Attachment 12 - JBSA-Soil Management Plan - Signed Jan 22.pdf

JOINT BASE SAN ANTONIO

SOIL MANAGEMENT PLAN

PREPARED FOR:

Joint Base San Antonio (JBSA), Texas

PREPARED BY:

802d Civil Engineering Squadron Joint Base San Antonio (JBSA), Texas

January 2022

Mission ~ Wingman ~ Partners

DEPARTMENT OF THE AIR FORCE

502D AIR BASE WING

JOINT BASE SAN ANTONIO

10 Jan 22

MEMORANDUM FOR RECORD

FROM: 802 CES/CL

SUBJECT: Annual Review of JBSA Soil Management Plan

1. An annual evaluation of the JBSA Soil Management Plan was conducted on 10 Jan 22 and the plan updated to reflect any administrative changes.

2. The review of this plan since the last annual evaluation would include a determination of the effectiveness of the plan and the accuracy of any administrative information.

3. For any questions or comments on the Soil Management Plan, contact Mr. C. Kaurian Butler- Edwards, charles.butler-edwards@us.af.mil, 210-671-4961.

JOSEPH S. HOCKADAY, P.E., GS-15

Director, 802d Civil Engineer Squadron

JBSA Soil Management Plan

TABLE OF CONTENTS

JOINT BASE SAN ANTONIO

SOIL MANAGEMENT PLAN

TABLE OF CONTENTS .......................................................................................................................... i

LIST OF ABBREVIATIONS / ACRONYMS

FOREWORD

1. INTRODUCTION / PURPOSE

2. APPLICATION

3. DEFINITIONS

4. DOCUMENTATION, RESPONSIBILITIES, AND COORDINATION

4.1. Project Planning Documents

4.2. Initial Request

4.3. Soil Sampling Determination

4.4. Responsibilities and Coordination

5. SOIL PROFILING

5.1. Soil Profile Stages

6. SOIL MANAGEMENT PROCEDURES

6.1. Soil Generated On-base

6.2. Incoming Soil from Off-base

6.3. Off-base Disposal

6.4. Explanation of Required Analysis Parameters

6.5. Other Soil Management Options

7. REFERENCES

APPENDIX A - JBSA Clean Soil Management Contacts APPENDIX B - Sample of Air Force Forms APPENDIX C - Soil Reuse Request Form APPENDIX D - Incoming Material Analytical Requirements Form

APPENDIX E – SOIL MANAGEMENT FLOW CHARTS

APPENDIX F - JBSA Soil Disposal Matrix

LIST OF ABBREVIATIONS / ACRONYMS

502 CES 502d Civil Engineer Squadron 502 CES/CEO 502d Civil Engineer Squadron/Operation Services 802 CES 802d Civil Engineer Squadron 802 CES/CEIE 802d Civil Engineer Squadron Environmental Management 802 CES/CEN 802d Civil Engineer Squadron Engineering Flight AF Air Force EPA Environmental Protection Agency HW Hazardous Waste IDW Investigation Derived Waste ISW Industrial Solid Waste JBSA Joint Base San Antonio BUL Joint Base San Antonio-Camp Bullis C&D Construction and Demolition CTA Joint Base San Antonio-Chapman Training Annex LAK Joint Base San Antonio-Lackland RND Joint Base San Antonio-Randolph MCL Maximum Contaminant Level MMRP Military Munitions Response Plan MSW Municipal Solid Waste SMP Soil Management Plan TAC Texas Administrative Code TCEQ Texas Commission on Environmental Quality TCLP Toxicity Characteristic Leaching Procedure TSDF Treatment, Storage or Disposal Facility PRT JBSA Port Annex (PRT) KFA Joint Base San Antonio -Kelly Field Annex SAM Joint Base San Antonio -Fort Sam Houston MCA Joint Base San Antonio -Medical Center Annex GSA Joint Base San Antonio -Grayson Street Annex BUL Joint Base San Antonio -Bullis SAF Joint Base San Antonio -Seguin Auxiliary Field CAN Joint Base San Antonio -Canyon Lake

FOREWORD

This document updates and supersedes all previous versions of the soil management plan applicable at Joint Base San Antonio (JBSA) facilities. No regulatory requirements for a Soil Management Plan (SMP) exist, however this document has been prepared in an effort to limit the legal liability of both JBSA and its contractors and personnel at the recommendation of State regulators. It is recommended that this document be reviewed every 5 years for continued relevancy. The Office of Primary Responsibility for this document is the 802d Civil Engineer Squadron Environmental Management Section (802 CES/CEIE). This office will coordinate with the JBSA Civil Engineer (CE) Program Managers and other facility staff as appropriate. Individual organizational contacts are provided in Appendix A including contacts from 502 CES/CEN (Engineering, Programming, Community Planning), and 802 CES/CEIE (the JBSA Environmental Compliance Chief, Solid and Hazardous Waste Managers, Environmental Protection Specialists). The procedures described in this document consider, as appropriate, applicable regulations, cost-effectiveness, efficiency, safety, and timely management of all excess soil, either generated on base or brought on base during various construction projects. Additional directives regarding soil management, analysis associated verification of classification status, and responsibilities thereof can be found in the JBSA Environmental Specification (01 57 20). The Environmental Specification is applicable to all entities operating on properties associated with JBSA, is provided by contracting to all contractors, and can also be obtained through 802 CES/CEIE contacts; see Appendix A.

