Loading...
HomeMy WebLinkAboutRISK MANAGEMENT 8/14/1992 REMEDIAL ACTION WORK PLAN FOR PETROLEUM IMPACTED SOIL DON KEITH TRANSPORTATION 2990 PIERCE ROAD BAKERSFIELD, CALIFORNIA August 14, 1992 Prepared by Earth Systems Environmental, Inc. 6701 McDivitt Drive, Suite B Bakersfield, California 93313 (805) 836-0901 FAX (805) 836-0911 Project No.: EB-8228-3 Earth Systems Environmental, Inc. A Member of The Earth Systems Group 6701 McDivitt Drive, Suite B · Bakersfield, CA93313 · (805)836-0901 · FAX(805) 836-0911 August 14, 1992 Doc. No.:9208-E028.WP Project No.: EB-8228-3 .... Kern County Resources Management Agency Department of Environmental Health Services 2700 M Street, Suite 300 Bakersfield California 93301 Attention: Ms. Flora Darling SUBJECT: REMEDIAL ACTION WORK PLAN FOR PETROLEUM IMPACTED SOIL DON KEITH TRANSPORTATION 2990 PIERCE ROAD BAKERSFIELD, CALIFORNIA REFERENCE: PRELIMINARY SITE CHARACTERIZATION OF PETROLEUM IMPACTED SOILS, DON KEITH TRANSPORTATION, BAKERSFIELD, CALIFORNIA (ESE, AUGUST 12, 1992) INTRODUCTION Earth Systems 'Environmental (ESE) has been contracted by Kern Environmental Service representing Don Keith Transportation to prepare this work plan for soil remediation activities at Don Keith's Asphalt and Diesel Transportation Company located at 2990 Pierce Road, Bakersfield, California. ESE proposes excavation and bio- reclamation of approximately 1,000 cubic-yards of soils impacted with petroleum based compounds associated with two earthen clarifiers connected to a truck wash ....... ii~"~'i. :~.i'.~'~'~'~ i .... "~3'~ rack as well as excavating and disposing of approximately .300::;~¢ubl~-yar~:~o ~:-~a petr01eum.;.;~7:~basb'dZ":7-~]~i~~ifft[d with the former operation of two tanker truck bottoms disposal pits recently documented by ESE in the above referenced report. After review of the available data, ESE believes the 1,000 cubic yards of impacted soil from beneath the former clarifiers can be treated on-site utilizing biological degradation technologies. The advantages of bio-reclamation is the permanent destruction of the petroleum hydrocarbons, thus minimizing the potential long term liabilities associated with off-site disposal at a hazardous waste facility. The final by- products of biologic degradation of the petroleum hydrocarbons consist primarily of carbon dioxide (CO2) and water. Don Keith Transportation 2 August 14, 1992 We propose the construction of a bio-reclamation treatment system on-site as the most suitable method for mitigating the semi-volatile petroleum based compounds and reducing the concentrations of. petroleum hydrocarbons within the soils at the above mentioned site to levels considered to be non-hazardous by Regional Water Quality Control Board Central Valley District, 'and Kern County Resources Management Agency, Department of Environmental Health Services' criteria. Following approval by Kern County Department of Environmental Health Services a biological treatment system will be implemented to treat impacted soils at the site. Upon successful completion of the biological treatment (reduction of total petroleum hydrocarbon concentration to below the acceptable limits), and with the permission of the local governing regulatory agency, we will request that the treated soil be on-site as as grading fill.'~ We anticipate the minimum time frame for spread successful treatment utilizing biological degradation capabilities to be on the order of 2 months. Based on our past experience with similar sites, we believe that the construction of an ab°ve ground treatment cell would present the most cost effective and efficient method for ~remediating the impacted soil. The treatment system is based on enhancing indigenous soil microbes and/or the introduction of cultured specific strains of common microbes suited for the biological degradation of semi-volatile petroleum based hydrocarbons. All methods employed are in compliance with regulations and guidelines set forth in California Code of Regulations (CCR) Title 22, Article l l, and Title 23, Chapter 3, California Site Mitigation Decision Tree Manual, the Code of Federal Regulations (CFR) Title 29, Part 1910, Section 120, CFR Title 40, Parts 300-399, and the San Joaquin Valley Unified Air Pollution Control District, Kern County Zone Rules 463.5 as well as accepted professional environmental/geotechnical engineering procedures and applicable local regulations. EB-8228-3 9208-E028.WP Don. K¢ith TransPOrtation 3 August 14, 1992 Subject to your acceptance of this work plan, our plan to excavated the soils beneath the 'former clarifiers and treat the soils with bio-reclamation technology as well as excavating and disposing, of the tank bottoms includes: · Preparation of a site Health and Safety Plan in accordance with regulations set forth in Federal OSHA CFR 29 1910.120, as well as California OSHA regulations. · Excavation of approximately 1,000 cubic yards of impacted soil beneath the location of the former truck wash clarifiers. · Excavation of approximately 300 cubic yards of sludge materials within the former tanker truck bottoms disposal pits. · Confirmatory sampling and analysis of the three excavation pit' bases and sidewalls. · Backfilling pit with "clean" import fill material, compacting, and returning to surface grade. · Loading and transporting the tank bottoms sludge to an appropriate petroleum waste disposal facility. · Placement of the clarifier impacted soil in a six inch lift over the rear portion of the property. · Mechanical cultivation increasing oxygenation and enhancing indigenous soil microbes to reduce the concentrations of the petroleum hydrocarbons to beneath -RWQCB recommended guidelines. · Progress monitoring and sampling. · 'Verification sampling and preparation of a final report documenting remediation activities. Subsequently we have developed the following scope of work: Site Description The site is located at 2990 Pierce ROad in the city. of Bakersfield in Kern County, California (Figure 1). The site is currently used as a parking area where the tanker trucks are parked. EB ~8228-3 9208-E028.WP Don Keith Transportation 4 August 14, 1992 The site is situated within a developed industrial area. Nearby surrounding properties are primarily retail businesses, petroleum service companies, refineries, and actual oil producing properties. The overall site topography is essentially-flat, with a very slight fall to the west. Background Based on conversations with Chris DeArmon, two locations on the subject property had a potential for subsurface soil' impacted with petroleum hydrocarbons and required assessment as part of a baseline environmental assessment at Don Keith's Asphalt and Diesel Transportation Company. The first area is that of a very large, two stage, earthen bottom clarifier system which formerly served the truck wash for the crude oil, asphalt, fuel oil and diesel fuel trucking firm. The clarifiers have been backfilled and no surface evidence, remains. The property owner has provided a description of the size of each clarifier, and flagged their boundaries. The second area consists of two disposal pits in the rear of the property which received tanker truck bottoms. The surface of these has been covered with soil, however stained soil is visible at the surface in the location of the two pits. ESE has conducted an initial site characterization consisting of eleven soil borings and laboratory analysis of 27 soil samples to evaluate the extent of petroleum hydrocarbons impacted soil in the vicinity of both the former truck wash earthen clarifiers and tank bottom disposal pits. Subsurface Investigation Drilling of four initial borings was conducted on July 13, 1992. Drilling of seven additional borings to more fully assess the vertical and lateral extent of the impacted soils was conducted on August 6, 1992. A total of eleven soil borings were drilled within this phase of soil characterization (Figure 2). One soil boring, TH-1 was drilled on July 13, 1992 through the center of the western of the two former truck wash clarifiers location to a depth of 31 feet below surface grade to assess the potential for petroleum hydrocarbons in the subsurface at that location. On August 6, 1992 this boring was twinned by boring TH-IA which was advanced to a depth of 46 feet to assess, the vertical limit of the petroleum hydrocarbons encountered in boring .TH-1. A soil boring, TH-2 was drilled on July 13, 1992 through the' center of the EB-8228-3 9208-E028.WP Don Keith Transportation 5 August 14, 1992 eastern of the two former clarifiers to a depth of 36 feet below surface grade to assess the potential for petroleum hydrocarbons at that location. On August 6, 1992 this boring was twinned by boring TH-2A which was advanced to a depth of 48.5 feet to assess the vertical limit of the petroleum hydrocarbons encountered in boring TH-2. Soil borings TH-3A, TH-4 and TH-4A were advanced around the peripherY of the two earthen clarifiers to assess the lateral limits of the petroleum hydrocarbons encountered in borings TH-1 and TH-2. Soil boring TH-3A was drilled drilled 35 feet southeast of TH-2 outside of the former eastern clarifier location to a dep~ to assess the the potential for lateral migration of petroleum hydrocarbons in that direction. Soil boring TH-4 was drilled drilled 20 feet north of TH-2 to a ~ feet to assess the the potential for lateral migration of petroleum hydrocarbons in that direction. Soil boring TH-4A was drilled drilled 35 feet southwest of TH-1 to a depth of 35 fee~,~o~,~ess~,~-th..~,~~tential for lateral migration of petroleum hydrocarbons in that direction. A soil boring, NP was drilled through the center of the northern tank bottom disposal pit location to a depth of 27 feet below surface~. grade to assess vertical migration of petroleum hydrocarbons at that location. Soil boring TH-3 was drilled drilled 25 feet northeast of NP to a depth of 31 feet to assess the the potential for lateral migration of petroleum hydrocarbons in that direction. A soil boring, SP was drilled through the center of the southern tank bottom disposal pit location to a depth of 36 feet below surface grade to assess vertical migration of petroleum hydrocarbons at that location. Soil boring SPL was drilled drilled 35 feet east of SP to a depth of 21 feet to assess the the potential for lateral migration of petroleum hydrocarbons in that direction. To 'better define the limits of the two tank bottoms disposal pits a backhoe operated by Kern Environmental Service was used to excavate five foot deep trenches in the rear portion of the property. Upon exposing the limits of the pits a composite soil sample was collected from the sludge within the two pits at a depth of three feet below surface grade. Laboratory Analysis Twenty-six soil samples and one sludge sample were submitted to B. C. Laboratories of Bakersfield, Califorinia for analysis. All twenty-seven samples were analyzed for Total Recoverable Petroleum Hydrocarbons (TRPH) as oil and grease using USEPA Test Method 418.1. Seven of the samples including the tank bottoms sludge were analyzed EB-8228-3 9208-EO28-Wp Don Keith Transportation 6 August 14, 1992 for California Title 22 metals. Six of the samples including four from the area of the earthen clarifiers, and two from the area of the tank bottoms disposal pits were analyzed for volatile and semi-volatile organics using USEPA Test Methods 8240 and 8270. Five samples including the sludge were analyzed for Total Extractable Petroleum Hydrocarbons as diesel (TEPHd) using the DOHS LUFT Manual Method. Four deeper soil samples beneath the earthen clarifiers were analyzed for total lead using the DOHS LUFT Manual Method. The tank bottom pit sludge was also analyzed for fuel constituent volatile aromatics using USEPA Test Method 8020, and for pH. Results of the Investigation Geologic Setting Regional Geology: The site is located in the southern part of the Great Valley geomorphic province. The Great Valley is a north-south trending valley, approximately 400 miles long by 50 miles wide. Surface and groundwater in the San Joaquin Valley is derived predominantly from the Sierra Nevada mountain range to the east, and is transported by five major rivers, the southern most being the Kern River. The subject site is located approximately 1/2 mile northwest of the Kern River. The surface of the San Joaquin Valley is composed primarily of unconsolidated Pleistocene (1.6 million to 11,000 years ago) and Recent (11,000 years ago to the present) alluvial sediments. Beneath the alluvial sediments are older, predominantly lake bed deposits. These lie unconformably on Mio-Pliocene marine sediments which extend to crystalline basement at approximately 20,000 feet. Site Geology: Geologic deposits in the study area include Pleistocene alluvial sediments of the Kern River Formation, which form a homocline dipping gently to the west. The deposits are alluvium consisting of poorly indurated and dissected fan deposits (CDMG, 1964). The depth to the regional unconfined aquifer was estimated prior to drilling to be approximately 50 feet below surface grade beneath the site (Kern County Water Agency, Improvement District No. 4, 1991 Report on Water Conditions, February EB-8228-3 9208-E028.WP Don Keith Transportation 7 August 14, 1992 1992). ~er was'not encountered in boring TH-2A which penetr~2ted to a~.~ w.