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BELLS FLATS TR A BK 3 ALL - ZCP (2)• ZONING COMPLIANCE PERMIT cw• Permi $20.00 . Kodiak Island Borough, Community Development Department, 710 Mill Bay Road (Rm. 205), Kodiak, AK 99615 PH:(907)486-9362 Fax(907)486-9396 http://www.kib.co.kodiak.ak.us 1. Property Owner/Applicant: IR r Mailing Address: Z7,0,6- M, 13i., 1 roZ,Z e-le_ e. Phone: 4! 2. Legal Description: Street Address: 7r2 4 2 I Tax Code: W2133(2010 3. Description of Existing Property/Current Zoning: Minimum Required Lot Area: 26, erts6 0 44- Width: 7S AI-- Actual Lot Area:____2_13, 3 q 6- sq g4-- . 11-, 0676 A-etrec Width: Minimum Required Required Setbacks: Sides: 20 A- Rear: Front: 3 6 j2 J-- Maximum Building Height: Use and size of existing structures on the lot: as _J-- 42/ 6 %A.-CI SIC re,-1 Number & size of parking spaces required per parkinglsite plan dated: le/Kg en • e....'_1:1 0 / Iv 5 ,161,6.6,-.. cAcLee.,_ __ A-- ) r ! C4- S YV , i g a T c.,-) 0 -street loading requirements: / D' y 3 0 / x tg,c (. tackdAK Spe,<A, a P1at/subdivisioi related requirements (e.g. plat notes, easements, subdivision conditionedralnage plan review, etc.) - Other Requirements (e.g. zero lot line, additional setbacks, projections into yards, screening, etc) 5zil Ratiu.Z1z-4, a eu \?-.Ifyt :I 01,11-- CL la2.1r I 03. 0 1/..-< t;c_ • _ . tii.-12---5 vkit-54- L Ovi^ f)(6- (/;W p,,e-v--i-ty .-KA0,04LA_ s -c 3' c>.e.Ar- te.-16C..- I - . il . Ma Coastal Management Program Applicable Policies (check appropriate category) Residential Business • Industrial (./e Other Is the proposed action consistent wiij the KIB Coastal Management Program: No Attachment: Yes No , t Description of proposed action (attach site plan): Cl„ C 60irliv041-00 • c/v. • 4.41 cmteckcir, ebyo,e,e4a 'to 4-ee, rciivid • NACKemplates. vAR.4. t--;•4=eAktwst,40/ a insveze kftei-e ee. • 60:1&13eye Lfirrja- 4— P41/ s --La 4 A-Dcc, scPia OP4-4ze , .14Ar vole; td4 '7 r — I rlitij 2.002„ CDREG FIREG viA • Zojii0M9Enyliancyrs,iliiiiffee Zoning CET 15:00:53 PAID $20.00 HO Paid in Full *** Kodiak Island BoTough Kodiak AK 99615 (957) 06-9324 THIS FORM DOES NOT AUTHORIZE CONSTRUCTION WHEN A BUILDING PERMIT IS REQUIRED EXPIRATION: A zoning compliance permit will become null and void if the building or use authorized by such permit is not commenced within 180 days from the date of issuance, or if the building construction or use is abandoned at any time, after the work is commenced, for a period of 180 days. Before such work can be recommenced, a new permit must first be obtained. (Sec. 106.4.4 Expiration, 1997 UBC) per KIBC 17.03.060. 4. Other: Subd. Case #: A.J 4-- Plat #: IU iP Bldg Permit #: 5. Driveway Permit (State, Borough, City) by/date: 6. Applicant Certification: I hereby certify that I will comply with the provisions of the Kodiak Island * Borough Code and that I have the authority to certify this as the property owner, or as a representative of the property owner. I agree to have identifiable corner markers in place in the field for verification of s tb. cks. By: Date: 7 DA.4zatAt4 NA. of Supporting documen attached (check one). Sit Plan X As-Built Survey: Other (List): te ole /Ayr- of- ae&vr,4r-fry deuta 2or)2 _((zz) Title: u c_e_ tresi 8. Community D 7 lop en for zoning, By: 9. Fire Marshal (UFC) by/date: 10. Title: Date: ' db,da (_12-1&) cize 41 et7-0 11. Solid Waste Disposal Fee: Gross square footage Of building- 11,13— X 0.266 = ja_pue This permit is ONLY for the proposed project as described by the applicant. If there are any changes to the proposed project, including its intended use, rior to or durin • its sitin construction or o eration contact this office immediately to determine if further review and approval of the revised project is necessary. N:\CD\Templates\ComDev\ZONING C' ,IANCE PERMIT Permit.doc Solid Waste Disposal Fee 12/09/02 18:23 FAX 269 7508 Air and Water Quality 1 STATE OF ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION Division of Air & Water Quality Air & Water Quality Program * Telephone: (907) 2694059 Fax: (907) 269-7508 FAX Zion Aemi"mwmulemm;"'"Imilliniml"."4"."1"."11 TO VC FROM: • FAX: 9 3f C. Total pages including cover: • PHONE: Transmittal date: SUBJECT: Urgent For Review CC: Please conunen Please Reply *P ease Recycle ACOMMENTS IN SPACE BELOW: 1 TAL (Target Anaiyte List) 1 Al, Sb, Ba, Be, Ca, Cd, Cr, Co, Gu, Fe, Mg, Mn, Ni, k, Ag, Na, V, Zn 1 As, Pb, Se, TI 1 Hg 1 Name Metals Lists ICP GFAA CVAA RCRA 8 As, Ba, Cd, Cr, Pb, Se, Ag HQ PPL (Priority Pollutant List) 1 Sb, Be, Cd, Cr, Cu, Ni, Ag, Zn 1 As, Pb, Se, T1 t Hg PPL & TAL GFAA metals may be done by ICP in soils AANALYTICA Wax ractrAtrAttaroup.,can , ALASKA tr4C, compay tut 10 im W.Aye 6438,544vo crivo Atichgtr, DOSOI A.1( tra;101 (9071M-2155 MI Th0044 FAX (OW) 2.-53,66,34 FAX.: (907) 7SCI-MAD nsAttfloekt*SItt,nel Chain of' Custod ;2159 PW.Iptias gm's rtir«011.00 414t (K.469-844:11041.34717 41113**),Z1 Hecor WNW CIS Re uest RE .%4E Y g.Dritt 4:1 rSefV.: a Y.' REU1EO elt 'RECEe'VED • USE UN V- :;tirer. flikeroter 6A.77"7-- 4t' PAGE_ OF_ Attgarto Oft 121/ore4ViiiiiStvig ,0300;011.t, AK IA.KKII ALYTICA t1011238-215$ D4113*CtLT-it L A S K A i'NC, FAL M7) ZW634 FAX (907) 709,i679 (50) 49 I.Pw.F1M Ewa, toe gtiM tr4,46WsAtlla EIC ONSMOV iftww • • od Hecord / Ana uest 111,00;1101; Kigzi 4er4 REL/MintiEVE;Y: traturd: ftn&VIAltrir atlatfor ges /scansi /alac.jpg ://64.140.4.11 Air and Water Quality A-44- AilikANALYTIC K i4 A. .,42Ct ALASA IC. wmcartalimFic9m LAC ' 121241tominztimatit 1101g2r.0014241 L�N 26q.efilb 1203)46S,Enitit4-OrfOrir7 Chain of Custody -Helord Anal sis Re uest cmpangriorm K4-diz:T (44ACO (;‘) el i/ . , III .1111110111 47 elki(t 6 Vc.Q. CP/ S— WOW 117: PAI.Ktmbet 1 0 0 Ri p ..„,.. .........0,, 11111111111111111111111111111111111111111111111111111111111111111111111111111111111111. 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CO(C S 4'-a- c12",'‘ 9 / . _.5 • ' - . a 'Fame 0 Ent ' Col aaAncie ot'w ems a . Fcmiattot 4 0 :, R OENEORit RaitiOle 4 0 0 8Y: REOEIVF-ORY: ONL FibarteigitionmailaTrall - Y! Oaaorim diSamrdeOcritAmm lam Ranavaa -*C Voiabe MGM_ OF - vaw. naharlIrra , - . - rj a,- 9 st-i p, +es__ 266 — IC 3 v-c-geAd41 0 0 ttpJ /64.140.4.11 DEC -11 -02 WED 12:28 PM FAX NO. State of Alaska Department of Environmental Conservation 610 University Avenue Fairbanks, AK 9970:- YC P. 01 To: j)iuie L?rW .: //B Fax; C/� From: �� h�2 Phone, fsl-. i/� Date; Pages 3 , including this cover sheet Fax - (907) 451 -2188 E -Mail ..,@envircon.state.ak.us DEC -11 -02 WED 12:29 PM FAX NO P. 02 Alaska Department of Environmental Conservation Regulating Soil Remediation Burners (Soil Processing Inc.) December 2002 ADEC's responsibility is to cost effectively protect the public health and the environment by preventing, monitoring, and controlling emissions into the air and waters of the state. The Alaska Department of Environmental Conservation regulates soil retnediation burners, such as the Soil Processing Inc. (SPI) facility now operating in the Bell Flats area. Since SPI's start -up, questions have been raised and concerns expressed about the facility's compliance with Air and Water quality standards. The Alaska Department of Environmental Conservation (ADEC) has compiled this informational sheet to explain tests that were conducted at the facility and their results. How does ADEC determine whether a burner is in compliance with air and water quality standards? ADEC assures compliance by having the operator monitor and test in the following ways: • Source Testing • Sulfur Dioxide • Visual Emissions - Opacity • Carbon Monoxide, Volatile Organic Compounds, and Hazardous Air Pollutants • Have an approved Operation and Maintenance Plan Source Testing: Through source testing, particulate matter (such as dust, liquid droplets, excluding water) is measured from the exhaust stack while a facility is fully operating. Industrial processes and combustion devices in Alaska have to meet a particulate matter concentration standard and the particulate emission standard. Particulate matter may not exceed 0.05 grains per dry standard cubic foot (gldset), averaged over three lours (18 AAC 50.055(b)(1)). SPI's September 6, 2002 source test exceeded this standard with an average of 0.11 g/dscf. Facilities that do not pass a source test are usually asked to correct the problem and then retest within a reasonable time period (up to 45 days). As requested, SPI did this and passed the source test in November 2002, with an average of 0.027 g /dscf. ADEC officials were on site to observe the test to ensure that the source tester followed the detailed EPA- required method. Once a facility has passed a source test it is nol required to retest for 5 years. Sulfur Dioxide: Facilities in Alaska comply with sulfur dioxide emissions by burning fuel with low sulfur content, e.g. Number 1 or Number 2 diesel fuel. Since Alaska fuel is naturally low in sulfur, compared to fuel from other regions of the country, it is relatively easy for Alaska facilities to comply with Alaska's SO2 standards. SPI was found to be in compliance with Alaska's SO2 standards. Visible Emissions -- (Opacity): Opacity is the reduction in visibility, usually caused by particulate matter in the air. SPI is required to take routine visual emission readings, at !cast once during a 30 -day operating period or within two days of a startup at a new location. The state opacity standard from an exhaust stack cannot reduce visibility of light by more than 20 %, excluding steam. SPl passed the opacity test with no problems; they had about 0% opacity, which is perfect. Carbon Monoxide, Volatile Organic Compounds, and Hazardous Air Pollutants: In September 2002, SPI tested the accuracy of their carbon monoxide (CO) Continuous Emissions Monitor (CEM). A review of this test data is currently ongoing and issues concerning this monitor will be followed up at a later elate. The current permitted limit for CO is 100 parts per million corrected to 7% oxygen during operation and shut down operations. DEC -11 -02 WED 12 :29 PM FAX NO P, 03 The permitted CO limit and the required (minimum) exhaust temperature are monitored as surrogates to determine that complete combustion is occurring and other volatile organic compounds (VOCs) and hazardous air pollutants are not being emitted in significant concentrations. Operational Monitoring Records are required for: • tons of soil processed and maximum hourly rate • average fines (dust) of soils processed (usually test once per Job) • scrubber temperature and pressure drop • amount of water sprayed into scrubber to control dust • amount of fuel consumed • CO monitor and calibration records • afterburner exhaust stack temperature • maintenance/inspection log • results of source test within the last live years • results of visual emissions observation upon startup and 30 days of operation in same location ▪ smoke/no smoke visual emissions observed for electric generation engine • complaint logs It should be noted that SPI is not required to submit a report for every item they monitor for but must keep records of the information (fbr five years) and be able to provide it to ADEC if requested. Water Requirements. A wastewater discharge permit is required for SPI's recirculating settling pond. Due to the naturally occurring metals commonly found in groundwater, and the possibility of concentrating these metals in the wastewater stream, SPI was required to test for the presence of metals in this wastewater prior to discharge to the groundwater, a potential source of drinking water for the arca. The metals tested for are the primary metals found in the drinking water standards (18AAC 80). SP1 is required to test their discharge water and be below the maximum contaminate levels (MCL) for drinking water prior to their discharge. Metals, MCL's and the levels found in SPI's wastewater are listed below; Metal MC1, (Standard) Wastewater levels (Measured_) Units Antimony 6.0 3,47 micrograms /liter Arsenic 50 23.2 Barium 2000 13.7 • Beryllium 4 nondetect • Cadmium 5 nondetect Chromium 100 1.34 " Mercury 2 nondetect • Nickel 100 1.46 • Selenium 50 14.9 " Thallium 2 0.0878 • All measured levels for these regulated metals at SPI were well below the regulated MCL's for drinking water. For more information about these tests or others concerning the SPI facility, contact: Bill Smyth (907) 451 -2177. FROM : R.HOLMES JOHNSON LIBRARY FAX NO. : 9074868681 Oct. 09 2002 05:44PM P1 Kodiak Island Borough Community Development Department Zoning Violation Complaint. Form I wish to report an alleged violation of the Borough's zoning regulations. I understand that this complaint will be investigated within 7 days of its receipt, and that 1 Mil be notified of any subsequent action taken regarding the investigation. Legal Description of Property Where Violation is Occuring: Zoning Street Address Property Owner of Above Property Tenant of Above Property (If Applicable) (Name & Meiling Address) Brechan Enterprises Batch Plant on Saimonberry Drive Telephone: Telephone ECEIVE OCT 1 0 2002 COMMUNITY DEVELOPMENT DEPARTMENT FROM : A.HOLMES JOHNSON LIBRARY FAX NO. : 9074868681 Oct. 09 2002 05:45PM P2 Complaint: • October 2, 2002 a Wednesday, rolling clouds (the size of a houses), blue-gray in color boiled up through the neighborhood from Brechan's batch plant and visited me at my house. I opened the door and was knock back buy the smell. It was a beautiful day and I had intended to finish planting my fall garlic crop. The fumes were so noxious that I was prevented from going out in my yard or opening a window. Fumes in my yard were as strong or stronger then walking into a sealed one car garage'with a car running in it. Bob Hale with Brechan spoke with me on the phone and admitted a burner kept going out causing him to stop and restart the batch plant....which according to him is what really generate .s the exhaust. This was the 3'15 Wednesday that I was home and experience this kind of pollution (smoke, exhaust, gasses, odors etc.) My first Wednesday experience with it was waking in the morning with my house full of exhaust. It was summer, my bedroom windows were open and I woke ill. Extreme headache. I ran to the basement thinking my own furnace had malfunctioned. I found the basement clear and then noticed my yard was full of a blue-gray haze. Same grilell as previously described. I was trapped I couldn't clear my house as open windows had let it in! A date can be supplied upon request as a neighbor telephoned DEC about it the same day and logged the call. My neighbors and I have suffered tremendously this summer with Brechan and SPI generating Noise, Smoke, Fumes, Odors, Steam, Gases etc. According to KIB 1724.060 Performance standards for Businesses operating in Industrial Zoned properties. I will quote: D. Odor. Uses causing the emission of obnoxious odors of any kind and the emission of any toxic or corrosive fumes or gases are prohibited . E. Dust and Smoke. Dust and smoke created by industrial operations shall not be exhausted into the air in such a manner s to create a nuisance. McGraw Hill Encyclopedia of Science & Technology tells me water has a gaseous state called steam. It also defines toxins as chemicals and physical agents that have harmful effects on living systems. Corrosion is the destruction, degradation or deterioration of material due to the reaction between the material and it's environment. Websters defines obnoxious as "harmful or merely unpleasant" . Nuisance is defined as "harmful, or annoying, or merely unpleasant" Brechan's Technical assessment for the Drum Asphalt plant calculates 30 tons of Sulfur Dioxide emissions in a year. Websters defines Sulfur Dioxide as a "heavy pungent toxic gas....and a major air pollutant especially in industrial areas." This is only one of the toxic/corrosive emissions mentioned in the technical assessment. Brechan/SPI are guilty of violating D & E ofICIB 17.24.060 every time they operate because they have an obnoxious odor (prohibited by D.) and Sulfur Dioxide is toxic & corrosive and is being plumed in gas & fume emission (again prohibited by D.) Under E. FROM : A.HOLMES JOHNSON LIBRRRY FAX NO. : 9074868681 Oct. 09 2002 05:45PM P3 I and my neighbors find their smoke a nuisance. (smoke is defined in Webster s as "....fume and vapor often resulting from the action of heat on moisture") I expect relief under your code aside from any pending lawsuits from The Women's Oay Council. I reject any attempt to defer to DEC or other regulatory agencies as I do not see in your code that you deferring to their measurements and standards. Respectfully, Lisa Booch Complainant (Name & Mailing Address): Staff Accepting Complaint: Date Signature: CAWINDOWSVremporary Interact Filcs1ContamIEME11)21)NVJVcrning Viointion Complaint.doc Kodiak Island Borough Community Development Department 710 Mill Bay Road Kodiak, Alaska 99615 Phone (907) 486-9363 Fax (907) 486-9396 www.kib.co.kodiak.ak.us Monday, October 28, 2002 VIA REGULAR MAIL RE: Bells Flats Alaska Subdivision Block 3 Tract A / 224 Salmonberry Drive Applicable Zoning District: I - Industrial Zoning District (Kodiak Island Borough Code 17.24) Ms. Lisa Booch Post Office Box 2619 Kodiak, AK 99615 Dear Ms. Booch, This letter is in response to the written complaint received in the Community Development Department by FAX at 5:45PM on October 9, 2002. The complaint was date stamped received in the department the next business day on October 10, 2002. The complaint alleges that the conduct of current land use activities on the property described above violate certain sections of the Kodiak Island Borough Code. Specifically, allegations are made that the day-to-day operation of the asphalt batch plant, operated by Brechan Enterprises, is not in compliance with the performance standards listed in Kodiak Island Borough Code 17.24.060.D —Odor, and 17.24.060.E — Dust and Smoke. The complaint was submitted to this department a substantial amount of time