A04__BIA_FY_2026_TCD_Solid_Waste_Disposal_SOW.pdf

Table of Contents

Tuba City Dump Solid Waste Disposal and Purchase of Soil Borrow

SECTION ............................................................................................................................................................ PAGE

1.0 BACKGROUND

2.0 STATEMENT OF WORK

3.0 WASTE EXCAVATION, CHARACTERIZATION, AND TRANSPORTATION

3.1 Waste Excavation

3.2 Waste Characterization

3.3 Waste Transportation

3.4 Soil Borrow

4.0 PERIOD OF PERFORMANCE

5.0 DELIVERABLES

1.0 Background

Pursuant to the Administrative Order on Consent, dated November 28, 2023, between the Environmental Protection Agency (EPA), Region 9 and the Bureau of Indian Affairs (BIA), BIA is working on the cleanup and closure of the Tuba City Dump (TCD) under Section 7003 of the Resource Conservation and Recovery Act, 42 U.S.C. 6901, et. seq., as amended (RCRA). The BIA will complete the cleanup and closure of the TCD over several years under annual fiscal year (FY) work plans developed by BIA and the Hopi Tribe to determine the work needed in each FY with the funding available for that year and the overall progress and pace of the project.

The Hopi Tribe has contracted with the BIA to perform construction and solid waste removal activities and associated planning and community outreach for the cleanup and closure of the TCD under the Indian Self-Determination and Education Assistance Act, P.L. 93-638. The Hopi Tribe’s Department of Natural Resources administers the Hopi Tribe’s contractual obligations under this contract.

Through this process, the Hopi Tribe has contracted with Haley Aldrich to construct an access road and staging area with that work planned to be completed in July 2026. After that, beginning on July 31, 2026, Haley Aldrich will manage the excavation, characterization, transportation, and disposal of at least an estimated 20,000 loose cubic yards (LCY), with Hopi Tribal plans to increase the contract for the removal of an additional 50,000 LCY.

2.0 Statement of Work

This work involves the permanent acceptance of a base or minimum amount of 70,000 LCY of TCD solid waste at a RCRA Subtitle D compliant landfill/disposal facility for a one-year period with the possibility of increasing the LCY amount during this one-year period.

Solid waste densities will vary with an estimated density range of 1.2 to 1.7 tons/LCY.

Corresponding tons disposed of at the facility range from 84,000 tons to 119,000 tons of TCD solid waste processed for disposal. Based on recent density data, an average density of 1.4 tons/LCY will be used indicating that the estimated tons to be disposed of at the facility is 98,000 tons.

Solid waste disposed of at the facility will meet the requirements of the disposal facility. Solid waste disposed of at the facility will meet EPA solid waste designation requirements. Waste characterization will occur to ensure that the waste is not hazardous.

After the disposal of 20,000 LCY of TCD solid waste, the construction contractor will be, after TCD waste disposal, backhauling soil borrow at 50,000 LCY from the facility to the Tuba City Dump Site. The estimated soil borrow purchase is 50,000 LCY.

Based on the 24-ton and 24 LCY tonnage and capacity limits, respectively, of the haul trucks and density variability, each truck will contain between 14 and 20 LCY at up to 24 tons per truck.

Initially, ten trucks will be making two trips to the facility per day or 280 to 400 LCY and up to 480 tons per day. The number of trucks may increase to 20 trucks making two trips to the facility per day or 560 to 800 LCY and up to 960 tons per day.

3.0 Waste Excavation, Characterization, and Transportation

The facility will be receiving TCD solid waste during the operating hours of the facility. This effort will occur continuously, other than holidays and possible field condition issues until 70,000 LCY is disposed of at the

The BIA has completed the characterization needs for waste disposal. Since the Hopi Tribe has contracted to conduct waste characterization planning and implementation pursuant to its Self- Determination Contract, the Hopi Tribe is managing the waste characterization through the attached Draft Sampling and Analysis Plan (Plan), dated February 2023. The Plan is currently being reviewed by Haley Aldrich with plans to finalize that plan prior to waste characterization work.

Additionally, the Hopi Tribe completed a waste characterization report, Waste Characterization, dated August 14, 2024 (copy attached) that included comparing field measurements of radioactivity compared to laboratory measurements for radium isotopes.

The construction contractor will excavate, transport, and store solid waste in 1,000 cubic-yard stockpiles on the staging area. The staging area encompasses approximately 4.7 acres on the south side of the west disposal cell. The waste staging area construction includes 4.0 inches of asphalt underlain by 8-inches of base course. The staging area is designed for waste loading, waste unloading, waste staging, and storage of equipment and materials. The staging area is graded to drain stormwater into a collection basin. The area established for waste management is planned to accommodate eleven (11) 1,000 LCY waste piles. The staging area is secured by an eight-foot-high steel, security fence.

