-identified release(s),

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and may require the Permittee to prepare a plan for the investigation andjor interim measure. The plan will be reviewed for approval as part of the RFI Workplan or a new RFI Workplan under MODULE.~v .N. 3. The Permit will be modified according to MODULE V.B.3 to incorporate the investigation, if required. ·

M. INTERIM MEASURES

1. If during the course of any activity initiated under this Permit, the Administrative Authority determines that a release or potential release of hazardous constituents from a SWMU poses a threat to human health and the environment, the Administrative · Authority may require interim measures. The Administrative Authority shall determine the ·specific measure{s) or require the Permittee to propose a measure(s). The interim measure(s) may include a permit modification, a schedule for implementation, and a written plan. The Administrative Authority shall notify the Permittee in writing of the requirement to perform interim measures. The Administrative Authority shall modify this Permit according to MODULE V. B. 3 to incorporate interim measures into the Permit .

2. The following factors will be considered by the Administrative Authority in determining the need for interim measures:

a. Time required to develop and implement a final remedy;

b. Actual and potential environmental receptors;

exposure to human and

c. Actual and potential contamination of drinking water supplies and sensitive ecosystems;

d. The potential for further degradation of the medium in the absence of interim measures;

e. Presence of hazardous wastes in containers that may pose a threat of release;

f. Presence and concentration of hazardous waste including hazardous constituents in soil that have the potential to migrate to ground water or surface water;

g. Weather conditions that may affect the current levels of contamination;

h. Risks of fire, explosion, or accident; and

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i. Other situations that may pose threats to human health and the environment.

RFI WORKPLAN

1. The RFI Workplan as specified in MODULE V. V.3 shall be submitted to the Administrative Authority within 120 days of the effective date of this Permit. The RFI Workplan must address releases of hazardous waste or hazardous constituents to all media for those SWMUs listed in Table 2. The SWMU numbers are from the RFA Report, prepared by A. T Kearney, Inc., dated March 1989.

2.

a. The Workplan shall describe the objectives of the investigation and the overall technical and analytical approach to completing all actions necessary to characterize the direction, rate, movement, and concentration of releases of hazardous waste or hazardous constituents from specific units or groups of units, and their actual or potential receptors. The RFI Workplan shall detail all proposed activities and procedures to be conducted at the facility, the schedule for implementing and completing such investigations, the qualifications of personnel performing or directing the investigations, including contractor personnel, and the overall management of the RFI. The Scope of Work for a RCRA Facility Investigation (RFI) is in MODULE v.v.

b. The RFI Workplan shall describe sampling, data collection quality assurance, and data management procedures, including formats for documenting and tracking data and other results of investigations, and health and safety procedures.

c. Development of the RFI Workplan and reporting of data shall be consistent with the following EPA guidance documents or the equivalent thereof:

1} RCRA Facility Investigation Guidance Document (EPA 530/5W-89-031};

2) RCRA Groundwater Monitoring Technical Enforcement Guidance Document {OSWER 9950.1) September 1986; and

3) Test Methods for Evaluating Solid Waste {SW 846, 2nd ed.) 1982.

After the Permittee submits the Workplan, the Administrative Authority will either approve, disapprove, or modify the Workplan in writing.

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If the Administrative Authority approves the workplan, the Permittee shall implement the plan within two weeks ( 14 days) of receipt of approval, according to the schedule contained in the plan. All approved workplans become incorporated into this Permit as per MODULE V. B. 8.

In the event of disapproval (in whole or in part) of the workplan, the Administrative Authority shall specify deficiencies in writing. The Permittee shall modify the plan to correct these within the time frame specified in the notification of disapproval by the Administrative Authority. The modified workplan shall be submitted in writing to the Administrative Authority for review. Should the permittee ·take exception to all or part of the disapproval, the Permittee shall submit a written statement of the grounds for the exception within 10 days of receipt of the disapproval per MODULE V.I.4.

The Administrative Authority shall review for approval as part of the RFI Workplan or as a new workplan any plans developed pursuant to MODULE V. K addressing further investigations of newly-identified SWMUs, or MODULE V.L. addressing new releases from previously-identified SWMUs.

0. RFI IMPLEMENTATION

Upon receipt of written approval from the Administrative Authority for the RFI Workplan, the Permittee shall implement the RFI according to the schedules and in accordance with the approved RFI Workplan and the following:

1. The Permittee shall notify EPA and the NMED at least 10 days prior to any sampling, testing, or monitoring activity required by this Permit to give Agency personnel the opportunity to observe investigation procedures and/or split samples.

2. Deviations from the approved RFI Workplan which are necessary during implementation of the investigations must be approved by the Administrative Authority and fully documented and described in the progress reports and in the RFI Final Report.

P. RFI FINAL REPORT AND SUMMARY

1. Within sixty (60) calendar days after the completion of the RFI, the Permittee shall submit an RFI Final Report and summary. The RFI Final Report shall describe the procedures, methods, and results of all investigations as described in MODULE V. V. 5. This includes SWMUs and their releases, the type and extent of contamination at the facility, sources and migration pathways, and actual or

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potential receptors. The RFI Final Report shall present all information gathered under the approved RFI Workplan. The RFI Final Report must contain adequate information to support further :corrective action decisions a·: the facility. The summary shall summarize the RFI Final Report.

2. After the Permittee submits the RFI Final Repot t and Summary, the Administrative Authority shall '!ither approve or disapprove them in writing.

If the Administrative Authority approves the RFI Final Report and Summary, the Permittee shall mail the ap}•roved summary to all individuals on the facility mailint' list established pursuant to 40 CFR 124.10(c) (1) (ix), \'ithin fifteen (15) calendar days of receipt of approval.

If the Administrative Authority determines the RFI Final Report and summary do not fully meet the obj ec ti ves stated in MODULE v.v., the Administrative Authorit"{ may disapprove the RFI Final Report and Summary. Ii' the Administrative Authority disapproves the Report, the Administrative Authority shall notify the Permittoe in writing of the Report's deficiencies and specify c due date for submittal of a revised Final Report and Sulllt.:ary. Once approved, the summary shall be mailed to all individuals on the facility mailing list as specified above.