after the events were alleged to have occurred. Due to this passage of time, staff was not in a position to independently verify the allegations by first person observations. The Kodiak Island Borough's complaint enforcement policy calls for a review of the file of the property during the initial investigative stage. The purpose of the review is to establish whether any previous complaints of a similar nature had been recorded for the property in question. The record for this particular property covers a time period of approximately thirty (30) years. Staff can find no prior record of complaints regarding air quality issues for the property in question. However, our property record file does contain letters of compliance issued by the Alaska Department of Environmental Conservation, Division of Air and Water Quality, Air Permits Program. These letters are dated September 26th and September 27th 2002, and report the latest available findings for the soil remediation facility (SPI) and the asphalt batch plant (BEI) respectively. "...the facility(s) appeared to be operating in compliance with state and federal requirements at the time of the evaluation." The only caveat noted in the report(s) was a problem of fugitive dust, of which, the reviewer also credited Brechan employees for moving expeditiously to address. \\Dove\Users\mlydick\word\Zoning Violations\Complaints\Bells Flats Bk 3 Tr A Booch Response.doc10/28/02 Page 1 of 3 Locally adopted, i.e., enforceable, performance standards contained in Kodiak Island Borough Code 17.24 — I - Industrial Zoning District must be interpreted with reference to Kodiak Island Borough Code 17.24.005 — Description and Intent. Contained therein are the words... "land uses...which may create some nuisance." The department believes that the citations (KIBC17.24.060 (D) and (E)) you use to indict the land users in this instance may have been inappropriately interpreted. The department believes restrictions regarding odor, dust, and smoke as contained in KIBC17.24.060 should not be interpreted so as to mean "Zero Tolerance." Zero tolerance, if applied literally, would mean that occasional and intermittent transgressions due to equipment startup, temporary mechanical failure, and or breakdown, would be an actionable cause leading to the possible closure of a facility of uncontested value to the community at large. Such an interpretation would contravene the intent wording cited above, and would impose a technological burden that even the most advanced federal agencies have been unable to attain at a reasonable economic cost. The terms "obnoxious" and "nuisance" which you employ, and artfully define, in your complaint are indeed used in the performance standards incorporated in KIBC 17.24. However, these terms are so inherently subjective that any number of reasonable people may disagree as to when the threshold of applicability is reached. Based upon the Community Development Department's review of the property record file, the latest available third -party observations, findings, and reports, and the analysis above, the Community Development Department finds that no actionable cause, sufficient to compel this department to issue a Formal Notice of Complaint for violation of zoning district standards, exists for the incidents as related in the complaint dated October 10 ", 2002. In the event that you disagree with this administrative determination, you have the right to appeal this decision per Kodiak Island Borough Code 17.75.030 — Penalties and Remedies, which reads in part: 1 B. Notwithstanding the availability of any other remedy, the borough or any aggrieved person may bring a civil action to enjoin any violation of this title, any order issued under subsection 17.75.010(A) of this chapter, or any term or condition of a conditional use, variance or other entitlement issued under this chapter; or to obtain damages for any injury the plaint suffered as a result of a violation. An action for injunction under this section may be brought notwithstanding the availability of any other remedy. Upon application for injunctive relief and the finding of an existing or threatened violation, the superior court shall enjoin the violation. \ \Dove \Users\mlydick \word\Zoning Violations \Complaints\Bells Flats Bk 3 Tr A Booch Response.docl0/28 /02 Page 2 of 3 Respectfully, Martin Lydick, Associate Planner_Code Enforcement Kodiak Island Borough Community Development Department Cc: Duane Dvorak, Director, KIB / CDD Patrick S. Carlson, Manager, KIB MB Planning & Zoning Commission Brechan Enterprises, Inc. Soils Processing, Inc. via email File. Move\Users\mlydick\word\Zoning ViolationsTomplaintsWells Flats Bk 3 Tr A Booch Response.doc10/28/02 Page 3 of 3 10/25/2002 FRI 14:57 FAX 907 222 2760 JESM -s-* -, KIB JAMIN, EBELL, SCHMITT & MASON 1007 W. Third Avenue, Suite 201 Anchorage, Alaska 99501 (907) 278 -6100 Fax: (907)222 -2760 lj 001 /oo5 FAX TRANSMISSION COVER SHEET Date: October 25, 2002 To: Pat Carlson, Manager Kodiak Island Borough From: Sheila Miller Re: Soil Remediation Our File No. 4702-826 Phone Fax: Original mailed: yes _no x YOU SHOULD RECEIVE 5 PAGES, INCLUDING THIS COVER SHEET. IF YOU DO NOT RECEIVE ALL THE PAGES, PLEASE CALL (907) 278 -6100. This transmission is intended for the sole use of the individual and entity to whom it is addressed, and may contain Information that is privileged, confidential, and exempt from disclosure under applicable law. You are hereby notified that any dissemination, distribution, or duplication of this transmission by someone other than the intended addressee or its designated agent is strictly prohibited. If your receipt of this transmission is in error, please notify this firm immediately by collect call to (907) 278 -6100, and send the original transmission to us bV return mail at the above address. REMARKS: Attached for your review is a letter dated October 24, 2002, from Greg Oczkus, t4 R E + .b -- -__..7 OCT 242002 __ �L, MNA F I 10/25/2002 FRI 14:57 FAX 907 222 2760 JESM 444 KIB U002/005 JAM1N, BELL, SCHMITT & MASOti A professional Corporation Greg Oczkus Law Offices 430 W. 742, Suite 202 OCT 2 5 200Z Anchorage, Alaska 9950.1 Phone-276-6550 Fax-258-6902 ANCHORAGE, ALASKA M Gregory Oczkus M. Jane Pettigrew October 24, 2002 Via Fax # 222-2760 Walter C. Ebell Attorney at Law 1007 W. 3rd, #201 Anchorage, AK 99501 Re: Soils Processing, Inc. Soil Remediation Equipment Dear Sir My office has represented Soils Processing, Inc and its owner, George Cline, for approximately 12 Years. I am aware of the complaints of th.e residents of Woman's Bay and the reporting of the Kodiak newspaper. I believe that there are important facts about this machine that you should know. The machine is designed using asphalt plant technology The technology is based upon the introduction of materials and heat into a rotating cylinder. In an asphalt plant, rocks and sand are heated to 400 degrees Fahrenheit in a rotating cylinder and then transferred to a dug mill where asphalt and oils are introduced and mixed with the heated material. The material is then delivered to the road for paving. SPI's soil remediation unit is a sophisticated improvement on this technology. In the SPI equipment contaminated soils are introduced into a rotating drum and heated to 1019 degrees Fahrenheit Secondary gases are then removed and heated in a second chamber to 1730 degrees Fahrenheit. The heated soils are disgorged from the machine to cool. The gases in the secondary chamber are converted to distilled steam. 10/25/2002 FRI 14:57 FAX 907 222 2760 JESM -+-+ -► RIB ►1009 /005 Walter C. Ebell October 24, 2002 Page 2 Over the past 12 years the equipment has been substantially modified and improved over its original design. The drum where soils are heated has been lengthened and its diameter expanded. This permits more retention time for the soils to be heated and made cleaner. This equipment has an enhanced secondary chamber where the off gas is cleaned. Off gas is hydrocarbons . and gases which did not burn in the rotating heat chamber. The equipment has the capacity of 12 tons per hour depending on the condition of the soils, The Kodiak soil is so laden with oil, asphalt, and moisture that the machine is operating at approximately 5 -6 tons per hour, It is necessary to slow down the process because the soils need more retention time in the primary combustion chamber. The remediation processing is computer regulated. A technician sets the required temperatures in order to remediate the contaminated soils. Both the final product and the waste products are continually monitored. After every 500 tons an independent third party sampler sends a sample to the lab to verify cleanliness and absence of contaminants. The secondary combustion chamber is monitored by a continuous emissions monitor (CEM) which tests the air every 10 seconds and maintains a continuous computer record of chamber activity. DEC specifications limit contaminants to 100 ppm in a one -hour period. Soil Processing's emissions on this project range from 5 to 40 ppm. As a point of comparison, one burning cigarette cam range from 500 to 1500 ppm. The successful goal of the secondary combustion chamber is to reduce the gases to pure water (steam). In order to accommodate the residents near Woman's Bay, SPY purchased and installed special beat resistant, sound absorbing material around the combustion chamber. The crusher was also enclosed with sound absorbing materials. The equipment operates at less than 40 decibels. Soil Processing stopped production for three (3) days to install this accommodation which cost about $7,000 in labor and materials. 10/25/2002 FRI 14:57 FAX 907 222 2760 .TESM 444 KIB Walter C. Ebell October 24, 2002 Page 3 Soil Processing has scheduled delivery of material so that the trucks run approximately six (6) out of every 21 days. This was done to minimize the impact on the residential area. The three (3) 10,000 gallon propane tanks are DOT approved tanks for LPG. They have special safety features: automatic shut off valves; one quarter turn emergency safety valves; and fusible links. The links are lead which will melt and automatically shut down the system if a human is unable to approach a fire. These LPG tanks are inspected by the State of Alaska/DOT annually and whenever the tanks are moved. They were inspected before transportation to Kodiak. Every five (5) years the tanks under go hydrostatic testing internally and externally at Suburban Propane. U.S. Coast Guard approved the tanks before then were placed on the barge. The Kodiak fire marshal inspected the tanks and all in -line connections and valves while at the site. The company has never had a problem with a fire. There has never been an explosion or a fire on the project. The company has never had a worker's compensation claim and have over 200,000 man -hours without lost time due to accident. IJ 004/005 This equipment has worked on the North Slop for ARCO-Phillips and in Cook Inlet for Unocal. It operated in Valdez within 200 feet of the tank storage area. The equipment has been inspected on numerous occasions by the oilfield safety inspectors and specialists Soil Processing crews have all graduated from fire protection classes while on the North Slope.. While this equipment has been in Kodiak it has been inspected by the U.S. Coast Guard, the State of Alaska/DOT and the FAA while at the Kodiak airport. Last year the company received the US Army Corps of Engineers' small - business safety award. 10/25/2002 FRI 14:58 FAX 907 222 2760 JESM 444 KIB 0005/005 Walter C. Ebell October 24, 2002 Page 4 I believe you and the Kodiak Borough should have this information. The local newspaper has never asked to see written specifications concerning the equipment or the technology. I believe people should be advised of how safe this equipment is and how sophisticated it has become over the past 12 years. All statements in this letter can be verified. MGO:as cc: Client FAClint1Kcaliaka4serslEbell Sincerely, M. Greco DIVISION OF AIR AND WATER QUALITY AIR PERMITS PROGRAM September 27, 2002 W. E. Oliver Vice President Brechan Enterprises, Inc 2705 Mill Bay Road Kodiak, Alaska 99615 610 University Avenue Fairbanks, AK 997093643 Phone: (907) 451-2360 FAX: (907) 451-2187 http://www.state.ak.us/dec/home.htm ADEC File No: 900.16.005 Certified Mail Return Receipt Requested Re: Air Quality Compliance Evaluation for Brechan Enterprises, Inc Air Quality General Permit (GP) Number 332GP301 Dear Mr. Oliver: The purpose of this letter is to present you with the Department of Environmental Conservation's (Department) air quality compliance evaluation findings for Brechan Enterprises, Inc (BEI). On September 19, 2002 an air quality compliance evaluation and inspection was conducted at the BEI asphalt facility located in Bell Flats on Kodiak Island. Based on an pre-inspection review of BEI file documents, an interview with the BEI facility manager Bob Hales, a visible emission observation, and inspection of the facility while in operation, and a on-site facility records assessment, the facility appeared to be operating in compliance with state and federal requirements at the time of the evaluation. However, it should be mentioned that an excessive amount of fugitive dust was coming from the reject loadout area during operation. Mr. Hales and I discussed this concern and a method to eliminate the issue was determined. When I was leaving the facility I noticed that the Brechan Enterprises employees were working on an water misting manifold for the end of the conveyor system, at the reject loadout area, this remedy should eliminate the fugitive dust issue. The Department would like to thank Mr. Hales and the BEI employees for the courtesy, hospitality, and cooperative attitude extended during the on-site air quality compliance evaluation. The compliance evaluation and attachments have been enclosed for your files. If you should have any questions, please call me at (907) 451-2149. Sincerely, Randall E. Lucas Environmental Engineer Air Quality Inspector Compliance Services Attachments cc: Jim Baumgartner, ADEC/APP, Juneau Cynthia Espinoza, ADEC/APP, Anchorage John Pavitt, US EPA, Anchorage Don Dossett, US EPA Region X, OAQ-107 Patrick S. Carlson, Tom Chapple, ADEC, Anchorage Kodiak Borough Manager 710 Mill Bay Road Kodiak, AK. 99615 Facility Name: Physical Location: Permittee: AIR QUALITY COMPLIANCE EVALUATION REPORT AS 46.14.515 Brechan Enterprises, Inc. (B 57 42' North 152 34' Salmonberry Road Bell Flats Kodiak, Alaska Brechan Enterprises, Inc. Mailing Address: 2705 Mill Bay Rd. Kodiak, AK 99615 Facility Compliance Officer: Mr. Randall E. Lucas Inspector: Mrs. Beverley Williams Facility Representative: Mr. Bob Hales AQ Title V Permit Number: A000332 AQ Permit file Number: 900.16.005 On -Site Full Compliance Evaluation This air quality full compliance evaluation was citizen - complaint driven and included both facilities of BEI and Soil Processing, Inc. A facility odor determination and a visible emission observations (VE) were performed at each facility. The facility odor determinations, over three consecutive days, September 18 to September 20, 2002, showed no unusual odors at both the BEI and Soil Processing, Inc. sites The original BEI Cedar Rapids model #17251 batch plant was permitted under air quality control permit to operate #9425- AA006. This unit was rated at 250 tons per hour. The BEI facility is located in a industrial zoned area, and has been in its present locale in Bell Flats on Kodiak Island since about 1975. Based upon the April 30 to May 2 source testing the BEI facility operates only about 50 days per year, at about 180 tons per hour with the new wet scrubber unit and 170 tons per hour with baghouse in line. BEI applied for approval to operate a Cedar Rapids asphalt plant under General Permit #3 (GP3) on February 2, 1998. Authorization to operate under this GP3 was granted December 30, 1998. On March 27, 2001, BEI applied for a construction permit for the new AESCO/MADSEN model DM 7228 Hot Mix Asphalt Plant. Construction Permit 0125 -AC007 was issued June 22, 2001. The new BEI AESCO /MADSEN drum mix asphalt plant is equipped with a wet scrubber to control emissions. After a few days of operation at the Kodiak airport, in the summer of 2001, BEI moved the facility back to their property in Bell Flats, and reassembled the unit. In March 2002, BEI applied for a new General Permit and was assigned a GP -3, permit number 332GP301, for the AESCO /MADSEN Cedar Rapids 7228 drying drum hot mix asphalt plant. This permitted set -up includes the construction permitted new AESCO /MADSEN model DM 7228 Hot Mix Asphalt Plant, permitted under Construction Permit 0125- AC007, and the originally permitted drying drum with attached baghouse (only used as a dryer - not the mixer capability) from Cedar Rapids model #17251 batch plant. The exhaust from the pre- drying process baghouse and the exhaust from the wet scrubber were source tested independently by AM Test -Air Quality, LLC of Preston, Washington from April 30 -May 3, 2002. The source tests conducted on the baghouse exhaust were three (3) 60- minute tests, EPA Reference Methods 1, 2, 3A, 4, and 5. Results averaged over three (3) sample runs from the Particulate Matter (method 5) tests were 0.0026 grains per standard cubic foot (gr /dscf) on the baghouse exhaust stack. The wet scrubber exhaust stack averaged over three (3) sample runs was 0.0243 gr /dscf. The State of Alaska particulate matter emission standard is 0.04 gr /dscf. In conjunction with the source testing, EPA Method 9 visible emissions (VE) opacity observations were performed by a certified visible emission observer, from the independent source test company, during each of the Method 5 exhaust stack tests. The average opacity observed at the baghouse exhaust stack was seven (7) percent. The average opacity observed at the wet scrubber exhaust stack was twelve (12) percent. The State of Alaska opacity standard (limit) is 20% opacity. At the end of my full compliance evaluation on Thursday, September 19, 2002, I conducted a 12 minute VE observation with 0% opacity readings from the continuous exhaust stack plume. See attached VE observation form for details. Evaluation Summary: Based on the pre- inspection document review, past facility operating reports, on -site facility records assessment, an interview with the BEI facility manager Bob Hales, visible emission observation, and inspection of the facility while in operation, the facility appeared to be operating in compliance with state and federal requirements at the time of the evaluation. It should be mentioned that an excessive amount of fugitive dust was coming from the reject loadout area during operation. Mr. Hales and I discussed this concern and a method to eliminate the issue was determined. When I was leaving the facility I noticed that the Brechan Enterprises employees were working on an water misting manifold for the end of the conveyor system, at the reject loadout area, this remedy should eliminate the fugitive dust issue. DIVISION OF AIR AND WATER QUALITY AIR PERMITS PROGRAM September 26, 2002 Ms. Jennie D. Sharpe CEO Soil Processing, Inc. 207 E. Northern Lights Blvd., Suite 103A Anchorage, Alaska 99503 610 University Avenue Fairbanks, AK 997093643 Phone: (907) 451-2360 FAX: (907) 451-2187 http://www.state.ak.us/dec/home.htm ADEC File No: 900.16.082 Certified Mail Return Receipt Requested Re: Air Quality Com`pliance Evaluation for Soil Processing, Inc Air Quality General Permit (GP4) Number A000204 Dear Ms. Sharpe: The purpose of this letter is to present you with the Department of Environmental Conservation's (Department) air quality compliance evaluation findings for Soil Processing, Inc (SPI). On September 19th and 20th, an air quality compliance evaluation and inspection was conducted at the SPI soil remediation facility, presently located at the Brechan Enterprise, Inc. property in Bell Flats on Kodiak Island. Based on a review of SPI file documents, an interview with the SPI facility operator George Cline, two visible emission observations (on two different days), and inspection of the facility, and a on-site facility records assessment, the facility appeared to be operating in compliance with state and federal requirements at the time of the evaluation. The Department would like to thank Mr. Cline and the SPI employees for the courtesy, hospitality, and cooperative attitude extended during the on-site air quality compliance evaluation. The compliance evaluation and attachments have been enclosed for your files. If you should have any questions, please call me at (907) 451-2149. Attachments cc: Jim Baumgartner, ADEC/APP, Juneau John Pavitt, US EPA, Anchorage Jim Frechione, ADEC, Kenai Tom Chapple, ADEC, Anchorage Sincerely, Randall E. Lucas Environmental Engineer Air Quality Inspector Compliance Services Cynthia Espinoza, ADEC/APP, Anchorage Don Dossett, US EPA Region X, OAQ-107 Patrick S. Carlson, Kodiak Borough Manager 710 Mill Bay Road Kodiak, AK. 99615 Facility Name: Physical Location: (at time of evaluation) Permittee: Mailing Address: AIR QUALITY COMPLIANCE EVALUATION REPORT AS 46.14.515 Inspector: Facility Representative: AQ GP 4 Permit Number: AQ Permit file Number: Soil Processing Inc. (SPI) Salmonberry Road Bell Flats Kodiak, Alaska Soil Processing, Inc. 207 E. Northern Lights Blvd., Suite 103A Anchorage, Alaska 99503 Mr. Randall E. Lucas Mr. George Cline, Facility Operations Manager A000204 900.16.082 Facility History and Facility Qualifying Criteria The Soil Processing Incorporated (SPI) soil remediation unit is a portable unit and is permitted under an Alaska Department of Environmental Conservation (ADEC) Air Quality General Permit 4 (GP4) number A000204. The SPI facility, which is presently located on Salmonberry Road, at the Brechan Enterprises,Inc. property in the Bell Flats area, on Kodiak Island. The SPI unit was assembled and in full operation on the dates of the evaluation. The qualifying criteria for a soil remediation facility approved to operate with this ADEC Air Quality general permit (GP -4) is described by SIC code 1629. Alaska law requires operators of soil remediation units (SRU) to obtain an operating permit if the plant meets any of the following criteria: • a potential to emit greater than 100 tons per year of a regulated air contaminant, • a source with a rated capacity greater than 100 Million BTU/hr, • a controlled source with a total rated capacity or equipment throughput greater than 5 tons per hr, • a controlled source with a rated capacity greater than 50 Million BTU /hr, or • equipment subject to a federal emission standard, such as rock crushers. The SPI facility is permitted to remediate contaminated soils that have crude oil, liquefied natural gas, gasoline, fuel oil, and other non - chlorinated refined petroleum products. The facility is prohibited from burning soil contaminated with hazardous waste listed under the Resource Conservation and Recovery Act (RCRA) or toxic substances listed under the Toxic Control Act (TSCA). Inspection — Facility Site Visit and Evaluation Summary: This air quality full compliance evaluation was citizen - complaint driven and included both a facility odor determination and two visible emission observations (VE). The facility odor determination showed no unusual odors on three different days at the SPI site. The VE's showed essentially all continuous exhaust steam plumes and zero percent opacity over the 10 and 15 minute observations (see attached VE observation forms). On Thursday and Friday, September 19th and 20th, I met with Mr. George Cline, the SPI facility manager and operator, for my facility evaluation. The SPI remediation unit was fully assembled and operating on September 18, 19 and 20th, 2002, the days of the evaluation. On September 18, 2002, I drove to the SPI facility unannounced to conduct odor and VE observations. During the evaluation, at the SPI facility, I went over the SPI GP4 permit condition by condition. I also observed during the evaluation that the SPI facility emission control device was a wet scrubber and that the cooling pond was of proper size and was fully lined. I noted that the facility is operated by propane gas. I looked at the SPI facility daily operating logs, and discussed the September 5, 2002, Particulate Matter (PM) and Certified Emission Monitor System (CEMS) C0 /02 monitor relative accuracy tests, including permit required daily calibration checks. Recent discussion with the independent source test company indicated the results of the SPI facilities PM source tests and CEMS RATA conducted on September 5, 2002, were within permit requirements. Recent soil analyses, required by permit, by an independent laboratory, showed that five independent soil analysis were done at SPI. All results showed post - remediation detects of zero on the chemical characterizations. Based upon the in -office SPI records, including the last facility operating report for July 2001 through July 2002, and SPI file review, on -site evaluation, including VE observations and document review, at the time of evaluation, there are no apparent compliance issues. FILE COPY Alaska Department of Environmental Consery Bells Flats, Kodiak Island : Questions & Answers January 2003 I. Department oversight of soil treatment facilities an Why did the department allow these facilities to operate? Soil treatment facilities and asphalt plants both provide vital services to the community. When operating in compliance with permits, these facilities pose little threat to public health or the environment. DEC permitted these facilities because it believed, and continues to believe, the facilities can operate in compliance with air quality requirements. The asphalt plant has operated where it is and how it is for years. Why is the department concerned now? DEC is concerned because a recent modeling analysis indicates that emissions from Brechan and SPI could possibly cause violations of ambient air quality standards. This analysis was not conducted when the asphalt plant was initially permitted. Although assumptions used in the model likely result in higher predicted values than actually would occur, DEC is taking a closer look at the analysis. Additional controls will be required if necessary to address the department's concern. Why does Brechan have to bear the expense of investigating this issue when other plants operate throughout the state without such investigation? As provided for in 18 AAC 50.201, once DEC determines that a facility's emissions are likely to cause a violation of an ambient air standard it can require the facility to further investigate the impact of their emissions on air quality. DEC has not made a similar determination for other facilities. Will these facilities be allowed to operate this summer? Yes, the facility will be able to operate under conditions that reasonably assure DEC that pollution will not exceed the ambient air quality standards. DEC will establish these conditions as provided for in 18 AAC 50.201. Why can't the SPI plant be moved to someplace else where people don't live right next door? DEC cannot require SPI to relocate. If SPI were to relocate, it would have to find a suitable location that met local zoning requirements. At what point is the state simply going to pull the permits for one or both of these operations? DEC will take ineagures.to pull,nr teiminate facility permits when it determines that operations cannot be conducted in a manner that allows compliance with ambient air quality standards, or when facilities become uncooperative and continuously violate or ignore permit terms and conditions. DEC has:no immediate plans to terminate either Brechan's or SPI's permit. DEC may-rnodifY:Onelorgopi of the permits to address concerns resulting from the modeling anabrsis. LI How will DEC engiii.e,the facility operates in compliance? The department,willleoiiitnue to monitor facility operations by reviewing the facility's operating reports,source test information and other information that Comes into its possession, including that provided-by'crit4ens:DEC will physically inspect each facility's operation when it -det'ennines:arin4eaiOniS warranted to gather additional information. DEC is not here on a day-to-day basis. What are citizens supposed to do when these plants have air pollution incidents? Citizens are encouraged to document and report problems to DEC. It is true that the department cannot provide a day-to-day presence in Kodiak; It is also true that the department will unlikely travel to Kodiak to investigate each and every complaint received. DEC will, however, investigate each complaint to the best of its ability when the complaint is received. To contact DEC: Write to: Bill Smyth, Alaska Department of Environmental Conservation 610 University Avenue, Fairbanks, AK 99709 Email: bill_smyth@envircon.state.ak.ts Call (907) 451-2177 or Fax (907) 451-2188 II, Last Year's Issues Did SPI or Brechan violate their permits last summer? Yes, a source test conducted by SPI on September 6, 2002 indicated that SPI was in violation of their permitted particulate matter emission limit. They reported this finding to the department and voluntarily ceased operations until repairs were made and an additional source test confirmed they were in compliance. Following the source test, facilities have 45 days to complete an analysis of the test and submit a report to the department. When SPI's consultant notified them that they failed the source test, SPI notified the depai talent and submitted the report as required. What did DEC do about it? DEC reviewed the source test report and confirmed a violation existed. The department then sent SPI a Notice of Violation and requested that they cease operations until repairs were made and the source test repeated. SPI voluntarily complied with the department's request. The test was repeated November 9 — 11, 2002, during which a depai tment inspector was present to ensure the test was conducted properly. The test showed SPI to be in compliance. Did the dust on the ponds last year come from SPI's facility? Results as to where the dust came from are inconclusive and it may not be possible to reach a conclusion as to its source and content. -2- Did the dust on the ponds affect public health? There is no evidence that it did. Did Brechen or SPI get fined for the dust fall -out event in November? If not, why not? No, neither facility was fined for the reported November dust fall -out. DEC has been unable to confirm thus far that dust found on ponds and puddles in November was the result of either facility's operation, or that an actual violation occurred. In addition, DEC does not have administrative penalty authority. The courts must either impose fines or facilities can agree to penalties as part of an out -of -court settlement with the department. Pollution last summer was intolerable. Will DEC let last summer be repeated? What will DEC do to stop that from happening again? Both the department and facility operators have an increased awareness for the public's concern in Bell Flats. Facility operators have indicated their desire to be good neighbors. The Bell Flats residents have become frustrated with what they believe is unhealthy air and an inadequate response by the department. DEC believes both Brechan and SPI have the right to operate in Bell Flats provided they do so in compliance with existing laws and regulations. At the same time, the department believes the residents of Bell Flats are entitled to clean, healthy air. To this end, DEC hopes to work with both facility operators and the public to allow operations while ensuring clean air. III. Air Quality Concerns How do we know whether the air is safe to breathe? Based on health studies, the EPA has established National Ambient Air Quality Standards for common pollutants. Air that contains less pollution than the standards is considered safe. Air that contains more pollution than the standards is considered unhealthy. To ensure air is safe, we use computer models to predict the concentration of pollution that a facility will cause, and compare the prediction to the standards. The computer modeling results for Bell Flats are discussed below. What is a computer model, and why should we believe the results? A computer model is a set of mathematical equations, which calculate how pollution moves through the atmosphere. These equations use the known rate at which pollutants are emitted and the historical weather data for an area to calculate the maximum concentration of pollution expected. The models are tested rigorously by EPA and usually predict higher concentrations than actually occur. Of course, the accuracy of the results depends greatly on the accuracy of the emission and weather information. OK, what does the computer model show for the Bell Flats areas, and how accurate are these predictions? The models predict that the asphalt plant will cause sulfur dioxide concentrations above the standard, and that the soil remediation plant will cause particulate matter concentrations above the standard. While we examined the combined impact of both facilities, the model predicts that the combined impact will not increase pollution concentrations further. -3- These are preliminary results— adequate to convince us that the air quality should be investigated further. However, we know that the accuracy of the emission information can be improved. We expect that a more accurate model result will predict less concentration of pollutants, maybe even showing compliance with the standards. DEC is currently working with the facility operators to get this more accurate prediction. What can DEC do based on model results? We use model results to warn us of possible air quality problems, and to trigger further work to make sure those problems do not occur or continue. We may require a permittee to further reduce their emissions or start another control strategy to reduce the concentration of pollutants in the air. Our regulations require that we will consult with the affected owner, and provide the affected public an opportunity for comment and hearing before imposing an emission reduction or control strategy. Why hasn't the department measured the actual air quality? DEC does not routinely measure air pollution for small facilities because monitoring is expensive, requires significant lead time, and cannot always be traced back to a given facility. Also, monitoring can miss the highest concentration of pollutants because small changes in wind direction can change where the pollution goes. However, we recognize the value in actual measurements, and we do require large facilities that can better afford the cost to monitor air quality at their fence -line. In this case, based on the size of the facility and time available, we decided that computer modeling would give more timely and cost- effective information on whether there truly is an air quality problem, which must be solved. Will the department actually measure the air quality this year? Maybe. As discussed above we intend to take a closer look at the model predictions and work on control strategies to reduce the possibility of unhealthy air. Monitoring existing air quality impacts could serve to verify or dispute the computer model predictions, and help determine the appropriate level of controls. However, the time and cost of monitoring must be weighed against this potential added value. More accurate computer prediction and simple control measures may show that monitoring will not be worth the cost. Why didn't the department's air permits prevent this impact? For this size of facility the air permits did exactly what they were designed to do— ensure that the facilities operated in compliance with air quality emission limits. Until we complete the more accurate