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Luckey Soils Remedial Action Scope of Work LUCKEYSOILRASOW
Section 02 81 00 Page 1
SECTION 02 81 00
TRANSPORTATION AND DISPOSAL OF HAZARDOUS MATERIALS
02/10
PART 1 GENERAL
1.1 REFERENCES
The publications listed below form a part of this specification to the extent referenced. The publications are referred to within the text by the basic designation only.
INTERNATIONAL AIR TRANSPORT ASSOCIATION (IATA)
IATA DGR (2013) Dangerous Goods Regulations
U.S. ARMY CORPS OF ENGINEERS (USACE)
EP 200-1-2 (2010) Process and Procedures for Shipping Hazardous
Waste and Other Hazardous Materials
EP 415-1-266 (2000) Resident Engineer Management Guide (REMG) for Hazardous, Toxic, and Radioactive Waste (HTRW) Projects
U.S. DEPARTMENT OF TRANSPORTATION (DOT)
DOT 4500.9R Defense Transportation Regulation, Part 2, Cargo
Movement, Chapter 204, Hazardous Material
U.S. NATIONAL ARCHIVES AND RECORDS ADMINISTRATION (NARA)
40 CFR 261 Identification and Listing of Hazardous Waste
40 CFR 262 Standards Applicable to Generators of Hazardous Waste
40 CFR 263 Standards Applicable to Transporters of Hazardous Waste
40 CFR 264 Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities
40 CFR 265 Interim Status Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities
40 CFR 266 Standards for the Management of Specific Hazardous Wastes and Specific Types of Hazardous Waste Management Facilities
Section 02 81 00 Page 2
40 CFR 268 Land Disposal Restrictions
40 CFR 270 EPA Administered Permit Programs: The Hazardous Waste
Permit Program
40 CFR 279 Standards for the Management of Used Oil
40 CFR 300 National Oil and Hazardous Substances Pollution Contingency Plan
40 CFR 302 Designation, Reportable Quantities, and Notification
40 CFR 61 National Emission Standards for Hazardous Air Pollutants
40 CFR 761 Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions
49 CFR 107 Hazardous Materials Program Procedures
49 CFR 172 Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Emergency Response Information, and Training Requirements
49 CFR 173 Shippers - General Requirements for Shipments and
Packagings
49 CFR 178 Specifications for Packagings
1.2 DEFINITIONS
1.2.1 Hazardous Material
A substance or material determined to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce pursuant to the Hazardous Materials Transportation Act, 49 U.S.C. Appendix Section 1801 et seq. The term includes materials designated as hazardous materials under the provisions of 49 CFR 172, Sections .101 and .102 and materials which meet the defining criteria for hazard classes and divisions in 49 CFR 173. U.S. Environmental Protection Agency (USEPA) designated hazardous wastes are also hazardous materials.
1.2.2 FUSRAP Waste
Excavated or accumulated soil, fill, debris, sludge, or liquids from the site that contain beryllium, lead, radium-226, thorium-230, uranium-234, and/or uranium-238 at concentrations greater than or equal to the criteria identified in the SOW and Section 02 61 13.
1.2.3 Hazardous Waste
Section 02 81 00 Page 3
A waste which meets criteria established in RCRA or specified by the USEPA in 40 CFR 261 or which has been designated as hazardous by a RCRA authorized state program.
1.2.4 Non-Contaminated Demolition and Other Debris
Demolition and other debris from the site that does not contain beryllium, lead, radium-226, thorium- 230, uranium-234, and/or uranium-238 and chemical contaminants at concentrations greater than or equal to the criteria identified in the SOW and Section 02 61 13.