1. INTRODUCTION / PURPOSE

The purpose of this JBSA Soil Management Plan (SMP) is to provide guidance to site contractors and other JBSA organizations on soil management practices. Soil excavated on base, and/or imported/exported soil, shall be handled properly to avoid intermingling resulting in hazardous constituents. This plan also promotes the conservation and on-site reuse of approved soil at all JBSA locations including but not limited to JBSA-Randolph (RND), JBSA-Lackland (LAK), JBSA-Chapman Training Annex (CTA), JBSA-Port Annex (PRT), JBSA-Kelly Field Annex (KFA), JBSA-Fort Sam Houston (JBSA-SAM), JBSA- Medical Center Annex (MCA), JBSA-Grayson Street Annex (GSA), JBSA-Bullis (BUL), JBSA-Seguin Auxiliary Field (SAF), and JBSA-Canyon Lake (CAN). In addition, it provides for coordination between 802 CES/CEIE, 802 CES/CEN Program Managers and Contractors. This document provides guidance for all JBSA personnel, including but not limited to Air Force (AF) Project Engineers; Design Engineers; Planners; Contracting Agents; Contractors and Environmental Program Managers. This SMP addresses the following:

• Assigns roles and responsibilities of various JBSA organizations regarding soil management procedures;

• Ensures that soil that is excavated onsite, brought onto JBSA facilities, or leaves JBSA facilities does not become contaminated;

• Promotes the on-site reuse of soil;

• Provides a process for determining whether soil is contaminated; and

• Provides a tracking method for soil disposition at JBSA facilities.

2. APPLICATION

This SMP applies for all entities involved in construction, demolition, and maintenance (including servicing utilities) for JBSA facilities, in accordance with Department of Defense (DoD) Regulation 5400.7/AF Supplement, 22 Jul 99, DoD Force Freedom of Information Act. Operational Security and Communication Security are incorporated into this plan and must be executed by anyone using the plan.

The SMP applies to:

• Excess soil generated by JBSA projects;

• Fill dirt, gravel, spoils, sand, soil, aggregate, and infrastructure supporting earthen material required by JBSA projects;

• Soil imported for JBSA use;

• Soil disturbed due to on-property projects of any nature;

• Investigation Derived Waste (IDW).

Implementation of this SMP is effective immediately and is intended for use on all JBSA on-property projects that use or disturb soil. Please note that use of the SMP is not applicable for any spill and/or emergency response, leaks, or releases that may impact soil within the site from daily facility operations. These incidents may require reporting and subsequent coordination with the appropriate local, state, and federal agencies as required.

3. DEFINITIONS

Class 1 Waste. Any non-hazardous industrial solid waste or mixture of industrial solid wastes which, because of its concentration, or physical or chemical characteristics, is toxic, corrosive, flammable, a strong sensitizer or irritant, a generator of sudden pressure by decomposition, heat, or other means, or may pose a substantial present or potential danger to human health or the environment when improperly processed, stored, transported, or disposed of or otherwise managed, as further defined in the Texas Administrative Code (TAC), Title 30 (Environmental Quality), Part 1 Texas Commission on Environmental Quality (TCEQ), Chapter 335 (Industrial Solid Waste and Municipal Hazardous Waste), Subchapter R (Waste Classification), Rule §335.505 (Class 1 Waste Determination).

Class 2 Waste. Any individual non-hazardous solid waste or combination of industrial solid waste which cannot be described as hazardous, Class 1 or Class 3 as defined in 30 TAC 335, Subchapter R, Rule §335.506.

Class 3 Waste. Inert and essentially insoluble non-hazardous industrial solid waste, usually including but not limited to, materials such as rock, brick, glass, dirt, and certain plastics and rubber, etc., that are not readily decomposable, as further defined in 30 TAC 335 Subchapter R Rule §335.507 (relating to Class 3 Waste Determination).

Clean Fill/Clean Soil. For the purposes of this plan, the term ‘Clean Soil’ refers to soil that qualifies as Class 3 non-hazardous inert Solid Waste according to the 7-day leachate testing method as prescribed by the Texas Commission on Environmental Quality (TCEQ). Soil is designated as ‘Clean Soil’ based on 802 CES/CEIE confirmation. Contact POCs outlined in Appendix A for further details.

Contractor. A person or operator, including a utility provider, who performs construction, maintenance, or other work activities on the property of any JBSA facility pursuant to a contract, lease, or agreement with the AF.

Hazardous Waste. Any solid waste identified or listed as a HW by the Administrator of the Environmental Protection Agency (EPA) under the Federal Solid Waste Disposal Act, as amended by Resource Conservation and Recovery Act (RCRA), 42 United States Code, §§ 6901 et seq., as amended. Soil must be tested according to the analytical methods outlined in the JBSA Environmental Specification (01 57 20) to eliminate hazardous categorization in order to be managed as non-hazardous. Determinations made by 802 CES/CEIE personnel.

Industrial Solid Waste. Industrial solid waste means solid waste generated by manufacturing or industrial processes that is not a HW regulated under Subtitle C of RCRA.

Industrial solid waste may include, but is not limited to, waste resulting from industrial/ commercial activities such as, electric power generation, fertilizer/agricultural chemicals, food and related products/by-products, nonferrous metals manufacturing/foundries, organic chemicals, plastics and resins manufacturing, pulp and paper industry, rubber and miscellaneous plastic products, stone, glass, clay, and concrete products, textile manufacturing, transportation equipment, water treatment, and impacted soils from industrial and/or manufacturing activities.

Municipal Solid Waste Construction and Demolition (C&D) Waste. Construction and demolition waste is defined in the 30 TAC 330 Rule §330.3(33) Construction or Demolition waste--Waste resulting from construction or demolition projects; includes all materials that are directly or indirectly the by-products of construction work or that result from demolition of buildings and other structures, including, but not limited to, paper, cartons, gypsum board, wood, excelsior, rubber, and plastics.