modeling, we are unsure whether the emission limits adequately protect air quality in this situation. What is the air pollution coming from the dirty soil stored on site - are hazardous vapors coming from that stuff? The stored contaminated soil is covered. Those covers prevent significant vapors from being emitted from the storage piles. Refueling a car causes greater exposure to hazardous vapors. IV. Contaminated Soil and Water Quality concerns May SPI use treated soil to fill in the Brechan pit pond? Won't that contaminate the ground water? SPI has not requested to use treated soil as fill material into the pond on site. DEC's policy is that treated soil may not be disposed in an "environmentally sensitive area." This includes within a certain distance of groundwater and/or surface water. The soil treatment process is designed to treat soil to the most stringent cleanup level (i.e. to prevent contamination and migrating to groundwater). DEC's goal is to ensure treated soil is not placed in an area where it might impact public health or the environment. How does DEC know whether soil is being used to fill the pond? Our knowledge is based on the operations plan. We make periodic inspections to assure the operations plan is being followed. The plan requires design and construction of storage cells and containment areas to ensure protection of the underlying soil. If the soil is protected, ground or surface water should not be impacted. Therefore, the plan is to ensure containment throughout the process. What happens to the soil SPI treats? SPI's clients are ultimately responsible for their treated soil. The majority of the soil treated by SPI has been returned to'their original sites. If a client does not want the soil back, the operator may decide to keep it or ask the responsible party to remove it. I thought DEC was going to do some monitoring of the water last summer? What happened? Were samples taken? What are the results? Water samples were collected in September 2002 from Brechan's Pond and Orbin Lake. The water was sampled for petroleum hydrocarbons. Contamination was not detected in either water body. 05/15/2002 16:54 FAX 9074884889 RECHAN ENTERPRISES. Inc GENERAL CONTRACTORS BRECHAN ENTERPRISES INC oo2 SRECHAN ENTERPRISES, INC / GENERAL CONTRACTORS 2705 MILL BAY ROAD • KODIAK, ALASKA 99615 December 20, 2001 TO: Borough Manager Patrick Carlson FROM: Brechan Enterprises Michael Martin RE: Solid Wood Waste Disposal Dear Mr. Carlson: Brechan Enterprises currently has a burn permit #2319 issued February 12, 2001. We believed that this permit allowed us to burn wood waste from construction projects as long as the burn occurred on our property such as our industrial property in Bells Flats, locally called Pit 1. As you know, this has been a common practice with other contractors through out Kodiak and has been a traditional practice for us. It has been brought to my attention that there are residents that have concerns about Brechan Enterprise burning wood material at Pit 1. The first concern brought to my attention has been about hazardous waste. Specifically, Brechan Enterprises has not, and will not intentionally bring hazardous waste to our property for burning or disposal. As an additional insurance on.this issue, we propose using an excavator to separate the large pile of wood into a smaller manageable pile for burning. This will also allow secondary segregation of material in case of inadvertent inclusion of non - permissible burn materials. • • The second concern was the size of the burn. As noted above, we feel a smaller burn pile will address this concern. Additionally, we will make every attempt to bum during Northwesterly wind direction. Because of our location, this should keep most smoke produced away from residential homes. At the conclusion of the burn, we will load and deliver all burn by- products and all non -burn material to the Borough Landfill. We have contacted D.E.C. in Anchorage, advising of our intent to burn. We believe giving D.E.C. the opportunity to send someone to observe our burn would alleviate `PKONE: 907.485.3215 • FAX: 907.485.4889 ALASKA BUSINESS #001858 • ALASKA CONTRACTORS #AA441 We 11173 An Equal OpportunJy Employer. 05/15/2002 16:55 FAX 9074664689 BRECHAN ENTERPRISES INC 0003 . . . NA147 • • • concerns that we may be trying to burn something inappropriate. I also understand that there may be issues with borough landfill dump usage under Borough Code 8.20.030. Brechan Enterprises recognizes the limited space that the Borough has for landfill. We believe that if this section does apply, it is in the bestinterest of Brechan and the borough to allow an exemption to burn this material on our property. To further alleviate resident concerns, Brechan Enterprises would propose that any other large construction project debris be pre-arranged with the borough as whether to use the Borough Landfill or our property for burning. Thank you for you consideration on this matter, Respectfully, 7fax,41/7/10(.& Michael R. Martin President of Brechan Enterprises /1(11:<6^ peiv-,,ie ale 6,1;_x -7-C-74_4/41 df Dec le 01 01:12p " ••••■■ r ..■1 e.■•• ss I. t .1 • U LP Doug Mathers 907-486-8071 DEIP'T. OF ENVIRONMENTAL CONSERVATION DIVISION OF ENVIRONMENTAL HEALTH SOLID WASTE PROGRAM 555 CORDOVA STREET ANCHORAGE, ALASKA 99501 littp://vrww.state.akus/deeThome.htm June 17, 17, 1997 Mr. Bill Oliver Brechan Enterprises 2705 Mill Bay Road Kodiak, Alaska 99615 Re: Expired Solid Waste Disposal Permit No. 8621-BA019 Dear Mr. Oliver: P.1 TONY KNOWLES, GOVERNOR Telephone: (907) 269-7590 Fax: (907) 269-7655 Recently we received an inquiry about waste disposal activities in the Bells Flats area of Kodialc Island. We have reviewed our records and wanted to notify you that the solid waste disposal perrnit (No. 8621-BA019) issued to Brechan Enterprises has expired. The expired permit, issued to Brechan Enterprises on May 7, 1987, allowed the dispdsal of inert debris in an area known as Bells Flats. The referenced permit prohibited the. dispbsal Of Metals, garbage,' asphalt, olarly other leachable waste. Please provide the required documentation described in the permit showing the closure conditions have been met. Also, be aware that a permit issued by our Department is required to dispose of solid waste. This is separate from, and may be in addition to, a Conditional Use permit which may be required by the Kodiak Island Borough. If Brechan Enterprises has a future need to dispose of limited volumes of inert waste, you may want to apply for coverage under our General Permit for this type of operation, otherwise an individual peintit will be required. Permit applications are available at ADEC's offices or if you request we can send one to you.. If you have any questions or need additional information, please do not hesitate to call me at above phone number. Sincerely, attnZ Laura Ogar Solid Waste Program Coordinator cc: Bill Rieth, ADEC/Anchorage Everett Stone, ADEC/Kodiak Linda Freed, KIB ij 1 91991 :74 February 7, 2002 Michael R. Martin, President Brechan Enterprises, Inc. 2705 Mill Bay Road Kodiak, Alaska 99615 Kodiak Island Borough Finance Department 710 Mill Bay Road Kodiak, Alaska 99615 Phone (907) 486-9320 Fax (907) 486-9399 www.kib.co.kodiak.ak.us Re: Solid waste disposal of building demolition material by open burning on Block 3, Tract A, Bells Flats Alaska Subdivision. Dear Mr. Martin: This letter is in response to your request dated December 20, 2001, requesting approval under KIBC 8.20.030, to allow the above referenced disposal of building demolition material by open burning on your Industrial zoned lot in Bells Flats. Staff has previously reviewed the applicable Borough codes relating to zoning and open burning and found that, subject to the reasonable precautions that would normally be stipulated in a burn permit, there is no reason not to allow your request on that basis. In addition, we recognize that clean air standards are the responsibility of the Alaska Department of Environmental Conservation (ADEC). Should there be any question about the open burning of the type or quantity of demolition material you have stockpiled, you would be well advised to consult with ADEC before beginning the burn. The only issue to be resolved at this time involves the Borough regulations regarding solid waste collection and disposal, as referenced in KIBC 8.20.030. When the solid waste disposal system, i.e. landfill, was originally set up, it was established on the basis of an exclusive road system utility service area. In order to be economically viable and to ensure that the intent of the many state and federal regulations are met, it is essential to be able to control the waste stream to ensure that solid wastes are disposed of properly. KIBC 8.20.030 provides that the Borough finance director may exempt a person from the requirements if he determines that the person requires solid waste collection and disposal service, which cannot be provided by the Borough system. In this instance, there is no question that the Borough cannot provide a collection service for the demolition material. With regard to the disposal service, the Borough could probably provide the service if the material was brought to the landfill on an incremental basis, however, the Baler/Landfill is not normally staffed to handle and dispose of a extremely large quantities of demolition material if it is delivered in a relatively short time frame. Of course if the material were delivered, it would eventually be disposed of in the most efficient and economic manner possible, however this might require staging the material at the landfill until it can be systematically evaluated and disposed of. The bottom line is that it might end up sitting at the landfill for a while until it could be incorporated into the day- to-day operations of the baler/landfill. Under these circumstances, the Borough is willing to grant an exemption, as permitted by KIBC 8.20.030, in order to allow the disposal of demolition material by open burning on your site, subject to the following: 1. This approval is in response to a specific request, at a specific date and time and, as such, it does not constitute a waiver of KIBC 8.20.030 for the purpose of future disposal plans on Block 3, Tract A, Bells Flats Alaska Subdivision. This exemption does not establish a precedent to be used for future requests, but is based upon the specific proposal contained in the letter dated December 20, 2001 and the staff judgment of Borough baler/landfill capabilities available at the time of this request. Similar requests in the future will be handled on a case-by-case basis based on the circumstances of the request that are existing at that time and will be approved or denied on merits of the individual request and the ability of the Borough to provide the requested solid waste collection and disposal service. 2. The exemption is approved subject to the representations contained in the letter dated December 20, 2001, from Brechan Enterprises spelling out the manner in which the demolition building material will be disposed of and indicating an understanding of the applicable regulations with regard to burn permits and clean air requirements as they apply to open burning. 3. The bum activity will be monitored at all times in conformity with a bum permit issued by the local fire marshal, as required for all open burning of this nature. 4. Block 3, Tract A, Bells Flats Alaska Subdivision is no longer a permitted disposal site recognized by ADEC and it does :pot appear that it was ever permitted as a disposal site for open burning of material. As a result, the residual waste products that result from the open burning should be removed from the bum site at the conclusion of the bum and delivered to the landfill for appropriate disposal. As mentioned in your letter, we anticipate that future burns will be prearranged through the Borough, preferably prior to the actual stockpiling of building demolition material on the site. As alluded to above, there does not appear to be a procedure for a blanket exemption and it appears that a new determination under KIBC 8.20.030 is required for each similar disposal that you anticipate in the future. If you have any questions about this determination, or require additional information about Borough codes and regulations, please feel free to contact me for assistance. Sincerely, Karleton Short, Finance Director Cc: Patrick S. Carlson, Manager Andy Nault, Fire Marshal Dale Rice, Womans Bay Fire Chief Alaska Dept. of Environmental Conservation IN THE DISTRICT/SUPERIOR COURT FOR THE.STATE-C1SKA 1 AT KODIAK WOMEN'S BAY COMMUNITY COUNCIL, INC., VS. KOnTAK ISLAND BOROUGH, Plaintiff(s), Defendant(s). To Defendant: Kodiak Island Borough Clerk r_FCIEVEI, SEP 3 2002 KODIAK ISLAND BOR011-1 = OFFICE OEL-ENROL21-1 CLERK " PE CASE NO. 3K0-t02- 407 EIEVED SUMMONS F SEP 4 2002 co,r4).a.inifVfiich- with' the 1•:...LAND 23R01;:lii OFcbuitBUFaiii..:CH CLERK You are hereby summoned and required to file with the court an answer to the accompanies this summons. 204 Mission Road, Room 10- Your answer must be filed Kodiak, Alaska 99615 within 20 (address) days* after the day you receive this summons. In addition, a copy of your answer must be sent to the plaintiff's attorney, Willi am S Ourfirni ngs , whose address is: Ashburn Maon, 1130 West Sixth Avenue, Suite 100, Anchorage, AK 99501 If you fail to file your answer within the required time, a default judgment may be entered against you for the relief demanded in the complaint. 71 This case has been assigned to Superior Court Judge DONALD D HOPWCA)l) n This case has been assigned to District Court Judge KODIAK ISLAND BOK° H is a District Court case and will be assigned to an mail 60fiffig BOROUGH CLERK Date • CLERK OF COURT Cr'7IF:,D TO: By FILE\ Prt;tYi-Deputy * The State or a state officer or agency named as a defendant has 40 days to file its answer. CIV-100 (3/87)(st.3) SUMMONS Civil Rules 4, 5, 12, 55 SHBURNAND MASON LAWYERS PROFESSIONAL CORPORATION SUITE 100 130 WEST SIXTH AVENUE ANCHORAGE, ALASKA 99501-5914 (907) 276-4331 IN THE SUPERIOR COURT FOR THE STATE OF ALASKA THIRD JUDICIAL DISTRICT AT KODIAK WOMEN'S BAY CO ITY ) COUNCIL, INC., ) ) ) ) ) ) ) ) ) ) Plaintiff, VS. KODIAK ISLAND BOROUGH, Defendant. E.EC.IEVEF,) SEP 3 2002 f. 1Y:7.11-N4c IF,LAND 130ROUTri 111: CLERK Case No. 3K0-02-3,.-_-- Civil COMPLAINT Plaintiff Women's Bay Community Council, Inc., by and through its counsel Ashburn & Mason, P.C., states the following as its complaint against defendant Kodiak Island Borough. 1. Plaintiff Women's Bay Community Council, Inc. ("WBCC") is an Alaska nonprofit corporation. 2. Women's Bay is a community of approximately 750 residents located on Kodiak 3. The Women's Bay Community Council fanned as an unincorporated association of residents and property owners in the Women's Bay community in the 1980s, in order to provide a means of community self-expression, assist in the orderly development and improvement of the community, provide for community representation, provide and maintain a community development plan to ensure proper development, and advocate for the proper enforcement of the ordinances and regulations that govern land use in Women's Bay. ASHBURNAND MASON LAWYERS A PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE. ALASKA 99501-5914 (907) 276-4331 4. Women's Bay Community Council incorporated in 2002. 5. Kodiak Island Borough ("KIB") is a second class borough located on Kodiak Island, Alaska. 6. KIB is responsible for zoning and zoning enforcement within the borough territory, including Women's Bay. 7. Title 17 of the Kodiak Island Borough Code ("KIBC") sets forth the zoning ordinances applicable within the borough. 8. KIBC § 17.24.010 lists the permitted uses in the industrial district. Soil remediation is not listed as a permitted use. 9. KIBC § 17.24.020 lists the uses which may be permitted in the industrial district by first obtaining a conditional use permit. Soil remediation is not permitted as a conditional use. 10. KIBC § 17.03.080 provides that "land uses not listed as a permitted use in a district are prohibited." 11. Tract A, Block 3, Bells Flat Alaska Subdivision is located in the Women's Bay community. 12. Tract A, Block 3, Bells Flat Alaska Subdivision is zoned "industrial." 13. For purposes of Title 17 of the KIBC, the KIB comprehensive plan consists of several documents, including the Women's Bay community plan. 14. Regulations governing the use and occupancy of land must be in accordance with the comprehensive plan. COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No, 3K0-02-S...-1 Civil Page 2 of 17 ASHBURN AND MASON LAWYERS A PROFE5i1ONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE, ALASKA 99501-5914 (907)276-4331 16. The owner of Tract A, Block 3, Bells Flat Alaska Subdivision (hereinafter the "Brechan Property") is Brechan Enterprises, Inc. ("Brechan"). 17. Brechan has entered into an agreement with Soil Processing, Inc. ("SPI") to allow SPI to use part of the Brechan Property as a site for thermal soil remediation. 18. Thermal soil remediation, as planned by SPI for the Brechan site, involves trucking in contaminated soil from other locations, stockpiling it on site, and burning it in a processing chamber. 19. SPI has stated that it "intends to accept and treat only petroleum-contaminated soil from underground storage tanks or other contaminated sites." There is no guarantee that the soils will not have other contaminants, as the testing procedures rely on analysis of relatively few samples from very large volumes of contaminated soil. Testing of contaminated soil at various contaminated sites in the region has confirmed the presence in some samples of contaminants other than petroleum, including heavy metals and other highly toxic, non-petroleum substances. 