1.3 SUBMITTALS
Government acceptance is required for submittals with a "G" designation; submittals not having a "G" designation are for Contractor Quality Control approval and shall be submitted to the Contracting Officer for information. When used, a designation following the "G" designation identifies the office that will review the submittal for the Government. Submit the following in accordance with Section 01 33 00:
SD-03 Product Data Notices of Non-Compliance and Notices of Violation Packaging Notifications Waste Management, Transportation and Disposal Plan [G] Spill Prevention and Control Plan [G]
SD-06 Test Reports Waste Profiles [G] Recordkeeping Spill Response Exception and discrepancies reports Waste shipping schedules
SD-07 Certificates Reporting forms (state and disposal facility) Acceptance letters (state and disposal facility) [G] Certification [G] Security Plan [G] Transportation and Disposal Coordinator [G] Exclusive Use Agreement for railcars [G] USEPA Offsite Policy Certificates of Disposal and Weight Tickets [G] Shipping Documents and Packagings Certification[G] Waste Minimization [G]
1.4 QUALITY ASSURANCE
1.4.1 Waste ManagerTransportation and Disposal Coordinator
Designate, by position and title, one person to act as the Waste ManagerTransportation and Disposal Coordinator (TDC) who will serve as a single point of contact for all waste management regulatory
Section 02 81 00 Page 4 matters and have overall responsibility for total waste management and disposal compliance, including, but not limited to accurate identification and classification of regulated materials;
determination of proper shipping names; preparation of shipping documents for all materials transported using language concurred with by the USACE; completion of all exception and discrepancy reports; identification and compliance with marking, labeling, packaging and placarding requirements;
preparation and submission of Daily Status Tracking Reports; coordination with USACE, USACE representatives, disposal facility, and transportation agencies as applicable; and preparation and submission of any other documents required by federal, state, and local laws and regulations, by USACE, or the disposal facility. The Waste Manager must coordinate review and approval procedures for all manifests. shall serve as the single point of contact for all environmental regulatory matters and shall have overall responsibility for total environmental compliance at the site including, but not limited to, accurate identification and classification of waste materials; determination of proper shipping names; identification of marking, labeling, packaging and placarding requirements;
completion of waste profiles, waste manifests, bill of ladings, exception and discrepancy reports; and all other environmental documentation. The Waste Manager must have the following qualifications:TDC shall possess qualifications identified in Section 01 45 00.
• A college degree from an accredited school in engineering, construction management, health physics, geology, chemistry, or a related field or 10 years experience performing waste management activities associated with coordinating packaging, transport and disposal of Low Level Radioactive Waste (LLRW), Mixed Waste (MW) and other wastes at FUSRAP and other Department of Defense (DoD) sites
• The capability to identify all required permits
• Specialized training in Hazardous Materials Transportation
• Requirements for DOT certification
1.4.2 Training
The Contractor's site employees shall be trained, tested, and certified to safely and effectively carry out their assigned duties in accordance with Section 01 35 29. Employees transporting hazardous materials or preparing hazardous materials for transportation, including samples, shall be trained, tested, and certified in accordance with 49 CFR 172, Subpart H, including security awareness and any applicable security plans. Employees making determinations that shipments do not constitute USDOT regulated hazardous materials shall also be trained, tested, and certified in accordance with 49 CFR 172, Subpart H.
1.4.3 Certification
The Contractor and/or subcontractors transporting hazardous materials shall possess a current certificate of registration issued by the Research and Special Programs Administration, USDOT, when required by 49 CFR 107, Subpart G. Submit copies of the certificates or written statements certifying exemption from these requirements.
1.4.4 Laws and Regulations Requirements
Work shall meet or exceed the minimum requirements established by federal, state, and local laws and regulations that are applicable. These requirements are amended frequently and compliance with amendments is required as they become effective. In the event that compliance exceeds the
Section 02 81 00 Page 5
SOW or conflicts with specific requirements of the contract, notify the Contracting Officer immediately.
PART 2 PRODUCTS
2.1 MATERIALS
2.1.1 Shipping Materials
All of the materials required for packaging, labeling, marking, placarding and transporting the waste shall be provided in conformance with USDOT and USEPA standards listed in Titles 40 and 49 of the Code of Federal Regulations. Details in this SOW shall not be construed as establishing the limits of the Contractor’s responsibility.