DETERMINATION OF NO FURTHER ACTION

1. Based on the results of the RFI and other rele rant information, the Permittee may submit an applicatio.l to the Administrative Authority for a Class III pe: -mit modification under 40 CFR 270.42 (c) to .terminate the RFI/CMS process for a specific unit. This pel mit modification application must contain information demonstrating that there are no releases of hazardous waste including hazardous constituents from a particular SWMU at the facility that pose threats to human health and/or the environment, as well as additional informat i.on required in 40 CFR 270.42(c). ·

If, based upon review of the Permittee's request fo1· a permit modification, the results of the RFI, and ot:t .er information, including comments received during the sb. ty (60) day public comment period required for Class III permit modifications, the Administrative Authority determines that releases or suspected releases which we :-e investigated either are non-existent or do not pose a threat to human health and/or .the environment, t 1e

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Administrative Authority will grant the requested modification.

2. If necessary to protect human health or the environment, a determination of no further action shall not preclude the Administrative Authority from requiring continued or periodic monitoring of air, soil, ground water, or surface water, when site-specific circumstances indicate that releases of hazardous waste or hazardous constituents are likely to occur.

3. A determination of no further action shall not preclude the Administrative Authority from requ1r1ng further investigations, studies, or remediation at a later date, if new information or subsequent analysis indicates a release or likelihood of a release from a SWMU at the facility that is likely to pose a threat to human health or the environment. In such a case, the Administrative Authority shall initiate a modification to the Permit according to MODULE V.B.3.

R. CMS PLAN

1. If the Administrative Authority has .reason to believe that a SWMU has released concentrations of hazardous constituents, or if the Administrative Authority determines that .contaminants present a threat to human health or the environment given site-specific exposure conditions, the Administrative Authority may require a CMS and shall notify the Permittee in writing. The notification may also specify remedial alternatives to be evaluated by the Permittee during the CMS.

2. The Permittee shall submit a CMS Plan to the Administrative Authority within forty five· {45} calendar days from notification of the requirement to conduct a CMS. The Scope of Work for a CMS Plan is in MODULE V.W.3.

The CMS Plan shall provide the following information:

a. A description of the general approach to the investigation, and potential remedies;

b. A definition of the overall objectives of the study;

c. Specific plans for evaluating remedies to ensure compliance with remedy standards;

d. Schedules for conducting the study; and

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e. The proposed format for the presentation of information.

3. After the Permi-ttee submits the CMS Plan, the Administrative Authority will either approve, disapprove, or modify the plan in writing.

If the Administrative Authority approves the CMS Plan, the Permittee shall implement the plan per MODULE v.s.

In the event of disapproval (in whole or in part} of the CMS Plan, the Administrative Authority shall specify deficiencies in writing. The Permittee shall modify the plan to correct these within the time frame specified in the notice of deficiency. The modified CMS Plan shall be submitted in writing to the Administrative Authority for review. Should the permittee take exception to all or part of the disapproval, the Permittee shall submit a written statement of the grounds for the exception within 10 days of receipt of the disapproval per MODULE V.I.4.

CMS IMPLEMENTATION

No later than fourteen (14) calendar days after the Permittee has received written approval from the Administrative Authority for the CMS Plan, the Permittee shall implement the Corrective Measures Study according to the schedules specified and in accordance with the approved CMS Plan. All approved plans become incorporated into this Permit as per MODULE V.B.8.

CMS FINAL REPORT AND SUMMARY

1. Within sixty (60} calendar days after the completion of the CMS, the Permittee shall submit a CMS Final Report and Summary. The Summary shall summarize the Final Report. The CMS Final Report shall discuss the results of investigations of each remedy studied and of any bench-scale or pilot tests conducted. It must include an evaluation of each remedial alternative. The CMS Final Report shall present all information gathered during the CMS, and must contain adequate information to support the remedy selection process. In the CMS Final Report, the Permittee shall propose a corrective action program that shall:

a. attain compliance with corrective action objectives for hazardous constituents in each medium, as established in MODULE V. W. i

b. control sources of releases;

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c. meet acceptable waste management requirements; and

d. protect human health and the environment.

2. After the Permittee submits the CMS Final Report and Summary, the Administrative Authority will either approve or disapprove them in writing.

3.

If the Administrative Authority approves the CMS Final Report and summary, the Permittee shall mail the approved Summary to all individuals on the facility mailing list established pursuant to 40 CFR 124.10(c)(1) (ix), within fifteen {15) calendar days of receipt of approval.

If the Administrative Authority determines the CMS Final Report and Summary do not fully meet the objectives stated in MODULE v.w., the Administrative Authority may disapprove the CMS Final Report and Summary. If the Administrative Authority disapproves the Report, the Administrative Authority shall notify the Permittee in writing of the Report's deficiencies and specify a due date for submittal of a revised Final Report and Summary. Once approved, the summary shall be mailed to all individuals on the facility. mailing list as specified above.

Based on preliminary results and the CMS Final Report, the Administrative Authority may require the Permittee to evaluate additional remedies or particular elements of one or more proposed remedies.

U. CORRECTIVE MEASURE (REMEDY) SELECTION AND IMPLEMENTATION

Within fifteen {15) calendar days from receipt of approval of CMS Final Report and Summary, the Permittee shall submit a Permit Modification request according to MODULE V.B.3, for corrective measure (remedy) selection, based on the approved CMS Final Report. The resultant modified permit will include schedules for remedy implementation.

V. RFI SCOPE OF WORK

1. Purpose

The purpose of the RFI is to determine the nature and extent of releases of hazardous wastes or hazardous constituents from solid waste management units. The required information shall include each item specified under Tasks I-III. The Permittee shall furnish all personnel, ·materials, and services necessary for, or incidental to, performing the RFI.

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If the Permittee believes that certain requirements of the Scope of Work are not applicable, the specific requirements shall be identified and a detailed rationale for inapplicability shall be provided.

2. Scope

3.

