October 23, 2007 The Boeing Company MC-033-T487 Subject ......The Boeing Company 5800 Woolsey Canyon...
Transcript of October 23, 2007 The Boeing Company MC-033-T487 Subject ......The Boeing Company 5800 Woolsey Canyon...
October 23, 2007 The Boeing Company 5800 Woolsey Canyon Rd. MC-033-T487 Canoga Park, California 91304-1148 Attention: Mr. Art Lenox Subject: Transportation Plan for
Northern Drainage Debris/Asbestos Removal Santa Susana Field Laboratory Ventura County, California Dear Mr. Lenox: Enclosed is our plan, Transportation Plan for Northern Drainage Debris/Asbestos Removal, Santa Susana Field Laboratory, Ventura County, California. This transportation plan describes the transportation of asbestos-containing material and incidental soil from the LOX debris area and from the Northern Drainage bank and sediments to off-site disposal facilities, as described in Northern Drainage Debris/Asbestos Work Plan, Santa Susana Field Laboratory, Ventura County, California (Zenco, 2007). We appreciate the opportunity to work with The Boeing Company on this project. Please advise if you have any questions or wish further discussion of this report. Sincerely yours,
for Dixie Hambrick, P.G. Vice President Enclosure Figures:
Figure 1 - Site Location Map Figure 2 - Location of LOX Debris Area Figure 3 - Transportation Route Detail – Inside SSFL Figure 4 - Transportation Route Detail – SSFL to State Highway 118 Figure 5 - Transportation Route Detail – Route from State Highway 118 to Chemical Waste Management, Kettleman Hills Facility, Kettleman City, California
USPAS3S02/DEI/Rocketdyne SSFL/Projects/North Drainage Deliverables/DTSC Deliverable 10-23-07/2007-1023-MWH-Trans. Plan-ACM
3050 Saturn Street, Suite 205 Brea, CA 92821
Tel: 714-646-2020 Fax: 714-986-9834 BUILDING A BETTER WORLD
1. INTRODUCTION This Transportation Plan was prepared by MWH, and outlines proposed asbestos-containing material (ACM) transportation activities to be completed by The Boeing Company (Boeing) in the debris area east of the former liquid oxygen (LOX) plant. Removal of the ACM from the Northern Drainage bank and sediments is described in Northern Drainage Debris/Asbestos Work Plan, Santa Susana Field Laboratory, Ventura County, California (Zenco, 2007), herein referred to as the Work Plan. Deposits of ACM and debris in the Northern Drainage will be removed by an excavator and hand tools. The removal, transportation, and disposal activities will be performed in accordance with applicable federal, state, and local laws, regulations, and ordinances. The LOX debris area is located on the Mountains Recreation Conservancy Authority (MCRA) Sage Ranch property, immediately north of the Santa Susana Field Laboratory (SSFL), Ventura County, California. The Northern Drainage occurs both on Sage Ranch and SSFL property, and extends farther northward onto Brandeis-Bardin Institute (BBI) property. SSFL is located in the Simi Hills of southeastern Ventura County in Southern California (Figure 1), approximately 29 miles northwest of Los Angeles. Site features are described below. 1.1 Facility Description The LOX debris area is approximately 0.2 acres in size and is located in the MRCA – Sage Ranch property adjacent to the northeastern portion of SSFL Area I, near the former LOX plant (Figure 1). The LOX debris area consists of a drainage area bounded by bedrock outcrops to the north and south. No buildings or other structures currently exist at the LOX debris area. The Northern Drainage roughly bisects the LOX debris area, extending east to west. An unpaved hiking trail generally parallels the drainage on the north side. Beyond the LOX debris area to the west, the Northern Drainage enters SSFL property southeast of the former LOX Plant. The Northern Drainage then trends northwest, leaves SSFL property approximately 500 feet north of Outfall No. 009, and extends onto the BBI property. The Northern Drainage extends approximately 13,600 linear feet (approximately 2.5 miles) from the east end of the former shooting range into the BBI property (Figure 2). Currently, no active SSFL facilities or operations are in the vicinity of the Northern Drainage. 1.2 Site Features The elevation of the LOX debris area is approximately 1,740 feet above mean sea level (MSL). Vegetation is relatively dense in some areas. Several oak trees border the debris along the southern boundary. Alluvial thickness is generally less than a few feet throughout the LOX debris area.. Surface water discharge is ephemeral, resulting from rainfall, and generally flows via sheet flow into the Northern Drainage which extends east to west through the LOX debris area.