2.1.2 Packaging
The Contractor shall perform all functions and activities necessary to bring the packaging into compliance with 49 CFR Part 173 and 178 as warranted. If repacking is necessary the Contractor shall provide containers, a size of its choosing, for packaging the waste consistent with the authorizations referenced in the Hazardous Materials Table in 49 CFR 172, Subsection 101 and Column 8. Bulk and non-bulk packaging shall meet packaging requirements of 49 CFR 301 and 49 CFR 302. Each package shall conform to the general packaging requirements of Subpart B or 49 CFR 173, to the requirements of 49 CFR 178 at the specified packaging group performance level, and to the requirements of special provisions of Column 7 of the Hazardous Materials Table in 49 CFR 172.101. The Contractor shall also provide other packaging regulated materials such as materials used to cushion or fill voids in over packed containers, etc. Sorbent materials shall not be capable of reacting dangerously with, being decomposed by, or being ignited by the waste being packaged. Additionally, sorbents used to treat free liquids to be disposed in landfills shall be non-biodegradable as specified in 40 CFR 264.314.
2.1.2.1 Markings
Markings for each freight container and transport vehicle shall be provided consistent with the requirements of 40 CFR 172, Subpart D. Markings shall be capable of withstanding, without deterioration or substantial color change, a 180-day exposure to conditions reasonably expected to be encountered during container transport.
2.1.2.2 Labeling
Primary and secondary labels for the waste shipments shall be provided consistent with the requirements of 49 CFR 172, Section 101 and Column 6. The labels shall meet specifications required by 49 CFR 172, Subpart E, including size, shape, color, printing and symbol requirements. Labels shall be durable and weather resistant and capable of withstanding, without deterioration or substantial color change, a 180-day exposure to conditions reasonably expected to be encountered during container transport.
2.1.2.3 Placards
Section 02 81 00 Page 6
For each off-site shipment of waste, the Contractor shall provide primary and secondary placards consistent with the requirements of 49 CFR 172, Subpart F. Placards shall be provided for each side and each end of bulk packaging, freight containers, and transport vehicles requiring such placarding.
Placards may be plastic, metal or other material capable of withstanding, without deterioration, a 30-day exposure to open weather conditions and shall meet design requirements specified in 49 CFR 172, Subpart F.
2.1.2.4 Non-DOT Marking Stickers
In addition to the labeling, placarding and marking requirements of the USEPA, NRC, USDOT, the USACE requires the use of a secondary non-DOT communication “marking sticker” (Federal Railroad Administration designation) on all bulk containers of radioactive materials regardless of whether the material is a DOT hazardous material or not. The sticker indicates the destination of the shipment and a telephone number of a USACE Point of Contact with knowledge of the shipment. This additional marking sticker duplicates existing information that is required on shipping documents when the shipment is a DOT hazardous material. Marking stickers shall be placed in visible locations on the exterior sides of transport vehicles and the top of the container liner (e.g., burrito bag for bulk shipment) as applicable to ensure that workers observe the information prior to emptying the container or vehicle. A bulk container shall have the marking sticker on all four sides and if the transport vehicle is an open truck, there should be at least two stickers on top of the closed liner. An example of the marking sticker is provided below and on page A-64 and A-65 of USACE Engineering Pamphlet 200-1-2.
2.1.3 Spill Response Materials
Spill response materials shall be provided including, but not limited to, containers, adsorbent, shovels, PPE, and instrumentation for measuring and monitoring radiation. The spill response materials shall be available at all times in which waste is being handled or transported. Spill response materials shall be compatible with the type of material being handled.
The Contractor shall respond to any spill of material in their custody. All spills or accidents shall be reported to the CO/COR as soon as possible, but no more than 4 hours afterwards. Any direction
Section 02 81 00 Page 7 from the CO / COR concerning a spill or release shall not be considered a change under the Contract.
Any release to the environment shall be cleaned up as approved by the USACE at no additional cost to the Government.
Spill prevention measures shall be fully described in a SPCC Plan that is included as an attachment to the Waste Management, Transportation and Disposal Plan. This plan shall include a complete discussion of conformance with Federal, state, or local laws and regulations and shall include procedures/descriptions of the following:
a. Facility transfer operations.
b. Waste transport vehicle loading/unloading.
c. Appropriate containment and/or diversionary structures or equipment to prevent discharge of materials to the environment.
d. Instrumentation for measuring and monitoring radiation.
If materials are released, the Contractor shall provide a written description of the event, corrective action taken, and plans for preventing a recurrence, as well as a written commitment of manpower, equipment, and materials required to expedite control and removal of any materials released.
