Debris_Removal_Operations_Plan_Lassen_Volcanic_Park_Fire_Cleanup_REVISED_Drakesbad_WTP_6May2024.pdf
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- Removal of Hazardous Ash and Debris, Lassen VNP
- Solicitation number
- 140P8424Q0057
About this file
This document is a Debris Removal Operations Plan for the cleanup of fire ash and debris from the Dixie Fire that damaged properties in the Lassen Volcanic National Park, operated by the U.S. National Park Service.
The plan provides details on the assessment and quantities of hazardous and non-hazardous waste at various sites within the park, including the Drakesbad Water Treatment Plant, Kelley Cabin, and Mt. Harkness Lookout. It outlines procedures for the removal, handling, and disposal of the hazardous and non-hazardous materials, including asbestos and lead-acid batteries. The plan also addresses soil sampling and confirmation requirements. The related federal contract opportunity is for the removal of the hazardous ash and debris at the Drakesbad water tank site, with an estimated project range between $25,000 and $100,000. The requirement is a Total Small Business Set-Aside, and the Government anticipates awarding a firm-fixed-price purchase order.
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Debris Removal Operations Plan (“DROP”)
Lassen Volcanic Park Dixie Fire Cleanup
Address: 38050 Highway 36 E, Mineral, CA 96061 (NPS Headquarter)
Prepared by: XRF Research Inc.
Prepared for: FedVet Construction, Inc
Date of Report March 30, 2023
DROP edited to cover only Drakesbad Water Treatment Plant. Other portions of report pertaining to other sites within Lassen Volcanic National Park have been deleted from this version of this report. May 3, 2024
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| 9921 | Carmel | Mountain | Rd. | #326 | San | Diego, | CA | 92129 | 858-442-3230 |
March 30, 2023
Edgar DeLeon, President, Fedvet Construction
Re: Debris Removal Operations Plan, Lassen Volcanic Park Fire Cleanup
Dear Mr. DeLeon,
| The | following | document | is | a | plan | for | fire | debris | cleanup | operations | in | Lassen | Volcanic | |
| National | Park, | prepared | per | the | document | entitled | “140P8422Q0158 | Attachment | 01- | |||||
| Statement | of | Work, | Hazard | Assessment | and | Soil | Remediation” | (“Statement | of | Work”). | This | |||
| document | is | a | revised | version | of | an | older | document | dated | December | 11, | 2022, | per | request |
| of | the | National | Park | Service | (NPS). |
| It | has | specifications | for | work | that, | in | part, | are | based | on | findings | from | the | assessment |
| carried | out | in | October | 2022 | and | summarized | in | the | document | entitled | Fire | Cleanup | Project, | |
| Lassen | Volcanic | Park, | Phase | I | Site | Visit | Report | dated | November | 30, | 2022 | (“Site | Visit |
Report”).
| If | you | have | any | questions | regarding | this | plan, | please | feel | free | to | contact | me | at | 858-243- |
| 5415 | or | Ashley | Allison | (Certified | Asbestos | Consultant) | at | 619-961-5420. |
Regards,
| Javier | Gonzalez, | Ph.D., | President | of | XRF | Research, | Inc. |
| Senior | Industrial | Hygienist |
Ashley Allison, California Certified Asbestos Consultant #10-6804
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TABLE OF CONTENTS
I. Project Overview 4
Contact Information 5
II. Site Assessments 6
Waste and Debris Quantities 6
A/B) Mt. Harkness Fire Lookout and Pit Toilet 7
C) Kelley Cabin at Juniper Lake 14
D) Water Treatment Plant at Drakesbad 19
E/G) Drakesbad Area Boardwalks and Hot Springs Creek Bridge 25
F) Boardwalks, Grassy Swale 30
H) Devil’s Kitchen Boardwalk and Bridge 35
I) Boardwalks, Drake’s Lake Trail 41
J) Boardwalks, Summit Lake 50
III. Hazardous Waste Plan 56
1. Removal and Handling of both Hazardous Waste and Debris 56
2. Disposal and Recycling Facilities 61
IV. Background and Soil Confirmation Sampling 65
