LTLW-Batch-Pumping-etc-9-8-161020 Winding Creek Road, Suite 110, Roseville, CA 95678
tel 916.782.8700 fax 916.782.8750
September 8, 2016
Mr. Scott Reisch, Partner
Hogan Lovells US LLP
One Tabor Center, Suite 1500
1200 Seventeenth Street
Denver, CO 80202
Mr. William F. Tarantino, Partner
Morrison & Foerster LLP
425 Market Street
San Francisco, CA 94105
Subject: Workplan to Perform Batch Pumping
Lake Tahoe Laundry Works
1024 Lake Tahoe Boulevard
South Lake Tahoe, California
Dear Mssrs. Reisch and Tarantino:
E2C Remediation (E2C) is pleased to present this workplan for the Lake Tahoe Laundry Works
Site in South Lake Tahoe, California (Site). This workplan was prepared to comply to a request
from the Lahontan Regional Water Quality Control Board.
We look forward to working with you. Please contact Aiguo Xu or Philip Goalwin at 916-782-
8700, if you have any questions or if any further information is needed.
Respectfully Submitted,
E2C Remediation
cc: Ms. Tamerle M Lundquist, P.G.
cc: Ms. Lisa Dernbach, C.H.G.
Senior Engineering Geologist
CRWQCB – Lahontan Region, South Lake Tahoe Office
2501 Lake Tahoe Boulevard South Lake Tahoe, CA 96150 P.O Box 310
Tahoe Vista, CA 96148
Philip Goalwin, P.G. #4779
Principal Geologist
1020 Winding Creek Road, Suite 110, Roseville, CA 95678
tel 916.782.8700 fax 916.782.8750
EVALUATION OF POLISHING REMEDIATION OPTIONS
AND
WORKPLAN TO PERFORM
BATCH PUMPING
Lake Tahoe Laundry Works
1024 Lake Tahoe Boulevard
South Lake Tahoe, California
September 8, 2016
Project Number: 1950BK27
Prepared For:
Fox Capital Management Corporation
4582 S. Ulster Street Parkway, Suite 1100
Denver, CO 80237
Seven Springs Limited Partnership
c/o Christopher Blair
Vice President
The Commerce Trust Company
118 West 47th Street
Kansas City, MO 64112
Prepared By:
E2C Remediation
Environmental/Engineering Consultants
1020 Winding Creek Road, Suite 110
Roseville, CA 95678
Project Number 1950BK27 September 8, 2016
E2C Remediation i
TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................................... i
LIST OF FIGURES ....................................................................................................................... i
1.0 INTRODUCTION .............................................................................................................. 1
1.1 Site Description ............................................................................................................ 1
1.2 Rationale for Evaluation of Polishing Remediation Options.................................. 1
2.0 EVALUATION OF POLISHING REMEDIATION OPTIONS .......................................... 1
2.1 Batch Pumping ............................................................................................................ 1
2.2 In-Situ Thermal Treatment ........................................................................................ 2
2.3 In-Situ Chemical Oxidation ........................................................................................ 3
2.4 Selection of Remedial Option ..................................................................................... 5
3.0 BATCH PUMPING WORKPLAN ...................................................................................... 6
3.1 Batch Pumping Methods and Procedures ................................................................ 6
3.1.1 Batch Pumping Operation Description ............................................................. 6
3.1.2 Batch Pumping Monitoring ................................................................................. 6
3.1.3 Groundwater Monitoring ..................................................................................... 7
3.1.4 Extracted Water Discharge ................................................................................. 7
3.2 Batch Pumping Report of Findings ........................................................................... 7
4.0 QUALITY ASSURANCE PLAN ........................................................................................ 9
4.1 Sample Collection and Handling Protocol ................................................................ 9
4.2 Sample Identification and Chain-of-Custody Documentation .............................. 9
4.3 Analytical Quality Assurance ..................................................................................... 9
5.0 SITE SAFETY PLAN ....................................................................................................... 10
6.0 LIMITATIONS AND WORKPLAN CERTIFICATION .................................................... 14
LIST OF FIGURES
Figure 1 Site Location Map
Figure 2 Site Plan
Figure 3 Second Quarter 2016 Groundwater PCE Distribution Plot
Figure 4 Site Plan with Proposed Batch Pumping and Discharge Locations
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1.0 INTRODUCTION
Extremely low mass removal rates indicate that the operation of the soil vapor
extraction and groundwater air sparge system (SVE/GASS) at the site appears to be
approaching its limit of effectiveness. The persistent detection of low-moderate
dissolved phase PCE concentrations at MW-1S and MW-5S warrants consideration of
polishing remediation options in combination with ongoing operation of the
SVE/GASS. In letter dated May 24, 2016, The Lahontan Regional Water Quality
Control Board (LRWQCB) encouraged consideration of alternative technologies to
“polish” or achieve final cleanup of residual contaminants. In the 2016 First Quarter
Groundwater Monitoring Report and Current Site Remediation Status Report, dated
May 27, 2016, it was recommended that alternative options such in-situ thermal
treatment and in-situ chemical oxidation be evaluated to polish or achieve final
cleanup at the site. This work plan has been prepared for review and approval by
LRWQCB before its implementation.