The RFI consists of three tasks:

Task I: RFI Workplan

a. Introduction b. Environmental Setting c. Source Characterization d. Contamination Characterization e. Potential Receptor Identification f. Data Collection Quality Assurance Plan g. Data Management Plan h. Health and Safety Plan i. Community Relations Plan j. Project Management Plan

Task II: RCRA Facility Investigation

Task III: RFI Final Report and Summary

Task I: RFI Workplan

The Permittee shall prepare a RFI Workplan as specified in MODULE V. N. and the following. The RFI Workplan shall provide for and address the following information needs:

a. Introduction

1) Facility Description

The introduction shall summarize the regional location, pertinent boundary features, general facility physiography, hydrogeology, and historical use of the facility for the treatment, storage, or disposal of solid and hazardous waste. Informati·on from existing reports and studies is acceptable, as long as the source of this information is documented, pertinent, and reflective of current conditions. This section shall include:

a) Map(s) depicting the information specified below. All maps shall be consistent with requirements set forth in 40 CFR 270.14 and shall be of sufficient detail and accuracy to locate all current and future work performed at the site.

(1) general geographic location;

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{2) property lines, with the owners of all adjacent property clearly indicated, and all land previously owned andfor used by the Permittee around the facility;

{3) topography, waterways, wetlands, floodplains, water features, and drainage patterns;

(4) all tanks, buildings, utilities, paved areas, rights-of-way, and other features;

(5) all solid waste management units;

(6) all known past solid or hazardous waste treatment, storage and disposal areas or units regardless of whether they were active on November 19, 1980;

(7) surrounding land uses (residential, commercial, agricultural, recreational); and

(8) the location of all production and ground water monitoring wells. These wells shall be clearly labeled and ground and top of casing elevations inclu~ed (these elevations may be included as an attachment).

b) A history operation, solid treatment, storage facility.

and and

and

description hazardous disposal

of ownership and waste generation, activities at the

c) A summary of approximate dates or periods of past waste releases, identification of the materials released, the amount released, the location released, and a description of the response actions conducted (local, state, or Federal response units, or private parties), including any inspection reports or technical reports generated as a result of the response.

d) A reference to all environmental, geologic, and hydrogeologic studies performed by all parties, at or near the facility, with a short summary of the purpose, scope, and significant findings thereof.

e) A reference to all environmental permits, applied for andfor received, the purpose thereof, and a short summary of requirements.

2) Nature and Extent of Contamination

· a) The Introduction shall summarize all possible source areas of contamination. This, at a minimum, should include all SWMUs. For each area, the Permittee shall identify the following:

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(1) location of unitjarea on a facility map;

(2) quantities radiochemical wastes;

of solid, hazardous, and

(3) quantities of radiochemical and hazardous constituents, to the extent known; and

(4) identification of areas where additional information is necessary.

b) The Permittee shall prepare an assessment and description of the existing degree <tnd extent of contamination. This should include:

(1) available monitoring data and qualitative information on locations and levels of contamination at the facility;

(2) all information physiography, air quality;

potential migration pathways including on geology, pedology, hydrogeology, hydrology, water quality, meteorology, and and

(3) the potential impact(s) on human health or the environment, including demography, ground water and surface water use, and land use.

3) Implementation of Interim Measures

The Permittee shall document and report on all interim measures which ~ere or are being u1dertaken at the facility, including under state or Federa 1 compliance orders, other than those specified in the P· ~rmi t. This shall include:

a) Objectives of the interim measure 3: how the measure is mitigating a potential threat to l uman health or the environment and/or is consistent with and integrated into requirements for a long term solution;

b) Schedules monitoring; and

for design, construction

c) Schedule for progress reports.

b. Environmental Setting

and

The Workplan shall provide for ciolle·=tion of information to supplement and verify existing information on the environmental setting at the facility. The

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Workplan shall provide for characterization of the following:

1) Hydrogeology

The Workplan shall describe in detail a program to evaluate hydrogeologic conditions at the facility. This program shall provide for least the following information needs:

a) A description of the regional, local, facilitywide, and SWMU-specific geologic and hydrogeologic characteristics affecting ground water flow beneath the facility.

b) An analysis of any topographic features including surface water bodies that might influence the ground water flow system.

c) A representative and accurate classification and description of the hydrogeologic units which may be part of migration pathways at the facility (i.e. , the aquifers and any intervening saturated and unsaturated units) based on field data, tests (e.g., gamma and neutron logging of existing and new wells, piezometers and borings), and cores.

d) The extent (depth, thickness, lateral extent) of hydrogeologic units which may be part of migration pathways based on field studies and cores, structural geology, and hydrogeologic cross sections, including:

{1) unconsolidated sand and gravel deposits;

(2) zones of fracturing or channeling in consolidated or unconsolidated deposits; and

(3) zones of high permeability or low permeability that might direct and restrict the flow of contaminants.

e) A description of representative water level or fluid pressure based on data obtained from ground water monitoring wells and piezometers installed upgradient .and downgradient of the potential contaminant source. Information needs include: potentiometric surface maps; hydrologic cross sections showing vertical gradients; vertical and horizontal components of flow; temporal changes in hydraulic gradients; and flow nets.

f) A description of man-made influences that may affect site hydrogeology such as active and inactive

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local water-supply and production wells, pipelines, french drains, and ditches.

2) Soils

The Permittee shall describe in detail a program designed to characterize soil and rock units above the water table. such characterization shall include, but is not limited to, the following information: surface soil distribution; soil profile, including ASTM and uses classifications of soils; transects of soil stratigraphy; saturated hydraulic conductivity; porosity; cation exchange capacity (CEC); soil Ph; particle size distribution; depth to water table; moisture content; effect of stratification .on unsaturated flow; infiltration; evapotranspiration; residual concentration of contaminants in soil; total natural organic carbon content; and mineral and metal content.

c. Source Characterization

The Permittee shall describe in detail a program designed to completely characterize the wastes and the areas where wastes have been placed, including: type, quantity, physical form, composition, disposition (containment and nature of wastes), and the facility characteristics . affecting releases (e.g., facility security, engineered barriers). This shall include quantification of the following specific characteristics, at each source area:

1) Units, including but not limited to: location of unit; type of unit; design features; operating practices (past and present); period of operation; age of unit; general physical conditions; and method used to close the unit area.