2.2 EQUIPMENT AND TOOLS
All necessary equipment and tools shall be provided to handle waste in a safe and environmentally sound manner. On-site equipment shall include, but not be limited to; instrumentation for measuring radiation, PPE, equipment for repackaging and loading waste onto transportation vehicles, and a means for weighing containers placed in transport vehicles to assure that load limits are not exceeded.
PART 3 EXECUTION
3.1 GENERAL REQUIREMENTS
In accordance with the Contractors Waste Management Plan, the Contractor shall provide all labor, materials, equipment, utilities (if necessary) and other facilities and incidentals necessary to handle, transport, and dispose of FUSRAP contaminated soils / fill described in this SOW. The work shall be conducted in a manner that is protective of human health and the environment. The Contractor shall assume all responsibility for the waste from the onset of site activities until it is accepted by the disposal facility.
All work shall be performed under the oversight of the CO / COR and shall meet the substantive and/or administrative requirements of all environmental permits, licenses, and/or certificates required to complete the work within this SOW.
Disposal of radioactively contaminated materials from the site shall only occur at facilities licensed by
Section 02 81 00 Page 8 the NRC or an Agreement State, or at facilities permitted by a Federal or state regulator to accept radioactive materials in accordance with all applicable laws and regulations. Disposal of materials contaminated by beryllium and/or lead shall only occur at facilities that are permitted to accept the materials. Materials shall be disposed of in a cost-effective manner, considering all feasible options that achieve protectiveness and compliance with all applicable Federal, state, and local laws and regulations. The Contractor shall be responsible for segregating, handling, packaging and staging the waste materials as warranted or as directed by the CO / COR. The Contractor shall contact the disposal facility prior to work to ensure that any segregation is performed in accordance with the facility's waste acceptance criteria, protocols, and policies regarding radioactively contaminated materials. All correspondence with the disposal facility shall be properly documented.
Any hazardous materials shall be handled, packaged, transported, and disposed in accordance with Federal hazardous waste regulations (40 CFR 260-272), United States Department of Transportation (USDOT) regulations (49 CFR 171-178), state regulations, and any other applicable laws and regulations. The contractor shall comply with the notification requirements of the “Off-Site Rule,” found in the National Oil and Hazardous Substances Pollution Contingency Plan (40 CFR 300.440) and as described in EP 200-1-2, Process and Procedures for Shipping Hazardous Waste and Other Hazardous MaterialsEC 200-1-3, Off-Site Disposal of Materials from the Formerly Utilized Sites Remedial Action Program.
All incidental wastes generated during the performance of work authorized under this SOW shall be disposed of by the Contractor. The costs for management, transport, and disposal of incidental wastes generated during performance of the work shall be incorporated in the individual bid prices of the bidder’s proposal.
The Contractor shall ensure that all transportation operations comply with the Emergency Preparedness Community Right to Know Act (EPCRA). For any hazardous waste co-mingled with FUSRAP-related waste that is generated or stored at the site, the Contractor shall prepare a Treatment Plan to fulfill USACE obligations under Section 3021 (b) of the Resource, Conservation, and Recovery Act (RCRA), as amended by the Federal Facility Compliance Act of 1992.
3.2 SPECIFIC REQUIREMENTS
Prepare a Waste Management, Transportation and Disposal Plan in accordance with Paragraph Waste Management, Transportation and Disposal Plan.
Determine appropriate waste disposal requirements in accordance with RCRA regulations. The Contractor shall remove, transport, and dispose all wastes as documented in the SOW and Government approved Waste Management, Transportation and Disposal Plan. All used decontamination fluids and other wastewater from the site shall be characterized, managed, shipped, and treated/disposed in accordance with all relevant federal, state, and local laws and regulations.
The cost for these activities shall be incorporated into the individual prices on the BID SCHEDULE.
Develop waste profile sheets for each waste type that shall be submitted to the Contracting Officer for review and acceptance. The Contractor shall advise the Contracting Officer, in writing, of the RCRA status (i.e., hazardous or non-hazardous under RCRA) prior to preparing manifests and other transportation and disposal documents. All wastes shall be transported for disposal on Government accepted waste transportation vehicle(s) that shall be properly placarded and fully permitted.