1.1 Site Description
The Site is located approximately 9,000 feet south of Lake Tahoe in the City of South
Lake Tahoe, El Dorado County (see Figure 1). The Site is situated in the northwest
corner of the South Y Shopping Center, along Lake Tahoe Boulevard between U.S.
Highway 50 and Tata Lane and is cross-corner from the dead-end intersection of
Glorene Avenue with Lake Tahoe Boulevard (see Figure 2).
1.2 Rationale for Evaluation of Polishing Remediation Options
As of August 2016, site conditions are as follows:
1) Extremely low mass removal rates indicate that the operation of the air
sparge and vapor extraction system appears to be approaching its limit of
effective operation; and
2) The persistent detection of low-moderate dissolved phase PCE
concentrations at LW-MW-1S and LW-MW-5S warrants consideration of
polishing remediation options in combination with ongoing operation of the
SVE/GASS.
2.0 EVALUATION OF POLISHING REMEDIATION OPTIONS
This Section compares three alternative polishing remediation options for the final
cleanup of residual contaminants at the site. The three alternative remediation
options are:
1) Batch pumping at wells with significant PCE concentration fluctuations;
2) In-Situ Thermal Treatment; and
3) In-Situ Chemical Oxidation
2.1 Batch Pumping
Batch pumping using a vacuum trailer is a relatively non-intrusive method for removal
of vapor-phase and dissolved-phase contaminants of concern. Batch pumping with
vacuum consists of extracting groundwater with dissolved contaminants and vapors
from the smear zone while lowering the water table in an existing well. A vacuum
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trailer is used to accomplish this. In general, a vacuum is applied to the selected well
by extending a hose from the vacuum trailer to the well. The hose is fitted with a
stinger, which is lowered through a vacuum-tight boot, or grommet, slowly into the
impacted well until the stinger is primarily below the air-water interface. The applied
vacuum then removes vapors from the interface zone and extracts impacted
groundwater. Water removal rate depends on the rate of lateral groundwater recharge.
If recharge is relative slow, only a limited volume of impacted water can be extracted.
Batch Pumping Advantages: The advantages of batch pumping using a vacuum
trailer are:
Minimal disruption of business;
Removes contaminants;
Discharge of treated groundwater to land is allowable under a General Permit;
Does not require the immediate installation of a permanent remediation system
(including wells and infrastructure) that would require maintenance, as existing
site monitoring wells can be used for the batch pumping operations;
Batch pumping using a vacuum trailer would require no utility connections;
Reduces the toxicity, volume and mobility of contaminants beneath the affected
area and does not entail relocating contamination. The extracted water is
treated to non-detect concentrations with liquid-phase activated carbon prior to
being discharged to land; and
Is cost-effective for short-term remedial action as no additional infrastructure is
needed.
Batch Pumping Disadvantages:
Extracted water needs off-site disposal or a General Waste Discharge Permit for
on-site discharge; and
Multiple events may be necessary at each monitoring well.
2.2 In-Situ Thermal Treatment
In-situ thermal treatment methods (ISTT) move or “mobilize” contaminants in soil and
groundwater using heat. The contaminants move through soil and groundwater
toward wells where they are captured and routed via pipes to the ground surface to be
treated using other cleanup methods before discharge to the atmosphere. Some
contaminants may be destroyed underground during the heating process. ISTT is
described as “in situ” because the heat is applied underground directly to the
contaminated area. ISTT can be particularly useful for chemicals present in the form
of “non-aqueous phase liquids” or “NAPLs,” which do not dissolve readily in
groundwater and can be a source of groundwater contamination for a relatively long
time if not treated. ISTT can also be effective in “tight soils” where other remedial
methods are less effective. Examples of NAPLs include solvents, petroleum, and
creosote (a wood preservative).
In-situ thermal treatment methods heat contaminated soil, and sometimes nearby
groundwater, to very high temperatures. The heat vaporizes (evaporates)/volatilizes
the chemicals and groundwater converting them into vapors/gases. These
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vapors/gases can move more easily through soil. The heating process can make it
easier to remove NAPLs from both soil and groundwater. High temperatures also can
destroy some chemicals in the area being heated.