20. SPI's soil processing plant can process eight to ten tons of soil per hour. "A typical shift is 24 hours per day, 7 days per week." 21. The processing equipment burns approximately 85 gallons of liquefied petroleum gas ("LPG") per hour. If the processing equipment is down for preventative COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02--1 Civil Page 3 of 17 ASHBURNAND MASON LAWYERS A PROFESSIONAL CORPORATION SUITE 100 1190 WEST SIXTH. AVENUE ANCHORAGE. ALASKA 99501-5914 (907) 776-4331 maintenance four hours per day, this represents 1,700 gallons per day, and almost 12,000 gallons per week. This is at least one and one-half times (150%) more than the average weekly LPG use of all the rest of Kodiak Island business and residential users combined. 22. The zoning peiinit allows SPI to have unlimited amounts of LPG on site as long as the tanks are somehow connected to the soil remediation processor. 23. SPI has already installed three LPG transport tankers of approximately 8,000 gallons each on site to store this LPG. , These tanks will have to be refilled on approximately a weekly basis, which will require LPG tanker trucks to travel the streets of the Women's Bay community regularly. 24. The soil processing facility is being installed in close proximity to an existing asphalt plant on the same site. The asphalt plant has had a least one fire in the recent past. 25. The Women's Bay fire station is not equipped or trained to deal with a fire involving the LPG tanks. If such a fire occurs, the fire department's plan is to focus on evacuation of homes within a one-mile radius of the SPI facility and not attempt to fight the fire. Because the Brechan property is located at the entrance to the community, it will not be possible to evacuate most of the residents out of the community by road. Instead, residents will have to move farther back into the mountains at the back of the community. 26. There are approximately nine homes and businesses, or approximately 24 people, not including the fire hall crew, in the blast zone from an explosion at the LPG tanks, and an additional approximately 150 homes and 370 people in the one-mile radius evacuation zone around the site. COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02-c-)s:YACivil Page 4 of 17 4SHBURNAND MASON LAWYERS R PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE. ALASKA 99501-59t4 (907)276-4331 27. SPI's plant will be able to process 1,400 tons or more of soil per week. If all of this soil is kept on site, this would still require approximately 100 trucks entering the community with contaminated soil per week. If the processed soil is removed from the community, either these same trucks or an equal amount of other trucks will leave the community fully loaded. 28. Contaminated soil requires special care in transport, in order to minimize the possibility of a loss of material during delivery. Loads of contaminated soil will be transported in dump trucks that will be required to back onto a ramp covered with a removable "tire liner" and stop at the edge of the storage cell so all contaminated soil will be dumped inside the cell. After transporting contaminated soils, the truck tailgate, rear of the truck, and tires are cleaned before the truck leaves the tire liner area. 29. Plant operation will require approximately 4,800 gallons of water per day. 30. KIB 's Community Development Department has issued a permit allowing SPI to operate a soil remediation plant on the Brechan Property, in spite of the fact that soil remediation is not a permitted use in the industrial district. 31. KIB 's Community Development Department's purported justification for issuing the permit to SPI was that soil remediation was "similar" to those uses permitted by KIBC § 17.24.010. At the time this permit was issued, KIB 's Community Development Department based this determination on the recollections of former employees that they had told other people that the use was "similar" to an asphalt plant. No other soil remediation plant had COMPLAINT Women Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02-TA Civil Page 5 of 17 ASHBURN AND MASON LAWYERS A PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE, ALASKA 99501.5914 (907) 276.4331 actually received a penult based on these informal ad hoc statements. The Department later drafted a written "determination" to justify its prior action. 32. KIBC § 17.03.090 does provide 17.03.090 Similar uses may be permitted. A. Land uses other than those specifically permitted in a district may be allowed if they are similar to those listed and are found by the community development department to be similar in character and impact. B. Land uses other than those conditionally permitted in a district may be allowed if they are similar to those listed and are found by the commission, after a public hearing, to be similar in character and impact. C. In all cases, the outdoor storage of materials and equipment is prohibited unless it is listed as a permitted or conditional use in a district. 33. The KIB Community Development Department apparently determined, without any factual investigation or any opportunity for public comment, that a soil remediation plant was a "similar" use to an asphalt plant and that the thermal soil remediation plant would be "similar in character and impact" to an asphalt plant. 34. As an initial matter, soil remediation and asphalt production are quite different. One burns contaminated soil at high heat, using tremendous amounts of LPG in order to create waste gas and burned, sterile soil. The other combines asphalt, a tar-like heavy petroleum, with • sand or gravel to create a paving material. 35. The KIB Community Development Depaitinent's after-the-fact justification states that "soil remediation plant and an asphalt plant are similar in trip generation and type of traffic." This is false and is not supported by any factual investigation by the Department. COMPLAINT Woinen's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3KO-O2-i, Civil Page 6 of 17 ASHBURN AND MASON LAWYERS PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE. ALASKA 99501.5914 (907) 276.4331 The soil remediation plant will generate much more traffic on an annual basis than the asphalt plant. Although an asphalt plant on Kodiak Island only operates 30-50 days per year and does not operate 24 hours per day, the soil remediation plant will operate 365 days per year, 24 hours per day. In addition, contaminated soil is a regulated substance and must be transported in accordance with state and federal regulations. See 18 AAC 75.360, 18 AAC 78.250, 18 AAC 60.015; 49 C.F.R. § 171, et seq. 36. The KIB Community Development Depat tmene s after-the-fact justification also states that a soil remediation plant and an asphalt plant are similar in utility demands. This is also false and again is indicative of the Depattment's failure to conduct appropriate fact-finding. The entire basis for the Depai ment's "finding" is that both operations "process material through the application of high heat, which requires a great deal of fuel and electricity to operate the equipment and thereby process the material." However, soil remediation and asphalt production are two entirely different processes. Unlike the permitted use of an asphalt plant, thermal soil remediation requires tremendous amounts of LPG to be transported onto and stored on site. In contrast, the asphalt plant uses diesel fuel. The asphalt plant uses commercially available electricity, delivered by utility lines, while the soil remediation plant requires a generator. 37. Although the KIB Community Development Depaitment identified environmental impacts as an important concern in determining "similarity," its after-the-fact justification does not attempt to analyze these impacts, but instead states that such impacts are regulated by the Alaska Department of Environmental Conservation ("ADEC"). This is a COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02-Civi1 Page 7 of 17 ASHBURN AND MASON L-AWY MRS A PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE, ALASKA 99501-5914 (907) 276-4331 67. The then 'al soil remediation facility is also expected to affect the cost and availability of fire insurance rates for residents differently. 68. The presence of the fuel stored at the soil remediation plan has a much greater impact on the peace of mind of residents than the existence of the asphalt plant. COUNT IV DECLARATORY JUDGMENT 69. Plaintiff realleges the allegations contained in paragraphs 1 through 68 of the Complaint and incorporate them herein by reference, and further complains of the defendant as follows. 70. KIBC § 17.24.020(F) provides that "Petroleum or flammable liquid production refining, or storage" is only permitted in the industrial district "by obtaining a conditional use permit. ,, 71. SPI will be storing up to 24,000 gallons of LPG on the Brechan property at any given time. This is equivalent to an approximately three-week supply of LPG for all other LPG business and residential customers on Kodiak Island. 72. The KIB Community Development Department has decided that the storage of this great quantity of LPG does not require a conditional use permit because it interprets "storage" to mean "bulk storage," and, in turn, interprets "bulk storage" as only involving storage for further resale. Because SPI plans to bum its LPG on a constant basis, the KIB Community Development Department has decided that the clear language of KIBC § 17.24.020(F) does not apply. COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02,%)--1 Civil Page 15 of 17 ASHBURN AND MASON LAWYERS A PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE. ALASKA 99501 -5914 (907) 276 -4331 62. The environmental impacts of the soil remediation plant is also quite different from an asphalt plant because, among other possible impacts, (a) the soil remediation plant can operate seven to ten times more per year, and operates. 24 hours per day, creating more noise and road traffic; (b) the risks from an earthquake are much greater; (c) spillage in transport will contaminate community soil; (d) water runoff from the stored contaminated soil and the wastewater pond may enter groundwater; (e) sterile soil left on site creates a vegetation dead zone; and (f) unknown other contaminants in the soil may enter the community's air and water. 63. The type of traffic generated by these two uses is also quite different. Asphalt production requires ordinary truck traffic, while soil remediation involves regulated truck traffic. Transporting trucks must be covered and special procedures to clean the trucks after delivery are required. Soil transportation presents a risk of contamination if soil is spilled anywhere other than the prepared receiving pad and from water dripping from wet contaminated soil in the trucks during transport. 64. The soil remediation plant has a much bigger fire safety impact on the community than the asphalt plant alone would have, because of the three large LPG tanks on site. The local fire department is not equipped to handle a fire at these tanks. 65. WBCC seeks a declaration that the KIB Community Development Depaitment erred in approving a permit for operation of a thermal soil processing plant on the Brechan property, and that the soil processing plant is not a permitted use in the industrial zone. 66. Property values within the blast zone and the evacuation zone surrounding the thermal soil remediation plant will be negatively affected. COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3KO- 02- Civil Page 14 of 17 ASHBURNAND MASON LAWYERS A PROiESSIO NAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE, ALASKA 99501.5914 (907) 276.4331 asphalt — a heavy-end petroleum product — at moderately high temperatures with sand or gravel to produce hot asphalt for paving roads or driveways, and other commercial uses. 59. A soil remediation plant in Kodiak can operate 24 hours per day, 365 days per year, while an asphalt plant can only operate approximately 30-50 days per year. Operation of an asphalt plant is limited by weather conditions in at least two ways: First, conditions must be appropriate to apply the end product. Second, the manufacturing process requires minimum moisture content in the material. In addition, there is a practical limitation based on the amount of asphalt that is needed in the area. As a result, a soil remediation plant can generate seven to ten times as much traffic, and will generate traffic during winter months when the asphalt plant would not operate. In addition, truck traffic for a soil remediation plant is a regulated activity, because the soil is contaminated. 60. Because the soil remediation plant will operate 24 hours per day, 365 days per year, it will also generate more noise, light, and odor pollution. 61. A theinral soil remediation plant and an asphalt plant have very different utility requirements. Brechan's existing asphalt plant operates off the existing electrical utility network, while the SPI soil remediation plant will require a large generator. The soil remediation plant will also require tremendous quantities of LPG as fuel, while the asphalt plant is diesel oil-fired. The diesel tanks for the asphalt plant present a fire risk that the local fire company can handle, while the local fire company is unequipped to handle a fire at the LPG tanks. The KIB Community Development Department issued the permit to SPI before it requested the fire department to prepare a response plan for the site. COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02-Civil Page 13 of 17 ASHBURNAND MASON LAWYERS A PROFESSIONAL CORPDRATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE, ALASKA 99501-5914 (907) 276-4331 COUNT II DECLARATORY JUDGMENT 52. Plaintiff realleges the allegations contained in paragraphs 1 through 51 of the Complaint and incorporate them herein by reference, and further complains of the defendant as follows. 53. Alaska Statute 29.40.050 requires every borough assembly to provide by ordinance for an appeal from an administrative decision of a municipal employee, board, or commission made in the enforcement, administration, or application of a land use regulation. 54. The KIB has not provided for any appeal process from a decision by the KIB Community Development Depai tment to allow a new use in a zoning district based on a fmding that it is "similar" to a permitted use. 55. WBCC seeks a declaration that the KIB has violated AS 29.40.050 and must provide for an appeal procedure if KIBC § 17.03.090(A) has any continuing vitality. COUNT III DECLARATORY JUDGMENT . 56. Plaintiff realleges the allegations contained in paragraphs 1 through 55 of the Complaint and incorporate them herein by reference, and further complains of the defendant as follows. 57. A thermal soil remediation plant is not similar to an asphalt plant. 58. Thermal soil remediation is a process to de-contaminate soil by burning it at extremely high temperatures, producing inert soil. In contrast, an asphalt plant combines COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02-..,—\ Civil Page 12 of 17 .SHBURNAND MASON LAWYERS A PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE. ALASKA 99501-5914 (907) 276-4331 COUNT I DECLARATORY JUDGMENT 45. Plaintiff realleges the allegations contained in paragraphs 1 through 44 of the Complaint and incorporate them herein by reference, and further complains of the defendant as follows. 46. Alaska Statute 29.40.040 requires the Assembly, in accordance with a comprehensive plan adopted under AS 29.40.030, to adopt or amend provisions governing the use and occupancy of land "by ordinance." 47. Alaska Statute 29.25.020 provides the procedure that applies to the enactment of all ordinances. This procedure requires, among other necessary steps, a public hearing after appropriate notice and an opportunity to be heard. 48. Allowing non-permitted uses in a zoning district based solely on the unreviewable decision of an administrative employee violates AS 29.40.040 and AS 29.25.020. 49. To the extent that KIBC § 17.03.090(A) permits an administrative employee to expand the list of permitted uses in a district, it is an unlawful attempt to avoid the requirement that .a zoning regulation be accomplished by ordinance. 9, W13CC seeks a declaration that KIBC § 17.03.090(A) does not authorize the KIB Community Development Department to authorize new uses in a zoning district. 51. In the alternative, WBCC seeks a declaration that if KIBC § 17.03.090(A) does authorize the KIB Community Development Department to authorize new uses, it is an illegal delegation of the zoning power. COMPLAINT Wornen's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02----\ Civil Page 1.1 of 17 ASHBURN AND MASON LAWYERS A PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE. ALASKA 99501-5914 (907) 276-4331 "application of heat" are vastly different for asphalt manufacture and thermal resorption soil remediation processes. 41. The earthquake potential for Kodiak Island is one of the highest of any community in North America. The potential for a powerful earthquake (strong enough to cause significant damage to or destruction of facilities not specifically designed to resist severe earthquake ground motions) at Kodiak is comparable to the most earthquake prone locations in California immediately adjacent to the San Andreas fault. 42. Fire is a common result of a strong earthquake shaking, especially for facilities that have large amounts of flammable fuel on site and equipment not specifically designed to resist strong ground motions. There is no consideration of this hazard in the SPI operation plan, and it does not appear to have been considered in the design and installation of the facility. 