2.1.1 Narrative
Since site work was halted last November, the USCG Pacific Strike Team and/or EPA's Contractor (Environmental Quality Management ) periodically pumped accumulated rainwater from sumps to 20,000 gallon storage tanks.
Over the course of the past three months, the ERRS Contractor (EQM) has developed a demolition work plan and a revised Health and Safety Plan (HASP). The demolition plan is necessary to achieve access to the corrosive sludge that remains in many of the tanks that once held the 3 million gallons of highly caustic pulping liquors. The demolition plan and HASP were reviewed, commented, discussed, comments incorporated, and approved prior to mobilization.
Due to the scope of work, potential risk of injury, and the injury incident last fall, this site has been scrutinized by every level of EPA Region 9 management. Several meetings were held as the revised HASP evolved.
In addition to the HASP activities, Realm Engineering was subcontracted to provide a stamped demolition plan to identify technical approaches to critical lifts and safe crane operations. Appropriate lift and hoist/demolition information developed was included in the RFP for Crane Operations.
Redwood Electric was subcontracted to confirm a Zero Mechanical State in the work areas. EQM’s Hazardous Energy Control Program (SOP HS-Fld-5) will be utilized as general guidance to establish safe operations as it pertains to Hazardous Energy Control. The HASP has been updated with the project specific Hazardous Energy Controls, LO/TO.
2.1.2 Response Actions to Date
27Mar2015: OSC Calanog met with CalOSHA and the ERRS contractor regarding the work-plan in Redding, CA. CalOSHA approved the plan after questions and discussion and advised that they would be visiting the site periodically.
30Mar2015: OSC Weden met with the ERRS Response Manager and ERRS Health and Safety Officer to review and prepare for extensive on-site health and safety training program.
31Mar2015: All ERRS staff and subcontractors received part one of their in-depth site specific health and safety training. Site specific hazards and work protocols were discussed, followed by a rigorous fall protection training session. This included hands-on harness donning and doffing and man-lift operation. Finally, a 40 question test was administered and discussed.
After lunch, the crew policed the site for slip, trip, fall, and flat tire hazards. Cleared areas of debris for safe tank demolition operations and began staging equipment.
01Apr2015: All ERRS staff and subcontractors received part two of their in-depth site specific health and safety training. A thorough review of confined space entry procedures was presented followed by a quiz and discussion. SHN o/s to take pipe insulation samples for asbestos analysis. Realm engineer o/s to review pick points and general tank demolition advice.
02Apr2015: Began removal of solidified sludge from Tank 9. Asbestos results received, all non-detect. Began sampling pipes in rack along tanks 140-142 and began removal of pipes. All liquids were carefully drained into totes for assessment. Stocked emergency supplies 4th floor of Recovery Boiler building in case of earthquake/tsunami evacuation.
03Apr2015: Solidified sludge removal from Tank 9 completed. Tank 9 was pressure washed following permitted confined space entry o/s mtg. Began removing sludge from Tank 8. Access hole cut into Tank 142 for assessment of remaining liquid over sludge. Began removing outer insulation on Tank 36.
04Apr2015: Continue to solidify sludge in Tanks 7 & 8 and adjacent concrete black liquor sludge containment #2. Completed removal of pipe rack along Tanks 140-142. Completed removal of outer insulation around Tanks 36-38. Sample obtained of sludge from ‘Lime Mud” Tank 19. HBHD requested that Tank 19 be left intact for future use. Sample also obtained from Sulfur Tank. H&S Officer conducted high volume air sampling around Tank 9 during cutting torch activity. Began pressure washing steel for re-use and continued storm water management and dust control onsite. Replaced tarps over solidified sludge due to rain forecast.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
On-going
2.1.4 Progress Metrics
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
Recycled |
Caustic liquids |
liquids |
2.7m gallons |
|
|
|
To date - 2.7 million gallons
Kapstone Paper Company, Longview, WA |
Sulfuric Acid - Re-usable |
liquids |
6k gallons |
|
|
|
Purchased by Valley Acid, Stratford, CA (11/13) |
Sulfuric Acid - Waste |
liquids |
4k gallons |
|
x |
x |
21st Century Environmental Management of CA, LP |
Hydrochloric Acid - Waste |
liquids |
2,100 gallons |
011138259 JJK |
x |
x |
|
Corrosive sludges |
semi-solids |
9k tons |
|
|
x |
Recology, Vacaville, CA
To date: ~300 tons |
Turpentine |
liquids |
3k gallons |
|
|
|
|
Lab Chemicals |
various |
~2k containers |
0000990296DAT |
x |
x |
21st Century Environmental Management of CA, LP |
"HHW" type |
various |
~2k containers |
|
|
|
|
Hg |
liquids |
Unk at this time |
|
|
|
|
Waste oils |
liquids |
~2k gallons |
|
|
|
|
|