2) Waste characteristics, including but not limited to: type of waste placed in unit (hazardous classification, quantity, chemical composition); physical and chemical characteristics (physical ·form, physical description, temperature, pH, general chemical class, molecular weight, density, boiling point, viscosity, solubility in water, solubility in solvents, cohesiveness, vapor pressure); and migration and dispersal characteristics of the waste (sorption coefficients, biodegradability, photodegradation rates, hydrolysis rates, chemical transformations).

d. Contamination Characteristics

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The Permittee shall describe in detail a program to collect analytical data on ground water, soils, surface water, sediment, and subsurface gas contamination when necessary to chara-cterize contamination from a SWMU. The data shall be sufficient to define the extent, origin, direction, and rate of movement of contaminant plumes. Data required shall include time and location of sampling, media sampled, concentrations found, conditions during sampling, and the identity of the individual(s) performing the sampling and analysis. Each medium (ground water, surface water and sediments, soil, air, and gas) must be investigated. If the permittee believes certain media could not be affected by a release from a specific unit, a detailed justification for not investigating those media must be provided. The Permittee shall address the following types of contamination at the facility:

1) Ground Water Contamination

The Workplan shall describe in detail a program of ground water investigation to characterize any plumes of contamination at the facility. The program shall at a minimum provide for the following information needs:

a) a description of the horizontal and vertical extent of any immiscible or dissolved plume (s) originating from the facility;

b) the horizontal and vertical direction of contamination movement;

c) the velocity of contaminant movement;

d) the horizontal and vertical concentrations of any 40 CFR 264 Appendix IX constituents;

e) an evaluation of factors influencing the plume movement; and

f) an extrapolation of future contaminant movement.

2) Soil Contamination

The Permittee shall describe in detail a program to characterize contamination of soil and rock units above the water table in the vicinity of the contaminant release. The program shall provide for the following information needs:

a) a description of the vertical and horizontal extent of contamination;

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b) a description of contaminant and soil chemical properties within the contaminant source area. This includes contaminant solubility, speciation, adsorption, leachability, exchange capacity, biodegradability, hydrolysis, photolysis, oxidation, natural total organ-ic carbon content, and other factors that might affect contaminant migration and transformation.

c) plume migration and transformation; specific contaminant concentrations; the velocity and direction of contaminant movement; and an extrapolation to future contaminant movement.

3) Surface Water and Sediment contamination

The Permittee shall describe in detail a program to characterize contamination in surface water bodies and sediment resulting from contaminant releases at the facility. The investigation shall at minimum include the following:

a) a description of the surface water body including location, elevation, flow, velocity, depth, width, seasonal fluctuations, flooding tendencies, drainage patterns, and evapotranspiration rates.

b) a description of including depositional area, size, density, ion exchange organic carbon content.

sediment characteristics thickness, mineralogy, grain capacity, and total natural

c) maps for all areas included in surface water and , sediment investigations which meet requirements in 40 CFR 270.14 and which are sufficiently detailed and accurate to depict all the information required. ·

d) a description of the horizontal and vertical extent of any immiscible or dissolved plumes originating from the facility, and the extent of contamination in the underlying sediments;

e) the horizontal and vertical direction and velocity of contaminant movement;

f) an evaluation of the chemical, and radiochemical contaminant movement;

physical, factors

biological, influencing

g) an extrapolatio~ :to future contaminant movement;

h) a description of the chemistry of the contaminated surface waters and sediments. This includes

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pH, temperature, total dissolved solids, total suspended solids, biochemical oxygen demand, alkalinity, conductivity, dissolved oxygen profiles, nutrients, chemical oxygen :.:demand, total organic carbon, and specific contaminant concentrations.

4} Air Contamination

The Permittee shall describe in detail a program to characterize particulate and gaseous contaminants released into the atmosphere. This investigation shall provide the following information: a description of the horizontal and vertical direction and velocity of contaminant movement; the rate and amount of the release; and the chemical, radiochemical, and physical composition of the contaminants released, including horizontal and vertical concentration profiles.

5} Subsurface Gas

The Permittee shall describe in detail a program to characterize the nature, rate and extent of releases of reactive gases from the units. such a program shall include, but is not limited to: provisions for monitoring subsurface gases released from the unit, and an assessment of the potential for threat to human health andfor the environment.

e. Potential Receptors

The Permittee shall describe in detail a program to collect data to describe human populations and environmental systems that are susceptible to contaminant exposure from the facility. Chemical and radiochemical analysis of biological samples may be needed. Data on observable· effects in ecosystems may also be required. The following characteristics shall be identified:

1} Local uses and possible future uses of ground water, including:

a} type of use (i.e., potable, domestic, agricultural, residential, industrial, municipal)

b) location of all ground water wells, names of owners or tenants at those locations, USGS/DODT well designations, and current use of those wells within a 1 mile radius of facility.

2} Local uses and possible future uses of surface waters within a 1.5 mile radius of the facility,

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including domestic and municipal, recreational, agricultural, industrial, and environmental.

3) Human use of·--or- access to the facility and adjacent lands, including but not limited to recreation, hunting, residential, commercial, and industrial.

4) A demographic profile of people who use or have access to the facility and adjacent land, including, but not limited to age, gender, and sensitive subgroups.

5) A description of the local ecology, including biota in surface water bodies on, adjacent to, or affected by the facility, and a description of any endangered or threatened species near the facility.

f. Data Collection Quality Assurance Plan

The Permittee shall prepare a plan to document all monitoring procedures: sampling, field measurements, and sample analysis performed at the facility during the investigation to characterize the environmental setting, source, and contamination, so as to ensure that all information, data, and resulting decisions are technically sound, statistically valid, and properly documented.

1} The strategy section of the Data Collection Quality Assurance Plan shall include but not be limited to the following:

a) description of the intended uses for the data, and the necessary level of precision and accuracy for those intended uses;

b) description of methods and procedures to be used to assess the precision, accuracy and completeness of the measurement data; and

c) schedule and information to be provided in quality assurance reports, including at least:

(1) periodic assessment of measurement data accuracy, precision, and completeness;

(2) results of performance audits;

(3) results of systems audits; and

(4) significant quality assurance problems and resolutions.

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2) The Sampling and Field Measurements Section of the Data Collection Quality Assurance Plan shall at least discuss:

a) selecting appropriate sampling measurements locations, depths, etc.;

and field

b) providing a statistically sufficient number of sampling and field measurement sites;

c) determining conditions under which sampling or field measurements shall be conducted;

d) determining which parameters are to be measured and where;

e) selecting the frequency of sampling and length of sampling period;

f) selecting the types of sample (e.g., composites vs. grabs) and number of samples to be collected;

g) delineating procedures designed to prevent contamination of sampling or field measurements equipment and cross contamination between sampling points;

h) documenting procedures;

field sampling operations and

i) selecting appropriate sample containers;

j) preserving samples;

k) controlling chain-of-custody; and

1} disposing of all contaminated materials generated by activities in a manner compliant with all state and Federal regulations.