V. Signatures 67
VI. Appendix - Waste Characterization Lab Results Summary 68
VII. Attachment - Table II-1. Estimated Quantities of Waste for Sites 75
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I. Project Overview
| The | following | document | is | an | operations | plan | for | cleanup | of | fire | ash | and | debris | from | the | |
| Dixie | fire | (July | 2021) | that | damaged | a | number | of | properties | in | the | Lassen | Volcanic | National | ||
| Park | (LAVO), | operated | by | the | US | National | Park | Service. | Per | the | LAVO | website, | the | Dixie | ||
| Fire | started | on | July | 13, | 2021, | in | Feather | River | Canyon | southeast | of | Lassen | Volcanic | |||
| National | Park. | The | fire | entered | the | southeast | corner | of | the | park | near | Juniper | Lake | on | ||
| August | 5, | 2021. | The | Dixie | Fire | reached | its | final | size | of | 73,240 | acres | within | the | park | on |
| September | 30. | On | October | 26, | the | Dixie | Fire | reached | 100% | containment | with | a | total | size | of | |
| 963,309 | acres | making | it | the | largest | single | fire | in | California | history. | Final | Dixie | Fire | |||
| footprint | within | the | park | measures | 73,240 | acres | or | approximately | 8% | of | the | entire | Dixie | |||
| Fire | footprint. |
| The | burn | sites | are | all | in | rural | areas. | Most | consist | of | boardwalks | constructed | of | pressure | |
| treated | wood | in | watershed | or | marshy | areas, | some | accessible | only | on | foot. | Three | of | the | |
| sites, | the | Drakesbad | Water | Treatment | Plant, | Kelley | Cabin | at | Juniper | Lake, | and | Mt. | Harkness | ||
| Lookout | and | pit | toilet, | were | developed | sites | with | structures. |
| A | pre-work | trip | was | conducted | on | October | 1 | – | October | 11, | 2022 | to | survey | the | burn | sites |
| and | collect | ash | and | soil | for | composition | analysis. | The | results | were | summarized | in | a | trip | ||
| report | that | has | been | previously | submitted | and | reference | in | the | cover | letter | above. |
| Section | II | below | (Site | Assessments) | has | additional | site-specific | information | and | maps, | and | |||||||
| a | table | with | a | summary | of | all | the | sites | the | types | of | quantities | of | debris | and | waste | for | each. |
| Sections | III | – | IV | have | work | practices | and | information | that | are | based, | in | part, | on | the |
| document | entitled | Plumas | County | Fire | Debris | Removal, | Alternative | (Private) | Debris | Removal | |||||
| Program; | Beckwourth | Complex | and | Dixie | Fires, | September | 24, | 2021, | modified | per | NPS |
speccifications.
| Section | VI | is | the | waste | characterization | data | and | the | table | in | VII | indicates | removal |
| quantities | for | each | site. |
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Contact Information for project:
| • National | Park | Service | ||||
| Anna | Schrenk | |||||
| BAER | Implementation | Coordinator | for | Lassen | Volcanic | NP |
| 14412 | Kennedy | Memorial | Drive, | P.O. | Box | 188 |
| Whiskeytown, | CA | 96095 | ||||
| 530-242-3445 | (Office) | |||||
| 530-440-6636 | (Mobile) |
anna_schrenk@nps.gov
• Contractor
| Edgar | DeLeon, | President | ||
| FedVet | Construction | |||
| 3513 | Main | Street, | Suite | 104B |
| Chula | Vista, | CA | 91911 |
619-271-5888 Hazard Assessment Award 140P8422P0
| • Consultant | Industrial | Hygienist | ||
| Javier | Gonzalez, | President | ||
| XRF | Research | Inc | ||
| 170 | Eucalyptus | Avenue, | Suite | 105 |
| Vista, | CA | 92084 |
858-243-5415 jg@xrfresearch.com
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II. Site assessments
Table II-1. Estimated Quantities of Waste/Debris for Lassen Burn sites:
See §IV –ATTACHMENT – end of document
Figure II-1. Map of all burn sites.