Proponents. Those planning or requiring work, including, but not limited to the 502d Civil Engineer Squadron (502 CES) Operation Services (CEO) units, the 802d Civil Engineer Squadron (802 CES) and subordinate units/flights, Aircraft Maintenance Units, Maintenance Engineering, “Self Help”, all Training Wing Units, and all JBSA Associated Units and mission partners. The 802 CES/CEN (Engineering Flight) will typically be the project proponent for initiating actions under this SMP.

Produced Water. Wastewater produced during construction/demolition activities including incidental rainwater.

Service Provider. The organization that will perform the project work, which can include, but not limited to 502 CES/CEO, RED HORSE, US Army Corps of Engineers, and utility and private contractors.

Site (or on-site). This refers to the project location boundaries (site footprint) and not JBSA, or “nearby,” or any other designation. The 802 CES/CEN and 802 CES/CEIE should be consulted and will advise on the physical boundaries of the project site when they are not obvious to preclude any potential misinterpretation.

Soil. Any such material as soil, dirt, fill, gravel, sand, rock, aggregate, alluvium, crushed concrete, construction soils/spoils, demolition material, backfill, topsoil, engineering fill or earthen material.

Soil Management. The transportation, treatment, storage, testing, and on-site reuse and/or disposal of soil and includes soil that is imported, soil disturbed due to on-property projects, soil that is disturbed in the process of contaminant remediation, and IDW.

Solid Waste. Per 40 CFR 261.2, a Solid Waste is any material that is: abandoned by disposal/burning/incinerating; accumulated, stored, or treated before/in lieu of disposal/burning/incinerating; recycled; accumulated, stored, or treated before recycling;

considered inherently waste-like; or a military munition. See the JBSA Soil Disposal Matrix or 40 CFR 261.2 for further details.

Waste Management. The on-site storage, sampling, analytical testing, waste characterization, profile/manifest generation, on-site reuse, transportation and/or disposal.

4. DOCUMENTATION, RESPONSIBILITIES, AND COORDINATION

4.1. Project Planning Documents

Project planning and permitting documents such as AF Form 813, AF Form 103, etc., shall be first coordinated with the 802 CES/CEN and the 802 CES/CEIE in order to determine siting, environmental requirements and constraints. Proper coordination helps establish requirements for civil engineer Tririga work order requests, AF Form 813 (Environmental Impact Analysis), and AF Form 103 (digging permit) with entities such as Fire Department, Safety Office, etc.

4.2. Initial Request

The project proponent will initiate a Soil Management Form (Appendix B), cost estimate, and disposition with the 802 CES/CEIE. Initial coordination also allows preliminary assessment of project specific sampling, laboratory analysis, waste characterization, and disposal requirements by the 802 CES/CEIE Hazardous Waste team in accordance with the JBSA Environmental Specification (01 57 20).

4.3. Soil Sampling Determination

4.3.1. The 802 CES/CEIE Hazardous Waste team makes the determination of whether or not soil sampling according to the JBSA Environmental Specification (01 57 20) is required at a project site. The determination is based on available historic information, analytical data, past/current practices, process knowledge, and other considerations. Advanced planning and coordination of at least 30 days prior with the 802 CES/CEIE is recommended for the most economical soil management.

https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-261

4.3.2. If sampling is required, soil characterization shall be performed prior to soil importation or excavation. The designated Project Manager must survey the site for visual evidence of a spill or other contamination of soil. Soil samples will be collected as described in the project specific Soil Screening Plan in accordance with the JBSA Environmental Specification (01 57 20). Typically, this involves visual and olfactory soil observations, PID readings, headspace analysis, and soil sampling and/or supplier documentation.

4.3.2.1. All soils fitting the definition of Solid Waste as outlined by 40 CFR 261.2 will require sampling per State requirements regardless of the aforementioned factors. A complete list of exemptions from this definition is available in 40 CFR 261.4(a)(1)-(22). Should the proponent believe an exemption to be applicable, a request for exemption shall be submitted to the 802 CES/CEIE for consideration and soil disposition. All requests for exemption are subject to the approval of the 802 CES/CEIE.

4.3.2.2. Soils not fitting the definition of Solid Waste per

40 CFR 261.2 are still subject to Toxicity Characteristic Leaching Procedure (TCLP) sampling and analysis for delineation of hazardous/nonhazardous status per State requirements. All analysis shall be submitted to the 802 CES/CEIE for review and disposition prior to action.

4.3.3. During digging/excavation/earth moving, should anything unusual or unexpected be encountered, work should stop. A representative from the 802 CES/CEIE shall be contacted to investigate the discovery.

4.4. Responsibilities and Coordination

4.4.1. Project Proponent. The 802 CES/CEN will typically be the project “proponent” for initiating actions under this SMP, however, not always. Responsibilities include: securing approval from the 802 CES/CEIE for project-specific soil management in accordance with the JBSA Environmental Specification (01 57 20); acting as liaison between 802 CES/CEIE and the project Contractor; ensuring excess soil is managed in accordance with this SMP; and providing follow-up data to the 802 CES/CEIE Water Program Manager for the facility.

The project proponent’s responsibilities are as follows:

4.4.1.1. For each project, the proponent shall be responsible for initial planning and coordination with 802 CES/CEIE including, but not limited to, providing an estimate of excess soil (in cubic yards) that will be generated by construction activities, and a map showing the excavation boundaries.