~_th of-~48.5 fee~ ~ The deepest samples in the borings were moist, but did not have an 'indication that the capillary fringe to groundwater was at that depth. Because of the --- six consecutive years of drought, and the discontinuance by the Kern County Water Agency of using several large water recharge percolation ponds 1/2 'mile to the north, a drop in the elevati9n of groundwater by as much as 25 feet ~e ,,.o~c~.rred in the area. The nearest known occurrence of perched groundwater is 8 miles to the southeast at a depth of 20 feet in the abandoned Kern River channel to the ancient Kern Lake Bed (Kern County Water Agency, 1991 Water Supply Report, May 1992). No perched groundwater is known to exist beneath the subject site. Subsurface material encountered during drilling was alluvium to the total depth of each boring. The alluvium was characterized by unconsolidated, highly permeable, light brown, silty sand (SM) to a depth of approximately 7 feet, overlying unconsolidated, highly permeable, tan, well graded fine- to coarse- grained sand (SW) to a depth of approximately 23 feet. This is underlain by a sequence of unconsolidated, highly permeable, light tan, fine- to coarse- grained gravelly sand (SW/GW) to a depth of 38. Beneath this is a sequence of unconsolidated, highly permeable, light tan, fine- to coarse- grained sand (SW) to a depth of 43, overlying uncOnsolidated, highly permeable, light tan, well graded fine- to coarse- grained moderately silty sand (SW/SM) to a depth of approximately 46 feet. This is underlain by a sequence of consolidated, moderate to low permeability, light tan, very clayey silt (ML/CL) to a depth of 48.5 which was the greatest depth investigated. Laboratory Analytical Results Total Recoverable Petroleum Hydrocarbons (TRPH) as oil and grease were detected at a concentration of 7,900 mg/kg at 10 feet in boring TH-1 advanced through the center of the western clarifier location, but not at 20, 30, 40 and 45 feet in boring TH-lA advanced in the same location. TRPH was detected at a concentration Of 10,000 mg/kg at 10 feet in boring TH-2 advanced through the center of the eastern clarifier location and 40 mg/kg at 20 feet in boring TH-2A, but not at 40 and 47 feet in boring TH-2A. TRPH was not detected at depths of 15 and 25 feet in boring TH-3A advanced 35 'feet southeast of TH-2 on the outside of the former clarifier location, or at depths of EB-8228-3 9208-E028.WP Don Keith Transportat. ion 8 August 14, 1992 10-and 20 feet in boring TH-4 advanced 20 feet north of TH-2, or at depths of 10 and 25 feet in boring TH-4A advanced 35 feet southwest of TH-1. However, TRPH was detected at 20 rog/kg at a depth of 35 feet in boring TH-4A. Total Extractable Petroleum Hydrocarbons as diesel (TEPHd) were analyzed for in the soil samples at 20 feet in borings TH-lA and TH-2A at concentrations of 19 mg/kg, and 23 mg/kg, respectively. The fuel constituent volatile aromatics m- and p-xylenes were detected at a concentration of 0.006 mg/kg at 10 feet in boring TH-1. The fuel constituent volatile aromatics toluene was detected at a concentration of 0.022 rog/kg at 10 feet in boring TH-2. No other volatile organic hydrocarbons including those which constitute fuels and industrial solvents were detected at or above the minimum detection limit in the four soil samples collected from the clarifier area. No semi-volatile organic hydrocarbons (base neutral and acid extractables) were detected at or above the minimum detection limit in the four soil samples collected from the clarifier area. Lead was detected at an elevated concentration in one of eight samples from the clarifier area. Total lead was detected at a concentration of 27 mg/kg at a depth of 10 feet in boring TH-2 advanced through the center of the eastern clarifier, but was not detected in boring TH-2A at 20 and 40 feet, at 10 and 20 feet in boring TH-4 position 20 feet north of TH-2, and at 10 feet in boring TH-1 or 20 feet in boring TH-lA both located in the center of the western clarifier. Total lead was detected at 2.7 mg/kg at 20 feet in boring TH-lA. The State of California Title 22 Total Threshold Limit Concentration (TTLC) for lead is 1,000 mg/kg. However, the Soluble Threshold Limit Concentration (STLC) for soluble lead is 5 mg/kg. Because of the 10:1 dilution that occurs during the wet extraction any total concentration less than 50 rog/kg will necessarily be determined to have a soluble component less than the STLC of 5 mg/kg. Therefore, a soluble lead wet extract was not performed on the sample in this investigation with a concentration of total lead detected of 27 rog/kg. EB-8228-3 9208-EO28.WP Don Keith Transportation 9 August 14, 1992 Arsenic, barium, chromium, cobalt, copper, nickel, vanadium, and zinc were detected in the four soil samples from the clarifier area at concentrations typical of the background concentrations for these metals in the soil in the area of the subject property. The other Title 22 metals were not detected in the four soil samples from the clarifier area. Total Recoverable Petroleum Hydrocarbons (TRPH) as oil and grease was detected at a concentration of 45,000 mg/kg is the composite sample of the sludge from at depth of · three feet within the tank bottoms disposal pits. Total Extractable Petroleum ,(TEPHd)/-~as detected at a concentration of 12,000 mg/kg in Hydrocarbons as diesel this sample. The fuel constituent volatile aromatics benzene, toluene, ethylbenzene, and total xylenes were detected at concentrations of' 0.013 mg/kg, 0.038 mg/kg, 0.021 mg/kg, and 0.177 mg/kg, respectively. The pH of the sludge was measured at 7.17. TRPH was not detected in.the north pit vertical assessing boring NP at depths of 10, 20 and 25 feet, and in the north pit lateral boring TH-3 at 15 and 25 feet. TRPH was detected in the south pit vertical assessing boring SP at l0 feet at a concentration of 20 mg/kg and 25 feet at a concentration of 60 mg/kg and in the south pit lateral boring SPL at 10 feet at a concentration of 160 mg/kg, but not in vertical assessing boring SP at a depth of 35 feet, or in the south pit lateral boring SPL at 20 feet. The semi-volatile organic hydrocarbon diethyl phthalate was detected at a concentration of 0.1 mg/kg at 15 feet in boring TH-3 advanced adjacent to the northern tank bottoms disposal pit. No other volatile organic hydrocarbons, or semi- volatile organic hydrocarbons were detected at or above the minimum detection limit in the two samples collected from the area of the tank bottoms disposal pits. Lead was detected at an elevated concentration in the sample of the sludge from the disposal pits. Total lead was detected at a concentration of 44 mg/kg. The State of California Title 22 TTLC for lead is t,000 rog/kg. However, the STLC for soluble lead is 5 mg/kg. Because of the 10:1 dilution that occurs during the wet extraction any total concentration less than 50 mg/kg will necessarily be determined to have a soluble component less than the STLC of 5 mg/kg. Therefore, a soluble lead wet extract was not performed on the sludge sample. Cadmium was detected at 1.2 mg/kg in the EB-8228-3 9208-E028.WP Don Keith Transportation 10 August 14, 1992 sludge. Cadmium's TTLC is 100 mg/kg, and STLC is 1 mg/kg. Copper was detected at 66 rog/kg in the sludge. Copper's TTLC is 2,500 mg/kg, and STLC is 25 rog/kg. Mercury was detected at 0.39 mg/kg in the sludge. Mercury's TTLC is 20 mg/kg, and STLC is 0.2 mg/kg. Nickel was detected at 61 mg/kg in the sludge. Nickel's TTLC is 2,000 mg/kg, and STLC is 20 rog/kg. Vanadium was detected at 87 rog/kg in the sludge.' Vanadium's TTLC is 2,400 rog/kg, and STLC is 24 mg/kg. Each of these concentrations are far belOw their respective regulatory limits. Therefore, the sludge is not classified as a hazardous material by RCRA and California Title 22 criteria. However, these concentrations are in excess of that which occurs in the native soil and indicates an accumulation 'from the petroleum products. There may be a minor amount of mobility for these metals from the sludge into 'the underlying soil, 'however this has not been observed in the investigation. The Regional Water Quality Control Board provides recommended guidelines for TRPH as oil and grease, TEPH as diesel, the fuel constituent volatile aromatics, benzene, toluene, ethylbenzene and total xylenes, and the semi-volatile organic hydrocarbon diethyl phthalate using the LUFT methodology by multiplying the most stringent current federal or state water quality standards by a factor of 100 to account for attenuation due to site-specific parameters including vertical separation to ground water, soil lithology, fractures in subsurfaces, annual average precipitation, and any direct conduits to groundwater. These recommended guidelines are 1,000 mg/kg for TRPH as oil and grease, 100 mg/kg for TEPH as diesel, 0.3 mg/kg for benzene, 1.0 mg/kg for toluene, 4.0 mg/kg for ethylbenzene, 3.0 mg/kg for total xylenes, and 50 mg/kg for diethyl phthalate. Laboratory analytical results for the twenty seven soil samples from the eleven soil borings are summarized in Table I. EB-8228-3 9208'E028-WP Don Keith Transportation 11 ~f \ August 14, 1992 LABORATORY ANALYTICAL DATA SUMMARY OF ~values in mmlgrams ~er ~cno]~ram] II Total IDieth¥1]Total 3il__,~easel, benzene Xylene. s Phthalate Lead TH- 1 10', 7,900_ ~] ND 'ND ND 0.006 ND ND 3o' TH-lA 40' ND TH-IA 45' .~-----..2~D. / TH-2 10' 10~000 ~ ND 0.022 ND ND ND 27 TH-2A 20' 40T ND TH-2A 40' ND ~ ND TH-2A 47' ND TH-3A 15' ND TH-3A 25' ND TH-4 10' ND ND ND ND ND ND ND TH-4 20' ND ND ND ND ND ND ND TH-4A l 0' ND TH-4A 25' ND TH-4A 35' 20 Sludge '3' . '~'"--~,~ . 13 0.038 0.021 0.177 44 · NP ', 10' ' N_D _'J Np 2'0,' ~ NP 25' ND TH-3 15' ND ND ND ND ND 0.1 3.0 TH-3 25' ND ND ND ND ND ND ND SP 10' 20 ' SP 25' 60 SP 35 ND SPL 10' ~160J SPL 20' ND A L NA 1,000 0.3 1.0 4.0 3.0 50 NA TILC NA NA NA NA NA NA N,A 1 t000 MRL NA 20 0.005 0.005 0.005 0.005 0.005 2.5 ND: None Detected at or above minimum reporting level (MRL). NA: Not Applicable. A L: Regional Water Quality Control Board recommended guidelines for concentrations in soil. Recommended guidelines were calculated using the LUFT methodology by multiplying the most stringent current federal or state water quality standards by a factor of 100 to account 'for attenuation due to soil composition and distance from groundwater. TTLC: State of California Title 22 Total Threshold Limit Concentration. EB -8228 -3 9208-E028 .WP Don Keith Transportation ~ 12 August 14, ~992 Conclusions of the Investigation The data obtained suggest that soil impacted beneath the former location of the truck wash earthen clarifiers has been impacted by petroleum hydrocarbons at concentrations in excess RWQCB recommended guidelines to a depth of less than 20 feet below surface. The data does not'indicate that fuel constituents,· solvents, or heavy metals 'have imPacted this soil. ESE concludes that the petroleum hydrocarbons detected represent heavier molecular weight crude oil and refined products devoid of known hazardous constituents. The lateral extent of this impacted soil does not extend laterally from ~ the boundaries of the former clarifiers. Therefore, ESE estimates that the soil between the base of the former clarifiers at a depth of 8 feet to a depth of 18 feet has concentrations of TRPH as oil in grease in excess of the recommended guidelines over an area 75 feet long by 40 feet wide for a volume of impacted soil of approximately 1,000 cubic yards. It is ESE's oppinion that excavation of the soil to these dimensions will removal all of the impacted soil with concentrations of TRPH as oil and grease in excess of 100 mg/kg. The operation of the tank bottoms disposal pits appears to have impacted the soil to a depth of less than 5 feet at the location of the pits, The data does not indicate that fuel constituents, solvents, or heavy have impacted this soil. However, the sludge does contain slightly elevated concentrations of heavy metals, but remains classified as non-hazardous by RCRA and California Title 22 criteria. ESE concludes that the petroleum hydrocarbons detected represent heavier molecular weight crude oil and refined products. The lateral extent of this impacted soil does not extend laterally from the boundaries of the disposal pits. Therefore, ESE estimates that the soil within the northern pit to a depth of 5 feet has concentrations of TRPH as oil in grease in excess of the recommended guidelines over an area 30 feet long by 25 feet wide for a volume of impacted soil of approximately 140 cubic yards, and soil within the southern pit to a depth of 5 feet over an area 55 feet long by 15 feet wide for a volume of approximately 150 cubic yards. It is ESE's oppinion that excavation of the soil to these dimensions will removal all of the impacted soil with concentrations of TRPH as oil and grease in excess of 100 mg/kg. EB-8228-3 9208-E028.WP Don Keith Transportation 1 3 August 14, 1992 Recommenqlations of the Invest. igation ESE recommends excavation and surface bioremediation of the soil beneath the former clarifiers, and excavation and off-site disposal of the sludge from the disposal pits. The impacted soil from beneath the former clarifiers should be excavated to a depth 18 feet and treating the soil to concentrations less than the RWQCB recommended guidelines through the process of bioremediation at the subject property. Surface bioremediation has been shown to be particularly successful in the San Joaquin Valley given the high temperature, and low relative humidity. This option is particularly viable at this site since the facility has available land to treat the soil. The impacted soil beneath the former clarifiers will respond very well to surface bioremediation. Because the property is in a commercial/petroleum setting, there is only 'a slight risk of exposure of any off site population to volatilized petroleum hydrocarbons, and therefore very little health risk to the general public associated with the treatment. This option can be particularly attractive since on site treatment alleviates the clients future liability for the soil. On-site treatment is not recommended for the sludge from the disposal pits because it will require an inordinate amount of time and effort for bioremediation to reduce the concentrations to below the RWQCB recommended guidelines. The impacted soil from beneath the former disposal pits should be excavated to a depth of 5 feet where the site assessment indicates that the limits of concentrations .