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D) Water Treatment Plant at Drakesbad
Approximate Coordinates: 40.445209, -121.409165
| • Accessibility: | The | site | was | accessed | by | car. | It | can | be | found | right | at | the | end | of | the | |
| road | of | the | Chester | – | Warner | Valley | Road, | a | dirt | road | in | good | condition. | This | was | ||
| the | last | structure | traveling | West | after | passing | the | other | structures | (lodge, | cabins | ||||||
| and | boardwalk) | at | Drakesbad. | Parking | is | available | adjacent | to | worksite, | although | it | ||||||
| may | be | somewhat | difficult | for | a | large | vehicle | to | turn | around. |
| • Staging | Area: | The | recommended | staging | area | for | work | would | be | the | parking | area |
| by | the | Drakesbad | cabins | (coordinates | 40.444240, | -121.404271). |
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| • Hazardous | Trees: | No | hazardous | trees | were | observed | around | the | site | or | the | dirt | |
| road | / | staging | area | that | leads | up | to | the | site | that | would | impact | operations. |
| • Chimneys, | Septic | Systems, | and | other | hazardous | structures: | No | chimneys, | septic | |||||||
| systems, | or | other | hazardous | structures | were | present | at | this | site. | A | glass-lined | |||||
| water | storage | tank | that | had | been | damaged | by | the | fire | on | the | West | side | was | present | |
| (See | Figure | D-1, | below, | for | the | floorplan | of | the | worksite | and | maps). | Per | the | NPS, | ||
| the | fire | had | caused | the | interior | glass | lining | to | flake | off, | so | the | tank | will | be | removed |
| as | part | of | the | rebuilding | of | the | water | treatment | plan. | The | tank | was | observed | to | ||
| measure | approximately | 20’ | in | diameter | and | 15’ | tall | and | appeared | to | be | associated | ||||
| with | a | concrete | foundation, | though | only | a | portion | was | visible | on | the | Southeast | part | |||
| of | the | tank, | where | a | manhole | cover | was | present | on | the | foundation. | |||||
| The | ash | footprint | was | mostly | present | on | another | concrete | foundation | that | was | the | ||||
| base | for | a | pump | house | just | West | of | the | tank. | |||||||
| A | plastic | pipe | had | been | installed | to | divert | spring | water | into | a | larger | cast | iron | ||
| overflow | pipe | that | traveled | down | the | mountainside. | However, | the | large | pipe | was | |||||
| overflowing, | possibly | due | to | a | clog | at | a | lower | elevation. | This | plastic | pipe | was | |||
| draped | over | the | footprint | and | will | have | to | be | moved | (possibly | routed | to | the | West) | ||
| to | access | the | site | during | cleanup | operations. | Per | the | NPS, | this | spring | water | pipe | will | ||
| be | replaced | as | part | of | the | process | for | rebuilding | the | water | treatment | plant. |
| • Asbestos | Assessment: | Suspect | asbestos | fragments | from | gaskets | were | observed | on |
| the | West | side | of | the | footprint. |
| • Hazardous | Debris | Components: | A | large | lead-acid | battery | was | observed | in | the | East | ||
| part | of | the | footprint | in | degraded | condition, | with | both | fragments | of | lead | and | lead |
| oxide | in | particulate | form | mixed | into | the | ash | footprint. |
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Recyclable Material Weight (Lbs)
Metal (Steel) ~16,000
Concrete ~24,000
Plastic ~100
| • Hazardous | ash/soils: | The | ash | footprint | was | found | to | be | RCRA | hazardous | waste | ||||||
| (elevated | levels | of | lead) | also | California | Hazardous | waste | (for | lead | and | antimony). | ||||||
| Note | the | site | was | found | to | be | wet, | with | the | ash | in | the | burn | footprint | being | in | the |
| form | of | mud | or | sludge. | The | area | appears | to | be | a | watershed. | A | recommendation | ||||
| was | submitted | to | the | NPS | to | use | barriers | to | prevent | flow | of | contaminated | material | ||||
| (sludge) | from | the | worksite. | The | ash | waste | covers | an | area | of | 150 | ft2 | and | will | be | ||
| involve | additional | subsoil | removal | to | a | total | of | 9”, | so | this | represents | 13,000 | lbs | (~ | 4 | ||
| cubic | yards) | of | material. | Note | that | the | ash | footprint | extends | beyond | the | edges | of | a | |||
| concrete | foundation | and | has | mixed | with | soil. | The | ash | and | debris | would | be | removed | ||||
| from | concrete | foundation, | then | the | surrounding | areas | followed | by | removal | of | the | ||||||
| concrete | foundation | and | a | final | scrape. |
| • Non-hazardous | ash/soils: | Not | applicable. | The | ash | and | soil | on | site | were | found | to |
| be | classified | as | hazardous. |
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Figure D1. Map of the of the Drakesbad Water Treatment plant worksite
Remove 2" depth of soil within visible ash footprint outside the concrete footprint and three feet out from the southeast and northeast sides of pad.