In situ thermal methods generate heat in different ways:
Electrical resistance heating (ERH) delivers an electrical current between metal rods
called “electrodes” installed underground. The heat generated as movement of the
current meets resistance from soil converts groundwater and water in soil into steam,
vaporizing contaminants
Steam enhanced extraction (SEE) injects steam underground by pumping it through
wells drilled in the contaminated area. The steam heats the area and evaporates
contaminants.
Thermal conduction heating (TCH) uses heaters placed in underground steel pipes.
TCH can heat the contaminated area hot enough to destroy some chemicals.
In-Situ Thermal Treatment Advantages:
An effective in-situ method for cleaning up NAPLs;
Advantageous for silty or clayey soil where other cleanup methods do not
perform well; and
Applied to situations where access is very limited, such as at large depth below
ground surface or beneath buildings.
In-Situ Thermal Treatment Disadvantages:
Very high initial infrastructure cost for the heating element installation;
Heating of the sub-surface can damage underground utilities and remediation
infrastructure;
Disruption to normal business operation and may cause indoor air concerns;
Need large power sources/fuel sources and power/fuel consumption. The
electrical power requirements are not available from the local utility purveyor at
this site;
Not economical for large area; and
Not cost effective for low concentration conditions.
2.3 In-Situ Chemical Oxidation
In-situ chemical oxidation (ISCO) methods involve delivery of oxidants to impacted
media (soil and/or groundwater) to chemically oxidize or destroy harmful
contaminants into non-harmful substances.
Two oxidants have been evaluated for the proposed ISCO pilot test. They are PersulfOx
and potassium permanganate. PersulfOx (manufactured by Regenesis) is a catalyzed
formulation of sodium persulfate (Na2S2O8) designed to oxidize organic contaminants
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in groundwater and soil. In addition to sodium persulfate, this product contains a
patented silica and silicate-based catalyst to optimize oxidative destruction of
contaminants. Consultation with the product provider indicated that the persistence
time is relatively short (1-3 weeks) and the product is not highly effective with low
concentrations. As a result of the short persistence time, PersulfOx requires a
relatively large mass ratio of chemical to contaminants.
Potassium permanganate is widely used in water purification and treatment
applications. As the permanganate reaction time is relatively slower than other
oxidants, it is safer to use and application requires reasonable safety precautions.
The persistence of the oxidant in the subsurface is an important factor in preferring
potassium permanganate since this affects the contact time for advective and diffusive
transport and ultimately the delivery of oxidant to targeted areas/zones in the
subsurface. Permanganate persists for long periods of time (up to > 3 months), and
diffusion into low-permeability materials and greater transport distances through
porous media are possible. The site aquifer material is predominantly silty sand and
groundwater flow gradient is moderate (from 0.01 ~ 0.06). In addition, potassium
permanganate has excellent amenability for destruction of chlorinated ethenes, which
are the residual contaminants at the site. The chemical reactions for PCE, TCE, DCE
and vinyl chloride for the pH range of 3.5 to 12 are:
4 KMnO4 + 3 C2Cl4 + 4 H2O => 6 CO2 + 4 MnO2 + 4 K+ + 8 H+ + 12 Cl- (1)
2 KMnO4 + C2HCl3 => 2 CO2 + 2 MnO2 + 2 K+ + H+ + 3 Cl- (2)
8 KMnO4 + 3 C2H2Cl2 => 6 CO2 + 8 MnO2 + 8 K+ + 2 OH- + 6 Cl- + 2 H2O (3)
10 KMnO4 + 3 C2H3Cl => 6 CO2 + 10 MnO2 + 10 K+ + 7 OH- + 3 Cl- + H2O (4)
From the above equations, it can been seen that the primary by-products are carbolic
acid and MnO2. MnO2 is a solid precipitate in the pH range of 3.5 to 12.
With consideration of ease of application, persistence time, worker’s safety, as well as
limited by-product production of metals, potassium permanganate is considered as
the more preferred oxidant, if ISCO is chosen.
Oxidant will be introduced by a one-time application through temporary borings using
an injection tool. The injection will be conducted at elevated pressure to assure
oxidant delivery. The temporary injection locations and injection intervals can be
chosen to best deliver the oxidant to the targeted groundwater plume and/or possible
residual contaminant in soil based on historical soil and groundwater analytical data.