~ t_.he' - ' RWQCB recommend,ed guidelines wi'Il have been reached~ Selection of ~ ~~rt~'ate recycling or disPosal facility depends on the concentration of contaminants in the soil after it is stockpiled. Judging from the findings of this study, it appears likely that the semi-solid/semi-liquid state of the sludge from the disposal pits makes that material unacceptable to solid waste recycling facilities. It is ESE,s opinion that the appropriate classification for this material is as a designated petroleum waste, and that the sludge materials may be disposed of as non-hazardous petroleum waste landfill such as the McKittrick Waste Disposal Site. Don Keith Transportation 14 August 14, 1992 HEALTH & SAFETY PLAN A written Health and Safety plan will be implemented for site work conducted during the mitigation phase of this project. The purpose of the plan is-to provide specific - safety procedures to be implemented during the handling of petroleum hydrocarbon contaminated materials. The Health and Safety Plan is required under regulations set .forth in Federal OSHA CFR 29 1910.120, since the referenced report documented the presence of potentially hazardous materials at the site. This Health and Safety plan is included as Appendix A to the work plan. REMEDIAL ACTION PLAN Soil Excavation Kern Environmental Services will provide front,/el~--~'o~rs, and a self-elevating paddle wheel scraper to excavate the estimated~l,00~; yards of impacted soil beneath the the two former clarifiers, and the 300 ~ yards of tank bottoms within the former disposal pits. · Based upon Regional Water Quality Control Board Recommended Guidelines,' and Kern County policy, ESE proposes an action level of 1,000 mg/kg for the maximum concentration of Total Recoverable Petroleum · Hydrocarbons (TRPH) as oil and grease. Subsequent to the Kern County Resources Management Agency, Department of Environmental Health Services approval, soils will be excavated until the soils remaining in-place are believed to have concentrations of TRPH as oil and grease less than 1,000 rog/kg. However, the additional excavation required to remove all impacted soil with concentrations of TRPH as oil and grease in excess of 100 mg/kg is relatively insignificant. It is ESE's opinion that the proposed excavation dimensions will remove all impacted soil with concentrations in excess of 100 mg/kg. Prior to excavation, Underground Service Alert (USA) will be notified 48 hours in advance. In addition, the excavation contractor will obtain any necessary excavation permits from California Occupational Safety and Health Administration (Cai OSHA). The excavation will be performed so that sidewall slopes conform to California and Federal OSHA code requirements. ~! . EB -8228 -3 9208-E028 .WP Don Keith Transportation 15 August 14, 1992 Mitigation of dust is an important concern during the excavation and positioning 'of soil during this project. Water trucks will be on-site to wet traffic paths to control all dust emissions.. Excavation Air Emissions Volatile aromatic hydrocarbons may be emitted during the excavation and placement of the semi-volatile petroleum impacted soil at the site. However, a review of the available analytical data indicates that the profile of petroleum hydrocarbons impacting the soil qualifies for an exemption to air emissions permitting as described in the San Joaquin Valley Unified Air Pollution Control District Kern County Zone Rule 463.5. The fuel constituent volatile aromatic benzene has been detected in only one of the soils samples during the investigation. Benzene was detected in that sample at a trace concentration of 0.013 mg/kg. Assuming that the entire mass of benzene within the impacted will volatilize in the first day of aeration, then less than 0.05 pounds of benzene will be emitted in that day. This is an overly conservative approach, since excavation will likely require several working days. Because the emission of benzene for that day will be less than 0.05 pounds per day, the site qualifies for an exemption as described in Rule 463.5. The methodology of the California Air Pollution Control Officers Association (CAPCOA) "Screening Level Risk Assessment" indicates that the maximum potential emission of benzene over the duration of the project does not present a public health risk. 'The soil was impacted with heavier molecular weight petroleum hydrocarbons including crude oil, asphalt fuel oil and diesel, all of which have a boiling point greater than 400°F. Since the boiling point is greater than 302°F, the project qualifies for an exemption under Rule 463.5 Therefore the entire 1,000 cubic yards of impacted soil may be excavated and placed onto the uncovered treatment pad during one continuous time period. EB-8228-3 9208-E028.WP Don Keith Transportation 16 August 14, 1992 Excavation Pit Field Sereening During excavation soil samples will be collected from the base and sidewalls of the three proposed excavation pits, and will be screened for total organic vapors with a portable photoionization detector (PID). Headspace vapor analysis will be performed by filling a mason jar to 50% capacity to produce a head space allowing volatilization for a period of 15 minutes, and protruding the probe of the PID through the cap and into the headspace for analysis. The PID readings will be recorded on the dail__y log...L.C) When field screening indicates concentrations less than 100 ppm___,fi~i-he excavation will...-) be discontinued. Otherwise excavation will continue until field screening indicates concentrations less than 100 ppm. ~_LA~' '~,.x~ '"'~0(~i~}/~' Soil Sample Collection Following excavation twelve verification soil samples will be collected from the base and sidewalls of the excavation pit at the location of the former truck was clarifiers. At this time ESE estimates that given the final excavation dimensions required to excavate the approximate 75 foot by 40 foot by 20 foot plume ot impacted soil will require at least two samples from each of the four sidewalls, and four samples from the excavation base so that each sample represents less than 200 square feet of surface area. ESE also estimates the five soil samples will be required at the location of both of the former tank bottoms disposal pits with a sample from the center of the base of the excavation at each pit , and a sample from each of the four sidewalls at both pits. The soil samples will be collected in brass sleeves filled in such a way that no headspace remains, immediately sealed with Teflon® film, capped, security taped, labeled, and placed on ice for transport to. a California Department of Health Services (DOHS) certified laboratory at less than 4°C. Strict chain of custody procedures will be utilized for all samples collected to ensure sample integrity and to document sample possession t¥om the time of collection to the final destination. All sampling equipment will be Washed with TSP (tri-sodium phosphate) cleanser, and rinsed with tap water and de-ionized water prior to sampling, between sample intervals to minimize the possibility of cross-contamination. EB -8228 -3 9208-E028 .WP Don Keith Transportation 17 August 14, 1992 Laboratory Analysis: Excavation Verification Soil Samples The twenty-two soil samples will be analyzed for Total Recoverable Petroleum Hydrocarbons as oil and grease by USEPA ~Test Method 418.1. /~\~ //'" ,t\ Backfill and Compaction The excavation pits resulting from soil removal will be backfilled with the "clean", over excavated soil, and enough import soil to replace the removed impacted soil. The soil will be compacted to 90% relative compaction in 12 inch lifts under the direction of an on-site soils engineer. Compaction tests will be performed on each lift from the base of the excavations to the surface. Backfilling will be accomplished using an 815 mechanical compacter, a 966 loader, and a water truck. A report will be prepared by the Earth Systems Consultants which certifies that the excavation was backfilled in such a way that the compaction exceeds 90%, and provide the compaction test reports as documentation. Soil Loading and Transportation KES will provide a front end loader to load the estimated 300 cubic yards of tank bottoms sludge at the site into approximately sixteen 20 yard. end dump trucks operated by KES's affiliated company, KVS Transportation, Inc. Non-hazardous Wastes Manifests will be prepared by/' KES and signed by Don Keith Transportation's authorized representative at the site.X/ Each of the 20 yard end dump trucks will be lined with visqueen plastic sheeting and covered with a tarpaulin prior to leaving the site location. Upon leaving the site, the trucks will enter the right hand lane of south bound Pierce, and proceed i/8 mile south to the intersection of Pierce Road and Rosedale Highway. The trucks will then proceed west on Rosedale Highway to Highway 33 were they will proceed south to the entrance of the Mckittrick Waste...~.. Disposal Site. ESE will provide supervision of the loading and transportation process. The ESE supervisor Will assure that all of the stockpiled tank bottoms sludge is removed from the site. The stockpiled soil will be removed in such a way that a one inch layer of "clean" soil from beneath the removed visqueen plastic sheeting will also scraped up and included with the sludge for disposal. The native soil base will then observed for EB-8228-3 9208-EO28~WP Don Keith Transportation 18 August 14, 1992 any evidence of discoloration, or odor. If nOne is observed, then it will be determined that all of the soil which had been stockpiled has been removedqgz> Remediation of Petroleum Impacted Soil -'"-~'"~' The 1,000 cubic yards of soil excavated from beneath the former truck wash clarifiers will be spread out over the rear portion of the property in a six inch lift. A berm will be constructed surrounding the treatment area to a minimum height of 2 feet and width of 3 feet at the toe of slope. Once soils have been placed within the treatment area mechanical cultivation will be initialed to increase the oxygenation of the hydrocarbons, and enhance the indigenous microbes. , The final by-products of biologic degradation of the petroleum hydrocarbons will consist primarily of carbon dioxide (CO2) and water. We estimate the placement of the soil within the treatment area can be performed within the time frame of approximately three days with obtainment of the proscribed RWQCB clean up levels within a two month period.~ The bioremedial system will utilize active mechanical cultivation by a tractor and plow or dozer and ripper combination. Tilling of the stockpiled material would be conducted on a weekly basis. Treatment Cell: Interim and Verification Soil Sampling The ~progress of the treatment will be monitored periodically by an assistant geologist or engineer using a OVM photo-ionization detector (PID) or a Foxboro® OVA (organic vapor analyzer) 108 flame-ionization meter. Approximately two interim soil sampling events will be conducted and soil samples analyzed to evaluate the progress of the treatment process. Verification soil sampling will be accomplished with a 2.5-inch diameter hand held ring sampler equipped with stainless steel liners for soil retention. Soil samples will be collected upon setup of the system to obtain initial concentrations and at periodic intervals, as well as for final verification of treatment. When contaminant levels are thought to be acceptably low (to specified clean-up level or less), the soil stockpile will be sampled in the presence of a representative of the Kern County Department of Environmental Health Services. Soil samples will be sealed with Teflon® film, EB-8228-3 9208-E028.WP Don Keith Transportation 19 August 14, 1992 capped, and placed on ice for transport to a California Department of Health Services (DOHS) certified laboratory. Strict chain of custody procedures will be utilized for all samples collected to ensure sample 'integrity and to document sample possession from the time of collection to the final destination. All sampling equipment will be 'washed with TSP (tri-sodium phosphate) cleanser, and rinsed with tap water and de-ionized water prior to sampling, between sample intervals to minimize the possibility of cross-contamination. Laboratory Analysis of Soil Samples We anticipate a total of 4 t0 5 soil samples will be collected during each sampling interval. We anticipate the final verification sampling may require at least 10 soil samples. Soil samples will be sent to a state-certified laboratory for chemical analysis. Soil samples will be analyzed for Total Recoverable Petroleum Hydrocarbons as oil and grease by USEPA Test Method 418.1. Treated Soil Disposition The clean treated soil will be used as grading fill on the subject property. The treated soil will be spread at a thickness of no greater than two inches over the property. Report Preparation The project manager will prepare a final report documenting the results of the soil treatment which will be sent to the client. The final report will be signed by a Registered Geologist and will contain a summary of the installation and treatment activities, required permits, a site map showing soil sample locations, description of methodologies used, certified laboratory reports and chain of custody documents. A request will be made for closure of the case at this time. Schedule and Conditions ~' It is expected that the excavation and backfilling of the excavation pits, transportation and disposal of the tank bottoms sludge, and placement of impacted soil in the treatment area will be completed within two weeks of approval from the Kern County Department of Environmental Health Services to proceed. EB-8228-3 9208-E028.WP Don. Keith Transportation 20 August 14, 1992 We anticipate that the soil will be monitored once every two weeks with' a OVA, with the first interim sampling to be conducted approximately 3 weeks from the initial construction. Verification sampling will be conducted in the presence of the Kern County Department of Environmental Health Services representative ~ly 45 days after initiating soil treatment. A final report will be submitted to the client and the Kern County Department of Environmental Health Services upon verification that clean up levels have been obtained. With approval of the Kern County Department of Environmental Health Services the remediated soils will be used as grading fill on- site. Thank you for yoUr consideration of this work plan. If you have any questions, or if we can be of service in any way, please contact this office at your convenience. EARTH SYSTEMS ENVIRONMENTAL, INC.