Transport of all wastes shall be performed by a transporter registered with the governing state to
Section 02 81 00 Page 9 transport the waste.
Identify the proposed disposal facility(ies) for acceptance by the USACE prior to removing any waste from the site. The Contractor shall assume responsibility for the safe and proper removal and transportation of all wastes and the disposal of such waste at the accepted disposal facility(ies).
Use disposal facilities that are fully licensed to accept disposal of wastes from the site. The facility(ies) must demonstrate proof of compliance with all appropriate RCRA requirements (RCRA Subtitle C and D) and proof of operating permits. The facility(ies) must provide certificates of disposal and copies of permits for USACE review and acceptance. The Contractor shall supply USACE a copy of the acceptance letter indicating the waste is acceptable for disposal at the designated facility(ies).
Selection of the approved disposal facility shall be based upon cost-effectiveness, compliance status, regulatory agency input and USACE acceptance.
Determine appropriate waste disposal requirements in accordance with RCRA regulations. The Contractor shall remove, transport, and dispose all wastes as documented in the USACE-accepted Waste Management, Transportation and Disposal plan. All used decontamination fluids and other wastewater from the site shall be characterized, managed, shipped, and treated/disposed in accordance with all relevant federal, state, and local laws and regulations. The cost for these activities shall be incorporated into the individual bid prices.
Develop waste profile sheets for each waste type that shall be submitted to the USACE for review and acceptance. The Contractor shall advise the USACE, in writing, of the RCRA status (i.e., hazardous or non-hazardous under RCRA) prior to preparing manifests and other transportation and disposal documents. All wastes shall be transported for disposal on USACE-accepted waste transportation vehicle(s) that shall be properly placarded and fully permitted. Transport of all wastes shall be performed by a transporter registered with the governing state to transport the waste.
Determine the state reporting requirements (i.e., generator state and/or disposal state) and obtain current state reporting forms. A completed draft of all required forms, with applicable attachments shall be submitted to the USACE for acceptance prior to submission to the federal or state regulator.
The state reporting forms shall also be included within the close-out documentation.
List all waste materials going off-site including the description, quantity, destination, purpose, and hazardous waste classification.
Notify the CO / COR a minimum of seven (7) calendar days prior to the scheduled shipment that the waste has been properly packaged, labeled, marked and placarded in accordance with all applicable Federal, state, and local laws and regulations, including but not limited to the requirements of the USACE, USDOT, NRC, USEPA, OEPA, and the disposal state.
Load onto transport vehicles and provide safe transportation of the waste to the disposal facility. The work shall include the following:
a. Securing all permits and/or licenses necessary to perform this work.
b. Notifying all appropriate stakeholders and agencies.
Section 02 81 00 Page 10
c. Performing all activities associated with the loading, transportation, and disposal of the waste from the site to the disposal facility.
d. Paying all taxes, surcharges, and fees of any kind associated with transport of the waste, including but not limited to all fees imposed by federal, state, regional, county and/or local governmental agencies or authorities. In addition, all fees, transportation costs and special precautions shall be the responsibility of the Contractor. The Contractor shall bear full responsibility for any and all fines or assessments levied against the Project due to improper handling and disposal of the waste.
e. Furnishing all transportation equipment, tools, materials, equipment, labor, services, insurance, and supervision to perform all required work.
f. Decontaminating transportation equipment prior to mobilization to the site and upon completion of the work.
Transport the waste directly to the designated disposal facility and each shipment shall not exceed seven (7) calendar days to reach the facility.
Utilize a tracking system acceptable to the USACE. In instances where characteristic wastes are deactivated on-site or at the disposal facility and sent to a Subtitle D facility, the Contractor shall follow appropriate notification and certification requirements under 40 CFR 268.9.
Ensure that each waste shipment is accompanied by properly completed shipping documents.
Shipping documents shall be submitted to the USACE COR for review and acceptance a minimum of seven (7) calendar days prior to the first shipment of waste.