4.4.1.2. Proponent shall coordinate with the 802 CES/CEIE to determine if the excess soil is likely to be clean inert soil (request for Soil Profile Screening) based on historic information or by obtaining appropriate analytical data in accordance with the JBSA Environmental Specification (01 57 20). If soil cannot be classified as clean inert soil, sampling and analysis is required for all soil planned for disposal at an off-base disposal facility; see the JBSA Environmental Specification (01 57 20) for detailed requirements. Program/Project Managers and their Contractors are responsible for ensuring the integrity of any soil transported https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-261 off base to an approved disposal facility regardless of classification status. The 802 CES/CEIE will not inspect actual project soil.

4.4.1.3. Proponent shall coordinate with the 802 CES/CEIE to develop an estimate for sampling, analysis, transportation, and soil management requirements in accordance with the JBSA Environmental Specification (01 57 20).

4.4.1.4. Proponent shall implement procedures, or delegate responsibility to the service provider, and adhere to guidelines and restrictions as follows:

4.4.1.4.1. Accomplish the initial planning and coordination

requirements reusing the maximum amount possible of the soil generated during site preparation and construction on the project site or used for another approved beneficial use on the installation.

4.4.1.4.2. Proponent acknowledges that off-site soil staging is NOT permitted at any JBSA property. All soil excavated from JBSA property that is to be transported offsite for disposal will require testing and manifesting as outlined in the JBSA Environmental Specification (01 57 20) in accordance with TCEQ guidance and permitted landfill requirements.

4.4.1.4.3. Facilitate the analysis of the samples for the specified constituents and test methods as required by the JBSA Environmental Specification (01 57 20) in accordance with TCEQ guidance and permitted landfill requirements for all excavated soils that are to be transported offsite for disposal. Provide the complete laboratory analysis report, including analytical results, chain-of-custody, and quality control data to the 802 CES/CEIE.

4.4.1.4.4. Coordinate with the 802 CES/CEIE for soil management in accordance with the JBSA Environmental Specification (01 57 20), including: 1) management of soil free from any construction debris; 2) management of demolition debris or any other type of debris on-base; and/or, 3) management/transport of impacted soil (waste) off-base as directed by the 802 CES/CEIE. For reference, all soils containing man-made constituents or debris are considered impacted soil and are therefore treated as nonhazardous municipal solid C&D waste when transported off JBSA property in accordance with guidance from the TCEQ. Soils originating from KFA are considered to be hazardous until proven otherwise and must be managed accordingly. All soils intended for transport off JBSA property require testing in accordance with State requirements.

4.4.1.5. Within 30 days of excavating soil that is disposed offsite, proponent shall provide documentation with an estimate of the amount of soil excavated and transported off base to a TCEQ-permitted disposal facility to the 802 CES/CEIE (ref: JBSA Environmental Specification).

4.4.1.6. For material to be disposed of off base, coordinate with the 802 CES/CEIE to select a facility permitted by the TCEQ appropriate to the class of waste/recycled material to be disposed in accordance with the JBSA Environmental Specification (01 57 20). Before transporting waste/materials off the installation, provide the waste profile sheet, analytical results, and process knowledge sheets to 802 CES/CEIE (HW Manager) for signature during normal business hours (7:00 a.m. to 4:00 p.m., Monday through Friday) in accordance with the JBSA

Environmental Specification (01 57 20). Once signed, the proponent shall provide said documents to the proposed receiving facility for review/approval purposes. The proponent shall prepare the waste manifests for signature by the 802 CES/CEIE and ensure the final manifests from the disposal facility are provided to the 802 CES/CEIE within 30 days upon off-site disposal of excess soils. For further details and guidance, please see the JBSA Environmental Specification (01 57 20) or contact the 802 CES/CEIE; see Appendix A for POCs.

4.4.1.7. Maintain records of amount and location of soil managed either on or off base in accordance with the JBSA Environmental Specification (01 57 20).

4.4.2. Environmental Management Section Responsibilities. The 802 CES/CEIE personnel responsibilities under this SMP are as follows:

4.4.2.1. Provide initial planning and coordination support as stated in Section

4.4.1. to include proper designation of soil for future management and, if applicable, determination of need to perform analytical sampling and sampling parameters.

4.4.2.2. Upon receipt of excess soil analytical results, advise Contractor to coordinate with the 802 CES/CEIE in accordance with the JBSA Environmental Specification (01 57 20) for soil classification and available soil management options, and approve/disapprove the treatment, storage and disposal facility (TSDF) chosen by the proponent.

4.4.2.3. Sign or secure signature for all manifests in accordance with the JBSA Environmental Specification (01 57 20) and, if hazardous, track and report all wastes/soils manifested from the property of any JBSA facility.

4.4.3. Operations Flight Responsibilities. The 502 CES/CEO will no longer operate/maintain soil management areas at JBSA properties.

4.4.4. Environmental Stormwater Program Responsibilities. The 802 CES/CEIE Water Program Manager will ensure that any JBSA soil management areas (project sites) are compliant with applicable stormwater permitting and best management practices in accordance with the JBSA Environmental Specification (01 57 20).

5. SOIL PROFILING

5.1. Soil Profile Stages. There are several stages where soil profiling can occur during any given project that may generate excess soils. They include:

5.1.1. When a project is first identified, if it has been determined that excess soil will be generated, the proponent will initiate communication through the 802 CES/CEN Project Manager. The 802 CES/CEIE will be contacted for application of process knowledge, determination of sampling requirements (number and location of samples), analytical parameters, and soil reuse or disposal options in accordance with the JBSA Environmental Specification (01 57 20) if not previously specified.