~~'~~ Mark R. Ma Senior Geologist cc: I - Addressee ,< ~,'. ~z~,~'..~:;.~ I - Don Keith Transportation - Ken Keith 1 - I-lEI - James Hubbard I - KES - Chris DeArmon 1 - SLO 1 - BAK EB-8228-3 9208-E028.WP > .o.. ,,-q.~l, E ~ ~ ' i~ )BERTS~ J,. "~ ':11 ""~'"~o, 'o&a ;~hf~--J: rd ~ I Ave. THE RIVER ::'~ '~_ O:l~ 4--~-.~- = ': ~,[~ Bemd$1ey Ave ...~.~ ~, [ · _ ;.~ ~ rx~ ~ ; )od ~ !:~' ~ . :'1 ~ . ' A~mour Ave. ~ Itl ~ ,.~ / Ii -1 I~ ~. Ell~l ;;,~ ~ / /~ ~ E Jll I I I ~ /~/Ill:lA : ~ /~ ,- ..'*~ ~ - ~ . ,~ X ,~' -' ~ ,~ Il ~t '- ~ ~ D,~,, I,~,L I l ~,-~f~. ,' I e ~ u ] ~:~ sc ~. ~ · ([ ~. HIGH ., 71:1 L EaCh SYstems _ T I~LE Figure Environmental, Inc. ~~~~~/~~ A Mem~r of T~ EaCh Systems Grip ~ - -- ,701.McDivi. Drive SuiteB ~~~~O~T~r/O~ (805) 836-0901 ~~/~Z~I ~Z/~- JOB NO. ~ (805~ 836-o911 ~ ~ ~ ~ ~~ Earth SYstems TITL£ Figure Environmental, Inc. -. .~*' 6701 Mc~ ~o. SuMo B ~kersfle~, ~ 9~13 (8~) ~6-~ ~~~/~ ~ JOB NO. APPENDIX A SITE HEALTH AND SAFETY PLAN SITE HEALTH AND SAFETY PLAN SITE DESCRIPTION The site is located at 2990 Pierce Road in the city of Bakersfield in Kern County, California (Figure 1). The site is currently used as a parking area where the tanker trucks are parked. The site is situated within a developed industrial area. Nearby surrounding properties are primarily retail businesses, petroleum service companies, refineries, and actual oil producing properties. The overall site topography is essentially flat, with a very slight fall to the west. BACKGROUND Two areas have been identified on the subject property where soil has been impacted by petroleum hydrocarbons in excess of RWQCB guidelines. Remedial actions are planed including the excavation and on-site surface bioremediation of approximately 1,000 cubic yards of soil from beneath two former earthen clarifiers associated with a truck wash rack, and the excavation and disposal of approximately 300 cubic yards of tank bottoms sludge from two former disposal pits. PURPOSE The purpose of this plan, which was developed specifically for operations at the referenced site, is to assign responsibilities, establish personnel protection standards and mandatory safety procedures, and provide for contingencies that may arise while removal, and bioremediation of the diesel impacted soil are being conducted at the site. This plan complies with, but does not replace, Federal Health and Safety Regulations as set forth in 29 CFR. 1910 and 1926, California Health and Safety Regulations set forth in Title 8, California Code of Regulations, and guidance established by the California Department of Health Services. This plan is to be used by ESE as a supplement to such rules, regulations, and guidance. Don Keith Transportation 2 August 14, 1992 APPLICABILITY The provisions of the plan are mandatory for all on-site ESE employees engaged in activities known to be or potentially associated with the presence of hazardous materials. These activities may include, but are not limited to, mobilization, project operations, and demobilization. Changes and/or unanticipated site conditions may require modification of this Site Health and Safety Plan (SHSP) in order to maintain a safe work environment. Any proposed changes to this plan should be reviewed by the Corporate Health and Safety Officer of ESE, prior to their implementation. If this is not feasible, the project team leader may modify the plan and record all changes in the field log book. Under no circumstances will the Plan modifications conflict with Federal, state, or local health and safety regulations. Under 29 CFR 1910.120 (b) (15) ESE is required to notify each subcontractor of the hazardous materials identified by ESE. The acceptance of such responsibility does not and shall not be deemed an acceptance of responsibility for any other health and safety requirements, such as those related to excavating, trenching, drilling or backfilling. Each subcontractor shall perform all work in accordance with a Site Health and Safety Plan for its employees, which covers any exposure to hazardous materials which may be present on site. The subcontractor shall hold ESE harmless from, and indemnify it against, all liability in the case of any injury or injury of its own employees. ESE reserves the right to review the subcontractor's Site Health and Safety Plan at any time. ESE reserves the right t° suspend the subcontractor's site work and ask the subcontractor's personnel to evacuate the hazard area in the event of grossly inadequate health and safety precautions on the part of the subcontractor or the belief that the subcontractor's personnel are or may be exposed to an immediate health hazard. -'- EB-80228-3 9208-E0328.WP Don Keith Transportation 3 August 14, I992 KEY PERSONNEL AND RESPONSIBILITIES The key personnel and their responsibilities for this project are as follows: -- Corporate Health and Safety Officer The ESE Corporate Health and Safety Officer (CHSO) for this project is Mr. Robert Mohle. It is his responsibility for developing and coordinating the ESE health and safety programs. For this project, he is responsible for reviewing and approving this SHSP for accuracy and incorporating new information or guidelines which aid the Project Manager and Site Health and Safety Officer in further definition and control of potential health and safety hazards associated with the project. Project Manager The ESE Project Manager (PM) for this project is Mr. Mark Magargee. It is his responsibility to report to upper-level management. The duties of the PM are as follows: .- PrePare and organize the SHSP which describes all planned field activities that may be encountered at the site. · Obtains permission for site access and coordinate field activities. · Brief field team on specific assignments and potential hazards, and ensures that all health and safety requirements are met. · Provides a copy~ of this SHSP to each member of the project field team. Site Health and Safety Officer The ESE Site Health and Safety Officer (SHSO) for this remediation is Mr. Kenneth Mitchell. He advises the PM on all aspects of health and safety on-site and recommends stopping work if any operation threatens worker or public safety. Other duties include: · Implement the SHSP. · Select personal protective clothing and equipment specific for the project and ensures that. they are properly stored and maintained. · Assure that all personnel assigned to site have appropriate health and safety training and have a current baseline medical examination. EB-802'28-3 9208-E0328.WP Don Keith Transportation 4 August 14, 1992 · Assign key safety duties and responsibilities to team members. · Monitor the work parties for signs of stress, and also monitors on-site hazards and conditions. · Know emergency procedures, evacuation routes, arranges on-site first aid facilities and off-site emergency care. · Conduct daily safety meetings and periodic inspections to determine if SHSP is being followed. · Establish and maintain site record keeping, including reporting accidents, as required. · Participate in preparation of SHSP and revise it as necessary. · Verify that drilling or excavation locations have been cleared for underground utilities and other subsurface structures before subsurface exploration is initiated. Team Members The responsibilities for the team members are as follows: · Take all reasonable precautions to prevent injury to themselves and to their fellow employees; and · Performing only those tasks that they believe they can do safely, and immediately reporting any accidents and/or unsafe conditions to the client and the CHSO. · Implementing the procedures set forth in the SHSP, and reporting any deviations from the procedures described in the Plan to the SHSO and to the CHS©. SITE INFORMATION All field activities will take place on the Don Kieth Transportation Company, 2990 Pierce Road property. All excavation activities will take place in the daylight hours between 7:00 A.M. and 7:00 P.M. The presence and location of potentially hazardous materials, which are hydrocarbon 'compounds, has been confirmed through previous investigation. If needed, three blasts of a horn will be sounded for site evacuation: This site information is current and has been verified through analytical testing. EB-80228-3 9208-E0328.WP Don Keith Transportation 5 August 14, 1992 HAZARD ASSESSMENT Hazardous Materials Hazardous materials may be a-health hazard to site personnel via ingestion, Skin absorption, or inhalation. Biohazards or accidental ingestion of contaminants may occur via hand-to-mouth actions. Dust inhalation may also contribute to ingestion of chemical contaminants. During excavation, soil sample collection, and sample preparation, inhalation of contaminant vapors could occur. Skin absorption may occur via contact with contaminated soil and/or ground water. The degree of hazard depends upon the adverse characteristics and toxicity of the chemical contamination, the amount of potential contact, and the exposure time. The greatest potential for chemical hazard to' site personnel is during excavation activities. The following substance is potentially a chemical hazard at the subject site: Substances Involved Physical State Characteristics Petroleum Compounds Liquid/Absorbed Irritant The following materials potentially present at this project site are specified by California Health and Safety Code 25249.5 as recognized and confirmed by the State of California as carcinogenic and/or mutagenic: 1. Petroleum Compounds containing benzene. Potential Worker Hazards With hydrocarbon-based liquids, contact may result in dermal irritation due to desiccation. Respiration of air laden with hydrocarbon vapors may result in oxygen deficiency and/or mucous membrane irritation. Mixtures of air and hydrocarbon fuels exhibit an explosive range thus presenting an explosion hazard. Petroleum compounds may contain minor amounts of benzene, a proven human carcinogen. P°tential exposure values and limits for benzene are listed in the table below. EB-80228-3 9208-E0328.WP Don Keith Transportation 6 August 14, 1992 TABLE I - POTENTIAL EXPOSURE VALUES Chemical Highest Conc. Ip1 TLV2 IDLH3 Flammable --' Detected in (electron (ppm) Level Range Samples (p.pm) volts) (p.ereent) Benzene 0.013 0.9245 10 Carcinogen 1.3 - 7.1 lionization Potential in electron volts (eV) 2Threshold Limit Value as the time-weighted average (TWA) published by the American Conference of Governmental Industrial Hygienists (ACGIH) 3Immediately dangerous to life and health (IDLH) level as published by National Institute of Occupational Safety and Health (NIOSH), Publication Number 85-114, September 1985. NA: not available Benzene is a colorless liquid with an aromatic odor. It is incompatible with strong oxidizers like chlorine or bromine with iron. The routes of exposure for benzene include inhalation, skin absorption, ingestion, and skin and/or eye contact. Symptoms of exposure to benzene include irritation to the eyes, nose, and respiratory system, giddiness, headache, nausea, staggering gait, fatigue, anorexia, lassitude, dermatitis, and abdominal pain. The potential health hazard from benzene exposure is very slight at this site. Conditions for Suspension of Operations Site monitoring equipment will include a Photo-ionization detector (PID) or a Flame- ionization' detector (FID) during drilling and trenching. Field activities at Level D will be suspended when the continuous FID or PID level in the breathing zone increases to ten times background levels (assuming an ambient range of five to ten ppm). Level of Protection The level of Personal Protection Equipment (PPE) needed for this investigation is Level D. Level D PPE includes coveralls, leather boots with steel toes and shanks, eye protection, safety helmet and gloves. If warranted, this Site Safety Plan can be -80228 -3 9208-E0328 .WP Don Keith Transportation 7 August 14, 1992 modified for use of Level C situations. Modification' to Level B or Level A is beyond the scope for this Site Safety Plan and is not permitted. .... The criteria for upgrading to Level C PPE is the detection of unknown gasses or vapors in concentrations greater than 10 times background levels or unknown liquids present within the work area. Level C PPE includes Tyvek suits, nitrile gloves and rubber boots, eye protection, hard hat, and a full-face air-purifying respirator with Scott. 