Submit detailed information on the tare and gross weights of each container and vehicle to the USACE prior to leaving the site. The Contractor shall ensure that all gross vehicle weights and axle weights meet applicable state and local regulations and are legal before the vehicles leave the site. The Government, the Government’s representatives, and the site owner will not assume any responsibility for violation of federal, state and/or local waste management and transportation laws or regulations, including weight limits.
Document field activities in accordance with Attachment 6(Section 01 35 45).
Address any discrepancies due to differences between the quantities or types of waste designated on the manifest or shipping papers and the quantity or type of waste received at the disposal facility.
These discrepancies shall be reported to the CO / COR and rectified by the contractor within 10 calendar days after the waste has been received at the disposal facility.
Submit Certificates of Disposal and weight tickets, issued by the disposal facility, and any shipment records to USACE within 10 calendar days of waste receipt by the disposal facility.
Within eight (8) hours of receipt, notify and provide the CO / COR with copies of any notice of non-
Section 02 81 00 Page 11 compliance or notice of violation from any federal, state or local regulatory agency issued in connection to any work performed under this SOW. The Contractor shall also furnish all relevant documents regarding any incidents and any information requested by the CO / COR and shall coordinate its response to the notice(s) with the CO / COR prior to submission to the notifying authority. The Contractor shall furnish a copy of all documents submitted to the regulatory authority to the CO / COR for review and acceptance, including the final reply to notice(s), and all other materials, until the matter is resolved. This coordination shall not relieve the contractor of their responsibilities.
3.2.1 Waste Management, Transportation, and Disposal Plan
Prepare a plan detailing the manner in which wastes will be managed, transported and disposed. The plan shall include, at a minimum, the following:
a. Name, address, telephone number, and appropriate permit information for each licensed / permitted disposal facility along with the facility's requirements for accepting each waste stream, including their waste acceptance criteria.
b. A letter from each accepting facility and its regulating authority acknowledging that the anticipated waste stream can be accepted.
c. Sampling, testing, and analytical results for each waste stream, including any results associated with sampling and analysis performed.
d. USEPA identification numbers.
e. Quantity of contaminated soils / fill requiring shipment.
f. The method to be used to ensure accurate piece counts and / or weights of shipments.
g. Transportation methods and routes from the site to the disposal facility(ies), including whether transfer facilities will be utilized.
h. Name, address, telephone number, and appropriate permit information for each waste transporter to be employed for waste shipment to the disposal facility. All waste transportation containers shall be used for sole source and an exclusive use agreement shall be obtained from the transporter.
i. Method of surveying the loading area and/or haul routes.
j. Demonstration that the proposed transportation mode is safe and cost-effective for waste transportation.
k. Methods used to prepare the waste transportation containers; leak and spill protection and prevention; and loading and transporting the waste.
Section 02 81 00 Page 12
l. Methods used for staging the contaminated soils / fill, labeling, placarding, marking, and preparing the shipping documents, and any other requirements for transportation of waste to the licensed/permitted disposal facility.
m. How the waste transportation containers will be inspected prior to leaving the site.
n. Examples of shipping documents, a list of corresponding labels, packages, marks, and placards to be used for shipment, and disposal facility advanced shipment notification forms, if required.
o. USACE-accepted Chain-of-Custody (COC) form that describes the material being shipped and includes certification that it is not radioactive material as defined in 49 CFR 173. An example of an approved COC can be found in EP 200-1-2, pages A-81 and A-82.
p. Waste minimization methods.
q. Waste preparation, packaging, loading and transport activities, including but not limited to physical, chemical and radiological safety, environmental protection, and security.
r. Techniques and equipment to be used for determining the weight of each shipment.
s. A rigging plan for lifts heavier than 20,000 pounds. The plan shall be signed by a licensed Professional Engineer.
t. Format and description of the tracking system to be used while wastes are being transported.
The Contractor shall use a tracking system that allows for daily monitoring of any vehicle used for transportation of material to the licensed/permitted facility.
u. Plans for transportation spill response and coordination with local responders (included as an attachment to the Waste Management, Transportation and Disposal Plan). See Paragraph Spill Response.
v. Plans for decontamination of the transportation equipment.
w. Plans and procedures to be implemented to ensure that operations conducted do not result in further contamination of the site or communities through which the waste is transported.
x. Spill prevention and control measures (Spill Prevention and Control Plan, included as an attachment to the Waste Management, Transportation and Disposal Plan).
y. Emergency procedures for contacting USACE and regulators in case of spills, notices of violation, or other incidents. Each transport vehicle shall have a contact number in case of emergency.