In-Situ Chemical Oxidation Advantages:
Fast treatment (weeks to months);
Injections can be targeted to treat volatile organic compounds (VOC) sources
above and below the water table;
Temporary facilities;
Effectively treats towards low-very low concentrations (non-detectable levels);
Effective on some hard to treat compounds; and
Low total life cycle costs
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In-Situ Chemical Oxidation Disadvantages:
Fast treatment requires a large capital outlay;
Multiple injections may be required;
Involves handling strong oxidants and may require special safety measures;
Possible side effects, such as generation of metals; and
May have delivery limitations
2.4 Selection of Remedial Option
The Lake Tahoe Laundry Works site has been remediated by SVE/GASS since 2010.
Groundwater contamination of chlorinated solvents has been remediated to relatively
low concentrations. Shallow soil vapor concentrations have declined to below the
Environmental Screening Levels (ESLs) for commercial/industrial land use. Nine (9)
shallow groundwater monitoring wells are in place for active quarterly monitoring. All
site wells except two monitoring wells have already achieved concentrations below the
maximum contaminant level for PCE. The estimated residual dissolved phase mass is
less than 0.1 pounds and the estimated residual contaminant mass in shallow soil
vapor is less than 0.01 pounds. In summary, the residual mass beneath the site is a
very small amount, and is distributed across a fairly wide area with limited
concentrated areas. The selection of a remedial option should be based on the current
site condition and the applicability to the site.
Batch pumping with subsequent treatment and infiltration at the LTLW site or
recycling at properly licensed facility appears to be the most feasible option because it
is easy to implement and is cost competitive with ISTT and ISCO. The site has
numerous horizontal and vertical vapor wells which can serve as an infiltration gallery
for on-site discharge of the extracted water after treatment with liquid phase activated
carbon vessels. The knock-out transfer pump and on-site water storage tank for SVE
system can also be utilized for water storage and transfer of water for on-site
discharge.
In-situ thermal treatment methods would work for the site by expediting the
volatilization of contaminants, however, a completely new set of heating infrastructure
would need to be installed. The site power supply is inadequate to accommodate the
extreme power supply requirements. There are also concerns that heating the
sub-surface would damage site underground utility infrastructure including the
sub-surface remediation infrastructure. In addition, there are concerns of mobilizing
soil vapors into the occupied buildings in the shopping center. Finally, the thermal
treatment method is ill-suited to site conditions due to low distributed concentrations
and small amount of residual contaminant mass.
In-situ chemical oxidation appears to be an appealing option for this site. Chemical
oxidants are readily available and can be delivered via temporary injection borings or
existing wells. In addition, chemical oxidant demand is low due to the small residual
contaminant mass and low organic content of the subsurface soils. Therefore, by
choosing a suitable oxidant, ISCO may be an alternative option. ISCO is retained as a
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supplemental technology if augmentation beyond batch pumping is required
In summary, batch pumping is the preferred polishing option; ISTT is ill-suited to the
site conditions; and ISCO is reserved as an option for further polishing needs, if they
arise.
3.0 BATCH PUMPING WORKPLAN
This Section describes the methods and procedures that will be used to conduct batch
pumping (polishing remedial action) at LW-MW-1S, LW-MW-5S, LW-MW-9S and
LW-MW-11S.
3.1 Batch Pumping Methods and Procedures
E2C proposes to perform batch pumping using a vacuum trailer (VacStar).
Observations made during batch pumping will supply data regarding radii of influence
for vapor extraction and groundwater extraction, both key elements in evaluation of
the polishing remedial action. The method removes a combination of vapor and water,
even though the primary function is to extract contaminated groundwater. The
extracted soil vapor will be directly discharged to the atmosphere and the contaminant
discharge will be de minimis (less than 2 lbs/day). The El Dorado County Air Quality
Management District Rule 501.1.N exempts soil and groundwater remediation
operations that emit less than 2 pounds of pollutants in any 24 hour period without
the benefit of air pollution control devices.
3.1.1 Batch Pumping Operation Description
Batch pumping will be conducted at well LW-MW-1S, LW-MW-5S, LW-MW-9S, and/or
LW-MW-11S for up to 8 hours per event, one event per week for a 2-month period.
Data collected during batch pumping will be used to evaluate trends (chemical and
groundwater elevation). It is expected that batch pumping using a vacuum trailer on
wells LW-MW-1S, LW-MW-5S, LW-MW-9S, and LW-MW-11S will draw impacted water
from the area around the pumping wells and enhance volatilization of residual PCE.