The construction contractor will scan the excavated waste for radioactivity, sample the stockpile at the staging area, process the samples for analysis for contaminants of concern, and haul the solid waste to the disposal facility. These efforts are described in the draft Radiological Waste Handling and Disposal Plan, dated June 2023 (copy attached). This document will be adopted by the construction contractor and possibly updated prior to excavation and characterization work.

3.1 Waste Excavation

Operators and equipment to excavate waste and load on to on-site transport trucks. These dump trucks, with at least a 12-cubic yard hauling capacity, will transport material from waste excavations to the staging area, and stage the waste in 1,000 LCY stockpiles. On-site radiological monitoring/screening will occur during excavation. Personnel will provide oversight of the excavation progress and verify waste removal.

The construction contractor will sample, containerize, transport, and analyze the solid waste in accordance with the Plan. Waste samples will be collected, containerized, and preserved in accordance with the relevant testing procedures and shipped under a chain of custody to a certified analytical laboratory for analysis. The samples will be analyzed for parameters, as directed by the receiving landfill, for waste acceptance.

During excavation, decontamination pads, tracking controls, silt fencing along the perimeter of the work area, and water diversion structures to divert or contain stormwater runoff will be used to prevent cross-contamination from stormwater runoff, and migration of contaminants from vehicles moving from impacted to clean areas of the site.

Areas where the waste contacts the water table will be dewatered during waste excavation. While the excavation is open, the groundwater shall be maintained below the working level. Shoring, as required, will be installed to protect project personnel.

3.2 Waste Characterization

Eleven (11) or more, stockpiles, measuring approximately 70 feet x 70 feet x 8 feet, will be placed at the staging area. Personnel will sample, store, and ship soil samples to a laboratory.

Personnel will perform sorting and segregation of waste (e.g. asbestos containing materials, tires, appliances, and recyclable waste (e.g. steel). Sorted materials will be segragated and appropriately managed at the staging area. Segragated waste will be properly transported and disposed of at an approved facility. Discovery of radioactive materials will result in a stoppage of work with actions taken in accordance with the draft Radiological Waste Handling and Disposal Plan can be implemented.

Excavated waste will be scanned for radiological materials by a certified Radiological Control Technician (RCT) using calibrated sodium-iodide probes or equivalent devices prior to being loaded onto dump trucks and transported to the staging area. Additionally, each haul truck leaving the site for disposal of waste material at the facility will be scanned for radiological materials by the RCT using previously described devices.

Radiological scanning will be performed as a precaution, due to the proximity of the former Rare Metals uranium processing facility (located approximately 3.5 miles northeast of the TCD on U.S. Highway 160). Should radiological materials be encountered, project operations will cease until implementation of the draft Radiological Waste Handling and Disposal Plan occurs to safely manage and dispose of the radiological materials. Based on several TCD waste characterization studies, no radiological materials are anticipated in the waste stream.

3.3 Waste Transportation

Initially, operators and dump trucks will be delivering ten truckloads, not to exceed 24 tons of waste per truck, of waste to the facility twice per day. Although the trajectory of waste transportation increases and dispoal frequency is not known, waste hauling delivery amounts are planned to increase to 20 trucks per day, arriving at the facility twice daily. Each truckload will not exceed 24 tons, of waste to the facility twice per day;

Haul trucks transporting waste from the TCD to the specified landfill must be in good condition and meet Arizona Department of Transportation safety requirements. The haul routes identified in the request for proposal will be followed for transporting waste to the accepting facility. A waste manifest for each waste load will be completed in accordance with disposal facility requirements. Copies of each fully executed waste manifest will be provided to the BIA along with scale tickets for each load disposed of at the landfill.

3.4 Soil Borrow

The Hopi Tribe has identified and made available soil borrow for waste excavation backfill and the construction of the access road and staging area. Borrow is permitted from a nearby source on Hopi Tribal land. The volume of available Hopi borrow will not be sufficient for the project and additional borrow at 50,000 LCY will need to be obtained from the facility. The construction contractor will provide the necessary equipment, initially planned to include an excavator and water truck for dust suppression when loading the soil borrow at the facility, and the installation of an on-site water tank. The facility shall provide an onsite water source for the construction contractor to utilize for dust suppression.

The construction contractor will ensure that the borrow will meet the requirements described in the construction specifications. The construction contractor will provide the operators and equipment needed to perform verification density testing of backfill materials to meet the requirements of the construction specifications. After the disposal of 20,000 LCY, the construction contractor will be, after TCD waste disposal, backhauling soil borrow at the rates described in Section 2.

4.0 Period of Performance

The period of performance will consist of one (1) 12-month base year and two (2) 12-month option years (OYs) as follows:

Base Year: TBD

OY 1: TBD

OY 2: TBD

Each OY will provide for a base or minimum amount of 20,000 LCY of solid waste or soil borrow or an estimated minimum of 24,000 tons of solid waste.

5.0 Deliverables

The facility shall provide BIA with fully executed waste manifests. The facility accepting the TCD solid waste will hold the BIA harmless from any liability associated with the TCD solid waste.