3) The Sample Analysis shall include:

a) chain-of-custody procedures;

b) sample storage procedures and holding times;

c) sample preparation methods;

d) analytical procedures;

e) calibration procedures and frequency;

f) data reduction, validation and reporting; and

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g) frequency of internal quality control checks and laboratory performance audits.

g. Data Management Plan

The Permittee shall develop and initiate a Data Management Plan to document and track investigation data and results. This plan shall identify and set up data documentation materials and procedures (data record), project file requirements, and project-related progress reporting procedures and documents.

1) The data record shall include at least the following for all sample and field measurements: unique measurement code; measurement location; measurement type; laboratory ID number; property or component analyzed; and results of analysis.

2) The Data Management Plan shall provide the format to be used to present the data and conclusions of the investigation, etc.

a) The following shall be presented in tables: raw data; data sorted by significant features such as location, media, constituent; data reduction for statistical analysis; and summary data.

b) The following shall be presented in graphical formats (e.g. , bar graphs, 1 ine graphs, plan maps, isopleth plots, cross-sections, three-dimensional displays, etc.): sampling location and grid; levels of contamination at each sampling location; geographical extent of contamination; and changes in concentration relative to source, time, depth, and other parameters.

h. Health and Safety Plan

1) The Permittee shall prepare a facility Health and Safety Plan, which shall include:

a) a description of the facility including availability of resources such as roads, water supply, electricity and telephone service;

b) a description of the known hazards and evaluation of the risks associated with each activity conducted, including but not limited to on and off-site exposure to contaminants during implementation of interim measures;

c) a list of key personnel and alternatives responsible for site safety, response operations, and for protection of public health;

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d) a delineation of the work area;

e) a description of levels of protection to be worn by personnel in the work area;

f) procedures established to control site access;

g) decontamination procedures for personnel and equipment;

h) site emergency procedures;

i) emergency medical care procedures for injuries and toxicological problems;

j) requirements monitoring program;

for an environmental field

k) routine and special training requirements for responders; and

1) procedures for weather-related problems.

protecting workers from

2) The Facility Health and Safety Plan shall be consistent with:

a) NIOSH Occupation Safety and Health Guidance Manual for Hazardous Waste Site Activities (1985);

b) EPA Order 1440.1 - Respiratory Protection;

c) EPA Order 1440.3 - Health and Safety Requirements for Employees engaged in Field Activities;

d) approved Facility Contingency Plan;

e) EPA operating Safety Guide (1984);

f) OSHA regulations, particularly 29 CFR 1910 and 1926;

g) State and local regulations; and

h) other EPA guidance as provided.

i. Community Relations Plan

The Permittee shall prepare a plan for dissemination of information to the public regarding investigation activities and results.

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j. Project Management Plan

The Permittee shall prepare a Project Management Plan which will inclUde a discussion of the technical approach, schedules, budget, and key project personnel. The project management plan will also include a description of qualifications of key project personnel performing or directing the RFI, including contractor personnel. This plan shall also document the overall management approach to the RFI.

4. Task II: RCRA Facility Investigation

5.

The facility investigation activities shall follow the RFI Workplan. All sampling and analyses shall be conducted in accordance with the Data Collection Quality Assurance Plan. All sampling locations shall be documented in a log and identified on a detailed site map. During the RFI, it may be necessary to revise the RFI Workplan to increase or decrease the detail of information collected to accommodate the facility specific situation.

The Parmi ttee shall conduct investigations of SWMUs previously identified with known or suspected releases of contamination to characterize the facility (Environmental Setting), define the source {Source Characterization), define the degree and extent of contamination {Contamination Characterization), and identify actual or potential receptor~.

The investigations should result in data of adequate technical quality to develop and evaluate corrective measures alternatives during the Corrective Measures study, when necessary.

Task III: RFI Final Report and summary

The Permittee shall analyze all facility investigation data collected during the RFI process and prepare a detailed report on the type and extent of contamination at the facility including sources and migration pathways. All information generated during the investigation shall be presented and analyzed. All evidence and procedures used for making any determinations (e.g., velocity of groundwater, extent of contamination) shall be fully documented. The report shall describe extent of contamination (qualitative/quantitative) in relati·on to background levels indicative for the area. The report shall contain the results of all tests, calculations, inspections, record searches, and observations. It shall contain soil and ground water contamination profiles,

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statistical comparisons, and the results of all sampling events conducted as part of the investigation. It shall display results in tables, graphs, maps, and cross sections as discussed in the Data Management Plan.

The Permittee shall identify all relevant and applicable standards for the protection of human health or the environment (e.g., National Ambient Air Quality standards, Federally-approved State water quality standards, ground water protection standards, etc.)

Data shall be evaluated to ensure it is sufficient in quality (e.g. , quality assurance procedures have been followed) and quantity to describe the nature and extent of contamination, to evaluate the potential threat to human health or the environment, and to support a CMS, if required. The report shall present all data in an Appendix.

General RFI Reporting Requirements

a. Two hard copies and one IBM compatible disk copy of all reports and data shall be submitted by the Permittee to the Administrative Authority as specified in MODULE V.V.B.7.

b. The RFI Workplan shall be submitted by the Permittee to the Administrative Authority as described in MODULE V.N.

c. The RFI Final Report and Summary shall be submit by the Permittee to the Administrative Authority as described in MODULE V.P.

d. Within 90 days of the effective date o·f this Permit, the Permittee shall provide the Administrative Authority with signed, quarterly progress reports as specified in MODULE V .J .1.

W. CMS SCOPE OF WORK

1. Purpose

The purpose of the CMS is to develop and evaluate corrective measures alternatives and to recommend the corrective measure or measures to be taken. The required information shall include each item specified under CMS Tasks IV-VI. The Permittee will furnish the personnel, materials, and services necessary to prepare the CMS, except as otherwise specified.

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If the Permittee believes that certain requirements of the Scope of Work are not applicable, the specific requirements shall be identified and the rationale for inapplicability shall be provided.