3.1.2 Batch Pumping Monitoring
Prior to the start of batch pumping operations, depths to water will be measured in all
shallow monitoring wells (LW-MW-1S, LW-MW-2S, LW-MW-5S, LW-MW-9S, and
LW-10SR through LW-MW-13S). During each event, field data will be collected on an
hourly basis, as summarized below:
Applied vacuum (expected to be approximately above 18 inches of mercury) at
the monitoring well where batch pumping is occurring;
Induced vacuums at monitoring wells and vapor sampling points will be used to
observe the effects of the applied vacuum;
Influent vapor flow rate at the monitoring well where batch pumping is
occurring;
VOC concentration of the influent vapor stream to the VacStar using a Photo
Ionization Detector (PID);
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Groundwater level measurements in the monitoring well where batch pumping
is occurring and monitoring wells that are being used for observational
purposes; and
Groundwater removal rate.
These data will allow for calculation of the following parameters:
Radius of influence (Vapor phase)
Radius of influence (groundwater phase); and
Mass removal (vapor and groundwater phases).
3.1.3 Groundwater Monitoring
Prior to initial batch pumping operations and upon completion of the batch pumping
operation period, groundwater samples will be collected from wells LW-MW-1S,
LW-MW-5S, LW-MW-9 and LW-MW-11 used for batch pumping. During the batch
pumping operation period, a minimum of two additional sampling events will be
performed to monitor the effectiveness and progress of the batch pumping operation.
The pre- and post-batch pumping sampling will be attempted to coincide with regular
quarterly sampling event, if feasible. On the day after completion of each batch
pumping event, depths to groundwater will be measured at all wells. The first
progress sampling event will occur no longer than three weeks from the start of batch
pumping and the second progress sampling event will occur no longer than three
weeks from the first progress sampling event.
Groundwater samples will be transported to and chemically analyzed at ProVera
Laboratories, Inc. (ProVera), of Roseville, California, State of California-certified
analytical laboratory (DHS ELAP Certification #2606), for VOCs including PCE using
EPA Method 8260b.
3.1.4 Extracted Water Discharge
Water extracted during batch pumping operations will be stored on site in a storage
tank. The stored water will be treated with liquid-phase granular activated carbon
before on-site discharge under an appropriate General Waste Discharge Permit or off-
site recycling at a properly licensed facility. For on-site discharge, the treated water
will be fed either by gravity or by a transfer pump to the existing soil vapor extraction
wells (Figure 4) for discharge through existing plumbing with control values at the on-
site equipment compound. Samples of the treated water will be collected and analyzed
to comply with the Waste Discharge Permit requirements before discharge begins. The
pre-batch pumping water quality analytical data will be used as the influent data for
liquid GAC treatment system sizing and will be used to calculate mass of
contaminants removed in the dissolved phase.
3.2 Batch Pumping Report of Findings
Upon completion of the above-described batch pumping at LW-MW-1S, LW-MW-5S,
LW-MW-9S and LW-MW-11S, a report of findings (ROF) will be prepared, which will
detail the pumping methods and procedures. The ROF will be prepared under the
supervision of, be reviewed by, and be certified by a State of California Registered
Professional Geologist or Engineer and will include at a minimum the following:
Description of methods and procedures for batch pumping;
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Descriptions of vapor sampling and groundwater sampling methods and
procedures;
Tabular summaries of batch pumping field data;
Tabular summaries of vapor and groundwater analytical data;
Tabular summaries of vapor and groundwater extraction flow rates;
Estimates of chlorinated hydrocarbon mass removed, both vapor and
dissolved-phase;
Interpretation of testing results (including radii of influence for both vapor-
and dissolved-phase components); and
Evaluation of remedial option effectiveness.
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4.0 QUALITY ASSURANCE PLAN
This section describes field and analytical quality-assurance procedures to be followed
during the batch pumping remedial option and verification monitoring.
4.1 Sample Collection and Handling Protocol
Proper sample collection and handling are essential to assure quality of data obtained
from a sample. Each sample, therefore, will be collected in clean containers, preserved
correctly for the intended analysis and stored for no longer than permissible holding
time prior to analysis.
4.2 Sample Identification and Chain-of-Custody Documentation
Sample identification and Chain-of-Custody procedures are designed to assure sample
quality and to document sample possession from collection time to the time of
ultimate disposal.
The container for each sample submitted for analysis will have a label affixed with the
identifying number or the number will be inscribed directly on the container. The
analytical laboratory will assign a separate sample number unique to that sample for
internal sample coordination and identification. A description of the sample including
the sample number and other pertinent information regarding its collection and/or
geologic significance will be written in field notes and/or a geologic boring log being
prepared by the site geologist. These field documents will be kept in a permanent
project file. All samples will be analyzed by a state certified laboratory for the analyses
requested.
A properly completed Chain-of-Custody Form will be submitted to the analytical
laboratory along with sample. The laboratory's assigned number will be properly
entered on the form. A quality control officer at the lab will verify integrity of sample
submitted; proper sample volume, correctness of containers used, and properly
executed Chain-of-Custody Form. Pertinent information will be entered into a logbook
kept by the laboratory.