The number shall be in service 24 hours per day, 7 days per week.
Section 02 81 00 Page 13
z. A treatment plan to fulfill RCRA obligations for any hazardous waste comingled with FUSRAP-related radioactive wastes
3.2.2 Coordination With USACE
The Contractor shall maintain direct, concise and daily contact/coordination with USACE concerning field operations and scheduling for off-site shipments. Waste shipping schedules shall be confirmed by the contractor, in writing, to the CO / COR on a weekly basis. The Contractor shall be responsible for maintaining adequate records to support information provided to the CO / COR.
3.2.3 Waste Preparation Prior to Transportation
The following activities shall be performed, as a minimum, prior to loading FUSRAP-contaminated soil / fill for transport to the disposal facility.
Secure Licenses, Permits and Approvals – Obtain all licenses, permits and/or approvals necessary to transport the material to the disposal facility. This shall be in full compliance with federal, state and local laws and regulations, USACE guidance and disposal facility requirements. Supply USACE with a copy of the disposal state acceptance letter indicating the waste is acceptable for disposal at the designated facility prior to mobilizing for shipment off-site.
Solidify Free Liquids – Solidify all non-hazardous waste as necessary to eliminate free liquids, as determined by the “paint filter test” method, prior to removing wastes from the site for off-site transport. Free liquids must be solidified in accordance with disposal facility requirements. Free liquids shall not be added to soil waste for solidification.
Achieve Optimum Moisture Content of Wastes - Make adjustments to the soil / fill as necessary to meet the disposal facility’s “optimum moisture content” requirements. The Contractor may do so either at the site or arrange for the disposal facility to undertake that effort, at the Contractor’s discretion. However, the Contractor is responsible for directly paying any and all surcharges or fees charged by the disposal facility if they adjust the moisture content. .
Manage Decontamination Fluids / Solids and PPE - Any fluids generated from equipment or personnel decontamination shall be consolidated with other wastewater on-site per USACE acceptance. All solids (i.e., spent PPE) generated during waste preparation activities shall be placed into containers and transported for disposal. The Contractor shall make every effort to minimize the volume of decontamination fluids/solids and PPE wastes. The costs for management, transport, and disposal of the decontamination fluids shall be incorporated into the individual bid prices of the bidder’s price proposal.
Prepare Shipping Documents – Prepare and submit draft copies of all waste profile sheets and shipping documents for review and acceptance by USACE and subsequently prepare, secure approvals for and manage final shipping documents.
3.2.4 Packaging / Repackaging of Wastes
Section 02 81 00 Page 14
All containers and packaging/repackaging efforts shall comply with Federal, state and local laws and regulations, including but not limited to USEPA, NRC, and USDOT requirements, and USACE guidance.
Any containers that are determined to be unsuitable for loading and transport will be either decontaminated for free release and removed from the site by the Contractor, or crushed and disposed with other debris being transported to the disposal facility in accordance with this SOW.
Wastes may be repackaged into larger containers (overpack) if the sole purpose is to replace existing containers that are unsuitable (i.e., corroded or damaged) for loading and transport. Approval from the USACE is required prior to any packaging/repackaging of waste.
Do not mix soil with debris or other wastes for any purpose; however, partial containers of like material may be combined to reduce number of containers to be shipped. Wastes may be combined per the approved waste profile description if shipment is to be in bulk.
Soil shall not be mixed with debris in individual containers being transported unless the waste is being shipped in bulk packages.
If sampling/laboratory analysis identifies that any of the waste is also a “RCRA hazardous waste,” the contractor shall not mix or place those “mixed wastes” in the same containers with any other waste not deemed mixed waste.
3.2.5 Loading and Transportation of Contaminated Soils / Fill
All trucks and railcars used to transport contaminated material from the site shall be dedicated solely to this project throughout the duration of transportation activities. The Contractor shall obtain and submit an exclusive use agreement for all railcars used on this project.