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2. PURPOSE AND OBJECTIVE The purpose of this Transportation Plan is to identify and minimize potential health, safety, and environmental risks resulting from the implementation of the Work Plan, particularly during loading, Site entry, and egress, and during transportation of waste on public roads. The Transportation Plan as well as the included Contingency Plan Section will be used as a stand-alone document by personnel involved in the transportation of the excavated debris. 3. WASTE CHARACTERIZATION AND QUANTITY The estimated volume of ACM, debris and incidental soil likely to be generated in the LOX debris area is approximately 500 cubic yards. 3.1 Estimated Waste Quantity The total volume of ACM debris and incidental soil is not anticipated to exceed 500 cubic yards, or approximately 34 truck loads, assuming an average truck load of 15 cubic yards and no bulking. Because adjustments to the limits of removal may be warranted based on visual field evidence (e.g., additional ACM), volumes are estimates and do not include potential additional soil and debris removal that may be necessary in order to meet the post-removal goals of the Work Plan. 3.2 Waste Profiling Representative debris and soil samples were collected from targeted removal areas for the purpose of waste characterization and profiling. Chemical analysis was conducted by a California-certified laboratory. Based on the chemical analysis, the ACM, debris and incidental soil will be classified as hazardous waste. One of three samples of grey foam insulation contained antimony concentrations greater than the Soluble Threshold Limit Concentration (STLC) for antimony, therefore it is expected that the pieces of grey foam insulation will be managed, transported, and disposed of as a state-regulated hazardous waste. Analytical results will be submitted to the appropriate disposal facilities for approval and disposal of waste. Once approval from the disposal facility is obtained, the waste will be transported to the disposal facility. 4. WASTE STAGING OPERATIONS It is anticipated that the removed debris and incidental soil will be promptly loaded in a closed-top roll off bin for transport to a staging area on Boeing property near the front gate of SSFL. Upon filling the lined waste bin, the contents of each bin will be “burrito-wrapped” and decontaminated as necessary. Asbestos labeling will be applied to the exterior of each liner. Each bin will then be promptly transported to the storage pad on Boeing property near the front gate, where it will then be prepared for off-Site disposal.
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No more than 6 trucks will arrive and leave the Site on the same day. It is anticipated that one or two trucks may be staged at the loading area at any one time. 5. REQUIREMENTS OF TRANSPORTERS A transporter or combination of transporters will be selected prior to the implementation of this Transportation Plan. The selected transporters will be qualified, fully licensed, and insured to transport the wastes generated. For transportation of hazardous wastes, if necessary, the selected transporter will be a registered hazardous waste hauler. The excavated ACM and debris will be transported in roll-off bins, using roll-off trucks, or equivalent, each with a capacity of 15 to 18 yards of material. Resource Conservation and Recovery Act (RCRA) or California-hazardous wastes will be placed in labeled, DOT-approved, 55-gallon drums or other DOT-approved containers for shipment. 6. TRAFFIC CONTROL PROCEDURES The plan is to dispatch trucks to and from the Site at set intervals to avoid traffic problems along Woolsey Canyon Road, the significant local traffic bottleneck. Between 7 a.m. to 9 a.m. and 4 p.m. to 7 p.m., trucks traveling on City of Los Angeles streets will be staggered at a minimum of 15 minute intervals. For other periods, the interval will be approximately 10 minutes. Although truck drivers will be instructed to approach the Site at the prescribed intervals, there is always the possibility that some trucks will approach the Site ahead of time. Each truck driver will make a temporary stop at the facility entrance at the end of Woolsey Canyon Road. The driver will park the truck at an area designated by the security guards. The security guard will issue a temporary pass permit to the driver and authorize the truck entry to the facility. The driver will proceed to the loading area following the posted signs. While at the Site, vehicles will be required to maintain slow speeds for safety purposes and for dust control measures. 7. TRUCK LOADING OPERATIONS Rolloff bins will be loaded at a staging area alongside the asbestos debris area (Figure 2). The bins will be place on top of traffic plates that will help prevent the trucks from coming into contact with the ground beneath. The traffic plates will be kept free of debris to prevent truck tires from coming into contact with asbestos-containing material or debris.