5.1.1.1. If the 802 CES/CEIE determines that soil sampling and analysis is necessary for soil management prior to any site activities, at least one representative soil sample will be collected per 200 cubic yards in accordance with the JBSA Environmental Specification (01 57 20), with no less than two samples collected at the project site. This sampling requirement may be changed at the discretion of the TSDF and 802 CES/CEIE.

5.1.2. When project excess soils are generated and initial screening was not completed, the proponent will initiate communication through the 802 CES/CEN Project Manager and the 802 CES/CEIE prior to soil management activities in accordance with the JBSA Environmental Specification (01 57 20).

5.1.2.1. Due to lack of historical or process knowledge of the project location, if the 802 CES/CEIE determines that samples are required for classification, at least one sample will be taken for every 200 cubic yards of excess soil in accordance with the JBSA Environmental Specification (01 57 20). This requirement may be changed at the discretion of the receiving facility and the 802 CES/CEIE. The 802 CES/CEIE will advise on the analytical parameters. Receipt of analytical data will be approximately 30 working days from the date the sample(s) are collected.

5.1.3. When excess soil already exists, the 802 CES/CEIE will coordinate with other CE functions to determine the source of the soil and apply process knowledge. If the 802 CES/CEIE determine that soil analyses should be performed, soil sampling will be performed in accordance with the JBSA Environmental Specification (01 57 20).

5.1.4. As determined by the 802 CES/CEIE, all soils that cannot be reused at the project site or another approved location on the installation will be required to be disposed of as a nonhazardous municipal solid waste at a TCEQ permitted Landfill in accordance with the JBSA Environmental Specification (01 57 20) with the exception of those originating at KFA (see Section 6.4.2.). The 802 CES/CEN Project Manager shall be responsible for notifying the proponent of these requirements early in the planning process, and the proponent shall procure funding for the costs of characterization and disposal of these soils.

6. SOIL MANAGEMENT PROCEDURES

6.1. Soil Generated On-base

6.1.1. Service providers shall reuse any soils generated during site preparation and construction on the project site to the maximum extent practicable in accordance with the JBSA Environmental Specification (01 57 20). Wet soil (moist to saturated) shall not be back-filled unless otherwise authorized by the Contracting Officer with a written authorization.

6.1.2. Based on either historic and/or current operational conditions and/or analytical results, the 802 CES/CEIE may classify soils as not contaminated or impacted. These soils may, in coordination with the 802 CES/CEIE and in accordance with this SMP and the JBSA Environmental Specification (01 57 20), be reused as fill in other areas of the project site; used for beneficial use elsewhere on the installation to make the land suitable for the construction of surface improvements; or taken to a TCEQ-approved/permitted disposal facility. Temporary storage of stockpiled soil is not permitted anywhere outside of the project’s limits of construction. Once a project is completed, the proponent shall remove all excess soils from the project site to be used at an approved location on the installation or disposed of in accordance with the JBSA Environmental Specification (01 57 20).

6.1.3. Excess soils that are considered contaminated based on either historic or current operational conditions and/or analytical results shall be sent off-site for disposal in accordance with applicable regulations and the JBSA Environmental Specification (01 57 20). The procedure for off-site management is described in Section 6.3.

6.1.4. Onsite storage, treatment, and disposal of contaminated soils is generally not allowed. Stockpiling or onsite treatment of soils and sediments, to include drying beds, aerobic decomposition, de-watering, bioremediation, vapor extraction, solvent extraction and/or surfactant washing treatments will not be conducted on JBSA property and soil must be taken offsite for proper disposal. Any requests for drying or treatment of non-HW contaminated soil will only be approved on a case-by-case basis, and with full approval and authorization by JBSA and the TCEQ.

6.2. Incoming Soil from Off-base

6.2.1. For incoming material (soil and/or fill, etc.), all analytical parameters in Section

6.3. as well as those in the JBSA Environmental Specification (01 57 20) will be applied. The Incoming Material Analytical Requirements form (Appendix D) shall be completed by the proponent and signed by the 802 CES/CEIE prior to materials entering any JBSA property.

6.2.2. The service provider or contractor that brings fill and/or soil on-base for construction projects shall provide a Letter of Compliance that certifies that the fill and/or soil material is clean and, if analyzed by the criteria that govern waste classification, would not exhibit any characteristics of a hazardous waste or Class 1, Class 2, or Class 3 non-hazardous waste as defined by applicable regulations, nor contain levels of contaminants exceeding Tier I residential soil levels per 30 TAC 350. In accordance with the JBSA Environmental Specification (01 57 20), only soil free from any debris or foreign material qualifying for an exclusion from categorization as Solid Waste shall be imported onto JBSA property as a fill material. Documents such as purchase tickets or invoices should be attached as further evidence that the soil does not exhibit any characteristics previously mentioned in this section and outlined in the JBSA Environmental Specification (01 57 20).

6.2.3. Sampling and analytical results may be requested by the 802 CES/CEIE prior to delivery in accordance with the JBSA Environmental Specification (01 57 20). The cost of sampling and analysis is non-reimbursable by 802 CES/CEIE. Such costs should be accounted for in contract negotiation.

6.2.4. Manufactured soil (crushed rock, gravel, etc.) does not require a Letter of Compliance. However, the load must be inspected by a CE representative upon delivery. The CE representative will provide 802 CES/CEIE with a memorandum verifying that the soil was in fact manufactured soil and showed no evidence of contamination.

6.3. Off-base Disposal

6.3.1. If soils are identified for transport off JBSA property for disposal, coordination with the 802 CES/CEIE must occur BEFORE any transport takes place. These soils shall be sampled in accordance with Section 5.1.2.1. and analyzed in accordance with the contents of this section and the JBSA Environmental Specification (01 57 20).

