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RE_ Request for Access - South Y Sewer Line CCTV SurveyFrom:Ivo Bergsohn To:"Kyle S. Flory" Cc:Chris Stanley; Shannon Cotulla; John Thiel; gkvistad@bhfs.com; Brooks, Jeff@Waterboards; Scott Ferguson; Cazier, Abby@Waterboards; "Grey, Brian@Waterboards" Bcc:Doug Van Gorden; Richard Jones IV Subject:RE: Request for Access - South Y Sewer Line CCTV Survey Date:Thursday, February 28, 2019 10:50:48 AM Hi Kyle- Responses to your questions/comments are provided below. With these responses, I will request our legal counsel to move forward with developing a Reimbursement Agreement. Thanks, Ivo Bergsohn, PG, HG Hydrogeologist South Tahoe Public Utility District 1275 Meadow Crest Drive South Lake Tahoe, CA 96150 (530)543-6204 From: Kyle S. Flory [mailto:kflory@pesenv.com] Sent: Wednesday, February 27, 2019 10:09 AMTo: Ivo BergsohnCc: Chris Stanley; Shannon Cotulla; John Thiel; gkvistad@bhfs.com; Brooks, Jeff@Waterboards; ScottFerguson; Cazier, Abby@Waterboards; 'Grey, Brian@Waterboards'Subject: RE: Request for Access - South Y Sewer Line CCTV Survey Hi Ivo, Thank you for the proposed approach and fee estimate to conduct the work. The proposed approach is acceptable; however, we have a few comments/questions. The Water Board requested that we describe any defects observed during the CCTVsurvey in accordance with the National Association of Sewer Service Companies’(NASSCO) codes. Please confirm defects will be described in accordance with theNASSCO codes. Yes, personnel conducting the CCTV Survey from the DistrictsUnderground Repair-Sewer Department (U/G Repair-Sewer) are NASSCO certified.Coding of defects will be performed in the field by our personnel during the survey. Given that the work is being performed in accordance with a Water Board-approvedWork Plan prepared by the Working Parties, I presume that PES can be present toobserve the survey? Please confirm. Yes, PES is welcome to observe our U/G Repair- Sewer crew conduct the CCTV Survey. We will contact PES when this work can bescheduled, following completion of the Reimbursement Agreement. To the extent practicable, PES recommends performing the survey during low-flowconditions (i.e., when the depth of flow does not exceed one third of the pipe diameter). Our U/G Repair-Sewer crew will schedule the work for a period when conditions arefavorable for CCTV Survey. Our U/G Repair-Sewer crew believe that bellies may occur along the line of Sewer Main identified for CCTV Survey. In this case, the camera may follow the nozzle of the Hydro Truck and apply suction to evacuate the belly; or the upstream manhole would be plugged to allow for evacuation of the bellyand subsequent CCTV Survey of the Sewer Main. Please confirm PES will be provided a copy of the CCTV survey upon completion ofthe work. Yes, please have a flash drive for field transfer of the CCTV Survey files directly from our CCTV Truck. Thanks, Kyle 415-899-1600 From: Ivo Bergsohn <Ibergsohn@stpud.dst.ca.us> Sent: Tuesday, February 26, 2019 8:24 AM To: Kyle S. Flory <kflory@pesenv.com> Cc: Chris Stanley <cstanley@stpud.dst.ca.us>; Shannon Cotulla <scotulla@stpud.dst.ca.us>; John Thiel <JThiel@stpud.dst.ca.us>; gkvistad@bhfs.com; Brooks, Jeff@Waterboards <Jeff.Brooks@Waterboards.ca.gov>; Scott Ferguson <scott.ferguson@waterboards.ca.gov>; Cazier, Abby@Waterboards <Abby.Cazier@Waterboards.ca.gov>; 'Grey, Brian@Waterboards' <brian.grey@waterboards.ca.gov> Subject: RE: Request for Access - South Y Sewer Line CCTV Survey Hi Kyle- For your benefit, attached is the South Tahoe Public Utility District (District) proposed approach to complete the Stage 2 Proposed Video Survey of a section of the District’s Sewer Main, as shown on Plate 3 of the September 28, 2018 Preferential Pathway Evaluation Work Plan (PPEWP). If this approach is acceptable, I will request our legal counsel to develop a Reimbursement Agreement for this work. Thanks, Ivo Bergsohn, PG, HG Hydrogeologist South Tahoe Public Utility District 1275 Meadow Crest Drive South Lake Tahoe, CA 96150 (530)543-6204 From: Grey, Brian@Waterboards [mailto:brian.grey@waterboards.ca.gov] Sent: Thursday, February 14, 2019 3:51 PMTo: Ivo BergsohnCc: Chris Stanley; Shannon Cotulla; John Thiel; gkvistad@bhfs.com; Brooks, Jeff@Waterboards; ScottFerguson; Kyle Flory (kflory@pesenv.com) (kflory@pesenv.com); Cazier, Abby@WaterboardsSubject: RE: Request for Access - South Y Sewer Line CCTV Survey Ivo, Thank you for your February 11, 2019 re Request for Access- South Y Sewer Line CCTV Survey email and brief discussion yesterday. We appreciate your cooperation and understand your concerns. As you are aware, this office issued Cleanup and Abatement Order R6T-2017-0022 (CAO) to the responsible parties of the Lake Tahoe Laundry Works (LTLW) site on May 12, 2017. The CAO required an investigation to determine the lateral and vertical extent of contamination originating from the LTLW site, including evaluation of potential preferential pathways, and a corrective action plan to clean up and abate the contamination associated with the LTLW site. The September 28, 2018 Preferential Pathway Evaluation Work Plan (PPEWP) addresses the CAO requirement to investigate potential preferential pathways and to evaluate LTLW’s potential contribution to the regional PCE contamination. In your email, you indicate PES would not be able access the District’s infrastructure based on concerns associated with the age of the sewer lines and the potential damage from hydro-cleaning or the potential for equipment to become stuck if hydro-cleaning is not performed. However, you do offer to develop an investigation approach and to perform the investigative work using District personnel and equipment to limit any potential damage. You specifically requested to understand how the information obtained from the proposed CCTV inspection of the sewer lines would be used so that you could design an appropriate investigation to best achieve the objectives. You also indicate that a reimbursement agreement would be necessary to reimburse the District its costs for any performed work or for any potential damages prior to spending time developing an investigation approach. As indicated in the PPEWP, the CCTV inspection would be used to document the sewer line condition and to identify potential defects (ie open/offset joints, blockages, broken pipe, root penetrations, etc.) and any other potential release locations. The information from the CCTV inspection, in addition to any additional information (ie maintenance/inspection/repair/flow/blockage records) obtained during records review, would be used to target locations for the collection of additional soil vapor, soil, and groundwater samples. The targeted sampling would be used to evaluate if contaminant transport is occurring along preferential pathways (ie utility backfill), if other potential sources of chlorinated hydrocarbons are present, and if these potential sources are contributing to the regional PCE contamination. Staff support the investigation of potential preferential pathways and remaining PCE source areas so that appropriate remedial alternatives to cleanup and abate the regional PCE contamination can be developed. Available information indicates that elevated concentrations of PCE have recently been detected in passive soil gas samples and historically from discrete depth groundwater samples along Glorene Avenue. Staff encourage you to work with PES Environmental, Inc. to enter into a reimbursement agreement so that an investigation approach can be developed and agreed upon. Kyle Flory of PES Environmental, Inc, is cc:ed on this message. Please contact me directly with any other questions or comments in the meantime. Again, we appreciate your assistance and cooperation. Thank you. BG Brian Grey, PG Engineering Geologist Lahontan Water Board- Region 6 2501 Lake Tahoe Boulevard South Lake Tahoe, CA 96150 (530) 542-5421 (direct) (530) 544-2271 (fax) Brian.Grey@Waterboards.ca.gov Tuesday-Friday 7:00AM-4:30PM From: Grey, Brian@Waterboards Sent: Tuesday, February 12, 2019 7:23 AM To: Ivo Bergsohn <Ibergsohn@stpud.dst.ca.us> Cc: Chris Stanley <cstanley@stpud.dst.ca.us>; Shannon Cotulla <scotulla@stpud.dst.ca.us>; John Thiel <JThiel@stpud.dst.ca.us>; gkvistad@bhfs.com; Brooks, Jeff@Waterboards <Jeff.Brooks@Waterboards.ca.gov>; Ferguson, Scott@Waterboards <scott.ferguson@waterboards.ca.gov> Subject: Re: Request for Access - South Y Sewer Line CCTV Survey Thanks Ivo. I'll look forward to touching base soon and discussing further. Brian Grey, PG Engineering Geologist Lahontan Water Board- Region 6 2501 Lake Tahoe Boulevard South Lake Tahoe, CA 96150 Direct: 530 542-5421 email: Brian.Grey@Waterboards.ca.gov Schedule: Mondays off; Tues.