642-OA-H cartridge-filters or equivalent. Physical Hazards Excavation equipment will be working near petroleum pipelines. All workers will be positioned upwind from operating equipment at all times. Excavation Sloping Contaminated soils in the areas identified by ESE will be removed by excavating with a backhoe. Excavating will. proceed to the maximum depth of 20 feet below grade, if necessary. It is recommended that all open excavations be fenced. The sidewalls for all excavations will be designed to protect employees working in excavations from cave-ins and be in accordance with Federal OSHA requirements in 29-CFR Part 1926, Appendix B to Subpart P. The maximum allowable slope for each excavation will depend on the soil type and shall be determined from Table B-1 in 29 CFR Part 1926. The actual slope of the excavations will be less than the maximum slope, when there are signs of distress. If this situation occurs, the slope will be cut back to an actual slope which is at least one-half horizontal to one vertical (I/2 H: 1 V) less steep than the maximum allowable slope. Slips, Trips and Falls All field personnel shall become familiar with the general terrain and potential physical hazards (ravines, potholes, and loose gravel) which would be associated with accidental risk to slips, trips and/or falls. EB-80228-3 9208-E0328.WP Don Keith Transportation 8 August 14, 1992 Splashes and Spills All field personnel shall wear appropriate chemical resistant gloves and goggles to prevent potential dermal exposure to accident splashes and spills that may occur -- during excavation of contaminated soil and soil sampling. Sunburn Working outdoors on sunny days for extended periods of time can cause sunburn to the skin. Excessive exposure to .sunlight is associated with the development of skin cancer. Field staff should take precautions to prevent sunburn by using sun-screen lotion and/or wearing hats and long-sleeved garments. Heat Stress Heat stress can be a major hazard, especially for workers donning personnel protective equipment (PPE). The same protective materials that shield the body from chemical exposure also limit the dissipation of body heat and moisture. Heat stress can occur very quickly, depending on the work being performed, the ambient weather conditions, clothing, and the individual characteristics of the worker. Because heat stress is probably one of the most common (and potentially serious) illness at hazardous waste sites,, regular monitoring and other preventive precautions are vital. Heat stress monitoring should commence when personnel are wearing PPE, including Tyvek-type coveralls, and the ambient temperature exceeds 70°F. If impermeable garments are not worn, monitoring should start when the temperature reaches 85°F. The following monitoring program is for workers wearing semipermeable or impermeable encapsulating ensembles when the temperature in the work area is above 70°F: Heart Rate should be measured by the radial pulse during a 30 second period as early as possible in the rest period. The next work cycle should be shortened by one-third while the rest period is kept the same, if the heart rate exceeds 110 beats per minute. If the heart rate still exceeds 110 beats per minute at the beginning of the next rest period, shorten the following work cycle by one- third. -'- EB-80228-3 9208-E0328.WP Don Keith Transportation 9 August 14, 1992 Preventing heat stress is particularly important because once someone suffers from heat stroke or heat exhaustion, that person may be predisposed to additional heat injuries. To avoid heat stress, the following steps may be taken: · Modify work/rest schedules according to monitoring requirements, and mandate slowdowns as needed. · Alternate personnel assigned to particular tasks to minimize over stress at one job function. · Add additional persons to work team, and work during cooler hours, if possible. · Provide shelter or shaded areas to protect personnel during rest periods. · Maintain workers body fluids to ensure that' the cardiovascular system functions adequately by having workers drink 16 ounces of fluid (preferably water) before beginning work, and urge workers to drink at least 16 ounces of fluid during each rest period. · Encourage workers to maintain an optimal level of physical fitness. An initial work/rest cycle on one hour work and fifteen minutes rest is recommended for protection of staff when the heat stress hazard is high. The recommended cycle will be adjusted up or down based upon worker monitoring, environmental conditions, and the judgement of the site safety officer. At any time field team members recognize the signs or symptoms of heat stress prior to a scheduled rest period, they will notify the site safety officer immediately in order that a rest period can be called. Some of the signs and symptoms of heat stress are heat rash, heat cramps, heat exhaustion, and heat stroke. Heat rash is characterized by a decreasing ability to tolerate heat and skin irritation and may result from exposure to heat or humid air. Skin cleanliness and treatment with mild drying lotions are necessary to prevent infection. Heat cramps are caused by heavy sweating with inadequate electrolyte replacement and are characterized by muscle spasms and pain in the hands, feet, and abdomen. Treatment of this disability, consists of administering salted liquids orally. .... EB -80228 -3 9208 -E0328 .WP Don Keith Transportation 10 August 14, 1992 Heat exhaustion may result form physical exertion in a hot environment when cardiac output is inadequate to meet increased flow of blood that results from dilation of peripheral blood vessels or dehydration. It is distinguished by pale, cool, moist skin, heavy sweating, dizziness, nausea, and fainting. First aid for heat exhaustion is as follows: I. Immediately remove victim to support area, or if you are the victim, proceed to the support area. 2. Decontaminate, if practical, before entering support area. .. 3. Start cooling, but be careful not to cause a chill. 4. If conscious and not in shock, give water to drink slowly. 5. If vomiting, and/or signs and symptoms are not lessening within an hour, call for emergency help and/or transport victim to emergency room. 6. If person is a victim of heat exhaustion, they should not work the remainder of the day. The most serious form of heat stress is heat stroke. This is caused when the temperature regulation fails and the body temperature rises to critical levels. Immediate action must be taken to cool the body before serious injury and death occur. Red, hot, usually dry skin, lack of reduced perspiration, nausea, dizziness and confusion, strong, rapid pulse, and coma are the signs and symptoms of heat stroke. First aid for heat stroke is as follows: 1. Immediately move victim to cool, uncontaminated area, the support area, and remove and dispose of victim's chemical-resistant clothing, if wearing any. 2. Cool the victim rapidly using whatever means necessary. This can include, but may not be limited to, removing clothing, fanning, and placing in water. 3. Do not give drinking water to victim. 4. Treat for shock, if needed. 5. Transport the victim to a medical facility immediately for further cooling and monitoring of body functions. EB-80228-3 9208-E0328.WP Don Keith Transportation I 1 August 14, 1992 Cold Stress Cold stress is a particular concern when field activities are performed while the air temperatures at the site are below 40°F. If winds are blowing at 5 mph or grater and/or the weather is damp or wet, cold stress is even more of a potential hazard. Donning of appropriate clothing, having warm shelter readily available, carefully scheduling work and rest periods, and monitoring workers' physical conditions are precautions that will be taken to prevent cold stress. Cold injury (frostbite and hypothermia) may occur if cold stress is not prevented. As a preventive measure, the body core temperature must not drop below 96.8°F. Pain in the extremities is the first early sign of cold stress. Severe shivering sets in when the body core temperature drops below 95°F. If this occurs, work will stop immediately and the affected worker(s) will take a warming break of sufficient duration that the signs and symptoms of cold stress go away. Noise Heavy equipment, such as excavators, may produce loud noise. The effects of noise can include, but may not be limited to: · Distracted, annoyed, or startled workers. · Physical damage to the ear, pain, and temporary and./or permanent hearing loss. · Communication interference that may increase potential hazards due to the inability to warn of dangers and the proper safety precautions to be taken. OSHA regulation 29 CFR Part 1910.95 describes an effective hearing conservation program that must be administered whenever noise exposures equal or exceed an 8- hour, time-weighted average sound level of 85 dBA (decibels on the A-weighted scale). In addition, if workers are subjected to noise exceeding an 8-hour, time- weighted average sound level of 90 dBA, feasible administrative or engineering controls must be utilized. EB-80228 -3 9208-E0328.WP Don Keith Transportation 12 August 14, 1992 Heavy Equipment and Excavating Before beginning any site work, the excavator subcontractor will perform a safety inspection of the excavation equipment. Personnel shall not work with equipment that they judge to be unsafe because of deterioration, missing parts, obvious defects, or improper use for site conditions. All equipment shall be bonded and grounded, sparkproof, and explosion-resistant, as appropriate. Operation of excavators or other heavy equipment in areas with steep embankments or unstable ground will be avoided, if possible. The subcontractor will make appropriate provisions to ensure safe operation of equipment, if it is necessary to operate equipment in these areas. ANSI-approved hardhats must be worn at and near the excavator or any other heavy equipment. Since heavy pieces of equipment will be used during excavation, steel- toed boots/shoes are required during drilling operations, as well as during operation of other heavy equipment. The excavator must maintain a safe clearance (at least 10 feet) between overhead utility lines and the excavation machinery at all times. Underground Utilities The general engineering contractor will locate all underground utility locations prior to the starting of excavation activities. Resources used include site plans, utility companies, and Underground Services Alert (USA). In California, USA must be contacted at least two, but not more than fourteen, days prior to excavating on public property. MEDICAL MONITORING All Earth Systems Environmental, Inc. (ESE) employees assigned to the sampling operations must be active participants in ESE Employee Medical Surveillance Program, which meets the requirements of 29 CFR 1910.120. ESE's program requires employees assigned to hazardous waste site investigations and remediation to take pre-assignment, annual, and exit medical examinations. The CHSO. will maintain EB-80228-3 9208-E0328.WP Don Keith Transportation 13 August 14, 1992 current copies of training certificates and statements of medical program participation for all site personnel. Work-Rest Schedule Depending on the prevailing temperature and humidity, a work-rest schedule may be necessary. Duration and frequency will be at the discretion of the excavator and/or site supervisor. A supply of potable water will be kept available near the site. Safety Training Field personnel must receive 40-hour basic health and safety training, designed to comply with the OSHA/EPA requirements for hazardous waste operations and eight hours of annual refresher as set forth in 29 CFR 1910.120, and attend a site-specific safety orientation conducted by the project supervisor. The briefing shall include the following: 1) A briefing on the work to be performed and the work schedule 2) A discussion of the potential Chemical and physical hazards associated with the work to be performed 3 ) Hazard identification 4) Purpose and limitations of personal protective equipment 5) Decontamination and emergency response procedures 6) Proper on-site conduct. EMERGENCY CONTACT AND PROCEDURES Contacts Should any situation or unplanned occurrence require outside or support services, the appropriate contact from the following should be made: Agency Person to Contact Telephone Ambulance dispatcher 911 County Fire Department dispatcher 911 Police dispatcher 911 Mercy Hospital dispatcher (805) 326-2620 Dept. of Environ. Health Flora Darling (805) 861-3636 ' ' EB-80228-3 9208-E0328.WP Don Keith Transportation 14 August 14, 1992 To reach Mercy Hospital, take Pierce Road south to the Rosedale Highway-Highway 58/178 and turn left; take Rosedale Highway-Highway 581178 east 1/4 mile to Oak Street, and turn right. Proceed one mile south on Oak Street to Truxtun Avenue, and turn left. Proceed east on Truxtun Avenue following the signs to the emergency entrance of the hospital at 2215 Truxtun Avenue which will be on the right (south side of Truxtun Avenue in Bakersfield). Paramedics should be summoned in the event of a serious injury; they will arrange to transport the victim to the nearest appropriate facility. A first aid kit will be available at the site for use in case of minor injuries. If anyone receives a splash or particle in the eye, the portable eyewash will be used to irrigate the eye for 15 minutes. If direct contact with contaminants occurs, affected skin areas should be washed immediately with soap and water. At least one person at the site will have current certification in First Aid and CPR. SITE LAYOUT The level of hazard associated with the work to be performed does not require dividing the site into formal exclusion, contamination reduction, and support zones. However, care will be taken to avoid breathing vaporized petroleum hydrocarbons. CONTAMINATION MONITORING Organic vapor monitoring of the ambient air shall be conducted at reasonable intervals as determined by project personnel. The purpose of monitoring is to determine if vapor levels in the work area are high enough to warrant personal protection measures or evacuation of the site. Organic vapor levels should be monitored using an OVM photoionization meter with an 11.7 eV lamp (probe), calibrated to benzene or a Foxboro® OVA (organic vapor analyzer) 108 flame-ionization detector calibrated for non-methane hydrocarbons. Background should be determined by taking readings before sampling begins. All readings, background and others, must be recorded. If any continuous measurement . EB-80228-3 9208-E0328.WP Don Keith Transportation 15 August 14, 1992 is observed to be I0 times over background levels in the work area, respiratory protective action will be required. Lesser protective measures are at the field geologists or engineers discretion. DECONTAMINATION Before leaving the site/work area, personnel must remove all protective equipment and wash their hands, faces and necks. These washing procedures shall be observed before all work breaks. To minimize the potential for cross-contamination, all excavation equipment shall be decontaminated before the start of drilling, between borings, and before removal from the site. Sampling equipment shall be decontaminated before sampling, and between sampling with washing with laboratory-grade detergent, a water rinse and a contaminant-free distilled water rinse. EMERGENCY PROCEDURES Emergency conditions are considered to exist if: * Any member of the field crew is involved in an accident, experiences any adverse effects or symptoms of exposure while on-site; or * A condition is discovered that suggests the existence of a situation more hazardous than anticipated. In the event of an on-site emergency, the procedures described below are to be immediately followed. 