6.3.2. Unless otherwise specified by the 802 CES/CEIE, all samples shall be analyzed for the below parameters as identified in the JBSA Environmental Specification (01 57 20) based on landfill permit minimum requirements per TAC 30 Rule §330.203(c)(2). Unless otherwise stated, the methods are from EPA SW-846. A toxicity characteristic leaching procedure (TCLP) is required if parameters exceed maximum concentration levels (MCLs).

Parameter Method As, Ba, Cd, Cr, Pb, Ag, Ni, + Sb, Be, Ni 6010 Hg 7471 Se 6020 Organochlorine Pesticides/ Polychlorinated Biphenyls (PCBs) 8080 (Total) & 1311 (TCLP) Semi-Volatile Organic Compounds (SVOCs) 8270 (Total) & 1311 (TCLP) Volatile Organic Compounds (VOCs) to include BTEX 8260 (Total) & 1311 (TCLP) Total Petroleum Hydrocarbons (TPH) TX-1005 Reactivity, Corrosivity, Ignitability (R,C,I) Regulated Asbestos Containing Materials (RACM) EPA 600/R-93/116

6.3.3. Soils coming from Kelly Field Annex (KFA) are subject to additional classification based on TCEQ identifying the property as an Industrial Facility. In addition to non-hazardous determination, KFA samples should be dispositioned as Class 1, 2, or 3 waste. Standard testing methods listed above for delineating waste as non-hazardous are suitable for dispositioning Class 1 and 2 waste, however Class 3 inert waste dispositioning requires the following additional testing: (Note: Class 3 disposition is optional)

6.3.3.1. Class 3 Waste Evaluations require passing a 7-day Distilled Water Leachate Test Procedure (30 TAC Chapter 335 Subchapter R Appendix 4). This test is intended only for dry, solid wastes, i.e., waste materials without any free liquids.

6.3.4. The receiving disposal facility may require additional testing before accepting the soils. Any costs associated with these additional tests will be borne by the proponent.

6.4. Explanation of Required Analysis Parameters

6.4.1. Disposition of Non-Hazardous MSW C&D Soils. Soils at JBSA are generally designated as Construction or Demolition Municipal Solid Waste (MSW) with the exception of those from KFA. Construction and demolition (C&D) waste is defined in 30

TAC §330.3(33):

(33) Construction or demolition waste--Waste resulting from construction or demolition projects; includes all materials that are directly or indirectly the by-https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=30&pt=1&ch=330&rl=203 https://texreg.sos.state.tx.us/fids/30_0335_0521-6.html https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=30&pt=1&ch=330&rl=3 https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=30&pt=1&ch=330&rl=3 products of construction work or that result from demolition of buildings and other structures, including, but not limited to, paper, cartons, gypsum board, wood, excelsior, rubber, and plastics.

6.4.1.1. According to TCEQ, any soils containing man-made constituents fit the definition of Solid Waste per 40 CFR 261.2 and are also considered C&D waste.

As a MSW generator, TCEQ requires JBSA to perform laboratory testing of all soils to be disposed of in order eliminate the presence of hazardous constituents (see Section 6.3.2.). Soils proven not to contain hazardous constituents per the EPA test methods prescribed in the JBSA Environmental Specification (01 57 20) are classified by JBSA as non-hazardous C&D MSW; any further classification is performed at the TCEQ-permitted landfill post-transport from JBSA property. Soils not fitting the definition of Solid Waste per 40 CFR 261.2 are still subject to TCLP sampling and analysis for delineation of hazardous/nonhazardous status per State requirements; see Section 4.3.2.2.

Testing indicative of the presence of hazardous constituents will result in soil being processed as hazardous waste; contact the 802 CES/CEIE POCs in Appendix A for further information.

6.4.1.2. Disposal of Non-Hazardous C&D MSW Soils. Bexar County has two TCEQ-permitted Type 1 landfills:

• Bexar Co. (Permit #1410C) Tessman Road Landfill 1

• Bexar Co. (Permit #2093B) Covel Gardens Landfill 1.

Both accept non-hazardous C&D MSW. Soils leaving JBSA properties for disposal are tested and analyzed per the methods in the JBSA Environmental Specification (01 57 20) based on landfill permit minimum requirements per TAC 30 Rule §330.203(c)(2).

6.4.1.3. Type IV landfills are permitted by the TCEQ to accept inert/insoluble non-hazardous C&D MSW that has passed the 7-day Distilled Water Leaching procedure; however, there are no Type IV landfills in Bexar or surrounding Counties. The cost to transport soil to the nearest TCEQ-permitted Type IV landfill renders this option uneconomical.

6.4.2. Disposition of KFA ISW Soils. Soils from KFA are designated as Industrial Solid Waste (ISW) and require additional classification based on this status. The TAC 30 Rule §335.1(88) defines ISW as follows:

(88) Industrial solid waste--Solid waste resulting from or incidental to any process of industry or manufacturing, or mining or agricultural operation, which may include "Hazardous waste" as defined in this section.

