Hazardous Materials Management & Disposal

by Stan Reece

Excavator on the Loop 375 BWE project in El Paso, TX, managing hazardous materials disposal.

Excavation of Category II material from Utility Common Trench

The Loop 375 Border West Expressway (BWE) project, which is located in El Paso County, El Paso, Texas.  The project consisted of the construction of an approximately 6.9 mile tolled facility.  A portion of the project was constructed through a former copper smelting facility owned by American Smelting and Refining Company (ASARCO).  The former ASARCO site is included on the Environmental Protection Agency’s National Priority List.  The majority of the BWE project was also constructed within both Union Pacific Rail Road (UPRR) and Burlington Northern Santa Fe (BNSF) right-of-way (ROW). 

As part of the construction requirements for the project, Abrams-Kiewit Joint Venture (A-KJV), the design-build contractor for the Texas Department of Transportation, was contracted to remove and reconstruct the majority of Main Line 2 and Main Line 4 (existing railroad tracks) within UPRR ROW. The work within both UPRR ROW was included as part of two agreements negotiated between UPRR and TxDOT. As part of these agreements, A-KJV, was required to remove all hazardous materials from within UPRR ROW during the removal and reconstruction of the tracks.  The hazardous material consisted primarily of arsenic and lead-contaminated slag (Category I and Category II material) generated from the smelting process at the former ASARCO site. 

Per Texas Commission on Environmental Quality (TCEQ) regulations, A-KJV was required to prepare a Self-Implementation Notice (SIN) for submittal and approval by TCEQ. The SIN includes the following information related to hazardous waste removal activities: 1) Location of areas for hazardous waste removal (grid layouts of 30’ x 50’); 2) Requirements for confirmation sampling and Protective Concentration Levels (PCLs) to be met based on location of removal areas; 3) Estimated amount of material to be removed; and 4) Location for relocation and disposal of hazardous material.

As part of the preparation of the SIN, information regarding all previous Site Investigation Reports (SIR) needed to be compiled. In accordance with the Loop BWE Technical Provisions, preparation of an SIR is required when hazardous materials are encountered during construction activities. aci consulting personnel were instrumental in preparing six SIRs and receiving approval from TxDOT and UPRR which were included as part of the SIN submittal.  These six reports had been prepared for hazardous material removal within the grid alignments in UPRR ROW. The timely completion and approval of the SIRs was essential to maintaining the aggressive schedule for submittal of the SIN to the TCEQ.

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