43. No permitted use-in the industrial zone requires the same amount of fuel storage, so the thermal soil remediation facility is not similar to any of those uses. 44. The KII3 Community Development Department' s after-the-fact justification also states "both uses either introduce petroleum products into the material being processed or extract petroleum contaminants out of the material being processed." In other words, according to the KIB Community Development Depaitment, the two processes are "similar" because they have exactly the opposite goals. Also, this "reasoning" ignores the fact that asphalt and petroleum contaminants are very different types of petroleum products. COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02---\ Civil Page 10 of 17 ASHBURN AND MASON LAWYERS A PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE. ALASKA 99501-5914 (907) 276.4331 39. Because the soil processing plant can operate 365 days per year, 24 hours per day, its noise and odor impacts will be much greater. 40. The KIB Community Development Department's after-the-fact justification states that a soil remediation plant and an asphalt plant are similar because both operations "process material through the application of high heat." In fact, the temperature used in these processes is very different and results in very different chemical reactions that generate very different products. Asphalt manufacturing heats very viscous asphalt tar a modest amount, typically less than a couple hundred degrees Fahrenheit, in order to decrease the viscosity of the asphalt tar so it will mix with aggregate and be workable during paving. These temperatures are well below the ignition temperature of the petroleum components and results in minimal volatilization of petroleum products. In contrast, the temperatures used to remediate contaminated soil are much higher, in the 500 to 800 degree Fahrenheit range for the primary treatment chamber and the 1650 to 1800 degree Fahrenheit range in the secondary treatment or ignition chamber. These temperatures are well above the volatilization and ignition temperature of petroleum and many other substances. At these temperatures oxidization and other chemical reactions are promoted and new chemical compounds are produced. Most of these new chemical compounds are gasses at the elevated temperatures and are vented as exhaust gasses. At these very high temperatures many heavy metals, including mercury and lead, are volatilized, and arsenic is oxidized. PCP, PCB, and some other components of petroleum convert to dioxin at these temperatures. Clearly, the character and effect of the COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02-Civi1 Page 9 of 17 ASHBURNAND MASON LAWYERS A PROFESSIONAL CORPORATION SUITE 100 1190 WEST SIXTH AVENUE ANCHORAGE, ALASKA 99501.5914 (907) 276.4331 non-sequitur, as it is not necessary to regulate an environmental impact to deteiiiiine if it is, in fact, similar. 38. The KIB Community Development Depth tment also states in its after-the-fact justification that both uses require an air quality peimit through ADEC. This incorrectly implies that the two uses have a similar environmental impact. Asphalt manufacturing involves mixing a stable, heavy, and non-free flowing petroleum product with sand or gravel, and then removing it from the plant to use for paving. The manufacturing process releases steam into the air and creates some odors and noise. Because the asphalt plant cannot operate more than 30-50 days per year, these impacts are similarly limited. In contrast, a thermal soil remediation plant involves burning petroleum-contaminated soil with large quantities ofLPG. The petroleum in the soil is from a variety of sources, including waste lubricants and fuel that has leaked from World War II vintage underground tanks. This oil is less viscous and is much more likely to migrate than asphalt. The petroleum-contaminated soil must first be trucked into the community, with the attendant risk of spillage. Although the plant is supposed to process petroleum-contaminated soil exclusively, there is no guarantee that other contaminants, such as PCBs, heavy metals, and other toxins, which the thermal processingplant is not designed to remove from the soil, will not be in the soil. World War II vintage petroleum products can contain various toxic additives and impurities that are not present in most modern petroleum products, particularly lead, arsenic, other heavy metals, and PCP and PCBs. COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No, 3K0-02- Civil Page 8 of 17 ASHBURN AND MASON LAWYERS A PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE. ALASKA 99501 -5914 (907) 276 -4331 73. The KIB Community Development Department has also stated that it is its position that fuel storage that is "necessary in support of a permitted principal use may be allowed as a constituent part of the overall permitted use, so long as the amount of the fuel supply is customary and proportional to the use, and that the installation of those facilities are in compliance with applicable life safety and building safety requirements, and the performance standards of KIBC 17.24.060.C." 74. This analysis ignores the fact that storage of 24,000 gallons of LPG is not necessary in support of any permitted principal use. Soil remediation is not a permitted principal use. 75. The KIB Community Development Dep tilient has not pointed to any permitted use in the industrial zone that would require storage of 24,000 gallons of LPG accessory to its principal use. Therefore, the Borough Assembly has never implicitly approved of storage of this much propane as an accessory use. 76. SPI's proposed storage of LPG without a conditional use permit violates KIBC § 17.24.020. WBCC seeks a declaration that the storage of LPG is not allowed in industrial districts without a conditional use permit, and that because no conditional use permit has been issued, the storage is illegal. PRAYER FOR RELIEF WHEREFORE, having fully set forth its complaint, plaintiff prays for the following relief: COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3KO -02 -� c Civil Page 16 of 17 ASHBURN AND MASON LAWYERS A PROFESSIONAL CORPORATION SUITE 100 1130 WEST SIXTH AVENUE ANCHORAGE. ALASKA 99501-5914 (907) 276-4331 1 An order declaring that KIBC § 17.03.090(A) does not authorize the KIB Community Development Department to authorize new uses in a zoning district. 2. An order declaring that to the extent that KIBC § 17.03.090(A) does authorize the KIB Community Development Depar tiiient to authorize new uses, it is an illegal delegation of zoning power. 3. An order declaring that the KIB has violated AS 29.40.050 by not providing any procedure for appeal from the KIB Community Development Department's interpretation and application of KIBC § 17.03.090(A), and requiring KIB to adopt such a procedure. 4. An order declaring that the KIB Community Development Depai talent erred in approving a permit for the soil remediation plant, as a soil remediation plant is not similar to an asphalt plant or similar in character and impact to an asphalt plant. 5. An order declaring the permit issued for use of the Brechan property as a thermal soil remediation plant to be invalid because it purports to allow storage of LPG without a conditional use pellnit, in violation of KIBC § 17.24.020(F). 6. An award of plaintiff s full costs and attorney's fees, as public interest litigants. 7. Such other relief as the court deems just and reasonable. Date: ASHBURN & MASON Attorneys for Women's Bay Community Council, Inc. By William S. Cummings Alaska Bar No. 9407071 COMPLAINT Women's Bay Community Council, Inc. v. Kodiak Island Borough Case No. 3K0-02- Page 17 of 17 GP— Asphalt Plant General Permit — Facilities Operating Post 1973. General Asphalt Plant Operating Permit — Post 1973 Qualifying Criteria The facility approved to operate under this general operating permit (hereafter referred to as "the facility") is described by SIC codes 1611, 1771, or 1629 and primarily produces asphalt concrete for paving. In addition, the facility must have been constructed, reconstructed', or modified after June 11, 1973. Alaska law requires operators of asphalt plant to obtain an operating permit if the plant meets any of the following criteria: • a potential to emit greater than 100 tons per year of a regulated air contaminant, • a source with a rated capacity greater than 100 Million Btu/hr, • a controlled source with a total rated capacity or equipment throughput greater than 5 tons per hr, • a controlled source with a rated capacity greater than 50 Million Btu/hr, or • equipment subject to a federal emission standard, such as rock crushers. Rock Crusher(s) is subject to Subpart 000. A Subpart 000 processing plant is a processing plant that: • Has a cumulative rated initial grinding capacity larger than 150 tons per hour for a portable plant or 25 tons per hour for a fixed plant; and • includes all and any combination of equipment: Crusher or grinding mill; screening operation; bucket elevator and belt conveyor transfer points; bagging operation; storage bin; or/and enclosed truck or railcar loading. • Is constructed, reconstructed', or modified (any equipment change that increases air emissions after August 31, 1983; The facihty would be excluded from using this general permit if the following applies. However, if there is a general permit for the activities listed below, the facffity may operate under both permits. a. The facility is subject .to a fuel consumption limit or other facility-specific requirement established in a construction permit, or air quality control permit under the 18 AAC 50.400(effective prior to 1/18/97); b. The facility contains: • A boiler subject to 40 C.F.R. 60, Subpart Dc, unless the operator also obtains general permit GP5 for that boiler; • A fuel storage tank subject to 40 C.F.R. 60, Subparts Ka, or Kb, unless 0 the only requirement that applies is recordkeeping under Subpart Kb, §116b(a) and (b); Or o the operator also obtains general permit GP8.1 or GP8.3 for that tank; • A source subject to 40 C.F.R. 60, Subpart 000 that has mechanically induced air flow; • A source (other than an asphalt plant, crushing and grinding equipment, fuel storage tank, or boiler subject. to 40 C.F.R. 60, Subpart Dc) subject to a federal emission standard in 40 C.F.R. 60, 61, or 63; • A gas turbine; • An incinerator; or • A source subject to any standard in 18 AAC 50.055(a) — (f) other than standards for fuel burning equipment in (a)(1), (a)(4), (b)(1), (b)(5) and (c); or • 0jien Burning at the facility at any time during the permit terrn;` • Renovation and demolition activities at the facility that would need to comply with the provisions of 40 C.F.R., Part 61, Subpart M, Section 145, National Emission Standard for Asbestos, Standard for Demolition and Renovation. Reconstruction as defined by Code of Federal Regulations (40 CFR 60.673). May 1, 1998 2 Including all administrative revisions through November 4, 1999. Final GP3 — Asphalt Plant General Permit — Facilities Operating Post 1973. ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION AIR QUALITY OPERATING PERMIT Permit No. GP3 The Department of Environmental Conservation, under the authority of AS 46.03, AS 46.14, and 18 AAC 50.350, issues an Air Quality Operating Permit for: Permitted Facilities: Qualifying Asphalt plants that have been constructed, reconstructed', or modified after June 11, 1973. This permit authorizes the operation of asphalt plants for which the Department finds in writing: • Equipment meets the criteria established on page 2 of this permit; and • The department has received a complete application. For the department to find the application complete, the application must provide all of the information described, in the application form issued with this permit, for all equipment to be operated under this permit. This permit expires on May 1, 2003. To renew this permit, the owner or operator must submit a renewal application between November 1, 2001 and November 1, 2002. John M. Stone, Chief Air Quality Maintenance Section May 1, 1998 May 1, 1998 1 Final Including all administrative revisions through November 4, 1999. il GPs — Asphalt Plant General Permit — Facilities Operating Post 1973. • Recycling and emissions reduction of Class I and Class II refrigerants at the facility. These activities are subject to 40 C.F.R. 82, Subpart F, Section 82.150. Sources This permit authorizes the facility to operate any source identified in the permit application submitted for this general operating permit. The permittee may operate equipment concurrently at multiple locations under this general permit. An example would be asphalt plant with several rock crushing equipment subject to Subpart 000 operating at several locations. At any given site, the permittee must comply with the terms and conditions applicable to equipment at that site. The operator must report for the applicable standards for each piece of equipment. Permit Duration To request general permit renewal, submit a written request to the department, and inform us of any differences in information from the previous general operating permit application. Citations All regulatory citations have been included at the end of each permit condition. For more detail, see the Table included as ATTACHMENT 3. Standard Permit Conditions (Please note that these are standard conditions taken directly from 18 AAC 50.345(a)(1) -(10). Condition 10(a) does not limit the Federal Credible evidence rule 62 FR 8314. 1. The permittee must comply with each permit term and condition. Noncompliance constitutes a violation of AS 46.14, 18 AAC 50, and the Clean Air Act and is grounds for a. an enforcement action, b. permit termination, revocation and reissuance, or modification in accordance with AS 46.14.280, or c. denial of an operating permit renewal application. [18 AAC 50.345(a)(1), 1/18/97] 2. It is not a defense in an enforcement action to claim that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with a permit term or condition. [18 AAC 50.345(a)(2), 1/18/97] 3. Each permit term and condition is independent of the permit as a whole and remains valid regardless of a challenge to any other part of the permit. [18 AAC 50.345(a)(3), 1/18/97] 4. Compliance with permit terms and conditions is considered to be compliance with those requirements that are a. included and specifically identified in the permit, or b. determined in writing in the permit to be inapplicable [18 AAC 50.345(a)(4), 1/18/97] 5. The permit may be modified, reopened, revoked and reissued, or terminated for cause. A request by the permittee for modification, revocation and reissuance, or termination or a notification of planned changes or anticipated noncompliance does not stay any operating permit condition. [18 AAC 50.345(a)(5), 1/18/97] 6. The permit does not convey any property rights of any sort, nor any exclusive privilege. [18 AAC 50.345(a)(6), 1/18/97] 7. The permittee shall allow an officer or employee of the department or an inspector authorized by the department, upon presentation of credentials and at reasonable times with the consent of the owner or . operator, to a. enter upon the premises where a source subject to the operating permit is located or where records required by the permit are kept, May 1, 1998 3 Including all administrative revisions through November 4, 1999. Final GP3 — Asphalt Plant General Permit — Facilities Operating Post 1973. b. have access to and copy any records required by the permit, c. inspect any facilities, equipment, practices, or operations regulated by or referenced in the permit, and d. sample or monitor substances or parameters to assure compliance with the permit or other applicable requirements. [18 AAC 50.345(a)(7), 1/18/97] 8. The permittee shall furnish to the department, within a reasonable time, any information the department requests in writing to determine whether cause exists to modify, revoke and reissue, or terminate the permit or to determine compliance with the permit. Upon request, the permittee shall furnish to the department copies of records required to be kept. The department, in its discretion, will require the permittee to furnish copies of those records directly to the federal administrator. [18 AAC 50.345(a)(8), 1/18/97] 9. The permittee shall certify all reports, compliance certifications, or other documents submitted to the department under the permit as required by 18 AAC 50.205. [18 AAC 50.345(a)(9), 1/18/97] 10. The permittee shall conduct source testing as requested by the department and shall: a. use the applicable test methods set out in 40 C.F.R. Part 60, Appendix A, and 40 C.F.R. Part 61, Appendix B, to ascertain compliance with applicable standards and permit requirements, b. submit to the department, within 60' days after receiving a request and at least 30 days before the scheduled date of the tests, a complete plan for conducting the source tests, c. give the department written notice of the tests 10 days before each series, and d. within 45 days after completion of the set of tests, submit the results, to the extent practical, in the format set out in Source Test Report Outline in Volume 111, Section IV.3 of the State Air Quality Control Plan, adopted by reference in 18 AAC 50.030(8). [18 MC 50.345(a)(10), 1/18/97] May 1, 1998 4 Including all administrative revisions through November 4, 1999. Final GP3-- Asphalt Plant General Permit — Facilities Operating Post 1973. GP3 - General Permit Conditions Aggregate Dryer or Drum Mixer 11 Opacity & Particulate Matter Emissions 11.1 A. Do not reduce visibility through the exhaust effluent by more than, 20% measured as a six - minute average. B. Monitor effluent and facility operation using the monitoring plan conditions M1 - M7, M10, M12, and M14 — M20. C. Report using EE2, R3, R10, R13, P1 -P9. [18 AAC 50.050(a)(4), 5/26/72; 18 AAC 50.055(a)(4), 1/18.97; 40 C.F.R. 60.92(a)(2), 10/6/75] 11.2 A. Do not emit particulate matter concentrations greater than 0.04 gr /dscf. B. Monitor emissions using monitoring plan conditions Ml - M9, M14 -20 and P1 -P9. C. Report using EE2, R3, R11, R13, P1 -P9. [18 AAC 50.050(b)(5), 5/26/72; 18 AAC 50.055(b)(5), 1/18.97; 40 C.F.R. 60.92(a)(1), 10/6/75] 11.3 A. Do not operate the facility for more than 6 hours in any 24 -hour period, if the facility can not perform a Method 5 source test for particulate emissions within the time frame stated in the application. In addition, do not operate the facility for more than 30 days in any calendar year. If subject to this condition: B. Monitor hours and operating days using Ml, and C. Report operating hours and days using R11. [18 AAC 50.050(a)(4), (b)(5), 5/26/72; 18 AAC 50.055(a)(4), (b)(5), 1/18.97; 40 C.F.R. 60.92(a)(1), (2), 10/6/75] For facilities using a baghouse [4o C.F.R. 60.92(a)(1), (2), 10/6/75 18 AAC 50.050(a)(4), (b)(5), 5/26/72; 18 AAC 50.055(a)(4), (b)(5), 1/18.97] 11.4 A. Inspect the interior of the baghouse and complete required maintenance prior to equipment startup in a new location or after shutdown periods lasting more than 5 days. Within two days of startup after relocating the facility and every 30 days of operation at the same location, re- inspect the baghouse. Replace any worn out or damaged bags within 72 hours. B. Monitor using M14 and M15. C. Report any deviations using R3. 