2. Scope

The Corrective Measure study consists of three tasks:

Task IV: CMS Plan

a. Description of Current Situation b. Establishment of Corrective Action Objectives c. Description of Approach to CMS d. Schedule for CMS

Task V: Corrective Measures Study

a. Identification of Corrective Measures Alternatives(s)

b. Screening of Corrective Measures Alternatives(s) c. Development of Corrective Measures Alternative(s) d. Evaluation of Corrective Measures Alternative(s) e. Selection of corrective Measures Alternative(s)

Task VI: CMS Final Report and summary

3. Task IV: CMS Plan

a. Description of Current conditions

The Permittee shall briefly describe current conditions at the facility to update information provided in the RFI Final Report and Summary. This shall include previous and/or ongoing remedial activity or interim measures.

b. Establishment of Corrective Action Objectives

The Permittee shall propose to the Administrative Authority for review and approval, facility specific objectives for the corrective action. These objectives shall be based on public health and environmental criteria, information gathered during the RFI, EPA guidance, and the requirements of any applicable Federal statutes and regulations.

c. Description of Approach to CMS

The Permittee shall describe the general approach to the corrective measures study. The approach shall include identification, development, screening, and

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evaluation of the corrective measures alternatives, as discussed in detail in MODULE V. W. 4. The Permittee shall describe specific plans for laboratory and bench-scale studies, or field:studies, if needed. Specific plans for evaluating remedy effectiveness shall also be developed. The approach shall specify formats to be used for data presentation, including raw data, maps, charts, graphs, engineering schematics, construction design, etc.

d. Schedule

The Permittee shall develop a schedule for implementing the corrective measures study, and a schedule for submitting quarterly progress reports on the study implementation.

4. Task V: Corrective Measures Study

The CMS consists of five parts: identification, screening, development, evaluation, and selection of the corrective measures alternative(s).

a. Identification of Preliminary Corrective Measures Alternative(s)

Based on the results of the RFI and the CMS Plan objectives, the· Permittee shall identify all possible alternatives for removal, containment, treatment and/or other remediation of the contamination.

b. Screening Alternatives

of Preliminary Corrective Measures

The Permittee shall screen the identified preliminary corrective measures alternatives to eliminate those that may not prove feasible to implement, that rely on technologies unlikely to perform satisfactorily or reliably, or that do not achieve the corrective action objective within a reasonable time period. This screening process focuses on eliminating those technologies which have severe limitations for a given set of waste and site-specific conditions. The screening step may also eliminate technologies based on inherent technological limitations.

Site, waste, and technological characteristics which are used to screen inapplicable technologies are described in more detail below:

1) Site Characteristics. Site data should be reviewed to identify conditions which may limit or promote the use of certain technologies. Technologies whose use is

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clearly precluded by site characteristics should be eliminated from further consideration;

2) Waste Chara·cteristics. Identification of waste characteristics that limit the effectiveness or feasibility of technologies is an important part of the screening process. Technologies clearly limited by waste characteristics should be eliminated from consideration.

3) Technological Limitations. The level of technology development, performance record, and operation and maintenance problems shall be identified for each technology considered. Technologies that are unreliable, perform poorly, or are not fully demonstrated may be eliminated in the screening process.

c. Development of Corrective Measures Alternatives

The Permittee shall develop corrective measures alternatives based on corrective measures objectives, and identification and screening of preliminary alternatives. The Permittee shall rely on engineering practice to determine which of the previously identified and screened technologies appear most suitable for the site. Technologies can be combined to form the overall corrective measures alternatives. The alternatives developed should represent a workable number of options that each appear to adequately address all site problems and corrective action objectives. Each alternative may consist of an individual technology or a combination of technologies. The Permittee shall document the reasons for excluding technologies.

When a new technology is proposed or similar waste streams have not routinely been treated or disposed of using the technology, the Permittee shall conduct laboratory and/or bench-scale studies to determine the applicability to facility conditions. The Permittee shall analyze the technologies, based on literature review, vendor contracts, and past experience to determine the testing requirements.

1) The Permittee shall develop a testing plan identifying the type(s) and goal(s) of the study(ies), the level of effort needed, and the procedures to be used for data management and interpretation.

2) Upon completion of testing, the Permittee shall evaluate the testing results to assess the technology or technologies with respect to the site-specific questions identified in the test plan.

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3) The Permittee shall prepare a report summarizing the testing program and its results, both positive and negative.

d. Evaluation of Corrective Measures Alternative(s)

The Permittee shall evaluate each corrective measures alternative developed in MODULE V.W.4.c. The evaluation shall be based on technical, environmental, human health and institutional concerns. The Permittee shall also develop cost estimates for each corrective measure.

1) Technical, Environmental, Institutional Concerns

Human Health, and

The Permittee shall provide a description of each corrective measures alternative which includes but is not limited to the following: preliminary process flow sheets; preliminary sizing and type of construction for buildings and structures; and rough quantities of utilities required. The Permittee shall evaluate each alternative in the four following areas:

a) Technical

The Permittee shall evaluate each corrective measure alternative based on performance, reliability, implementability and safety.

(1) The Permittee shall evaluate performance based on the effectiveness and useful life of the corrective measure:

(a) Effectiveness shall be evaluated in terms of the ability to perform intended functions such as containment, diversion, removal, destruction, or treatment. The effectiveness of each corrective measure shall be determined either through design specifications or by performance evaluation. Any specific waste or site characteristics which could potentially impede effectiveness shall be considered. The evaluation should also consider the effectiveness of combinations of technologies.

(b) Useful life is defined as the length of time the level of effectiveness can be maintained. Each corrective measure shall be evaluated in terms of the projected service lives of its component technologies. Resource availability in the future life of the technology, as well as appropriateness of the technologies, must be considered in estimating the useful life of the project.

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(2) The Permittee shall provide information on the reliability of each corrective measure including operation and maintenance requirements and demonstrated reliability: ·-

(a) Operation and maintenance requirements include the frequency and complexity of operation and maintenance. Technologies requiring frequent or complex operation and maintenance activities should be regarded as less reliable than technologies requiring little or straightforward operation and maintenance. The availability of labor and materials to meet these requirements shall also be considered.