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III. Hazardous Waste Plan
| 1. Removal | and | Handling | of | Hazardous | Wastes | and | Non-Hazardous | Debris | Removal |
| and | Handling. |
| For | all | sites, | either | the | ash, | or | the | ash | with | underlying | soil | in | the | case | of | the | Drakesbad |
| Water | Treatment | Plant | and | Kelley | Cabin, | were | found | to | be | regulated | wastes, | either | RCRA | ||||
| or | more | commonly, | California | (“non-RCRA”) | Hazardous | Waste, | per | the | summary | in | the | ||||||
| revised | Trip | Report | dated | March | 30, | 2023. | The | following | considerations | apply | for | ||||||
| handling | and | removal | both | hazardous | and | non-hazardous | wastes/debris: |
| • See | Health | & | Safety | Plans | prior | to | starting | operations. | Workers | and | supervisors |
| should | have | HAZWOPER | training, | at | a | minimum. |
| • Dust | control | and | Stormwater | control | measures | should | be | used | (see | the | separate |
| documents | entitled | Dust | Control | and | Air | Quality | Monitoring | plan | and | Stormwater | |
| Pollution | Protection | Plan). | This | includes | the | following | measures: |
| o A | fine | mist | of | water | should | be | delivered | with | a | sprayer | in | order | to | moisten |
| the | waste. | However, | the | amount | of | water | used | should | be | limited | to | avoid | ||
| pooling | of | water | and | runoff. | This | should | be | done | continuously | during | the | |||
| process | of | collecting | ash, | dust | or | soil, | with | one | worker | in | charge | of | the | |
| wetting | process. | This | should | be | done | prior | to, | then | during | operations | ||||
| moving | the | waste. |
| o When | moving | or | dropping | bulk | waste, | this | should | be | done | with | care, | in | such |
| a | way | that | the | formation | of | visible | dust | emissions | is | minimized. |
| • Erosion | Control. | Precautions | should | be | taken | throughout | the | project | to | prevent | |
| erosion, | which | is | the | movement | of | material | containing | pollutants | from | the | burn |
| footprint | onto | other | areas: |
| o For | worksites | that | are | on | or | around | active | watersheds, | barriers | should | be | ||
| used, | such | as | hay | bales, | sand | bags, | silt | fences | or | berms | to | prevent | the |
| flow | of | sludge | or | water | through | the | worksite | during | operations. |
! The sites involving boardwalks typically are in or around watersheds.