18 AAC 50.055(a)(1), (b)(1) & (3) 1/18/97 and 18 AAC 50.050(a)(1),(b)(1) &(3) 5/26/72 11.5 A. Operate the baghouse efficiently to control opacity and particulate matter. B. Monitor baghouse operations using M4, M5, M16. C. Report any deviations using R3 and R13. 18 AAC 50.055(a)(1), (b)(1) & (3) 1/18/97 and 18 AAC 50.050(a)(1 ),(b)(1) &(3) 5/26/72 11.6 Inspect every component of the control device before the first operation each season and repair or replace any component that shows signs of deterioration. 18 AAC 50.055(a)(1), (b)(1) & (3) 1/18/97 and 18 AAC 50.050(a)(1),(b)(1) &(3) 5/26/72 For facilities using a scrubber [40 C.F.R. 60.92(a)(1), (2), 10/6/75; 18 AAC 50.050(a)(4), (b)(5), 5/26/72; 18 AAC 50.055(a)(4), (b)(5), 1/18.97] 11.7 Inspect every component of the control device before the first operation each season and repair or replace any component that shows signs of deterioration. 18 AAC 50.055(a)(1), (b)(1) & (3) 1/18/97 and 18 AAC 50.050(a)(1),(b)(1) &(3) 5/26/72 12 Sulfur -Oxide Emissions 12.1 A. Do not emit sulfur dioxide concentrations greater than 500 parts per million using a three hour average. B. Monitor emissions and relevant operating parameters using monitoring plan conditions M21 and M22. May 1, 1998 5 Including all administrative revisions through November 4, 1999. Final A report to the Community from the Womens Bay Community Council January 28, 2003 Litigation Update & Community Meeting February 1 lth The Womens Bay Community Council has exchanged proposals with SPI for the end to the soil burning over the past month and we have not been able to reach agreement. The mood of SPI is hostile and our counter settlement has been responded to. We are to try to resolve a settlement with terms that the Community can live with. We continue, with the help of many of you, to encourage our local government to put an end to the soil remediation plant in our neighborhood. Thank you so very much to all the 20+ friends who spoke up at the Borough Assembly meeting on January 16th, it was very gratifying to have the support! Our attorney, William S. Cummings, of Ashburn & Mason in Anchorage will be visiting us in Kodiak on February 11"' in a public meeting to be held at 6:30pm in the multi- purpose room, Peterson Elementary School. This will be a time to fully discuss the issue and where we are and the future of the suit might be. Please come and participate. Comprehensive Plan to go ahead The WBCC understands that the Comprehensive Plan will be going ahead soon. The Council had been advised the planning would be on hold for awhile due to Mr. Dvorak's reassignment at the Community Development Department. However, it was directed to proceed as planned Gary Carver has been assigned to the planning committee and will provide a voice for our community. The Council would encourage that a citizens committee for planning be established to advise the "real" Borough planning Committee. WBCC Regular Meeting February 4th, 7:30pm Womens Bay Firehall Agenda items for this meeting include: Litigation Update Treasurer's Report Committee Reports Planning Update Ideas for a spring gathering Community concerns ADEC workshop Jan. 29 The Alaska Department of Environmental Conservation will hold public workshops in Kodiak, concerning the renewal of the general permits for asphalt plants and rock crushing equipment. These two general permits were issued in the spring of 1998 for a term of five years. They will expire in the spring of 2003. These permits can be used for asphalt plants and rock crushers operating anywhere in the state. These workshops are to gather comment from plant operators and other members of the public before ADEC completes work on the draft renewal permits. The workshop is Wednesday, January 29th, 6pm, Borough Assembly Chambers. WB Fire Fighters Need Help Dale Rice reports that attendance is down at the weekly fire fighter training and new recruits are not to be seen on the horizon. If you have time to volunteer for our small community fire fighting force, please come to trainings held every Wednesday at the Firehall, 538 Sargent Creek Road. Our aging department (equipment -wise) could benefit from help of any kind, moral support especially! Please contact Dale Rice to volunteer: 487 -2589. Meetin Dates of Interest to Womens Ba Jan. 29th 6pm ADEC workshop -Born Assembly Chambers Feb. 4u' 7:30pm WBCC meeting - Fireball Feb. 6th 7 :30pm -Boro Assembly Regular Meeting Feb. 11th 6:30pm- Community Meeting - Peterson School ' 7 -2 :1. 7 FROM :SOILPRO FAX NO. :9072749295 May. 28 2002 11:53AM P1 SOIL PROCESSING INC. 207 E. NORTHERN LIGHTS BLVD., SUITE 103A A N17.1401.P.A.C-C_.ILLZ.-0012.1to FROM :SOILPRO FAX NO. :9072749295 SOIL PROCESSING INC. 207 E. NORTHERN LIGHTS BLVD., SUITE 103A ANCHORAGE, AK 99603 FAX TRANSMITTAL LETTER DATE; C TIME; 1(. 22. May. 28 2002 11:53AM P1 FROM: CONFIRM RECEIPT: Telephone (907) 274-3000 Fax (907) 274-9295 YES NO TRANSMITTING PAGES INCLUNDING COVER LETTER, FROM :50ILPRO FAX NO. :9072749295 May. 29 2002 11:53AM P2 Alaska Department of Environmental Conservation Request for Public Comment on Proposed Soil Remediation Facility to be located at Brechan Enterprises, Inc.'s industrial site, Kodiak, Alaska Comments must be received by May 22, 2002 The Alaska Department of Environmental Conservation (ADEC) is requesting public comments on an Operations Plan from Soil Processing Incorporated, Inc., (SPI) for DEC approval of a petroleum contaminated soil remediation facility to be located on off Salmonberry Drive on Brechan Enterprises' industrial site property on Block 3, Bell's .Flats Subdivision. SPI proposes to construct a soil remediation facility at this site in order to receive and treat contaminated soils under an ADEC approved Operations Plan, in accordance with the provisions of 18 AAC 75365 and 18 AAC 78.273 (Offsite Treatment Facilities). Soils would be trucked to the facility from surrounding areas for storage; pending treatment using thermal desorption technology. The soil processing equipment heats the soil to temperatures that drive off the petroleum contaminants, which are subsequently destroyed (oxidized) in a secondary afterburner. After soil sampling confirms that the treated soils meet ADEC required cleanup levels, the soils will be transported back to the place of origin or disposed at the soil treatment site. Facility construction activities are scheduled to begin this spring (2002)'and soil treatment could continue for three or more seasons. In order to comment on SPI's proposed soil remediation facility, ask questions about the proposed project, or to review any ADEC file information regarding this project, please contact: Paul Horwath ADEC Contaminated Site Program 43335 Kalifornsky Beach Road, Suite 11 Soidotna, Alaska 99669 Phone: (907) 262 -5210, ext. 250, Fax: 262 -2294 Ismail: Paul Horvath n.envicon.state.ak.us --- Robert Scholze From: Horwath, Paul [Paul_Horwath@envircon.state.ak.us] Sent: Tuesday, May 14, 2002 12:19 PM To: Robert Scholze Subject: FW: Soil Processing Incorporated Public Notice SPI - Kodiak 2002 Public Notic... Attached is the notice that should appear in the Kodiak paper soon. Hope this will be helpful to you. Best Regards, Paul Horwath > -----Original Message > From: Horwath, Paul > Sent: Monday, May 13, 2002 5:07 PM > To: 'Gary Carver' > Cc: Horwath, Paul; 'George Cline (SPI)' > Subject: Soil Processing Incorporated Public Notice > Attached is the Public Notice that should appear in the Kodiak Newspaper. > It should be published for two days in the paper, and then 7 days from the > last date of publication should be allowed for public comment. > With respect to providing comments; I see that my voice phone and fax > numbers are included at the bottom of the attached public notice. My > e-mail address and mailing address are also located there on the notice. > Best Regards, > Paul Horwath > Environmental Engineer > ADEC, Soldotna > «SPI - Kodiak 2002 Public Notice.doc» / Alaska Department of Environmental Conservation Request for Public Comment on Proposed Soil Remediation Facility to be located at Brechan Enterprises, Inc.'s industrial site, Kodiak, Alaska Comments must be received by (George: Insert date one week from date of last publication) The Alaska Department of Environmental Conservation (ADEC) is requesting public comments on an Operations Plan from Soil Processing Incorporated, Inc., (SPI) for DEC approval of a petroleum contaminated soil remediation facility to be located on off Salmonberry Drive on Brechan Enterprises' industrial site property on Block 3, Bell's Flats Subdivision. SPI proposes to construct a soil remediation facility at this site in order to receive and treat contaminated soils under an ADEC approved Operations Plan, in accordance with the provisions of 18 AAC 75.365 and 18 AAC 78.273 (Offsite Treatment Facilities). Soils would be trucked to the facility from surrounding areas for storage; pending treatment using thermal desorption technology. The soil processing equipment heats the soil to temperatures that drive off the petroleum contaminants, which are subsequently destroyed (oxidized) in a secondary afterburner. After soil sampling confirms that the treated soils meet ADEC required cleanup levels, the soils will be transported back to the place of origin or disposed at the soil treatment site. Facility construction activities are scheduled to begin this spring (2002) and soil treatment could continue for three or more seasons. In order to comment on SPI's proposed soil remediation facility, ask questions about the proposed project, or to review any ADEC file information regarding this project, please contact: CPTaul HorwatVEL ADEC Contaminated Site Program 43335 Kalifornsky Beach Road, Suite 11 _,Saldot-na,-Alaska9669„_„, PliOne: (997) 2622torzscv,rot:-2-6-2-294,-, ETTiali: Horwathenviitiat17:state:ak.iis'-. - / Robert Scholze From: Horwath, Paul [Paul_Horwath@envircon.state.ak.us} Sent: Thursday, May 09, 2002 2:19 PM To: Robert Scholze Cc: Horwath, Paul Subject: Soil Processing Incorporated - Soil Treatment Facility Bob: would like to talk with you when you get back to the office regarding the subject plan that ADEC has received for a soil treatment facility to be set up at Brechan Enterprises site in Bell's Flats Subdivision. I talked briefly with Martin Lydick today on the subject. Could you give me a call at 262-5210, x 250 please? Thanks, Paul Horwath Soldotna ADEC cLNILXPk e)-7 05/15/2002 16:54 FAX 9074864889 BRECHAN ENTERPRISES INC Zpoi a Brechan Enterprises, Inc. 2705 Mill Bay Road Kodiak AK 99615 (907) 486-3215 Fax: (907) 486-4889 FAX TRANSMISSION COVER SHEET Date: ,57/.5--ie Z.— To: DLIw Fax: 6-1'39 4 Subject: M R te Sender: t( YOU SHOULD RECEIVE3PAGE(S), INCLUDING THIS COVER SHEET IF YOU DO NOT RECEIVE ALL THE PAGES, PLEASE CALL (907) 486-3215. /15/2002.16:54 FAX 9074864889 RECHAN ENS Eki'RISE5. �nC BRECHAN ENTERPRISES INC a002 BRECHAN ENTERPRISES, /NC / GENERAL CONTRACTORS Z705 MIL. BAY ROAD • KODIAK, ALASKA 99615 December 20, 2001 TO: Borough Manager Patrick Carlson FROM: - Brechan Enterprises Michael Martin RE: Solid Wood Waste Disposal Dear Mr. Carlson: Brechan Enterprises currently has a burn permit #2319 issued February 12, 2001. We believed that this permit allowed us to burn wood waste from construction projects as long as the bum occurred on our property such as our industrial property in Bells Flats, locally called Pit 1. As you know, this has been a common practice with other contractors through out Kodiak and has been a traditional practice for us. It has been brought to my attention that there are residents that have concerns about Brechan Enterprise burning wood material at Pit 1. The first concern brought to my attention has been about hazardous waste. Specifically, Brechan Enterprises has not, and will not intentionally bring hazardous waste to our property for burning or disposal. As an additional insurance onthis issue, we propose using an excavator to separate the large pile of wood into a smaller manageable pile for burning. This will also allow secondary segregation of material in case of inadvertent inclusion of non - permissible burn materials. The second concern was the size of the burn. As noted above, we feel a smaller burn pile will address this concern. Additionally, we will make every attempt to burn during Northwesterly wind direction. Because of our location, this should keep most smoke produced away from residential homes. At the conclusion of the burn, we will load and deliver all burn by- products and all non -burn material to the Borough Landfill. We have contacted D.E.C. in Anchorage, advising of our intent to burn. We believe giving D.E.C. the opportunity to send someone to observe our burn would alleviate PHONE: 907.486.3215 • FAX: 907.485.4889 ALASKA BUSINESS #001 B5B • ALASKA CONTRACTORS #AA441 We Are An Equal OpporluniyEmployer 9/15/2002 16:55 FAX 9074864889 BRECHAN ENTERPRISES INC . . concerns that we may be trying to burn something inappropriate. I also understand that there may be issues with borough landfill dump usage under Borough Code 8.20.030. Brechan Enterprises recognizes the limited space that the Borough has for landfill. We believe that if this section does apply, it is in the bestinterest of Brechan and the borough to allow an exemption to burn this material on our property. To further alleviate resident concerns, Brechan Enterprises would propose that any other large construction project debris be pre-arranged with the borough as whether to use the Borough Landfill or our property for burning. Thank you for you consideration on this matter, Respectfully, Michael R. Martin President of Brechan Enterprises 0003 • February 7, 2002 Michael R. Martin, President Brechan Enterprises, Inc. 2705 Mill Bay Road Kodiak, Alaska 99615 Kodiak Island Borough Finance Department 710 Mill Bay Road Kodiak, Alaska 99615 Phone (907) 486-9320 Fax (907) 486-9399 www.kib.co.kodiak.ak.us Re: Solid waste disposal of building demolition material by open burning on Block 3, Tract A, Bells Flats Alaska Subdivision. Dear Mr. Martin: This letter is in response to your request dated December 20, 2001, requesting approval under KIBC 8.20.030, to allow the above referenced disposal of building demolition material by open burning on your Industrial zoned lot in Bells Flats. Staff has previously reviewed the applicable Borough codes relating to zoning and open burning and found that, subject to the reasonable precautions that would normally be stipulated in a burn permit, there is no reason not to allow your request on that basis. In addition, we recognize that clean air standards are the responsibility of the Alaska Department of Environmental Conservation (ADEC). Should there be any question about the open burning of the type or quantity of demolition material you have stockpiled, you would be well advised to consult with ADEC before beginning the burn. The only issue to be resolved at this time involves the Borough regulations regarding solid waste collection and disposal, as referenced in KIBC 8.20.030. When the solid waste disposal system, i.e. landfill, was originally set up, it was established on the basis of an exclusive road system utility service area. In order to be economically viable and to ensure that the intent of the many state and federal regulations are met, it is essential to be able to control the waste stream to ensure that solid wastes are disposed of properly. KIBC 8.20.030 provides that the Borough finance director may exempt a person from the requirements if he determines that the person requires solid waste collection and disposal service, which cannot be provided by the Borough system. In this instance, there is no question that the Borough cannot provide a collection service for the demolition material. With regard to the disposal service, the Borough could probably provide the service if the material was brought to the landfill on an,incremental basis, however, the Baler/Landfill is not normally staffed to handle and dispose of a extremely large quantities of demolition material if it is delivered in a relatively short time frame. Of course if the material were delivered, it would eventually be disposed of in the most .efficient and economic manner possible, however this might require staging the material at the landfill until it can be systematically evaluated and disposed of. The bottom line is that it might end up sitting at the landfill for a while until it could be incorporated into the day - to -day operations of the baler /landfill. Under these circumstances, the Borough is willing to grant an exemption, as permitted by KIBC 8.20.030, in order to allow the disposal of demolition material by open burning on your site, subject to the following: 1. This approval is in response to a specific request, at a specific date and time and, as such, it does not constitute a waiver of KIBC 8.20.030 for the purpose of future disposal plans on Block 3, Tract A, Bells Flats Alaska Subdivision. This exemption does not establish a precedent to be used for future requests, but is based upon the specific proposal contained in the letter dated December 20, 2001 and the staff judgment of Borough baler /landfill capabilities available at the time of this request. Similar requests in the future will be handled on a case -by -case basis based on the circumstances of the request that are existing at that time and will be approved or denied on merits of the individual request and the ability of the Borough to provide the requested solid waste collection and disposal service. 