1. Personnel on-site should use the "buddy system" (stay in pairs). In the event of a communication breakdown, i.e. radio malfunction or if radios are not available, "buddies" should use prearranged hand signals or other means of emergency signals as follows: * Hand gripping throat - out of air, can't breath. * Grip partner's wrist or place both hands around waist leave area immediately, no debate! EB-80228-3 9208-E0328.WP - Don K¢ith Transportation 16 August 14, 1992 * Hands on top of head need assistance * Thumbs down - no, negative. 2. The' field engineer or geologist will establish emergency evacuation routes and will make all project personnel aware of these routes prior to the first on-site activities. In the event of an emergency, selection other escape route will be based on the nature of the emergency and wind direction. 3. Visual contact should be .maintained between "buddies" on-site, with the team remaining in close proximity in order to assist each other in case of emergencies. 4. In the event that any member of the field crew experiences any adverse effects of symptoms of exposure while on site, the entire field crew should immediately halt work and follow the instructions provided the project supervisor. 5. Wind indicators visible to all on-site personnel should be provided by the project supervisor-to indicate possible routes for upwind escape. 6. The discovery of any condition that would suggest the existence of a situation more hazardous than anticipated should result in the evacuation of the field team and re-evaluation of the hazard and the level of protection required. 7. In the evenf an should accident occur, it will be necessary to complete an Accident Report Form with the company Safety Officer. STANDARD SAFE-WORK PRACTICES General 1. Eating, drinking, chewing tobacco and smoking are prohibited in~ the contaminated or potentially contaminated area 'of where the possibility for the transfer of contamination exists. EB-80228-3 9208-E0328.WP Don Keith Transportation 17 August 14, 1992 2. Avoid contact with potentially contaminated substances. Do not walk through puddles, pools, mud, etc. Avoid, whenever possible, kneeling on the ground, leaning or sitting on equipment or ground. Do not place monitoring equipment on potentially contaminated surfaces (i.e., ground, etc.). --- 3. All field crew members should be alert to the presence of strong, irritating or nauseating odors that could indicate a potentially dangerous situation. Other senses should be kept alert to possible hazards as well. 4. Precaution should be taken to prevent spillage. In the event a spillage should occur, the liquid should be contained. 5. Prevent splashing of the contaminated liquids. 6. Field crew members shall be familiar with the physical characteristics of investigations, including the following: * Wind direction in relation to ground-zero area. * Accessibility to associates, equipment, and vehicles. * Communications.. * Hot Zone (areas of known or suspected contamination). * Site access. * Nearest water sources. 7. The number of personnel and equipment in the contaminated area should be minimized but only to the extent consistent with work-force requirements of safe site operations. 8. All wastes generated during Earth Systems Environmental, Inc. and/or subcontractor activities at the site remain the property of the client. .EB-80228-3 .9208-E0328.WP Don Keith Transportation 19 August 14, 1992 The undersigned have read and understood the attached safety plan and agree to comply with the provisions of this plan. Name Date Name Date Position Position Name Date Name Date Position Position Name Date Name Date Position Position Name Date Name Date Position Position Name Date Name Date Position Position EB-80228-3 9208-E0328.WP Don Keith Transportation 1 8 August 14, 1992 PLAN ACCEPTANCE FORM The Plan Acceptance Form (attached) should be filled out by all employees working on the site and retained in the job file. Corporate Health & Safety Officer Robert Mohle (805) 541-5983 Site Safety Officer Kenneth Mitchell (805) 836-0901 - office (805) 837-8984 - home Project-Site Safety Plan prepared by Mark Magargee in conjunction with the Corporate Health & Safety Officer. Signature: Date: -' EB -80228 -3 9208-E0328 .WP REMEDIAL ACTION WORK PLAN FOR PETROLEUM IMPACTED SOIL DON KEITH TRANSPORTATION 2990 PIERCE ROAD BAKERSFIELD, CALIFORNIA August 14, 1992 Prepared by Earth Systems Environmental, Inc. 6701 McDivitt Drive, Suite B Bakersfield, California 93313 (805) 836-0901 FAX (805) 836-0911 Project No.:. EB-8228-3 Earth Systems Environmental, Inc. -- A Member of The Earth Systems Group 6701 McDivitt Drive, Suite B · Bakersfield, CA 93313 * (805) 836-0901 * FAX (805) 836-0911 August 14, 1992 Doc. No.:9208-E028.WP Project No.: EB-8228-3 Kern County Resources Management Agency Department of Environmental Health Services 2700 M Street, Suite 300 Bakersfield California 93301 Attention: Ms. Flora Darling SUBJECT: REMEDIAL ACTION WORK PLAN FOR PETROLEUM IMPACTED SOIL - DON KEITH TRANSPORTATION 2990 PIERCE ROAD BAKERSFIELD, CALIFORNIA REFERENCE: PRELIMINARY SITE CHARACTERIZATION OF PETROLEUM IMPACTED SOILS, DON KEITH TRANSPORTATION, BAKERSFIELD, CALIFORNIA (ESE, AUGUST 12, 1992) INTRODUCTION Earth Systems Environmental (ESE) has been contracted by Kern Environmental Service representing Don Keith Transportation to prepare this work plan for soil remediation activities at Don Keith's Asphalt and Diesel Transportation Company located at 2990 Pierce Road, Bakersfield, California. ESE proposes excavation and bio- reclamation of approximately 1,000- cubic-yards of soils impacted with petroleum based compounds associated with two earthen clarifiers connected to a truck wash rack as well as excavating and disposing of approximately petr~leum.:;7~ti~i~e'il~:-'-z:':'~]~'~i~?~'~'~'(3~)h't~d with the former operation of two tanker truck bottoms disposal pits recently documented by ESE in the above referenced report. After review of the available data, ESE believes the 1,000 cubic yards of impacted soil from beneath the former clarifiers can be treated on-site utilizing biological degradation technologies. The advantages of bio-reclamation is the permanent destruction of the petroleum hydrocarbons, thus minimizing the potential long term liabilities associated with off-site disposal at a hazardous waste facility. The final by- products of biologic degradation of the petroleum hydrocarbons consist primarily of carbon dioxide (CO2) and water. Don Keith Transportation 2 August 14, 1992 We propose the construction of a bio-reclamation treatment system on-site as the most suitable method for mitigating the semi-volatile petroleum based compounds and reducing the'concentrations of petroleum hydrocarbons .within the soils at the above mentioned site to levels considered to be non-hazardous by Regional Water Quality Control Board Central Valley District, and Kern County Resources Management Agency, Department of Environmental Health Services' criteria. Following approval by Kern County Department of Environmental Health Services a biological treatment system will be implemented to treat impacted soils at the site. Upon successful completion of the biological treatment (reduction of total petroleum hydrocarbon concentration to below the acceptable limits), and with the permission of the local governing regulatory agency, we will request that the treated soil be ' ~ We anticipate the minimum time frame for spread on-site as as grading fill.' successful treatment utilizing biological degradation capabilities to be on the order of 2 months. Based on our past experience with similar sites, we believe that the construction of an above ground treatment cell would present the most cost effective and efficient method for remediating the impacted soil. The treatment system is based on enhancing indigenous soil microbes and/or the introduction of cultured specific strains of common microbes suited for the biological degradation of semi-volatile petroleum' based hydrocarbons. All methods employed are in compliance with regulations and guidelines set forth in California Code of Regulations (CCR) Title 22, Article 11, and Title 23, Chapter 3, California Site Mitigation Decision Tree Manual, the Code of Federal Regulations (CFR) Title 29, Part 1.910, Section 120, CFR Title 40, Parts 300-399, and the San Joaquin Valley Unified Air Pollution Control District, Kern County Zone Rules 463.5 as well as accepted professional environmental/geotechnical engineering procedures and applicable local regulations. ~' ' EB-8228-3 9208-E028.WP Don Keith Transportation 3 August 14, 1992 Subject to your acceptance of this work plan, our plan to excavated the soils beneath the former clarifiers and treat the soils with bio-reclamation technology as well as excavating and disposing of the tank bottoms includes: · Preparation of a site Health and Safety Plan in accordance with regulations set forth in Federal OSHA CFR 29 1910.120, as well as California OSHA regulations. · Excavation of approximately 1,000 cubic yards of impacted soil beneath the location of the former truck wash clarifiers. · Excavation of approximately 300 cubic yards of sludge materials within the former tanker truck bottoms disposal pits. · Confirmatory sampling and analysis of the three excavation pit bases and sidewalls. · Backfilling pit with "clean" import fill material, compacting, and returning to surface grade. · Loading and transporting the tank bottoms sludge to an appropriate petroleum waste disposal facility. · Placement of the clarifier impacted soil in a six inch lift over the rear portion of the property. · Mechanical cultivation increasing oxygenation and enhancing indigenous soil microbes to reduce the concentrations of the petroleum hydrocarbons to beneath RWQCB recommended guidelines. · Progress monitoring and sampling. · Verification' sampling and preparation of a final report documenting remediation activities. Subsequently we have developed the following scope of work: Site Description The site is located at 2990 Pierce Road in the city of Bakersfield in Kern County, California (Figure 1). The site is currently used as a parking area where the tanker trucks are parked. EB-8228-3 · 9208-E028.WP Don Keith Transportation 4 August 14, 1992 The site is ~ situated within a developed industrial area. Nearby surrounding properties are primarily retail businesses, petroleum service companies, refineries, and actual oil pr°ducing properties. The overall site topography is essentially flat, with a very slight fall to the west. Background. Based on conversations with Chris DeArmon, two locations on the subject property had a potential for subsurface soil impacted with petroleum hydrocarbons and required assessment as part of a baseline environmental assessment at Don Keith's Asphalt and Diesel Transportation Company. The first area is that of a very large, two stage, earthen bottom clarifier system which formerly served the truck wash for the crude oil, asphalt, fuel oil and diesel fuel trucking firm. The clarifiers have been backfilled and no surface evidence remains. The property owner has provided a description of the size of each clarifier, and flagged their boundaries. The second area consists of two disposal pits in the rear of the property which received tanker truck 'bottoms. The surface of these has been covered with soil, however stained soil is visible at the surface in the location of the two pits. ESE has conducted an initial site characterization consisting of eleven soil borings and laboratory analysis of 27 soil samples to evaluate the extent of petroleum hydrocarbons impacted soil in' the Vicinity of both the former truck wash earthen clarifiers and tank bottom disposal pits. Subsurface Investigation Drilling of four initial borings was conducted on July 13, 1992. Drilling of seven additional borings to more fully assess the vertical and lateral extent of the impacted soils was conducted on August 6, 1992. A total of eleven soil borings were drilled within this phase of soil characterization (Figure 2). One soil boring, TH-1 was drilled on July 13, 1992 through the center of the western of the two former truck wash clarifiers location to a depth of 31 feet below surface grade to assess the potential for petroleum hydrocarbons in the subsurface at that location. On August 6, 1992 this boring was twinned by boring TH-IA which was advanced to a depth of 46 feet to assess the vertical limit of the petroleum hydrocarbons encountered in boring TH-I. A soil boring, TH-2 was drilled on July 13, 1992 through the center of the EB-8228-3 9208-E028.WP Don Keith Transportation 5 August 14, 1992 eastern of the two former elarifiers to a depth of 36 feet below surface grade to assess the potential for petroleum ' hydrocarbons at that location. On August 6, 1992 this boring was twinned by boring TH-2A which was advanced to a depth of 48.5 feet to assess the vertical limit of the petroleum hydrocarbons encountered in boring TH-2. Soil borings TH-3A, TH-4 and TH-4A were advanced around the peripherY of the two earthen elarifiers to assess the lateral limits of the petroleum hydrocarbons encountered in borings TH-I and TH-2. Soil boring TH-3A was drilled drilled 35 feet southeast of TH-2 outside of the former eastern clarifier location to a dep~ to assess the the potential for lateral migration of petroleum hydrocarbons in that direction. Soil boring TH-4 was drilled drilled 20 feet north of TH-2 to a ~ feet to assess the' the potential for lateral migration of petroleum hydrocarbons in that direction. Soil boring TH-4A was drilled drilled 35 feet southwest of TH-1 to a depth of 35 feeL..ao.