Off-Site Water Disposal ICN_2016-06_Redacted.pdf

Work Instruction

WORK INSTRUCTION

OFF-SITE TRANSPORTATION AND DISPOSAL OF

COLLECTED SITE WATERS

WI-5518

Revision 0

Effective: 06/05/19

Off-Site Transportation and Disposal of Collected Site Waters

Scope:

This work includes the on-site loading of tanker trucks, transport to the off-site discharge location, and discharge to the approved sanitary sewer point. The sanitary sewer lines are maintained by the Northwestern

Water and Sewer District (NWWSD) and ultimately lead to the City of Toledo’s Publicly Owned Treatment

Works (POTW). Only water that meets the guidelines of the City of Toledo’s POTW issued discharge permit will be transported off-site for disposal.

General requirements:

A Task Lead (TL) for the operation is responsible for field activities performed under this work instruction, and will verify with the Site Safety and Health Officer (SSHO) that all crew personnel meet training/qualification requirements. A Waste Management Specialist (WMS) or designee will serve as the

TL for water disposal activities. The TL will coordinate operations with the Site Superintendent (SS).

The Project Chemist will provide technical guidance on matters related to laboratory analyses and data quality practices.

The Waste Manager (WM) will verify that all required permits and documentation is in place prior to commencing work. Documentation required prior to work commencing is located in the Training/Permits section of this work instruction.

The Pump Operator (OP) will inspect and operate the pumping equipment onsite. The pump operator will be designated by the WMS with concurrence by the SS.

The Truck Driver (TD) will transport the water to the discharge location. In addition, the truck driver will conduct all off-site discharge operations.

Workers will be briefed to this work instruction prior to working under this scope of work.

Prior to commencement of work the TL shall:

o Verify that key personnel are present.

o Verify safe work conditions exist in the work area.

o Verify that needed supplies and equipment are available.

o Ensure all required equipment inspections are performed.

o Coordinate with adjacent operations.

Prior to commencement of work the WM shall verify that the following is approved and in place:

o City of Toledo Discharge Permit.

o Documentation that no permit is required from NWWSD.

o Permission to utilize surrounding property for truck turnaround.

o Activity Hazard Analysis (AHA) o Draft shipping paperwork package.

o Driver emergency response and route instructions.

On-Site Operations:

TL– Perform a walk down of the area with the SS to confirm staging locations for the tanker trucks, pump, and filter housing. The general area will be near the Modutank.

TL – Set up pumping equipment in the designated area identified in the previous step. The equipment may vary, but at a minimum will include a 4” or greater pump, sock filter housing with 50 micron (or smaller), hoses, and a spill containment berm. Fill ports for the tanker trucks are located on the bottom of the trailer.

Water will be pumped from the top of the Modutank through the filter housing and into the tanker trailer.

COLLECTED SITE WATERS

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Effective: 06/05/19

TL – Delineate area where tanker trucks will be parked. This area will remain delineated during the entire shipping campaign. This will allow the trucks to be loaded in the same spot which in turn allows them to be accurately measured for fill capacity based off of the truck’s air suspension gauges.

TL – Once the area setup is complete, a designated spotter will back the tanker trailer into position within the delineated area. The truck driver will prepare the tanker trailer to accept the water flow from the pumping system.

OP – Verify that the pump system is hooked up to the tanker truck and ready to accept water flow with the truck driver. Once verification is complete, begin filling the tanker trailer until the truck driver indicates that the desired payload has been reached.

OP – Close discharge valves and disconnect pumping system from the tanker trailer.

TL – Complete manifest and receive signature from USACE. Once complete, obtain signature from the driver, make appropriate copies, and give completed copies to the truck driver as referenced in PLN-5507

Waste management, Transportation, and Disposal Plan.

o On the first load for each individual tanker truck combination of the campaign, the trucks will be directed to the onsite scale and weighed to verify that the trucks are below DOT weight restrictions.

TL – Brief driver to the emergency response instructions and route guidance. After briefing, the truck can be released to perform the shipment.

Off-Site Operations:

TD – Remove manhole cover from discharge point. Note: NWWSD will provide a temporary cover that can be utilized during the day as to not have to remove the manhole cover each trip. The manhole cover will be replaced after the last load of each day.

TD – Attach discharge hose to the discharge port on the bottom of the tanker truck. Once attached, route the discharge hose to the discharge point. Open valve on tanker truck to empty the contents into the discharge point.

TD – Once the truck is empty, disconnect discharge hose from the tanker truck being cautious of any residual water in the hoses. Place temporary cover over the discharge point.

Tanker Truck Clean Out:

OP - Upon completion of the campaign, each tanker trailer used during the campaign will be filled with clean water either from the East Production Well or from treated effluent water from the Waste Water

Treatment Plant.

TD – Transport and discharge the load of clean water in accordance with the steps above.

Key Work Members:

Waste Management Specialist (WMS)

Pump Operator (OP)

Task Lead (TL)

Truck Driver (TD)

Site Superintendent (SS)

Waste Manager (WM)

Safety Oversight (ST)

COLLECTED SITE WATERS

WI-5518

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Effective: 06/05/19

Radiation Control Technician (RCT)

Site Safety and Health Officer (SSHO)

Radiation Safety Officer (RSO)

Training/Permits:

Project employees must meet the training requirements per the Luckey SSHO and the RSO.

Personnel performing work under this work instruction must be briefed to the requirements herein.

Approved City of Toledo Discharge Permit

Safety-Related Controls:

Ensure Spill berms are in place prior to operating pumps.

ST and RCT oversight will be present.

Radios required to maintain constant communication with co-located and other site operations.