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Gentle loading of debris into the rolloff bins will be performed to minimize the potential for spill or dust creation. Water spraying will be implemented as needed to suppress potential dust generation during loading operations. Loading will not be performed during unfavorable weather conditions (i.e., high winds or storms). Any material that is spilled during loading will be collected for subsequent loading. Asbestos-containing material and debris will be loaded into plastic-lined bins. Once loading is complete, the material will be “burrito-wrapped” with plastic sheeting. Trucks will then pass through the decontamination and inspection station. Each bin will then be promptly transported to the storage pad on Boeing property near the front gate, where it will then be prepared for off-Site disposal. Trucks will be inspected before leaving the Site. The inspection will include visual checking of tire conditions, brake pads, latches, properly-secured covering, decontamination, placarding, and hauling documents (manifests). The inspection results will be logged in the daily construction logs. 8. SHIPMENT DOCUMENTATION The characteristics of the waste will be determined prior to transportation off-Site. A copy of the shipping document for each truckload will be maintained on-Site until completion of waste transportation operations. 8.1 Hazardous Waste Shipment A manifest of hazardous waste will be prepared for each truck, based on analytical data and the landfill approval profile sheet. After loading the truck, a Boeing representative and the driver will sign the manifest. The generator’s copy (yellow) and the DTSC’s copy (blue) will be removed from the manifest package, by the transportation manager, for logging and tracking purposes. The balance of the manifest sheets will be handed over to the driver to accompany the shipment of the waste to the landfill facility. At a minimum, the manifest document will include the following information:
Name and Address of Waste Generator; Boeing EPA ID Number; Name and Address of Waste Transporter; Name and Address of Disposal Facility; Description of the Waste; and Quantity of Waste Shipped.
9. TRANSPORTATION ROUTES Transportation of wastes will occur on arterial streets and/or fwys, approved for truck traffic, to minimize any potential impact on the local neighborhoods. The primary routes and an alternate route are described in detail below. 9.1 Primary Route
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The primary truck route to the various facilities will be based on reaching the Ronald Reagan 118 Freeway (Fwy). To exit the SSFL Site from the former shooting range/Northern Drainage, vehicles will proceed directly towards the Site gate along Service Area Road (Figure 3). Primary Route to the 118 Fwy From the SSFL gate, vehicles will turn right (east) onto Woolsey Canyon Road, turn right (south) onto Valley Circle Boulevard, turn left (west) onto Roscoe Boulevard, and turn left (north) onto Topanga Canyon Boulevard (Figure 4). The entrance to the 118 Fwy is on Topanga Canyon Boulevard. Route to Chemical Waste Management – Kettleman Hills Facility Vehicles will go east on the118 Fwy, north on San Diego Fwy 405, north on I-5 to Kettleman Hills, south on Skyline Boulevard, and finally left on Old Skyline Road (Figure 5). The landfill is located at 35251 Old Skyline Road, Kettleman Hills. 9.2 Alternate Route An alternate route between the Site and a fwy entrance includes avoiding the 118 Fwy by using the 101 Fwy and 405 Fwy instead. This alternate route is not recommended because traffic on the 101 Fwy is usually heavier than on the 118 Fwy. Another alternate route is access to the 118 Fwy through De Soto Avenue instead of Topanga Canyon Boulevard. 10. OFF-SITE LAND DISPOSAL FACILITIES The asbestos-containing material and debris will be managed as hazardous waste and handled as outline above. It is anticipated that the grey foam insulation pieces, recovered down-drainage from the debris areas, will be managed as a hazardous waste. This material will be secured in 55-gallon drums or other DOT-approved containers and transported to the Kettleman Hills Facility for disposal. Copies of waste profile reports used to secure disposal permission from the facility will be provided to DTSC.
Facility Address Facility Contact Chemical Waste Management, Inc. Rachel Lopez 35351 Old Skyline Road Tel: (559) 386-9711 Kettleman Hills Facility Esther Salazar Kettleman City, California 93239 Tel: (559) 386-9711
11. RECORDKEEPING A daily field logbook will be maintained by the transportation manager during transportation activities. The field logbook will serve to document observations, personnel on-Site, important transportation information, and other vital project information. The daily field logbook will document the following waste transportation details for each load that departs the Site:
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Date and time of loading; Vehicle identification; Truck driver name and trucking company name; Approximate weight of the load; Decontamination verification; Comments or remarks; Handling or the hazardous waste manifest; Type and quantity of waste in container/load; Destination and departure time; Instruction to truck drivers on record-keeping; Handling of hazardous waste manifest (signature, distribution of copies and
handling); Handling of Transportation Plan; and Handling of driving certificate, maintenance log and vehicle permits.