4.3 Analytical Quality Assurance
In addition to routine calibration of analytical instruments with standards and blanks,
the analyst is required to run duplicates and spikes on 10 percent of analyses to
assure an added measure of reliability and precision. Accuracy is verified through the
following:
1. U.S. EPA and State certification of results;
2. Participation in inter-laboratory round robin program;
3. The quality control officer on a weekly basis submits “Blind” samples for
analysis. These are prepared from National Bureau of Standards
specifications of EPA reference standards; and
4. Verification of results with an alternative method.
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5.0 SITE SAFETY PLAN
Introduction:
This Site Safety Plan (SSP) is designed to address safety provisions needed during the
remedial batch pumping work. Its purpose is to provide established procedures to
protect all on-site personnel from direct skin contact, inhalation, or ingestion of
hazardous materials and/or potentially hazardous materials that may be encountered
at the site. The SSP establishes personnel responsibilities, personal protective
equipment standards decontamination procedures, and emergency action plans.
The SSP describes means for protecting all on-site personnel from deleterious
contamination or personal injury while conducting on-site activities. As described
below all requirements promulgated by the California Department of Health Services
will be met.
Scope of Services
E2C seeks to enter property described above for the purpose of performing batch
pumping including groundwater sampling.
Responsibilities of Key Personnel:
All personnel on site will have assigned responsibilities. Mr. Aiguo Xu, P.E. of E2C
Remediation will be the Project Manager and serve as the Site Safety Officer (SSO). As
SSO, Mr. Xu will distribute copies of the SSP to on-site personnel. Personnel will be
required to document their full understanding of the SSP before admission to the site.
Compliance with the SSP will be monitored at all times by the SSO. Appropriate
personnel will conduct a training session to assure that all are aware of safe work
practices. In the training session, personnel will be made aware of hazards at the site
and will utilize Material Safety Data Sheets for information on compounds to be
encountered.
Mr. Xu will also be responsible to verify that field personnel keep proper field notes,
collect and secure samples, and assure sample integrity by adherence to Chain-of-
Custody protocol.
On-site employees will take reasonable precautions to avoid unforeseen hazards. After
documenting understanding of the SSP, each on-site employee will be responsible for
strict adherence to all points contained herein. Any deviation observed will be
reported to the SSO and corrected. On-site employees are held responsible to perform
only those tasks for which they believe they are qualified. Provisions of this SSP are
mandatory and personnel associated with on-site activities will adhere strictly hereto.
Job Hazard Analysis:
Hazards likely to be encountered on site include those commonly encountered when
operating any mechanical equipment, such as the danger of falling objects or moving
machinery. Simple precautions will reduce or eliminate risks associated with
operating such equipment.
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Qualified personnel only will have any contact with this equipment. All on-site
personnel, including the drilling contractor and his employees, are required to wear
hard hats and steel-toed shoes when in close proximity to drilling equipment. Latex
gloves will be worn by persons collecting or handling samples to prevent exposure to
contaminants. Gloves will be changed between samples, and used ones discarded, to
avoid cross-contamination. Proper respiratory equipment will be worn if vapor
contamination levels on site exceed action levels as determined using a PID or FID.
Action levels requiring respiratory apparatus will be 5 ppm, in the breathing space.
Furthermore, no on-site smoking, open flame, or sparks will be permitted in order to
prevent accidental ignition.
Risk Assessment Summary:
Exposure to chemicals anticipated on site are Tetrachloroethene (PCE).
Tetrachloroethene (PCE)
Tetrachloroethene (PCE) is a manufactured chemical that is widely used for dry
cleaning of fabrics and for metal degreasing. It is also used to make other chemicals
and is used in some consumer products. It is a nonflammable liquid at room
temperature. PCE evaporates easily into the air and has a sharp, sweet odor. Most
people can smell PCE when it is present in the air at a level of 1 ppm, although some
can smell it at even lower levels. High concentrations of PCE (particularly in closed,
poorly ventilated areas) can cause dizziness, headache, sleepiness, confusion, nausea,
difficulty in speaking and walking, unconsciousness, and death. Irritation may result
from repeated or extended skin contact with it. Results of animal studies, conducted
with amounts much higher than those that most people are exposed to, show that
PCE can cause liver and kidney damage. The chemical is known to the State of
California to cause cancer.
The OSHA PEL is listed as 100 ppm.
The Cal/OSHA PEL is listed as 25 ppm.
The TLV is listed as 25 ppm.
The IDLH is listed as 500 ppm.
Exposure Monitoring Plan:
A hydrogen-fired Flame-Ionization Detector (FID), or Photo Ionization Detector (PID),
will be used to monitor vapor concentrations around the site.