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| ! The | Drakesbad | Water | Treatment | plant | was | observed | to | also | be | in |
| a | watershed | area. |
o Stockpiling of waste material should be avoided (i.e., the contaminated
| ash | and | soil | waste | should | be | placed | directly | in | lined | waste | containers | for |
| transportation). | However, | if | stockpiling, | or | temporary | storage | of | waste | ||||
| material | on | the | worksite, | is | necessary | for | logistical | reasons, | then | the | ||
| waste | should | be | enclosed | (e.g., | contained | with | plastic | sheeting) | so | it | is | |
| not | dispersed | by | water | or | wind. | Waste | soil | and/or | ash | should | be | |
| moistened | with | water | to | control | fugitive | dust | (without | causing | runoff) | |||
| prior | to | it | being | covered. |
| ! If | it | is | necessary | to | stockpile | material, | this | should | not | be | placed | in |
| a | roadway | or | traffic | area. |
• Asbestos Removal and packaging for staging/transport. Any suspect friable ACM
| (asbestos | containing | materials) | need | to | be | either | burrito-wrapped | or | bagged | (this | is | |||
| a | landfill | requirement), | so | bulk | suspect | materials | should | be | segregated | and | placed | in | ||
| waste | bags | for | characterization | and | disposal | prior | to | removal | of | non-hazardous | ||||
| debris, | ash | and | contaminated | soil. | This | operation | is | typically | done | at | the | same | time | |
| that | other | highly | concentrated | hazardous | wastes | are | removed | (vide | infra). |
o These materials include either/or window putty, gaskets, heat shields, vinyl
| floor | tile | or | any | other | suspect | materials | discovered | during | cleanup | in | the | ||
| sites | that | had | structures: | Drakesbad | Water | treatment | plant, | Kelley | Cabin | and | |||
| Mt. | Harkness | Lookout. | Note | that | suspect | bulk | materials | may | be | tested | as | part | |
| of | a | worksite | asbestos | survey | to | establish | asbestos | content. |
| o Per | NPS | specifications, | the | work | should | be | carried | out | by | a | licensed | Asbestos |
| Abatement | Contractor | and | overseen | by | a | Certified | Asbestos | Consultant. |
• Hazardous Debris Components removal and packaging. Highly concentrated
| hazardous | wastes, | other | than | asbestos, | such | as | the | degraded | lead-acid | batteries | and | ||
| associated | lead | oxide | beneath | and | around | them | should | be | bagged | in | 6-mil | ||
| construction | debris | bags | in | order | to | minimize | exposure | to | toxic | fugitive | dust | during | |
| operations. | As | in | the | case | of | asbestos | and | other | hazardous | waste | handling, | dust | |
| control | measures | and | personal | worker | exposure | monitoring | should | be | used. | This | |||
| operation | may | be | carried | out | in | parallel | with | asbestos | removal, | if | applicable. |
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| • Hazardous | Waste | (Ash | or | Ash/Soil) | removal. | The | regulated | ash | and/or | soil | should | |||
| be | placed | in | roll-off | dump | trailers | or | equivalent | containers | that | have | been | lined | ||
| with | 6-10-mil | polyethylene | plastic. | The | waste | should | be | wrapped | with | the | plastic | |||
| and | completely | covered | with | tarp | so | that | particulates | do | not | escape | during | the | ||
| transportation | process. | It | should | also | be | labeled | and | a | manifest | should | be | used: | See | |
| below, | licensed | hazardous | waste | transporters. |
| o Dust | control/erosion | measures, | personal | protection | and | monitoring | should | be |
| used | at | all | times. |
| o Precautions | should | be | taken | to | prevent | waste | material | from | escaping |
| containment | during | movement | from | the | burn | footprint | into | the | |
| transportation | container. |
| o The | process | or | removing | hazardous | waste | may | occur | in | parallel | with | |||
| removal | of | non-hazardous | debris, | depending | on | the | conditions | of | the | ||||
| worksite. | In | some | cases | it | is | necessary | to | rinse | and | remove | the | non- | |
| hazardous | debris | in | order | to | access | the | ash. | For | example, | the | Kelley | cabin | |
| burn | site | is | mostly | covered | in | galvanized | steel | roofing. |
| • Non-Hazardous | Debris | Removal, | Disposal | and | Recycling. | Debris | including | metal | ||||||||
| and | concrete | should | be | separated | from | the | ash | in | the | burn | footprint | for | recycling. | |||
| In | the | case | of | the | metal | debris, | this | should | be | done | prior | to | removal | of | the | regulated |
| waste | (ash | and/or | soil) | whenever | possible. | In | the | case | of | concrete, | it | may | be | |||
| more practical | to | remove | it | after | the | contaminated | ash, | as | this | ash | is | often | on | top | ||
| and/or around | it. |
| o Metals | such | as | steel, | aluminum, | die | cast | (zinc) | or | brass/bronze | that | can | be | ||
| recycled | should | be | rinsed | in-situ | with | water | as | they | are | removed | from | the | ||
| burn | footprint | area | in | order | transport | them | to | a | recycling | center | (see | below). | ||
| The | water | rinse | also | serves | to | maintain | the | footprint | adequately | wetted, | but | |||
| this | needs | to | be | limited | to | avoid | pooling | or | runoff. | Dust | and | erosion | controls | |
| listed | above | should | be | used. |
| o After | removal | of | the | ash, | but | prior | to | the | scrape, | the | concrete | shall | be | rinsed |
| in | situ or cleansed in | a | manner to render concrete non-hazardous. |
1, .,.,. XRF Research, Inc .
