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KIRTLAND AIR FORCE BASE ALBUQUERQUE, NEW MEXICO ...

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APPENDIX E<br />

3. WASTE MANAGEMENT CONTROL MEASURES<br />

This section describes the various waste management control measures planned for each potential waste<br />

stream. The waste management measures include segregation, containment, marking and labeling,<br />

logging, and tracking.<br />

3.1 Waste Characterization and Classification<br />

To determine proper waste management requirements for waste generated during project activities, waste<br />

characterization may be necessary. Unless a waste determination can be made based on generator<br />

knowledge and site data, all waste streams will be sampled and characterized in accordance with 40 CFR<br />

262.11 regulations. If samples for classifying waste are deemed necessary to meet characterization<br />

requirements, representative samples will be taken and analyzed in accordance with federal regulations<br />

and New Mexico Hazardous Waste Management Regulations and Solid Waste Management Regulations.<br />

Waste streams, including but not limited to debris and soil, decontamination water, and PPE, will be<br />

sampled and/or characterized using generator knowledge, TCLP testing, or total recoverable petroleum<br />

hydrocarbons (TRPH) analysis, depending on the nature of the material and expected contaminant.<br />

Generator knowledge is expected to be the primary means of characterizing wastes generated during this<br />

project. The basis for characterization will be material data safety sheets for materials brought onsite,<br />

prior site assessment data, and observations made and analyses conducted during site activities.<br />

Waste will first be characterized to determine whether it is a hazardous or special waste; waste is<br />

determined to be characteristically hazardous on the basis of its chemical constituents or physical<br />

properties. Listed wastes are specifically identified in 40 CFR Part 261, Subpart D. New Mexico special<br />

waste, which includes PCS, is identified as soil contaminated with a TRPH concentration greater than<br />

1000 mg/kg, a benzene concentration that exceeds 10 mg/kg and a total benzene, toluene, ethylbenzene,<br />

and xylenes (BTEX) concentration that exceeds 500 mg/kg. Asbestos waste will be categorized using the<br />

definitions specified in 20 NMAC 9.1, Solid Waste Regulations.<br />

Characteristic hazardous waste includes those wastes that exhibit toxicity in excess of the values<br />

indicated in 40 CFR Part 261, Subpart C. As previously discussed, any waste generated will first be<br />

characterized (if possible) based on generator knowledge. If generator knowledge is not sufficient to<br />

make an adequate determination, an exceedance of a toxicity characteristic will be determined through<br />

the waste’s constituent concentration comparisons with listed TCLP regulatory levels.<br />

PCS will be characterized using results from analysis for the toxicity parameters of volatile organic<br />

compounds, semivolatile organic compounds, pesticides, herbicides, and target analyte list metals. The<br />

analysis will be performed in accordance with EPA SW-846, Test Methods for Evaluating Solid Waste,<br />

Third Edition and Updates (EPA, 1986). The analytical results will be compared to 20 times the toxicity<br />

characteristic values for TCLP analytes. The 20-times value accounts for the sample dilution factor<br />

associated with the TCLP analysis. If an analyte concentration exceeds 20 times the TCLP regulatory<br />

level, then a TCLP analysis will be performed for that analyte to enable a direct comparison of the<br />

specific constituent concentration to the TCLP regulatory levels.<br />

The 20-times value above is related to the dilution factor used in the TCLP test. Consequently, TCLP<br />

analyses may not have to be performed if the total value is less than 20 times the indicated regulatory<br />

level for a particular constituent. Hydrocarbon contamination will be determined through testing for<br />

using EPA Method 9071A/418.1 or other approved method.<br />

Kirtland AFB<br />

IDW Management Plan E-19 April 2004

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