The contaminated soils / fill shall be loaded onto transport vehicles and safely transported to the disposal facility. Qualified personnel, materials, equipment and facilities shall be provided to perform the required work. The work shall include, but not be limited to, the following:
Notifying, arranging, and coordinating all activities for transportation of the waste, including mixed waste if any is present, from the site to the disposal facility.
Scheduling, delivering, preparing, and providing sufficient quantities of clean and serviceable containers, and/or transport vehicles, inner liners, covers, placards, stickers and associated materials.
Assuring that the transportation equipment is cleaned and decontaminated prior to being mobilized to the site and upon completion of the work.
Securing all waste packages/containers/drums/etc. against shifting, including relative motion between packages/containers/drums/etc., within the transportation vehicle.
Loading all waste packages/containers/drums/etc. in the correct position as indicated on the orientation markings in accordance with all applicable Federal, state, and local laws and regulations.
Assuring that the tare and gross weights of each vehicle leaving the site are in compliance with state and local laws and regulations.
Using appropriate methods to prevent vehicle movement during loading/unloading of the waste.
Section 02 81 00 Page 15
Preventing undue rise in temperature of packages/containers/drums/etc. during transport to the disposal facility.
Maintaining all regulatory required distances between packages/containers/drums/etc.
Surveying each transportation vehicle for radioactivity in accordance with Regulatory Guide 1.86 prior to being loaded with waste, prior to leaving the site, and after unloading the waste at the disposal facility. A transportation vehicle shall not be returned to service until the radiation dose at every accessible surface is acceptable to the USACE and in accordance with Federal, state, and local laws and regulations. The Contractor shall immediately provide all transportation vehicle survey results to the USACE.
3.2.6 Shipping Documents
Each waste shipment shall be accompanied by properly completed shipping documents.
Transportation shall comply with all relevant requirements of 49 CFR along with requirements provided in 40 CFR 262 Subpart B. 49 CFR 172.101 shall be used to identify proper shipping names for each hazardous material to be shipped off site. All completed shipping documents shall be furnished to the CO / COR for review and approval seven (7) calendar days prior to waste shipments. These will include the following (as appropriate):
a. Draft shipping documents.
b. List of proposed labels, packages, marks and placards to be used for shipment.
c. Disposal facility advanced shipment notification forms (if required).
A bill of lading/manifest shall be prepared for each shipment of hazardous material and submitted to the CO / COR for review and acceptance. The bill of lading shall satisfy the requirements of 49 CFR 172, Subpart C and any applicable state and local law and regulation, and disposal facility requirements. USACE will sign manifests/bills of lading requiring shipper’s certifications. The Contractor shall package, label, mark and placard any hazardous materials in accordance with the referenced authorizations.
Each shipment leaving the site shall have shipping documents consisting of at a minimum, a USACE-accepted COC form that describes the material being shipped and includes certification that the material is not radioactive material as defined in 49 CFR 173. An example of an approved COC can be found in USACE Engineering Pamphlet 200-1-2, pages A-81 and A-82.
The CO / COR shall be furnished with a completed “generator copy” shipping documents prior to transporting materials from the site when shipments originate.
3.2.7 Spill Response
The Contractor shall respond to any spill of material in their custody. All spills or accidents shall be reported to the Contracting Officer as soon as possible, but no more than 4 hours afterwards. Any direction from the Contracting Officer concerning a spill or release shall not be considered a change under the Contract. Any release to the environment shall be cleaned up as accepted by the
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Contracting Officer at no additional cost to the Government.
Spill prevention measures shall be fully described in a Spill Prevention and Control Plan that is included as an attachment to the Waste Management, Transportation and Disposal Plan. This plan shall include a complete discussion of conformance with federal, state, or local laws and regulations and shall include procedures/descriptions of the following:
a. Facility transfer operations.
b. Waste transport vehicle loading/unloading.
c. Appropriate containment and/or diversionary structures or equipment to prevent discharge of materials to the environment.
d. Instrumentation for measuring and monitoring radiation.
If materials are released, the Contractor shall provide a written description of the event, corrective action taken, and plans for preventing a recurrence, as well as a written commitment of manpower, equipment, and materials required to expedite control and removal of any materials released.
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