Personal Protective Equipment:
Personnel on site will have access to respirators with organic vapor and particulate
cartridges. Replacement cartridges will be available on site as needed. When handling
samples, the on-site geologist and technicians will wear latex gloves.
Hard hats and steel-toed shoes will be worn by all personnel at the Site when in
proximity of heavy equipment.
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Work Zones and Security Measures:
Access to the site will be restricted to authorized personnel. A set of cones, placards,
or wide yellow tape, surrounding the site will define the perimeter. The On-Site
technician will be responsible for site security.
Decontamination Measures:
Avoidance of contamination whenever possible is the best method for protection.
Common sense dictates that on-site personnel avoid sitting, leaning, or placing
equipment on possibly contaminated soil. All personnel will be advised to wash their
hands, neck, and face with soap and water before taking a break or leaving the site.
An eye wash station will be available at the site during chemical handling. Respirators
will be washed with soap and water following each day's use. Chemical handling
equipment used will be decontaminated by soap water. Sampling equipment will be
decontaminated before and after each sample is taken.
General Safe Work Practices:
All on-site personnel will be briefed each day in "tailgate" meetings as to the day's
goals and equipment to be used. Anticipated contaminants and emergency
procedures will be reviewed. Personal protective equipment (PPE), if necessary, will be
put on and verified correct by SSO, including respirator fit.
Sampling equipment will be new disposable equipment or will be steam-cleaned before
being brought on site.
The Project Manager will oversee operations. The Sample Coordinator will assure that
proper protocol is used at all times in collecting and handling samples.
Training Requirements:
The SSO will conduct a pre-site training session which will include all points of MSDS
forms, contaminant properties, warning signs, health hazard data, risk from exposure,
and emergency first aid. The SSO will assure that everyone fully understands site
hazards.
Medical Surveillance Program:
According to CFR 29, 1910.120, Paragraph (f), employees who wear respirators 30
days or more during one year or who have been exposed to hazardous substances or
health hazards above established permissible exposure limits are required to be
monitored medically. All site personnel will be required to have had a complete
physical examination within the past year.
Record Keeping:
Documentation will be kept on personnel exposed to contaminant hazards on the job
site according to OSHA regulations. These will include documentation that employees
received training on the SSP, respiratory protection, MSDS forms, and all emergency
procedures. These will be reviewed during the pre-site training meeting.
Project Number 1950BK27 September 8, 2016
E2C Remediation 13
Exposure records on each job will be kept for 30 years to meet requirements. Included
will be names and social security number of employees, medical evaluation, on-the-job
logs from entry to exit, first aid administered, visits on site by outside persons, and
personal air monitoring records.
Contingency Plans:
In the event of accident, injury, or other emergency, Project Manager, or other person
will notify appropriate government agencies or individuals as follows:
Police, Fire, or Ambulance Emergency 911 from pay/local phone (other for cellular)
Nearest Emergency Hospital
(See below for directions)
Nearest Hospital: (530) 541-3420
Barton Memorial Hospital
2170 South Ave
South Lake Tahoe, CA
DIRECTIONS TO HOSPITAL:
From Site travel northeast on Lake Tahoe Blvd toward Emerald Bay Rd and go 0.4
miles; turn right onto 4th St to hospital on left.
Emergency Numbers for E2C Remediation Personnel:
Mr. Aiguo Xu, P.E. of E2C will serve as the Project Manager and SSO. He may be
contacted by calling the following number: Cell Phone: (916) 580-9113.
In case of an emergency, you may contact Mr. Phil Goalwin, P.G. (President) of E2C at
the following number: Office Phone: (916) 782-8700.
DIRECTIONS TO BARTON MEMORIAL HOSPITAL
Project Number 1950BK27 September 8, 2016
E2C Remediation 14
6.0 LIMITATIONS AND WORKPLAN CERTIFICATION
This Workplan has been prepared under the professional supervision of the registered
professional whose seal and signatures appear herein. The conclusions of this Work
Plan are based solely on the Scope of Services outlined and the sources of information
referenced in this Work Plan. Any additional information that becomes available
concerning the Site should be submitted to E2C so that our conclusions may be
reviewed and modified, if necessary. This Workplan was prepared for the sole use of
Fox Capital Management and/or agent(s), Seven Springs Limited Partnership and/or
agents, the LRWQCB, the EDCEM.
E2C Remediation will perform the elements of the Workplan in accordance with the
generally accepted standards of care that exists in California at this time. It should be
recognized that definition and evaluation of geologic conditions is a difficult and
inexact science. Judgments leading to conclusions and recommendations are
generally made with limited knowledge of subsurface conditions present. No warranty,
expressed or implied, is made.