(b) Demonstrated and expected reliability is a way of measuring risk and effect of failure. The Permittee should evaluate whether technologies have been used effectively under analogous conditions; whether the combination of technologies have been used together effectively; whether failure of any one technology has an immediate impact on receptors; and whether the corrective measure has the flexibility to deal with uncontrollable changes at the site.

(3) The Permittee shall describe the implementability of each corrective measure including relative ease of installation (constructibility) and total time required to achieve a given level of response:

(a) Constructibility is determined by conditions both internal and external to facility conditions and includes such items as location of underground utilities, depth to water table, heterogeneity of subsurface materials, and location of facility (i.e., remote location vs. congested urban area). The Permittee shall evaluate what measures can be taken to facilitate construction under site specific conditions. External factors which affect implementation include the need for special permits or agreements, equipment availability, and the location of suitable off-site treatment or disposal facilities.

(b) Time has two components to be addressed: the time it takes to implement a corrective measure and the time it takes to see beneficial results. Beneficial results are defined as the reduction of contaminants to acceptable levels as established in the corrective measures objectives.

(4) The Permittee shall evaluate each corrective measures alternative with regard to safety. This evaluation shall include threats to the safety of nearby

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communities and environments as well as those to workers during implementation. Factors to consider include fire, explosion, and exposure to hazardous substances.

b) Environmental

The Permittee shall perform an Environmental Assessment for each alternative. The assessment shall focus on facility conditions and pathways of contamination actually addressed by each alternative. The Environmental Assessment for each alternative will include at a minimum, an evaluation of the short- and long-term beneficial and adverse effects of the response alternative, evaluation of any adverse effects on environmentally sensitive areas, and an analysis of measures to mitigate adverse impacts.

c) Human Health

The Permittee shall assess each alternative in terms of the extent to which it mitigates short- and long-term potential exposure to any residual contamination and protects human health both during and after implementation of the corrective measure. The assessment will describe the levels and characterizations of contaminants on-site, potential exposure routes, and potentially affected populations. Each alternative will be evaluated to determine the level of exposure to contaminants and the reduction over time. For management of mitigation measures, the relative reduction of impact will be determined by comparing residual levels of each alternative with existing criteria, standards, or regulations acceptable to the Administrative Authority.

d) Institutional

The Permittee shall assess relevant institutional needs for each alternative. Specifically, the effects of Federal, State, and Local environmental and public health standards, regulations, guidance, advisories, ordinances, or community ·relations on the design, operation, and timing of each alternative shall be considered.

2) Cost Estimate

The Permittee shall develop an estimate of the cost of each corrective measures alternative and for each phase or segment of the alternative. The cost estimate shall include capital, and operation and maintenance costs.

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a) Capital costs consist of direct and indirect costs.

(1) Direct capital costs include:

(a} Construction costs: Cost of materials, labor (including fringe benefits and worker's compensation), and equipment required to install the corrective measures alternative;

(b) Equipment costs: Costs of treatment, containment, disposal and/or servicing of equipment used to implement the action;

(c) Land and site development costs: Expenses associated with purchase of land and development of existing property; and

(d) Building and services costs: Costs of process and non-process buildings, utility connections, purchased services, and disposal costs.

(2) Indirect capital costs include:

(a) Engineering administration, design, drafting, and. testing alternatives;

expenses: Costs of construction, supervision,

of corrective measures

(b) Legal fees and license or permit costs: Administrative and technical costs necessary to obtain licenses and permits for installation and operation;

(c) Start-up and shakedown costs: Costs incurred during corrective measure start-up; and

(d) Contingency allowances: Funds to cover costs resulting from unforeseen circumstances such as adverse weather conditions, strikes, and inadequate facility characterization.

b) Operation and maintenance costs are post-construction costs necessary to ensure continued effectiveness of a corrective measure. The Permittee shall consider the following operation and maintenance cost components:

( 1) Operating labor costs: Wages, salaries, training, overhead, and fringe benefits associated with the labor needed for post-construction operation;

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(2) Maintenance materials and labor costs: Costs for labor, parts, and other resources required for routine maintenance of facilities and equipment;

(3) Auxiliary materials and energy: Costs of such items as chemicals and electricity for treatment plant operations, water and sewer service, and fuel;

(4) Purchased services: Sampling costs, laboratory fees, and professional fees which· can be predicted;

(5) Disposal and treatment: Costs of transporting, treating, and disposing of waste materials, such as treatment plant residues, generated during operation;

(6) Administrative costs: Costs associated with administration of corrective measures operation and maintenance not included under other categories;

(7) Insurance, taxes, and licensing costs: Costs of such items as liability and accident insurance; real estate taxes on purchased land or rights-of-way; licensing fees for certain technologies; and permit renewal and reporting costs;

(8) Maintenance reserve and contingency funds: Annual payments · into escrow funds to cover costs of anticipated replacement or rebuilding of equipment, and any large unanticipated operation and maintenance costs; and

(9) Other costs: Items that do not fit any of the above categories.

e. Selection of Corrective Measures Alternative(s)

The Permittee shall select a corrective measures alternative using technical, human health, and environmental criteria. At a minimum, the following criteria shall be used to select the final corrective measure or measures.

1} Technical

a} Performance. Corrective measure or which are most effective at performing their functions and maintaining performance over periods of time will be given preference;

measures intended extended

b) Reliability. corrective measure or measures which do not require frequent or complex operation and maintenance activities and have proven effective under

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conditions similar to those anticipated will be given preference;

c) Implementability. corrective measure or measures which can be constructed and operated to reduce levels of contamination to attain or exceed applicable standards in the shortest period of time will be preferred; and

d) Safety. Corrective measure or measures which pose the least threat to the safety of nearby residents and environments as well as workers during implementation will be preferred.

2} Human Health

The corrective measure or measures must comply with existing EPA criteria, standards, or regulations for the protection of human health. corrective measures which provide the minimum level of exposure to contaminants and the maximum reduction in exposure with time are preferred.

3} Environmental

The corrective measure or measures imposing the least adverse impact or greatest improvement on the environment over the shortest period of time will be preferred.

5. Task VI: CMS Final Report and Summary

The Permittee shall prepare a CMS Final Report and summary presenting the results of the CMS and recommending a corrective action program. The Report shall at a minimum include:

a. A summary of all the corrective measures alternatives originally identified, and the screening rationale employed. The results of development of each alternative shall be described, and the evaluation of those developed shall be presented in detail. The report will describe the rationale for selection of a corrective measures alternative, including performance expectations, preliminary design criteria and rationale, general operation and maintenance requirements, and long-term monitoring requirements. The report shall include summary tables which allow the alternative or alternatives to be easily understood. Trade-offs among health risks, environmental effects, and other pertinent factors shall be highlighted.