___a~sess~-~.~e~.~e~o.~ential for lateral migration of petroleum hydrocarbons in that direction. A soil boring, NP was drilled through the center of the northern tank bottom disposal pit location to a depth of_27 feet below surface. grade to assess vertical migration of petroleum hydrocarbons at tha~--~a~o~ Soil boring TH-3 was drilled drilled 25 feet northeast of NP to a depth of 31 feet to assess the the potential for lateral migration of petroleum hydrocarbons in that direction. A soil boring, SP was drilled through the center of the southern tank bottom disposal pit location to a depth of 36 feet below surface grade to assess vertical migration of petroleum hydrocarbons at that location. Soil boring SPL was drilled drilled 35 feet east of SP to a depth of 21 feet to assess the the potential for lateral migration of petroleum hydrocarbons in that direction. To better define the limits of the two tank bottoms disposal pits a backhoe operated by Kern Environmental Service was used to excavate five foot deep trenches in the rear portion of the property. Upon exposing the limits of the pits a composite soil sample was collected from the sludge within the two pits at a depth of three feet below surface grade. Laboratory Analysis Twenty-six soil samples and one sludge sample were submitted to B. C. Laboratories of Bakersfield, Califorinia for analysis. All twenty-seven samples were analyzed for Total Recoverable Petroleum Hydrocarbons (TRPH) as oil and grease using USEPA Test Method 418.1. Seven of the samples including the tank bottoms sludge were analyzed ' ' EB-8228-3 9208-E028.WP Don Keith Transportation 6 August 14, 1992 for California Title 22 metals. Six of the samples including four from the area of the earthen clarifiers, and two from the area of the tank bottoms disposal pits were analyzed for volatile and semi-volatile organics using USEPA Test Methods 8240 and 8270. Five samples including 'the sludge were analyzed for Total Extractable Petroleum Hydrocarbons as diesel (TEPHd) using the DOHS LUFT Manual Method. Four deeper soil samples beneath the earthen clarifiers were analyzed for total lead using the DOHS LUFT Manual Method. The tank bottom pit sludge was also analyzed for fuel constituent volatile aromatics using USEPA Test Method 8020, and for pH. Results of the Investigation Geologic Setting Regional Geology: The site is located in the southern part of the Great Valley ge0morphic province. The Great Valley is a north-south trending valley, approximately 400 miles long by 50 miles wide. Surface and groundwater in the San Joaquin Valley is derived predominantly from the Sierra Nevada mountain range to the east, and is transported by five major rivers, the southern most being the Kern River. The subject site is located approximately 1/2 mile northwest of the Kern River. The surface of the San Joaquin Valley is composed primarily of unconsolidated Pleistocene (1.6 million to 11,000 years ago) and Recent (11,000 years ago to the present) alluvial sediments. Beneath the alluvial sediments are older, predominantly lake bed deposits. These lie unconformably on Mio-Pliocene marine sediments which extend to crystalline basement at approximately 20,000 feet. Site Geology: Geologic deposits in the study area include Pleistocene alluvial sediments of the Kern River Formation, which form a homocline dipping gently to the west. The deposits are alluvium consisting of poorly indurated and dissected fan deposits (CDMG, 1964). The depth to the regional unconfined aquifer was estimated prior to drilling to be approximately ~50 feet below surface grade beneath the site (Kern County Water Agency, Improvement District No. 4, 1991 Report on Water Conditions, February EB -8228 -3 9208- E028.WP Don Keith Transportation 7 August 14, 1992 h~ h 1992). ~er was not encountered in boring~TH-2A w 'c penetrated to a ~m off--eel ~ The deepest staples in ~e borings were moist, but did not have an indication that ~e capillary ~inge to. groundwater was at that dept. Because of ~e six consecutive years of drought, and the discontinuance by the Kern Coun~ Water Agency of using several large water recharge percolation ponds I/2 mile to the north, a ~op in the elevation of groundwater by as much as 25 feet ~ have :~u~ed ~in the area. The nearest known occurrence of perched groundwater is 8 miles to ~e sou~east at a dep~ of'20 feet in ~e abandoned Kern River channel to the ancient Kern Lake Bed (Kern County Water Agency, 1991 Water Supply Report, May 1992). No perched ~oundwater is known to exist benea~ the subject site. Subsurface material encountered during drilling was alluvium to the total depth of each boring. The alluvium was characterized by unconsolidated, highly pe~eable, light, brown, silty sand (SM) to a depth of approximately 7 feet, overlying unconsolidated, highly permeable, tan, well graded fine- to coarse- grained sand (SW) to a depth of approximately 23 feet. This is underlain by a sequence of unconsolidated, highly permeable, light tan, fine- to coarse- grained gravelly sand (SW/GW) to a depth of 38. Benea~ this is a Sequence of ~consolidated, highly permeable, light tan, fine- to coarse- grained sand (SW) to a depth of 43, overlying unconsolidated, highly permeable, light tan, well graded fine- to coarse- grained mode~tely sil~ sand (SW/SM) to a dep~ of approximately 46 feet. This is ~derlain by a sequence of consolidated, moderate to low permeability, light tan, very clayeY silt (ML/CL) to a dep~ of 48.5 which was ~e ~eatest dep~ investigated. Laboratory Analytical Results Total Recoverable Petroleum Hydrocarbons (TRPH) as oil and grease were detected at a concentration of 7,900 mg/kg at l0 feet in boring TH-1 advanced through the center of the western clarifier location, but not at 20, 30, 40 and 45 feet in boring TH-lA advanced in the same location. TRPH was detected at a concentration of 10,000 mg/kg at 10 feet in boring TH-2 advanced through the center of the eastern clarifier location and 40 mg/kg at 20 feet in boring TH-2A, but not at 40 and 47 feet in boring TH-2A. TRPH was not detected at depths of 15 and 25 feet in boring TH-3A advanced 35 feet southeast of TH-2 on the outside of the former clarifier location, or at depths of EB -8228 -3 9208-E028 .WP ' Don Keith Transportation 8 August 14, 1992 10 and 20 feet in boring TH-4 advanced 20 feet north of TH-2, or at depths of 10 and 25 feet in boring TH-4A advanced 35 feet soUthwest of TH-I. However, TRPH was detected at 20 mg/kg at a depth of 35 feet in boring TH-4A. Total Extractable Petroleum Hydrocarbons as diesel (TEPHd) were analyzed for in the soil samples at 20 feet in borings-TH-IA and TH-2A at concentrations of 19 mg/kg, and 23 mg/kg, 'respectively. The fuel constituent volatile aromatics m- and p-xylenes were detected at a concentration of 0.006 mg/kg at 10 feet in boring TI,I-1. The fuel constituent volatile aromatics toluene was detected at a concentration of 0.022 rog/kg at 10 feet in boring TH-2. No other volatile organic hydrocarbons including those which constitute fuels · and industrial solvents were detected at or above the minimum detection limit in the four soil samples collected from the clarifier area. No semi-volatile organic hydrocarbons (base neutral and acid extractables) were detected at or above the minimum detection limit in the four soil samples collected from the clarifier area. Lead was detected at an elevated concentration in one of eight samples from the clarifier area. Total lead was detected at a 'concentration of 27 mg/kg at a depth of 10 feet in boring TH-2 advanced through the center of the eastern clarifier, but was not detected in boring TH-2A at 20 and 40 feet, at 10 and 20 feet in boring TH-4 position 20 feet north 'of TH-2, and at 10 feet in boring TH-1 or 20 feet in boring TH-IA both located in the center of the western clarifier. Total lead was detected at 2.7 mg/kg at 20 feet in boring TH-lA. The State of California Title 22 Total Threshold Limit Concentration (TTLC) for lead is 1,000 mg/kg. However, the Soluble Threshold Limit Concentration (STLC) for soluble lead is 5 mg/kg. Because of the 10:1 dilution that occurs during the wet extraction any total' concentration less than 50 mg/kg will necessarily be determined to have a soluble component less than the STLC of 5 mg/kg. Therefore, a soluble lead wet extract was not performed on the sample in this investigation with a concentration of total lead detected of 27 rog/kg. EB-8228-3 9208-E028.WP Don Keith Transportation 9 August 14, 1992 Arsenic, barium, chromium, cobalt, copper, nickel, vanadium, and zinc were detected in the four soil samples from the clarifier area at concentrations typical of the .background concentrations for these metals in the soil in the area of the subject '- property. The other Title 22 metals were not detected in the four soil samples from the clarifier area. Total Recoverable Petroleum Hydrocarbons (TRPH) as oil and grease was detected at a concentration of 45,000 mg/kg is the composite. Sample of the sludge from 'at depth of three feet within the tank bottoms disposal pits. Total Extractable Petroleum Hydrocarbons as diesel.,.(TEPHd)~vas detected at a concentration of 12,000 mg/kg in this sample. The fuel constituent vOlatile aromatics benzene, toluene, ethylbenzene, and total xylenes were detected at concentrations of 0.013 rog/kg, 0.038 rog/kg, 0.021 mg/kg, and 0.177 mg/kg, respectively. The pI-I of the sludge was measured at 7.17. TRPH was not detected in the north pit vertical assessing boring NP at depths of 10, 20 and 25 feet, and in the north pit lateral boring TI-I-3 at 15 and 25 feet. TRPH was detected in the south pit vertical assessing boring SP at 10 feet at a concentration of 20 mg/kg and 25 feet at a concentration of 60 mg/kg and in'the south pit lateral boring SPL at 10 feet at a concentration of 160 mg/kg, but not in vertical assessing boring SP at a depth of 35 feet, or in the south pit lateral boring SPL at 20 feet. The semi-volatile organic hydrocarbon diethyl phthalate was detected at a concentration of 0.1 mg/kg at 15 feet in boring TH-3 advanced adjacent to the northern tank bottoms disposal pit. No other volatile organic hydrocarbons, or semi- volatile organic hydrocarbons were detected at or above the minimum detection limit in the two samples collected from the area of the tank bottoms disposal pits. Lead was detected at an elevated concentration in the sample of the sludge from the disposal pits. Total lead was detected at a concentration of 44 mg/kg. The State of California Title 22 TTLC for lead is 1,000 mg/kg. However, the STLC for soluble lead is 5 mg/kg. Because of the 10:1 dilution that occurs during the wet extraction any total concentration less than 50 mg/kg will necessarily be determined to have a soluble component less than the STLC of 5 mg/kg. Therefore, a soluble lead wet extract was not performed on the sludge samplel Cadmium was detected at 1.2 mg/kg in the EB -8228 -3 9208-E028 .WP Don Keith Transportation 10 August 14, 1992 sludge. Cadmium's TTLC is 100 mg/kg, and STLC is I mg/kg. Copper was detected at 66 mg/kg in the sludge.. Copper's TTLC is 2,500 mg/kg, and STLC is 25 mg/kg. Mercury was detected at 0.39 mg/kg in the sludge. Mercury's TTLC is 20 rog/kg, and STLC is 0.~2 mg/kg~ Nickel was detected at 61 mg/kg in the sludge. Nickel's TTLC is 2,000 mg/kg, and STLC is 20 rog/kg. Vanadium was detected at 87 rog/kg in the sludge.' Vanadium's TTLC is 2,400 mg/kg, and STLC is 24 mg/kg. Each of these concentrations are far below their respective regulatory limits. Therefore, the sludge is not classified as a hazardous material by RCRA and California Title 22 criteria. However, these concentrations are in excess of that which occurs in the native soil and indicates an accumulation from the petroleum products. There may be a minor amount of mobility for these metals from the sludge into the underlying soil, however this has not been observed in the investigation. The Regional Water Quality Control Board provides recommended guidelines for TRPH as oil and grease, TEPH as diesel, the fuel constituent volatile aromatics, benzene, toluene, ethylbenzene and total xylenes, and the semi-volatile organic hydrocarbon diethyl phthalate using the LUFT methodology by multiplying the most stringent current federal or state water quality standards by a factor of 100 to account for attenuation due to site-specific parameters including vertical separation to ground. water, soil lithology, fractures in subsurfaces, annual average precipitation, and any. direct conduits to groundwater. These recommended guidelines are 1,000 mg/kg for TRPH as oil and grease, 100 mg/kg for TEPH as diesel, 0.3 mg/kg for benzene, 1.0 mg/kg for toluene, 4.0 mg/kg for ethylbenzene, 3.0 rog/kg for total xylenes, and 50 mg/kg for diethyl phthalate. Laboratory analytical results for the twenty seven soil samples from the eleven soil borings are summarized in Table I. EB-8228-3 9208-E028.WP Don Keith Transportation 1 1 '..f ~ August 14, 1992 S~M~Y OF ~O~TORY ~~C~ DATA (, ~ · [values ~n mm~grams ~er [nogramj ~1~ 'TRPH I BenzeneiToluene Ethyl-[ Total ] Diethy, ] Total ~ & Grease benzene] Xylenes Phthalate Lead " TH'-I 10' ) 7,9~_. ~ ~ ~ '~ 0.006 TH-lA 30' ~ 2.7 TH-IA 40' TH-lA 45' ~ TH-2 10' 10,0~ ~ 0.022 ND ~ TH-2A 20'. 