Prepared By:
Reviewed By:
Aiguo Xu, Ph.D.
Principal Engineer
C.E. # 72685
Philip Goalwin, P.G. #4779
Principal Geologist
Project Number 1950BK27 September 8, 2016
E2C Remediation Figures
FIGURES
Figure 1 Site Location Map
Figure 2 Site Plan
Figure 3 Second Quarter 2016 Groundwater PCE Distribution
Plot
Figure 4 Site Plan with Proposed Batch Pumping and Discharge
Locations
FIGURE
1
SITE
SITE LOCATION MAP
LAKE TAHOE LAUNDRY WORKS
1024 LAKE TAHOE BOULEVARD
SOUTH LAKE TAHOE, CALIFORNIA
1020 Winding Creek Rd., #110, Roseville, CA 95678
Phone: (916) 782-8700 Fax: (916) 782-8750
FIGURE2LAKE TAHOE LAUNDRY WORKS1024 LAKE TAHOE BOULEVARDSOUTH LAKE TAHOE, CALIFORNIANOT TO SCALESITE PLANLW-MW-1SLEGENDApproximate Location ofGroundwater Monitoring WellLW-MW-12SLW-MW-1SLW-MW-2SLW-MW-5SLW-MW-9SLW-MW-11SLW-MW-13SOS-1LW-MW-10SRN1020 Winding Creek Rd., #110, Roseville, CA 95678Phone: (916) 782-8700 Fax: (916) 782-8750
LAKE TAHOE LAUNDRY WORKS
1024 LAKE TAHOE BOULEVARD
SOUTH LAKE TAHOE, CALIFORNIA
TRANSIT
STATION
FIGURE
3SECOND QUARTER 2016
DISSOLVED-PHASE
PCE DISTRIBUTION PLOT
L A K E T A H O E B O U L E VA R DGLORENE AVENUERALEYS
LTLW
LEGEND
SZA Groundwater
Monitoring Well
LW-MW-1S
0 FT 50 FT
N
Tetrachloroethene (PCE)
Concentration (µg/L)
150
Not detected at or above
Method Reporting Limit
ND
LW-MW-2S
LW-MW-5S
LW-MW-11S
LW-MW-1S
LW-MW-12S
LW-MW-10SR
LW-MW-13S
LW-MW-9S
2.3
1.3
Dup. ND<0.50
110
0.64
0.66
?5
µg/L?5 g/Lµ
1020 Winding Creek Rd., #110, Roseville, CA 95678
Phone: (916) 782-8700 Fax: (916) 782-8750
ND<0.50
40
2.1
NS Not Sampled
LAKE TAHOE LAUNDRY WORKS
1024 LAKE TAHOE BOULEVARD
SOUTH LAKE TAHOE, CALIFORNIA
TRANSIT
STATION
FIGURE
4SITE PLAN WITH PROPOSED
BATCH PUMPING AND DISCHARGE
LOCATIONS
LAKE
T
AHOE
B
O
U
L
E
V
ARDGLORENE AVENUERALEYS
LTLW
LEGEND
Groundwater Monitoring Well
LW-MW-1S
0 FT 50 FT
N
LW-MW-5S
LW-MW-1S
LW-MW-5S
LW-MW-2S
LW-MW-11S
LW-MW-13S
LW-MW-9S
LW-MW-10S
LW-MW-12S
VP-1
VP-2
VP-3 VP-4
VP-5
VP-6
VP-7
VP-10
VP-8
VP-9
Soil-Gas Vapor Sampling Point
VE-1
VE-12
VE-13
VE-2
VE-19
VE-20
VE-18
VE-17
VE-16
VE-6
VE-7VE-10
VE-9
VE-15
VE-8
VE-14
VE-3
VE-5
VE-4
VE-11
VE-1
SVE Well Location
AS-1
AS-2
AS-3
AS-4 AS-5
AS-10
AS-8
AS-16
AS-11
AS-7
AS-13
AS-6
AS-20
AS-9
AS-15
AS-12
AS-14
AS-19
AS-21
AS-18
AS-22
AS-17
AS-23
AS-24
AS-25
AS-1 AS Well Location
AS-26
AS-27
Horizontal SVE Well Locations
(southern trench - 3 30’ HVE/northern trench 3 30’ HVE)
VP-10
1020 Winding Creek Rd., #110, Roseville, CA 95678
Phone: (916) 782-8700 Fax: (916) 782-8750
Batch Pumping Wells
Vapor Wells For
Extracted Water Discharge
After Treatment
Expected Radius of Influence
at a vacuum of 1 inch of water column