• T o Note that both metal and concrete need to be clean from the ash debris in order to be recycled.
o Both concrete and metal must be covered with tarp during transportation.
The vehicle used to transport metal must go be cleared by law enforcement:
The vehicle identification number must be submitted to the Plumas County Sheriffs Office, 530-283-7438.
o The worksites should be left clean of all debris.
• Soil Scraping. After removal of all of the debris and ash is completed from each site's burn footprint, an additional quantity of soil is to be removed from within the burn site perimeter.
o This removed soil must be disposed at an appropriate landfill using the same handling, transportation and disposal procedures as for the ash and debris.
o The soil remaining on the ground after the scraping process is sampled (See §IV, below).
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| • Transportation | and | Waste | Management | at | staging | areas. | This | refers | to | local | |||
| staging | prior | to | transfer | to | a | licensed | hazardous | waste | transporter | in | the | case | of |
| regulated | wastes. |
| o A | mini | (<1 | ton) | excavator | such | as | the | Caterpillar | 300.9D | (2061 | lb, | 29” | width) |
| or | equivalent | may | be | used | facilitate | removal | of | debris. |
| o A | Canycom | Toter | (e.g., | Model | BFP602) | or | equivalent | may | be | used | as | one | |
| option | to | move | debris | (and | waste) | from | remote | areas | that | are | not | easily | |
| accessible | by | truck, | in | order | to | take | the | waste | to | an | appropriate | staging | area |
| for | loading | and | transportation. |
| ! The | equipment | will | be | inspected | prior | to | entry | into | the | park | and | upon |
| exit | and | cleaned | as | needed | so | it | arrives | and | leaves | uncontaminated. |
! Staging areas may be designated by the NPS COR.
| http://www.xrfresearchinc.com; | info@xrfresearch.com | Page 61 of 75 | |||||||
| 9921 | Carmel | Mountain | Rd. | #326 | San | Diego, | CA | 92129 | 858-442-3230 |
2. Disposal and Recycling Facilities (final Treatment, Storage and Disposal Facilities, “TSDF”):
Facilities That California Hazardous Waste, RCRA Hazardous Waste and Asbestos (Subject to Confirmation by Contractor)
| • Chemical | Waste | Management, | Inc | (DBA | “WM” | or | “Waste | Management”) |
| EPA | ID | CAT000646117 | ||||||
| 35251 | Old | Skyline | Road | |||||
| Kettleman | City, | CA | 93239 | |||||
| Contact: | Nathan | Collins | ||||||
| Phone: | 209-331-3664 |
Ncollin2@wm.com Hours of operation: 8 A.M. – 3:30 P.M., Monday - Friday
| • Clean | Harbors | Buttonwillow | LLC | |||||||
| EPA | ID | CAD980675276 | ||||||||
| 2500 | West | Lokern | Road, | Buttonwillow, | CA | 93206 | ||||
| Phone: | 661-762-6200 | |||||||||
| Hours | of | operation | 9 | A.M. | – | 4 | P.M., | Monday | - | Friday |
| Note | 1: | The | hazardous | waste | is | to | be | transported | to | the | above | permitted | sites | by | a | licensed |
| hazardous | waste | transporter. |
| Note | 2: | In | addition | to | the | analyses | that | have | been | carried | out | per | NPS | specifications | (See | Trip |
| Report), | both | landfills | also | require | profiling | the | waste | for | VOCs | (Volatile | Organic | Compounds, | ||||
| e.g., | via | analytical | method | EPA | 8260) | even | if | the | waste | has | already | found | to | be | hazardous | due |