40 · ] TH-2A 40' ~~ TH-2A 47' TH-3A 15' TH-3A 25' TH-4 10' ~ ND ~ ~ ~ ~ ND TH-4 20' . ~ ~ ~ ND ~ TH-4A 10' TH-4A 25' TH-4A 35' 20 -~ Sludge '3'-~,~)' 0.013-- 0.038 0.021 0.177 '44 Np 25' TH-3 15' ND ~ ~ ~ ND 0.1 3.0 TH-3 25' ~ ~ ~ ~ ~ SP 10' 20 · SP 25' 60 SP 35 ~.. SPL 20' , , . A L NA 1,000 0.3 1.0 4.0 3.0 50 NA ~ NA NA NA NA NA NA ~ NA 1 ~000 MRL NA 20 0.005 0.005 0.005 0.005 0.005 2.5 ND: None Detected at or above minimum reporting level (MRL). NA: Not Applicable. A L: Regional Water Quality Control Board recommended guidelines for concentrations in soil. Recommended guidelines were calculated using the LUFT methodology by multiplying the most stringent current federal or state water quality standards by a factor of 100 to account 'for attenuation due to soil composition and distance from groundwater. TTLC: State of California Title 22 Total Threshold Limit Concentration. EB-8228-3 9208-E028.WP 'Don Keith Transportation t2 August 14, 1992 Conclusions of the Investigation The data obtained suggest that soil impacted beneath the former location of the truck wash earthen clarifiers has been impacted by petroleum hydrocarbons at - concentrations in excess RWQCB recommended guidelines to a depth of less than 20 feet below surface. The data does not indicate that fuel constituents,' solvents, or heavy · metals have impacted this soil. ESE concludes that the petroleum hydrocarbons detected represent heavier molecular weight crude oil and refined products devoid of known hazardous constituents. The lateral extent of this impacted soil does not extend laterally from the boundaries of the former clarifiers. Therefore, ESE estimates that the soil between the base of the former clarifiers at a depth of 8 feet to a depth of 18 feet has concentrations of TRPH as oil' in grease in excess of the recommended guidelines over an area 75 feet long by 40 feet wide for a volume of impacted soil of approximately 1,000 cubic yards. It is ESE's oppinion that excavation of the soil to these dimensions will removal all of the impacted soil with concentrations of TRPH as oil and grease in excess of 100 mg/kg. The operation of the tank bottoms disposal pits appears to have impacted the soil to a depth of less than 5 feet at the location of the pits. The data does not indicate that fuel constituents, solvents, or heavy have impacted this soil. However, the sludge does contain slightly elevated concentrations of heavy metals, but remains classified as non-hazardous by RCRA and California Title 22 criteria. ESE concludes that the petroleum hydrocarbons detected represent heavier molecular weight crude oil and refined products. The lateral extent of this impacted ~oil does not extend laterally from the boundaries of the disposal pits. Therefore, ESE estimates that the soil within the northern pit to a depth of 5 feet has concentrations of TRPH as oil in grease in excess of the recommended guidelines over an area 30 feet long by 25 feet wide for a volume of impacted soil of approximately 140 cubic yards, and soil within the southern pit to a depth of 5 feet over an area 55 feet long by 15 feet wide for a volume of approximately 150 cubic yards. It is ESE's oppinion that excavation of the soil to these dimensions will removal all of the impacted soil with concentrations of TRPH as oil and grease in excess of 100 mg/kg. EB-8228-3 9208-E028.WP Don Keith Transportation 1 3 August 14, 1992 RecommengJations of the Investigation ESE t:ecommends excavation and surface bioremediation of the soil beneath the former clarifiers, and excavation and off-site disposal of the sludge from the disposal '- pits. The impacted soil from beneath the former clarifiers should be excavated to a depth 18 feet and treating the soil to concentrations less than the RWQCB recommended guidelines through the process of bioremediation at the subject property. Surface bioremediation has been shown to .be particularly successful in the San Joaquin. Valley given the high temperature, and Iow relative humidity. This option is .~ particularly viable at this site since the facility has available land to treat the soil., The impacted soil beneath the former clarifiers will respond very well to surface bioremediation. Because the property is in a commercial/petroleum setting, there is only a slight risk of exposure of any off site population to volatilized petroleum hydrocarbons, and therefore very little health risk to the general public associated with the treatment. This option can be particularly attractive since on site treatment alleviates the clients future liability for the soil. On-site treatment is not recommended for the sludge from the disposal pits because it will require an inordinate amount of time and effort for bioremediation to reduce the concentrations to below the RWQCB recommended guidelines. The impacted soil from beneath the former disposal pits should be excavated to a depth of 5 feet where the site assessment indicates that the limits of concentrations · f the RWQCB recommended guidelines will have been reached~ Selection of /~ an appropriate recycling or disposal facility depends on the concentration of contaminants in the soil after it is stockpiled. Judging from the findings of this study, it appears likely that the semi-solid/semi-liquid state of the sludge from the disposal pits makes that material unacceptable to solid Waste recycling facilities. It is ESE,s opinion that the appropriate classification for this material is as a designated  petroleum waste, and that the sludge materials may be disposed of as non-hazardous ~.. at a petroleum waste landfill such as the McKittrick Waste Disposal Site. .' EB-8228-3 '/~~(I ' ' , 9208-EO28.WP Don Keith Transportation 14 August 14, 1992 HEALTH & SAFETY PLAN A written Health and Safety plan will be implemented for site work conducted during the mitigation phase of this project. The purpose of the plan is to provide specific safety procedures to be implemented during the handling of petroleum hydrocarbon' contaminated materials. The Health and Safety Plan is required under regulations set forth in Federal OSHA CFR 29 1910.120, since the referenced report documented the presence of potentially hazardous materials at the site. This Health and Safety plan is included as Appendix A to the work plan. REMEDIAL ACTION PLAN Soil Excavation Kern Environmental Services will provide front,/e~-~ers, and a self-elevating paddle wheel scraper to excavate the estimated~,,l,00a~d//~ yards of impacted soil beneath the the two former clarifiers, and the 300 ~ yards of tank bottoms within the former disposal pits. Based upon Regional Water Quality Control Board Recommended Guidelines, and Kern County policy, ESE proposes an action level of 1,000. mg/kg for the maximum concentration of Total Recoverable Petroleum Hydrocarbons (TRPH) as oil and grease. Subsequent to the Kern County Resources Management Agency, Department of Environmental Health Services approval, soils will be excavated until the soils remaining in-place are believed to have concentrations of TRPH as oil and grease less than 1,000 mg/kg. However, the additional excavation required to remove all impacted soil with concentrations of TRPH as oil and grease in excess of 100 mg/kg is relatively insignificant. It is ESE's opinion that the proposed excavation dimensions will remove all impacted soil with concentrations in excess of 100 mg/kg. Prior to excavation, Underground Service Alert (USA) will be notified 48 hours in advance. In addition, the excavation contractor will obtain any necessary excavation permits from Calitbrnia Occupational Safety and Health Administration (Cai OSHA). The excavation will be performed so that sidewall slopes conform to California and Federal OSHA code requirements. EB-8228-3 9208-E028.WP Don Keith Transportation 15 August '14, 1992 Mitigation of dust is an important concern during the 'excavation and positioning of soil during this project. Water trucks will be on-site to wet traffic paths to control all dust emissions. Excavation Air Emissions Volatile aromatic hydrocarbons may be emitted during the excavation and placement of the semi-volatile petroleum impacted soil at the site. However, a review of the available analytical data indicates that the profile of petroleum hydrocarbons impacting the soil qualifies for an exemption to air emissions permitting as described in the San Joaquin Valley Unified Air Pollution Control District Kern County Zone Rule 463.5. The fuel constituent volatile aromatic benzene has been detected in only one of the soils samples during the investigation. Benzene was detected in that sample at a trace concentration of 0.013 mg/kg. Assuming that the entire mass of benzene within the impacted will volatilize in the first day of aeration, then less than 0.05 pounds of benzene will be emitted in that day. This is an overly conservative approach, since excavation will likely require several working days. Because the emission of benzene for that day will be less than 0.05 Pounds per day, the site qualifies for an exemption as described in Rule 463.5. The methodology of the California Air Pollution Control Officers Association (CAPCOA) "Screening Level Risk Assessment" indicates that the maximum potential emission of benzene over the duration of the project does not present a public health risk. The soil. was impacted with heavier molecular weight petroleum hydrocarbons including crude oil, asphalt fuel oil and diesel, all of which have a boiling point greater than 400°F. Since the boiling point is greater than 302°F, the project qualifies for an exemption under Rule 463.5 Therefore the entire 1,000 cubic yards of impacted soil may be excavated and placed onto the uncovered treatment pad during one continuous time period. EB-8228-3 9208-E028.WP Don Keith Transportation 16 August 14, 1992 Excavation Pit Field Screening During excavation soil samples will be collected from the base and sidewalls Of the three proposed excavation pits, and will be screened for total organic vapors with a portable photoionization detectOr (PID). Headspace vapor analysis will be performed by filling a mason jar to 50% capacity to produce a head space allowing volatilization for a period of 15 minutes, and protruding the probe of the PID through the cap and into the headspace for analysis. The PID readings will be recorded on the daily log..L_ When field~_screening indicates concentrations less than 100 ppm,~'-~e excavation willy-) be discontinued. .Otherwise excavation will continue until field screening indicates concentrations less than 100 ppm. ~' ~w--,~ Soil Sample Collection Following excavation tWelve verification soil samples will be collected from the base and sidewalls of the excavation pit at the location of the former truck was clarifiers. At this time ESE ~estimates that given the final excavation dimensions required to excavate the approximate 75 foot by 40 foot by 20 foot plume o~ impacted soil will require at least two samples from each of the four sidewalls, and four samples from the excavation base so that each sample represents less than 200 square feet of surface area. ESE also estimates the five soil samples will be required at the location of both of the former tank bottoms disposal pits with a sample from the center of the base of the excavation at each pit , and a sample from each of the four sidewalls at both pits. The soil samples will be collected in brass sleeves filled in such a way that no headspace remains, immediately sealed with Teflon® film, capped, security taped, labeled, and placed on ice for transport to a California Department of Health Services (DOHS) certified laboratory at less than 4°C. Strict chain of custody procedures will' be utilized for all samples collected to ensure sample integrity and to document sample possession from the time of collection to the final destination. All sampling equipment will be washed with TSP (tri-sodium phosphate) cleanser, and rinsed with tap water and de-ionized water prior to sampling, between sample intervals to minimize the possibility of cross-contamination. EB-8228-3 9208-E028.WP Don Keith Transportation 18 August 14,' 1992 PLAN 'ACCEPTANCE FORM The Plan Acceptance Form (attached) should be filled out by all employees working on the site and retained in the job file. Corporate Health & Safety Officer Robert Mohle (805) 541-5983 Site Safety Officer Kenneth Mitchell (805) 836-0901 - office (805) 837-8984 - home Project-Site Safety Plan prepared by Mark Magargee in conjunction with the Corporate Health & Safety Officer. Signature: Date: EB-80228-3 9205-E0328.WP Don Keith Transportation 19 August 14, 1992 The undersigned have read and understood the attached safety plan and agree to comply with the provisions of this plan. Name Date Name Date Position Position Name Date Name Date Position Position Name Date Name Date Position Position Name Date Name Date Position Position Name Date Name Date Position Position EB-80228-3. 9208-E0328.WP