Personal protective equipment

Site Emergency Plan

Activity Hazard Analysis (AHA) “Transfer of Water from Storage Tank to Tanker”

Monitoring and Work Practices:

Verify valves are closed before disconnecting hoses.

Clean up any water spills immediately to not create a slipping hazard.

Shut down pump prior to closing any valves to prevent over pressurization of the system.

Place hose caps on the ends of the hoses when not in use.

Integration and constant communication with co-located operations team members is critical to safe operations.

Tools and Supplies Required:

Personal protective equipment per SSHO and RSO

Various hand tools for pumping operations

Site Radios

Safety Cones or other delineators

4” or larger water pump

Filter housing with 50 micron or smaller bag filter

Various plumbing

Spill Containments

Spill Kit for loading area

Use Documents:

PLN-5507, Waste Management, Transportation, and Disposal Plan for Luckey FUSRAP Remediation

Project (current revision)

Reference Documents:

PLN-5507, Waste Management, Transportation, and Disposal Plan for Luckey FUSRAP Remediation

Project (current revision)

COLLECTED SITE WATERS

WI-5518

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Effective: 06/05/19

Records Management:

Waste Management Specialist – Prepare Submittal to USACE of completed shipping packages. In addition waste records will be archived.

Attachments:

Checklist for Off-Site Transportation and Disposal of Water

Checklist for Off-site Transportation and Disposal of water

1 | P a g e

The following items are needed prior to shipping water from the site to the City of Toledo treatment plant via the Northwestern Water & Sewer District’s manhole located at the end of Commodore drive in

Walbridge:

☐ Site visit to discharge location

Notes:

☐ Develop and submit Discharge Permit Application to USACE for Review

Notes:

☐ Develop and Submit AHA to USACE for Review

Notes:

☐ Revised and resubmit ICN to Water Management Plan

Notes:

☐ Procure and schedule rental of 6” Pump and Filter Housing to fill trucks from Modutank

Notes:

☐ Submit Signed Discharge Permit application to City of Toledo

Notes:

☐ Schedule Preparatory Meeting for DFW

Notes:

☐ Develop Work Instruction

Notes:

☐ Submit confirmation email to USACE on permission to utilize JTI trucking lot for turnaround

Notes:

☐ Submit confirmation email to USACE that no permit with Northwestern Sewer District is necessary

Notes:

☐ Submit draft shipping package to USACE for review and comment

Notes:

Activity Hazard Analysis

Interim Change Notice for Water Management Plan

Applicability: Companywide INTERIM CHANGE NOTICE For use with QAP-3061

QAF- 3061.01

Owner: QA Manager Revision: 0

Effective Date: 04/26/17 For most recent revision or additional information:

https //portageap northwindgrp.com/dms/

NOTE: This completed form is a record and shall be completed entirely and maintained in accordance with project/program records management requirements.

TEM-3002, Rev. 0

ICN No.: 002

PLN-5506

Water Management Plan for the Luckey Formerly Utilized Sites

Remedial Action Program Remediation Project

Document Number Title Revision

Prepared by: (Type or Print)

Signature: Date:

06/05/19

Title:

Project Engineer

Approved by: (Type or Print)

Signature: Date:

06/05/19

Title:

Project Manager

The current approved version of this document can be found at the following intranet address:

This document is effective for use on ______06/05/19_________ and will remain in effect until it is withdrawn or replaced with a superseding version of the document listed above.

Mark this space if the change to the document only adds text or figures to the document.

Mark this space if the change to the document only deletes existing text or figures within the document.

Mark this space if the change to the document revises existing text or figures in the document.

Cite page numbers and sections that are added, deleted, or revised by this change. Where text or figures are added or revised, provide the additional text or figures or the revised text in the space provided below.

Page 19, Change Section 5. to now read:

5. OFFSITE REMOVAL OF WATER

NWP will utilize over the road tanker trucks to transport potentially contaminated waters offsite to an approved acceptance facility, such as a Publicly Owned Treatment Works (POTW). This option will be utilized when the onsite WWTP cannot reasonably process the volume of potentially contaminated site waters, which will consist primarily of excess water accumulation in open excavation areas. Water for offsite disposal will be managed in accordance with Work Instruction 5518 (Offsite Transportation and Disposal of Collected Site Waters) and Plan

5507 (Waste Management, Transportation, and Disposal Plan for the Luckey FUSRAP Remediation Project).

NWP will work in conjunction with the USACE to ensure appropriate approvals are received for the shipment process and acceptance facility prior to commencing any offsite shipping campaigns.

Applicability: Companywide INTERIM CHANGE NOTICE For use with QAP-3061

QAF- 3061.01

Owner: QA Manager Revision: 0

Effective Date: 04/26/17 For most recent revision or additional information:

https //portageap northwindgrp.com/dms/

NOTE: This completed form is a record and shall be completed entirely and maintained in accordance with project/program records management requirements.

TEM-3002, Rev. 0

5.1 Sampling and Analysis

Luckey FUSRAP Remediation Project sampling and analysis requirements and procedures are provided in the

SAP (USACE 2017b). NWP will work in conjunction with the USACE to ensure sampling and analysis satisfies the requirements of the acceptance facility (POTW).

Change:

5. EAST PRODUCTION WELL USE to 6. EAST PRODUCTION WELL USE (follow for subsequent sections as necessary to reorder Sections.)

Supporting documentation attached:

None – The USACE has requested this verbiage change in order to support the offsite shipping campaign for potentially contaminated waters.

Note: Only non-intent changes can be made utilizing the ICN process.

This form is retained as a record upon completion.

Draft Shipping Paperwork Package

Email from Northwestern Water and Sewer District re: additional permit

Email from ICE Services re: Use of JTI Trucking Lot