Each truck driver will be given a copy of this Transportation Plan, which includes complete instructions describing the route to each disposal facility. The Transportation Plan, trucking company’s Health and Safety Plan (HASP), manifests or bills of lading, and analytical results (profile) shall be kept by the truck driver in the cab of the truck with the driver. The driver will be responsible for handing over the manifest or the bill of lading to the disposal facility, at the disposal facility gate, for signature and processing by the disposal facility. 12. HEALTH AND SAFETY A site-specific HASP has been prepared for debris removal activities. Personnel working at the Site will be required to be familiar with the HASP. The HASP will be used for training purposes prior to the start of the project. Prior to transportation activities, the transportation manager will hold a health and safety meeting with all vehicle operators to thoroughly communicate the Transportation Plan and the HASP to the vehicle operators. Each vehicle operator will acknowledge their understanding of the plans by signing the attendance sheet. New truck drivers assigned to haul hazardous waste will go through the same procedures prior to being authorized to commence the work. Truck drivers hauling hazardous waste will have Health and Safety training in accordance with 29 Code of Federal Regulations (CFR) 191 0.120 and CFR Title 8 Section 5192. The drivers will be protected per level D and each will have a respirator available for upgrade to level C, if needed. On-Site personnel will not be allowed near the loading area to avoid unnecessary exposure to airborne dust and/or physical risks associated with movement of heavy equipment (loaders, etc.).
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13. CONTINGENCY PLAN Each waste hauler is required to have a contingency plan prepared for emergency situations (vehicle breakdown, accident, waste spill, waste leak, fire, explosion, etc.) during transportation of waste from the Site to the designated disposal facilities. Once the waste hauler is selected, a copy of their contingency plan will be attached to this Transportation Plan. Prior to transportation activities, the transportation manager will hold a kick-off meeting with all truck drivers to thoroughly communicate the Contingency Plan to the drivers. Each driver will carry a copy of the Contingency Plan in the cab of the truck and will be prepared to implement the tasks assigned to them. The transportation manager will communicate the Transportation Plan to emergency service organizations, law enforcement agencies, and transportation authorities that have jurisdiction along the proposed route. In case of hazardous waste release during transportation, the following shall be contacted by the driver:
911 if release originates on the highway (800) 852-7550 if release originates off highway (State Office of
Emergency Services) 911 Local Fire Department (415) 974-8132 EPA Regional Emergency Response Office, Region 9 (916) 255-6504 Department of Toxic Substance Control (DTSC) – Emergency
Response
REFERENCES 1. Zenco, 2007. Northern Drainage Debris/Asbestos Work Plan, Santa Susana Field
Laboratory, Ventura County, California. 10 September 2007.
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THE BOEING COMPANYSANTA SUSANA FIELD LABORATORYVENTURA COUNTY, CALIFORNIA
SITE LOCATION PLAN
SCALE: AS SHOWNOCTOBER 2007 FIGURE 1
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UNDEVELOPEDLAND
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LEGEND
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NOTE:ALL LOCATIONS AND DIMENSIONS ARE APPROXIMATE.
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S A N T A S U S A N A F I E L D L A B O R A T O R YDocument: LOX_AsbestosLocation.mxdDate: Oct 15, 2007 1 inch equals 500 feet
0 500 1,000Feet
Please Note: The original version of this figure includescolorized features and shading. A black and white copyof the figure should not be used because it may notaccurately represent the information presented.
SSFL - NORTHERN DRAINAGE LOX DEBRIS AREA
LOCATION MAP
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Base Map LegendSSFL BoundaryAdministrative Area BoundaryA/C CurbingDirt RoadRock OutcropElevation ContourDrainageNPDES Outfall
Extent of Asbestos Containing Material
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LEGENDROUTE FROM FORMER SHOOOTING RANGE / NORTHERN DRAINAGE TO THE MAIN GATEROUTE FROM NORTHERN GATE TO FORMER SHOOTING RANGEFORMER SHOOTING RANGE / NORTHERN DRAINAGEROAD
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TRANSPORTATION ROUTE DETAIL - INSIDE SSFL
THE BOEING COMPANYSANTA SUSANA FIELD LABORATORYVENTURA COUNTY, CALIFORNIA
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Santa Monica Mtns NraSanta Monica Mtns Nra
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THE BOEING COMPANYSANTA SUSANA FIELD LABORATORYVENTURA COUNTY, CALIFORNIA
TRANSPORTATION ROUTEDETAIL
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