| to | the | presence | of | other | contaminants. | This | should | be | done | prior | to | transporting | the | waste. |
| Recycling | Centers | and | Landfills | for | Non-Hazardous | materials. | The | following |
| landfills/recycling | centers | accept | un-contaminated | non-regulated | (non-hazardous) | wastes. |
Scrap Metals:
| • Chico | Scrap | Metal | |
| 878 | East | 20th | Street |
| Chico, | CA | 95928 |
530-343-7166
| http://www.xrfresearchinc.com; | info@xrfresearch.com | Page 62 of 75 | |||||||
| 9921 | Carmel | Mountain | Rd. | #326 | San | Diego, | CA | 92129 | 858-442-3230 |
Concrete and Asphalt:
• Franklin Construction
| 1019 | Neal | Road |
| Paradise, | CA | 95969 |
530-343-9600
| Non-hazardous | ash, | debris, | contaminated | soil | (in | addition | to | metal, | concrete | and |
| non-friable | asbestos): |
| • Anderson | Landfill | |
| 18703 | Cambridge, | Road |
| Anderson, | CA | 96007 |
530-347-5236
Labeling, Tracking and Manifesting Waste:
• Hazardous waste should be labeled indicating information on the generator/EPA ID,
| date | of | accumulation, | the | contents, | physical/chemical | properties | of | the | waste | and |
| manifest | number. |
| • Transporation | of | hazardous | waste | is | done | by | a | licensed | hazardous | waste | ||||
| transporter | requires | a | Hazardous | Waste | Manifest | (EPA | Form | 8700-22), | signed | by | ||||
| both | the | generator | and | transporter, | per | CCR | Title | 22, | §66263.20(a). | A | copy | of | the | |
| waste | manifest | is | an | important | document | that | should | be | retained. |
| • A | certificate | of | disposal | from | the | Plumas | County | Environmental | Health | Department | |||||
| will | be | needed | in | the | case | of | landfills. | Check | with | the | landfill | for | requirements | prior | |
| to | transporting. |
• Documentation of transportation and delivery of recycled materials should be retained.
| http://www.xrfresearchinc.com; | info@xrfresearch.com | Page 66 of 75 | |||||||
| 9921 | Carmel | Mountain | Rd. | #326 | San | Diego, | CA | 92129 | 858-442-3230 |
| (2) This | is | a | placeholder | for | site-specific | goals. | Background | (natural) | levels | of | Arsenic | in | |
| California | soil | are | higher | than | the | Risk-Based | screening | levels | and | typically | in | the | range |
| 0.6-11 | ppm*, | so | site-specific | BTVs | are | typically | used | to | establish | cleanup | goals**. |
See:
| • *Background | Concentrations | of | Trace | and | Major | Elements | in | California | Soils; | Kearney |
| Foundation | Special | Report, | University | of | California, | March | 199 |
| • **Arsenic | Strategies: | Determination | of | Arsenic | Remediation; | Development | of | Arsenic | |||
| Cleanup | Goals, | DTSC | (CA | Department | of | Toxic | Substances | Control), | January | 16, | 2009. |
| (3) This | is | the | TTLC | threshold | for | hazardous | waste | in | the | case | of | Cr | (VI) | that | could | be | used |
| in | the | absence | of | speciation | to | determine | the | oxidation | state | of | the | chromium. | The | TTLC | |||
| threshold | for | Cr | (III) | is | 2,500 | ppm, | which | could | alternatively | be | used | if | the | Chromium | is | ||
| known | to | exist | in | this | form | (established | through | testing). |
(4) TTLC (hazardous waste threshold concentration), From CCR Title 22, §66261.24.