6.4.2.1. According to the TCEQ, any KFA soils containing man-made constituents as outlined by this definition are also considered ISW. As an ISW generator, TCEQ requires JBSA to perform laboratory testing of all soils to eliminate the presence of hazardous constituents (see Section 6.3.2.). As previously stated, KFA soils require additional disposition per TAC 30 Rules §335.505 through 507. Testing indicative of the presence of hazardous constituents will result in soil being processed as https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-261 https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-261 https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=30&pt=1&ch=330&rl=203 https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=T&app=9&p_dir=F&p_rloc=199613&p_tloc=29395&p_ploc=14596&pg=3&p_tac=&ti=30&pt=1&ch=335&rl=1 https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=T&app=9&p_dir=F&p_rloc=199613&p_tloc=29395&p_ploc=14596&pg=3&p_tac=&ti=30&pt=1&ch=335&rl=1 https://texreg.sos.state.tx.us/public/readtac$ext.ViewTAC?tac_view=5&ti=30&pt=1&ch=335&sch=R&rl=Y hazardous waste; contact the 802 CES/CEIE POCs in Appendix A for further information.

6.4.2.1.1. Class 2 non-hazardous ISW disposition is the most

economical option. The TCEQ-permitted landfills in Bexar County require no additional testing to those identified in Section 6.3.2. to delineate this waste designation and avoid additional cost for disposal associated with Class 1. This form of disposal is the cheapest option. JBSA recommends Class 2 non-hazardous ISW disposition for KFA soils whenever possible.

6.4.2.1.2. Class 1 non-hazardous ISW disposition can be

determined through analysis of test methods identified in Section 6.3.2. Although no additional testing is required, Class 1 non-hazardous ISW is more expensive to dispose of than Class 2; therefore, Class 1 non-hazardous ISW disposition is not recommended by JBSA, unless waste does not qualify as Class 2 per analytical results.

6.4.2.1.3. Class 3 inert non-hazardous wastes require more

exorbitant testing costs and the increased workload of a 7-day leachate procedure (see Section 6.3.3.) which outweigh the disposal savings. Therefore, Class 3 non-hazardous ISW disposition is not recommended by JBSA.

6.5. Other Soil Management Options

6.5.1. Reuse. Soils that have been sampled, analyzed, and are determined to be non-hazardous should be considered for reuse on the project site from which they were generated or another approved location on the JBSA property where the soils will be used for approved beneficial use, but cannot be reused or transported to any other JBSA non-contiguous property location unless an exception is granted by 802 CES/CEIE. The proponent will coordinate with the 802 CES/CEIE to make this determination in accordance with the JBSA Environmental Specification (01 57 20).

6.5.2. Recycling of Non-hazardous Soils. The recycling process for soils strips the product of its most beneficial properties and is therefore not worth the processing cost for recycling centers in the local area. Given this fact, JBSA does not authorize recycling of soils regardless of non-hazardous status.

6.5.3. Disposal of Hazardous Soils. Soils determined to contain hazardous constituents based on test methods found in Section 6.3.2 should be dispositioned as outlined in TAC 30 Rule §335.504 and shipped to an appropriate facility; contact the 802 CES/CEIE POCs in Appendix A for further information.

7. REFERENCES

• Department of Defense Regulation 5400.7/AF Supplement, 22 Jul 99, DoD Force Freedom of Information Act.

• Texas Administrative Code (TAC), Title 30 (Environmental Quality), Part 1 (TCEQ), Chapter 330 (Municipal Solid Waste), Subchapter R (Waste https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=30&pt=1&ch=335&rl=504

Classification), Rule §330.3(33).

• Texas Administrative Code (TAC), Title 30 (Environmental Quality), Part 1 (TCEQ), Chapter 330 (Municipal Solid Waste), Subchapter E (Operational Standards For Municipal Solid Waste Storage And Processing Units), Rule §330.203(c)(2).

• Texas Administrative Code (TAC), Title 30 (Environmental Quality), Part 1 (TCEQ), Chapter 335 (Industrial Solid Waste and Municipal Hazardous Waste), Subchapter A (Industrial Solid Waste And Municipal Hazardous Waste In General), Rule §335.1(88).

• Texas Administrative Code (TAC), Title 30 (Environmental Quality), Part 1 (TCEQ), Chapter 335 (Industrial Solid Waste and Municipal Hazardous Waste), Subchapter R (Waste Classification), Rule §335.504.

• Texas Administrative Code (TAC), Title 30 (Environmental Quality), Part 1 (TCEQ), Chapter 335 (Industrial Solid Waste and Municipal Hazardous Waste), Subchapter R (Waste Classification), Rule §335.505-507.

• United States Environmental Protection Agency, 2013. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846 Compendium.

APPENDIX A - JBSA Soil Management Contacts

JBSA Soil Management Contacts

502 CES/Engineering Flight (210) 671-4750

802 CES/Community Planner (210) 671-2901

802 CES/Environmental

LAK-(210) 671-4844, SAM-(210) 221-1142,

RND-(210) 652-5666

Hazardous Waste Manager

LAK/RND-(210) 652-6204/(210) 452-8929,

SAM-(210) 221-4724

APPENDIX B - Sample of Air Force Forms

APPENDIX C - Soil Reuse Request Form

SOIL REUSE REQUEST FORM

PURPOSE:

The JBSA Soil Management Plan is intended to promote conservation and reuse of approved soil in compliance with all applicable environmental regulations. Approved soil, for the record, is soil free from foreign debris, contamination, and hazardous waste. This document provides a means of coordination for soil reuse between 802d Civil Engineer Squadron Environmental Management Section (802 CES/CEIE), Civil Engineer (CE) Program Managers and their Contractors to ensure soil management (soil reuse) activities are properly conducted.

RESPONSIBILITIES:

The 802 CES/CEIE is the approval authority for soil and, along with the cultural resource manager for the facility, will identify sampling requirements (if any) and provide preliminary approval for reuse based on the location of the project site and whether historical or current site activities may have potentially impacted the soil prior to implementation of the project. The 802 CES/CEIE will not inspect the actual project soil. Once project activities are initiated, CE program managers and Contractors are responsible for ensuring the integrity of the soil is maintained at the staging area.