-Fri. 7-4:30 From: Ivo Bergsohn <Ibergsohn@stpud.dst.ca.us> Sent: Monday, February 11, 2019 12:11 PM To: Grey, Brian@Waterboards Cc: Chris Stanley; Shannon Cotulla; John Thiel; gkvistad@bhfs.com Subject: Request for Access - South Y Sewer Line CCTV Survey Dear Brian, This email follows our recent conversations regarding PES' Environmental, Inc. (PES) request to accesscertain sewer lines owned by the District. We understand that the Lahontan Regional Water QualityControl Board (Regional Board) supports PES’s request. While the District desires to cooperate with theinvestigation, we do have certain concerns that need to be addressed. As background, PES requested access to perform a closed-circuit television video (CCTV) survey of thesewer lines located in Tucker Avenue, Glorene Avenue, and Lake Tahoe Boulevard (10-inch sewer mainsection extending from manhole TK-578 to TK-576 along Glorene Avenue ;and from manhole TK-576 toTK-536 along Tucker Avenue). Hydro-cleaning was also requested prior to performing the CCTV survey.We understand that the proposed work is required by the Responsible Parties' Preferential PathwayEvaluation Work Plan (PES, 9/28/2018) submitted to the Regional Board pursuant to Cleanup AbatementOrder R6T-2017-0022. However, the District does not allow third party hydro-cleaning or other access toits facilities for health and safety reasons. As I am sure you are aware, CCTV'ing of wastewater collectionpipelines without hydro -cleaning in advance is ineffective and occasionally leads to equipment beingstuck in the pipelines. The District is also concerned about possible damage from hydro-cleaning due tothe age of these sewer lines (the section of sewer line identified for Stage 2 Proposed Video Survey wasconstructed in 1960). For these reasons, the District was unable to allow PES access to its facilities. The District staff has discussed PES’ request after our recent conversations in an effort to cooperate withthe Regional Board's investigation of the PCE plume. In order to provide assistance, the District wouldlike to understand exactly what information PES and the Regional Board seeks to obtain from aninvestigation of the interior of the District’s sewer lines. In the Work Plan, the approach for the Stage 2investigation is left open to modification based on the findings of the Stage 1 investigation. If the Districtcan obtain that understanding, the District is willing to prepare an investigation approach on how bestobtain that information while limiting the potential for damage. The District would then propose arecommended approach to PES and the Regional Board for consideration. If acceptable, the Districtwould perform the investigation with its personnel and equipment. Prior to the District spending timedeveloping an investigation approach and performing the subsequent work, the District would require theResponsible Parties to enter into a reimbursement agreement with the District to reimburse its costs andexpense for this work, as well as any damage that might occur to the sewer line, in order to avoid theprohibition against gifting public funds. After you have an opportunity to consider the District’s recommendation, we should arrange a time todiscuss further. Ivo Bergsohn, PG, HG Hydrogeologist South Tahoe Public Utility District 1275 Meadow Crest Drive South Lake Tahoe, CA 96150 (530)543-6204 This email message has been delivered safely and archived online by Mimecast. This email message has been delivered safely and archived online by Mimecast. 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