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b. A proposed corrective action program that will attain compliance with concentration level objectives, control sources of releases, meet acceptable waste management requirements, and protect human health and the environment.

c. Design and implementation precautions, including special technical problems, additional engineering data required, permits and regulatory requirements, access, easements, and right-of-way, health and safety requirements, and community relations activities.

d. Cost estimates and schedules including capital cost estimate, operation and maintenance cost estimate, and project schedule (design, construction, operation).

e. A schedule implementation.

for corrective

General CMS Reporting Requirements

measure (remedy)

a. Two hard copies and one IBM compatible disk copy of all reports shall be submitted by the Permittee to the Administrative Authority as specified in MODULE V.B.7.

b. The CMS Plan shall be submitted by the Permittee to the Administrative Authority as described in MODULE V.R.

c. The CMS Final Report and Summary shall be submitted by the Permittee to the Administrative Authority as described in MODULE V.T.

d. Within 90 days of the date the Permittee is notified to begin a CMS, the Permittee shall provide the Administrative Authority with signed, quarterly progress reports as specified in MODULE V.J.l.

.. f,

,

.. ' ,.

Table 1: RFI/CMS SUBMISSION S~~y

46

Below is a summary of the planned reporting requirements pursuant to this Permit:

Actions

Progress reports on all activities

RFI Workplan

Revised RFI Workplan

RFI Report and Summary

Revised RFI Report and Summary

Notification of newlyidentified SWMUs

Notification of newlydiscovered releases

Interim Measures Plan

Revised Interim Measure Plan

CMS Plan

Due Date (examples)

quarterly; no later than ninety (90) calendar days after effective date of Permit

120 calendar days after the effective date of the Permit

as determined by the Administrative Authority, usually within thirty (30) calendar days of receipt of NOD

sixty (60) calendar days after completion of RFI


thirty (30) calendar days after discovery

fifteen (15) calendar days after discovery

as determined by the Administrative Authority

as determined by the Administrative Authority

forty-five (45) calendar days after notification of requirement to perform CMS

,

.. \ .

Revised CMS Plan

CMS Final Report and Summary

Revised CMS Final Report

Demonstration of Financial Assurance at Facility

47


sixty (60) calendar days after completion of CMS

as determined by the Administrative Authority, usually thirty (30) calendar days after receipt of NOD

one hundred and twenty (120) calendar days after permit modification to implement corrective measures

Table 2: SWMUs REQUIRING AN RFI

Below is a list of the SWMUs requiring an RFI.

SWMU 18 - McGregor "Rubble Pit" (Landfil No. 13) SWMU 19 - McGregor Range Oxidation Pond SWMU 20 - Inactive Open Detonation Area SWMU 25 - Oro Grande "Rubble Pit" (Landfill No.14) SWMU 25B- Oro Grande Oxidation Pond SWMU 27 - Dona Ana "Rubble Pit" (Landfill No. 12) SWMU 27B- Dona Ana Oxidation Pond SWMU 29 - Landfill No. 11 SWMU 76 - Meyer Range Oxidation Pond

SWMU 21 - McGregor Range Fire Training Area * SWMU 22 - McGregor Range Former Drum Storage Area *

* - SWMUs added in 1998

48

48

~able 2: SWMUs REQUIRING AN RFI

Below is a list of the SWMUs requiring an RFI.

SWMU 18 - McGregor "Rubble Pit" (Landfil No. 13) SWMU 19 - McGregor Range Oxidation Pond ---'F" ~o.:t.:;, il.;UQ. ~ce.c SWMU 20 - Inactive Open Detonation Area Sv&~'~'e 0

SWMU 25 - Oro Grande "Rubble Pit" (Landfill No.14) ~ SWMU 25B- Oro Grande Oxidation Pond ,_ - -SWMU 27 - Dona Ana "Rubble Pit" (Landfill No. 12) SWMU 27B- Dona Ana Oxidation Pond ---------------.+ SWMU 29 - Landfill No. 11 SWMU 76 - Meyer Range oxidation Pond ·--------~

TABLE 2

U.S. Anny Fort Bliss


NMED Control Copy

Page Modified December 15,2004

LIST OF SOLID WASTE MANAGEMENT UNITS (SWMUs) AND AREAS OF CONCERN (AOCs) REQUIRING CORRECTIVE ACTION

SWMU/AOC DESCRIPTION COMMENTS

18 McGregor Range Rubble Pit Inactive since approximately 1983 Landfill No. 13

19 Active McGregor Range Active since 1972 Evaporation Pond

20 McGregor Range Open Inactive since approximately 1960s Detonation Area

25 Orogrande Range Rubble Pit Dates of operation: 1950s to 1984 Landfill No. 14

26 Dona Ana Range Open Dates of operation: 1940s to 1997 Detonation Area

27 Dona Ana Range Rubble Pit Dates of operation: 1950s to 1984 Landfill No. 12

27B Active Dona Ana Range Active since 1965 Evaporation Pond Dona

29 Dona Ana Range Sanitary Inactive since approximately 1945 Landfill No. 11

76 Active Myer's Small Arms Active since 1969 Range Oxidation Pond

81 Organ Mountain Station Dates of operation unknown

-----

TABLE 3 LIST OF SOLID WASTE MANAGEMENT UNITS (SWMUS) AND AREAS OF CONCERN

U.S. Army Fort Bliss


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Page Modified December 15,2004

(AOCS) NOT CURRENTLY REQUIRING CORRECTIVE ACTION

SWMU/AOC DESCRIPTION DATE OF COMMENTS NFA

APPROVAL 17 Subpart-X Open Detonation DNA Active, permitted open

detonation unit 21 McGregor Range Fire Training Area Pending Inactive since

approximately 1983 22 McGregor Range Inactive Waste Drum Pending Inactive since

Storage approximately 1991 66 McGregor Range Borrow Pit Drum Burial Pending Dates of operation

Site unknown 78 Hueco Range Camp Pending Inactive since

approximately J.960_s ·-

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