CE Project Managers and their Contractors are responsible for conducting all activities in accordance with the Soil Management Plan, coordinating with the 802 CES/CEIE, performing required analytical testing, and ensuring that soils remain free of debris and/or visible contamination (e.g., concrete, asphalt, transite siding, piping, etc.) to prevent cross-contamination.

Contractors are responsible for loading, transporting, offloading, and identifying acceptable off-base Landfill locations.

Project Information (To be completed by the CE Program Manager)

Date Initiated: Project Name:

Work Task #/Project #/Siting #/NEPA Review #:

Estimated Project Start Date: Estimated Project End Date:

Project Description:

Current/Past Land Use:

Estimated Quantity of Soil: Soil Amount to Reuse On Site: Soil Amount to Disposal:

Project Manager Name:

Email: Phone:

Signature:

Project Site Screening (To be completed by 802 CES/CEIE)

Does Site Require Sampling? YES NO

• Sampling Requirements/Analytical Protocols [JBSA Environmental Specification (01 57 20)]:

• Any additional analysis requested (i.e., 7-day Distilled Water Leaching Procedure)

Approved material (soil, base material, sand) may be reused at the site from which it was generated. Soil IS NOT to be used at any other sites.

YES NO

Approved material (soil, base material, sand) may be utilized for beneficial reuse on the installation at an approved location.

YES NO

Contaminated material must be transported off base to a state approved disposal facility.

YES NO

802 CES/CEIE Program Manager Name:

Email: Phone:

Signature: Date:

APPENDIX D - Incoming Material Analytical Requirements Form

INCOMING MATERIAL ANALYTICAL REQUIREMENTS FORM

Project Information (To be completed by the CE Program Manager)

Date Initiated: Project Name:

Work Task #/Project #/Siting #/NEPA Review #:

Estimated Project Start Date: Estimated Project End Date:

Project Description:

Current/Past Land Use:

Soil Provider: Estimated Quantity of Soil:

Project Manager Name:

Email: Phone:

Signature:

* Attach Letter of Compliance/Certification, analytical results, invoices or receipts, etc.

APPENDIX E – Soil Management Flow Charts

Dispose of soil at appropriate TCEQ

Permitted HazWaste Disposal Facility Do soils exceed

HazWaste Standards?

WILL EXCESS

SOILS BE

DISPOSED

OFF-SITE?

Analyze soil for HazWaste determination per JBSA Environmental Specifications.

If disposal at a Type IV landfill is desired, add TCEQ 7 day leachate test.

Will proponent seek disposal at a TCEQ Permitted Type IV landfill?

Dispose of soil at appropriate TCEQ Permitted Type I Municipal Solid Waste

Landfill

NO

YES

NO

YES

Do soils pass the 7-day leachate

Inert/insolubility Test?

NO

Dispose of soil at appropriate TCEQ Permitted Type IV Municipal Solid Waste Landfill

Disposal location must be verified with CEIE prior to disposal.

NO

Determine if sampling will be required based on process knowledge.

ERP sites, housing areas, industrial areas will be sampled. If not sure, SAMPLE

APPENDIX F - JBSA Soil Disposal Matrix

JBSA Soil Disposal Matrix

YES NO

Step 1: Will soil be back filled into the original project site?

Waste is not generated; no disposal; no sampling required

Proceed to Step 2.

Step 2: Will soil be used to fill land elsewhere on the same contiguous property, “… to make the land suitable for the construction of surface improvements?”

(Must have approval from 802 CEIE before relocation)

Waste is not generated; no disposal; sampling may still be required; consult the 802 CEIE POCs for guidance.

(210) 671-4844

Proceed to Step 3.

Step 3: Is the soil considered a Solid Waste per 40 CFR 261.2?

Proceed to Step 4. Sampling may still be required; consult the 802 CEIE POCs for guidance.

(210) 671-4844

Step 4: Is the waste originated from

KFA?

Proceed to Step 5.

This waste is classified as an Industrial Solid Waste (ISW) per the TCEQ and must be tested per the JBSA Environmental Specification (01 57 20);

Proceed to Step 5.

This waste is classified as a Municipal Solid Waste (MSW) per the TCEQ and must be tested per the JBSA Environmental Specification (01 57 20);

Step 5: Conduct hazardous waste determination sample testing per the JBSA Environmental Specification (01 57 20). Is the waste hazardous?

If hazardous, manifest and dispose of waste at an appropriate TCEQ-permitted TSDF; consult the 802 CEIE POCs for guidance.

If non-hazardous, manifest and dispose of waste at an appropriate TCEQ-permitted TSDF; consult the 802 CEIE POCs for guidance.

Step 6: ***OPTIONAL*** does the proponent desire to delineate the soil as Class III Inert Waste?

The soil must pass the TCEQ 7-day Distilled Water Leachate Test Procedure (30 TAC Chapter 335 Subchapter R Appendix 4); consult the 802 CEIE POCs for guidance.

Return to Step 5.

***FOR GUIDANCE ON LAB RESULTS INTERPRETATION, SOIL DISPOSITION,

MAINFEST SIGNATURE AND SOIL REUSE, PLEASE CONTACT 802 CEIE AT

(210) 671-4844*** https://www.tceq.texas.gov/assets/public/legal/rules/rules/pdflib/335r.pdf https://www.tceq.texas.gov/assets/public/legal/rules/rules/pdflib/335r.pdf https://www.tceq.texas.gov/assets/public/legal/rules/rules/pdflib/335r.pdf