| (5) Based | on | the | DTSC-SL | for | Mercury | of | 1 | ppm | for | residential | soil. | Note | the | level | for | |
| commercial | is | 4.4 | ppm. | “DTSC-Modified | Screening | Levels | (DTSC-SLs)”; | HERO | HHRA | (Human | ||||||
| Health | Risk | Assessment) | NOTE | NUMBER | 3, | April | 2019, | California | Department | of | Toxic | |||||
| Substances | Control | (DTSC) | Human | and | Ecological | Risk | Office | (HERO) |
| http://www.xrfresearchinc.com; | info@xrfresearch.com | Page 71 of 75 | |||||||
| 9921 | Carmel | Mountain | Rd. | #326 | San | Diego, | CA | 92129 | 858-442-3230 |
| (1) | Note: | 2,3,7,8-TCDD | is | “Dioxin” | or | “TCDD” | (2,3,7-8-tetrachlorodibenzo-p-dioxin). | For | |||||||
| reference, | the | residential | CHSSL | is | listed | as | 4.6 | x | 10-6 | ppm | (0.0000046 | ppm, | or | 4.6 | ppt). |
| Commercial/industrial | 1.9 | x | 10-5 | ppm, | or | 19 | ppt. | ||||||||
| See | “Use | of | California | Human | Health | Screening | Levels | (CHHSLs) | in | Evaluation | of | ||||
| Contaminated | Properties”, | January | 2005, | California | Environmental | Protection | Agency |
| ¶TEQ | = | Total | Toxic | Equivalency. | This | takes | into | consideration | results | from | a | panel | of | 17 | ||
| dioxins, | weighted | for | toxicity | relative | to | TCDD. | The | table | is | color-coded | to | indicate | relative | |||
| levels… | green | numbers | are | below | the | most | stringent | state | screening | levels. | Yellow | is | ||||
| above | these | levels | and | red | is | ~ | ≥10-fold | typical | cleanup | levels. | See | “Review | of | State | Soil | |
| Cleanup | Levels | for | Dioxin”, | US | EPA | December | 2009 |
| (2) | A | remediation | goal | of | <40 | ppt | is | suggested | by | the | DTSC | for | agricultural | land | (also | 50 |
| ppt | for | residential | and | 220-700 | for | commercial/industrial | properties). | See | “Soil | Remedial | ||||||
| Goals | for | Dioxins | and | Dioxin-Like | Compounds | for | Consideration | at | California | Hazardous | ||||||
| Waste | Sites”; | Human | Health | Risk | Assessment | (HHRA) | Note | Number | 2. | April | 2017, | |||||
| California | Department | of | Toxic | Substances | Control | (DTSC) | and | Ecological | Risk | Office |
(HERO).
(3) Asbestos (Table VI-3, left). As measured by CARB-435 Level A (400 point count):
| • No | asbestos | was | detected | above | the | reporting | limit | of | 0.25wt% | in | any | of | the | sites | as |
| measured | by | CARB-435. |
| Note | however, | that | this | is | a | method | that | is | designed | primarily | for | asbestos | in | soil. | In | burn | |
| sites | asbestos-containing | materials | are | often | rendered | friable | after | a | fire, | but | may | retain | |||||
| enough | of | their | structural | integrity | that | they | remain | present | mostly | as | bulk | materials. | The | ||||
| CARB-435 | method | (requested | in | the | SOW) | may | be | useful | in | the | final | screening | of | soil | after | ||
| a | cleanup, | but | may | underestimate | the | presence | of | asbestos | in | the | ash | footprint | if | the | |||
| asbestos-containing | material | is | present | predominantly | in | bulk | form. |
(4) Mercury (Table VI-3, right). As measured by cold vapor AA:
| • Levels | of | mercury | were | below | the | STLC | (hazardous | waste) | trigger | of | 2 | ppm | and | also | |
| below | the | most | stringent | DTSC-SL | (suggested | cleanup | level) | of | 1 | ppm | for | all | sites. | See | |
| Table | V-3, | right | and | footnote. |
| http://www.xrfresearchinc.com; | info@xrfresearch.com | Page 75 of 75 | |||||||
| 9921 | Carmel | Mountain | Rd. | #326 | San | Diego, | CA | 92129 | 858-442-3230 |
VII. Attachment
Table II-1. Estimated Quantities of Waste for Sites
| *This | assumes | a | weight | of | 3105 | lbs/yd3 | (ir | 115 | lbs/ft3) | for | water-saturated | topsoil | (thecalculatorsite.com). | We | would | expect | these | conditions | based | on | |
| the | proposed | time | of | year | for | the | work | (early | summer) | and | also | due | to | work | practices | employing | water | to | reduce | dust. |
Ω The square footage has been adjusted in some cases from that in the original scope of work document to reflect what we observed.
File details come from the government source that posted it. Updated .