2. The exemption is approved subject to the representations contained in the letter dated December 20, 2001, from Brechan Enterprises spelling out the manner in which the demolition building material will be disposed of and indicating an understanding of the applicable regulations with regard to bum permits and clean air requirements as they apply to open burning. 3. The bum activity will be monitored at all times in conformity with a bum permit issued by the local fire marshal, as required for all open burning of this nature. 4. Block 3, Tract A, Bells Flats Alaska Subdivision is no longer a permitted disposal site recognized by ADEC and it does :-riot appear that it was ever permitted as a disposal site for open burning of material. As a result, the residual waste products that result from the open burning should be removed from the bum site at the conclusion of the bum and delivered to the landfill for appropriate disposal. As mentioned in your letter, we anticipate that future burns will be prearranged through the Borough, preferably prior to the actual stockpiling of building demolition material on the site. As alluded to above, there does not appear to be a procedure for a blanket exemption and it appears that a new determination under KIBC 8.20.030 is required for each similar disposal that you anticipate in the future. If you have any questions about this determination, or require additional information about Borough codes and regulations, please feel free to contact me for assistance. Sincerely, Wyva Karleton Short, Finance Director : Patrick S. Carlson, Manager Andy Nault, Fire Marshal Dale Rice, Womans Bay Fire Chief Alaska Dept. of Environmental Conservation 0445,0 &tie/24frae5 86-507/5~ ligefite &ST° k 1/99eMe otedme009- C is : ;(*Za lio,(,y &G9-65 t C vvrmee2 (ea Le /eVa'& c, jb o<e ( `, r�5 iv-) � Y e 0,,6 _vo Wes` kl�p ip, mit --pr Dec 18 01 01:12p 11 I\ i ;' C_ ! ti !— Dour Mathers 1 907 -406 -8071 ..�'. . .._ r'.:.r � r DEPT. OF ENVIRONMENTAL CONSERVATION DIVISION OF ENVIRONMENTAL HEALTH SOLID WASTE PROGRAM 555 CORDOVA STREET ANCHORAGE, ALASKA 99501 bttp://www.state.atus/dedhome.htm June 17, 1997 Mr. Bill Oliver Brechan Enterprises 2705 Mill Bay Road Kodiak, Alaska 99615 Re: Expired Solid Waste Disposal Permit No. 8621 -13A019 Dear Mr, Oliver: v . TONY KNOWLES, GOVERNOR Telephone: (907) 269 -7590 Fax: (907) 269 -7655 ),JeLLATt— _ Recently we received an inquiry about waste disposal activities in the Bells Flats area of Kodiak Island. We have reviewed our records and wanted to notify you that the solid waste disposal permit (No. 8621- BA019) issued to Brechan Enterprises has expired. The expired permit, issued to Brechan Enterprises on May 7, 1987, allowed the disposal' of inert debris"in:an'area known as Bells Flats. The referenced permit prohibited the disposal of metals; garbage; asphalt, braiiy other leachable waste. Please provide the required documentation described in the permit showing the closure conditions have been met. Also, be aware that a permit issued by our Department is required to dispose of solid waste. This is separate from, and may be in addition to, a Conditional Use permit which may be required by the Kodiak Island Borough. If Brechan Enterprises has a future need to dispose of limited volumes of inert waste, you may want to apply for coverage under our General Permit for this type of operation, otherwise an individual permit will be required. Permit applications are available at ADEC's offices or if you request we can send one to you. If you have any questions or need additional information, please do not hesitate to call me at above phone number. Sincerely, Laura Solid Waste Program Coordinator cc: Bill,Rieth, ADEC /Anchorage Everett Stone, ADEC/Kodiak Linda Freed, KIB , • • '.\;:". I" ft. • ;Fs- ,l`47 +i1' A,? �ii b' ?' • \clis a�. • DRAFT Offsite Portable Soil Treatment Operations Plan 20 June 2001 Prepared for Cascade Environmental Prepared by Montauk Environmental Engineering Dec 10 01 01:12p ,••••, I • p.m. IA‘ ; 71 I 't I i 1■■■7: J Doug Mathers 907-486-8071 7 4•4 t .v, : ; kk I . .■•• DEPT. OF ENVIRONMENTAL CONSERVATION DIVISION OF ENVIRONMENTAL HEALTH SOLID WASTE PROGRAM 555 CORDOVA STREET ANCHORAGE, ALASKA 99501 littp://www.state.ak.us/dee/home.htm June 17, 1997 Mr. Bill Oliver Brechan Enterprises 2705 Mill Bay Road Kodiak, Alaska 99615 Re: Expircd Solid Waste Disposal Permit No. 8621-13A019 Dear Mr. Oliver: . TONY KNOWLES, GOVERNOR p. 1 Telephone: (907) 269-7590 Fax: (907) 269-7655 2_ Recently we received an inquiry about waste disposal activities in the Bells Flats area of Kodiak Island. We have reviewed our records and wanted to notify you that the solid waste disposal permit (No. 8621-13A019) issued to Brechan Enterprises_ has expired. ,Thtexpired permit, issued to Brechan Enterprises on 'May 2, 1987,"allosVed the disposal of inert 'debris-in-in:area known as Bells Flats. The-referenced permit piinits;iiea iaisfiosa1' 3f dirbige; *hear, realiY other leachable waste. Please provide the required documentation described in the permit showing the closure conditions have been met. Also, be aware that a permit issued by our Department is required to dispose of solid waste. This is separate from, and may be in addition to, a Conditional Use permit which may be required by the Kodiak Island Borough. If Brechan Enterprises has a future need to dispose of limited volumes of inert waste, you may want to apply for coverage under our General Permit for this type of operation, otherwise an individual permit will be required. Permit applications are available at ADEC's offices or if you request we can send one to you. If you have any questions or need additional information, please do not hesitate to call me at above phone number. - Sincerely, ailed Laura Ogar Solid Waste Program Coordinator cc: Bill Rieth, ADEC/Anchorage Everett Stone, ADEC/Kodiak Linda Freed, KIB DRAFT Offsite Portable Soil Treatment Operations Plan 20 June 2001 Prepared for Cascade Environmental Prepared by Montauk Environmental Engineering Table of Contents Section Page. 1.0 Proposed Operation 1 2.0 General Information 1 3.0 Sampling and Analysis Plan (SAP) 4.0 Work Plan 8 5.0 References 10 Tables I Project Cleanup Standards 2 II Stockpile Samples Collected, etc 3 III Sampling Plan 6 Figures 1 Site Plan 4 2 Treatment Plant Design and Liner Detail 5 1.0 Proposed Operation Cascade Environmental (Cascade) requests the approval of the State of Alaska Department of Environmental Conservation (ADEC) to: 1. Transport approximately 400 tons (267 cubic yards) of petroleum-oil-lubricant (POL) contaminated soil from a nearby Remedial Action (RA) site to the treatment site, and; 2. Conduct a trial treatment of contaminated soil by a chemical oxidation method in accordance with the requirements of 18 AAC 75.365 and to the cleanup standards of 18 AAC 75.341. 2.0 General nformafion 2.1 Proposed Treatment Method: Cascade proposes to treat contaminated soil ex situ by a chemical oxidation method (the Soilsaver Process) developed by Big Blue, Inc. (BBI, a soil remediation equipment manufacturing company from Bixby, Oklahoma and holder of the Soilsaver Process patent). In the Soilsaver Process, excavated soils are fed into a mixing mill where they are combined with an ionized water and potassium permanganate (KMnO4, the oxidizer, at an approximate rate of 0.00625 mg/Kg of soil) solution. The resulting mixture is stockpiled and allowed to develop for 24-48 hours,. during which time POL constituents are theoretically broken down into the products manganese dioxide (Mn02), potassium carbonate (K2CO3), carbon dioxide (CO2) and water (H20). DRAFT Soil Treatment Operations Plan 1 Cascade Environmental 20 June 2001 2.2 Treatment Level: Soil will be treated to the following standards: Table I: Project Cleanup Standards Analyte Cleanup Level (mg/Kg) Regulatory Source Residual range organics 2000 18 AAC 75.341 Method One, Category A Diesel range organics 100 18 AAC 75.341 Method One, Category A Gasoline range organics 50 18 AAC 75.341 Method One, Category A Benzene 0.02 18 AAC 75.341 Method Two, Over 40" Zone Migration to Groundwater Toluene 4.8 18 AAC 75.341 Method Two, Over 40" Zone Migration to Groundwater Ethylbenzene 5 18 AAC 75.341 Method Two, Over 40" Zone Migration to Groundwater Xylenes 69 . 18 AAC 75.341 Method Two, Over 40" Zone Migration to Groundwater DRAFT Soil Treatment Operations Plan 2 Cascade Environmental 20 June 2001 2.3 Contaminated Soil Source and Characterization: The source of the test's 400 tons is an approximately 6,500-ton heating oil and diesel fuel-contaminated stockpile. The stockpile was formed during the execution of the Jacobs Engineering Group Inc. (JE) Buskin Beach Spill RA project at the United States Coast Guard (USCG) Base located on the Nyman Peninsula; Kodiak, Alaska, approximately five miles from the proposed treatment site. The Buskin Beach Spill RA project is a Delivery Order under JE's Total Environmental Restoration Contract (TERC) with the United States Army Corps of Engineers (USAGE). Table 11 presents analytical results from the two stockpile samples made available by JE. Additional pre-treatment samples are planned (see the Sampling and Analysis Plan, Section 3.0). Table II: Stockpile Samples Collected 28 February 2001, Analyzed by CT&E Sample No. BTEX (mg/Kg) Diesel Range Organics (mg/Kg) Residual Range Organics (mg/Kg) KOA900201 < 0.12 3170 4610 KOA900202 < 0.11 6550 10500 2.4 Treatment Facility Location: The proposed treatment plant is to be placed upon an approximately one million square foot industrial lot (the site of a former gravel pit and asphalt plant) located within the City of Kodiak Alaska (Tract A, Block 3, Bell Flat Subdivision), owned and operated by the construction firm Brechan Enterprises. The portion of the lot occupied by the treatment plant sits approximately 25 feet below surrounding grade. A small pond of exposed groundwater is located on the southeastern end of the lot, approximately 250 feet from the proposed treatment plant. A private water well used to supply the former asphalt plant is located approximately 250 feet southeast of the proposed plant. Orbin Lake is located approximately 450 feet southwest of the treatment plant. DRAFT Soil Treatment Operations Plan 3 cascade Environmental 20 June 2001 DRAFT Soil Treatment Operations Plan Cascade Environmental 20 June 2001 tH°T Cascade Soil Treatment Operations Plan Figure l: Site Plan Approx. Scale 1" = 150' Montauk HE Drawl by CJE 4 Secure top cover and bottom liner against outboard toe of berm with sandbags _ or clea n soil Top corer, 6 -mil HDPE factory-seam ed Wooden pallet placed over sump to s upport top cover Pre/post- treatment soil, max. ht 10' Sloped toward sump --► Groun d Iere I, a rea under bottom liner free of debris , large Liner, and/or sharp stones 20 -mil HDPE factory seam ed Berm min. 1' X 2' base, clean debris -free soil Liner, 10 -mil HDPE factory seamed Leachate collection sum p (3).3' X2' deep) Typ. Liner for Stoc kpil es a nd Treatment Ma chin ery Water from pond NR Valve Water ionizer 500 gal. ionized water tan k Water filter Sump Sloped tovterd sump Treated stockpile PIP) • Mang tank Mang tan k Treatment Plant Liner Ming (Pug) mill Liner f- Conveyor belt Hopper Ionized water and oxidizer d elivery s prayer Liner Untreated, contaminated soil w ti ) Hopper DRAFT Soil Treatment Operations Plan Cascade Environmental 20 June 2001 Cascade Sal Treatment Operations Plan Figure 2: Treatment Plant Design and Liner Detail (Not to Scale) Montauk E/E Drawn by CJE 5 3.0 Sampling and Analysis Plan (SAP) 3.1 Sampling Objectives: Field and laboratory soil samples will be collected in accordance with Table II: Table III: Sampling Plan Sample Type Purpose Analysis 1 Method Rate Collection Process Field soil , Select sampling points Headspace method by PID 1 per 100 square feet from surfaces, 1 per 10 cubic yards from stockpiled soil Grid method, from stockpile as being formed, or geometrically from existing stockpile, min. 18" depth Laboratory soil Record baseline chemical data from stockpile and treatment plant footprints GRO/AK101 BTEX/8021B DRO/AK102 RRO/AK103 2 samples each stockpile (pre- and post- treatment) footprint and 2 samples from beneath treatment machinery footprint 10' x 10' grid laid over each footprint, field sample collected from center of each grid iteration and analyzed by headspace method; highest 2 readings selected as lab' sampling points Laboratory soil Record pre- and post-treatment stockpile chemical data (267 cy assumed) . GRO/AK101 BTEX/8021B DRO/AK102 RRO/AK103 5 samples each stockpile . Each stockpile field screened at the rate of one sample per 10 cubic yards as formed, or samples collected geometrically at same rate from pre-formed stockpile; highest 5 readings selected as lab' sampling points Laboratory soil Record post- construction chemical data from stockpile and treatment plant footprints GRO/AK101 BTEX/8021B DRO/AK102 RRO/AK103 2 samples each stockpile (pre- and post treatment) footprint and 2 samples from beneath treatment machinery footprint 10' x 10' grid laid over each footprint, field sample collected from center of each grid iteration and analyzed by headspace method; highest 2 readings selected as lab' sampling points Key: BTEX Benzene, toluene, ethylbenzene and total xylenes by Test Method 8021B cy Cubic yards DRO , Diesel range organics by Test Method AK102 GRO Gasoline range organics by Test Method AK101 PID Photoionization detector RRO Residual range organics by Test Method AK103 DRAFT Soil Treatment Operations Plan 6 Cascade Environmental 20 June 2001 3.2 Methodology: Field and laboratory soil samples will be collected and analyzed by the methods presented in the Underground Storage Tanks Procedures Manual (1 December 1999. ADEC), the "Procedures Manual." Field and laboratory data quality, quality control requirements and reporting will be in accordance with the Procedures Manual. DRAFT Soil Treatment Operations Plan 7 Cascade Environmental 20 June 2001 4.0 Work Plan 4.1 Controlled Area: Treatment plant and stockpile areas will be surrounded by hazard tape to create an Exclusion Zone (EZ). Only authorized personnel will be permitted within the EZ. The EZ is depicted on Figure 1. 4.2 Decontamination: All equipment and personnel must be decontaminated before exiting the EZ. A Decontamination Zone (DZ, see Figure 1) consisting of 10 mil polyethylene will be constructed to straddle the EZ and work area. Equipment and personnel will be carefully inspected for contaminated soil. Contaminated soil will be dry-brushed from equipment and clothing. Decontamination-produced contaminated soil will be retumed to the contaminated stockpile. 4.3 Contaminant Control: Contaminated (pre-treatment) and post-treatment soil stockpiles will be constructed at the treatment. site. The treatment plant will be set atop a bermed liner. Liners will conform with the specifications in 18 AAC 75.370 Table D. Stockpiles will be constructed to shed water and withstand gusty wind conditions. Stockpiles will be inspected daily by Cascade to ensure they meet these requirements. If deficiencies exist, they will be corrected immediately. The treatment plant and stockpiles will be constructed as per Figure 2. 4.4 Transportation: Approximately 400 tons of POL-contaminated soil will be loaded aboard dump trucks at the. RA project site by front-end loaders. Care will be taken that contaminated soil does not spill from loader buckets, and that loader tires do not transport contaminated soil. When loading is complete, each dump truck will be covered and inspected to ensure contaminated soil does not spill from the bed, frame, tires or other truck surfaces. Loaders will be dry-brush decontaminated. DRAFT Soil Treatment Operations Plan 8 Cascade Environmental 20 June 2001 4.5 Treatment Narrative • Water will be supplied by the exposed groundwater pond. The water hose between the lake and ionization unit will be fitted with an automatic one-way valve to prevent back-flow of the water and potassium permanganate solution. • Leachate will be collected from a sump at the corner of the post-treatment stockpile and treatment plant liner, filtered, and retumed to the system. • Contaminated soil will be moved by front-end loader or excavator from the contaminated (pre-treatment) stockpile to the treatment plant hopper. From the hopper, two conveyor belts will move the contaminated soil to the Mixing (Pug) Mill, where the oxidizer and ionized water solution will be pumped onto the soil as it is being agitated. A third conveyor will move the moistened soil to a temporary holding area, where a front-end loader will transport the soil from the treatment plant to the post-treatment stockpile. The post- treatment stockpile will be covered and allowed to develop for 24-48 hours. Figure 2 depicts the major mechanical components of the treatment plant. • Post-treatment and post-construction chemical data will be collected, analyzed and reported. DRAFT Soil Treatment Operations Plan 9 ,Cascade Environmental 20 June 2001 5.0 References ADEC. 1 December 1999. Underground Storage Tanks Procedures Manual • • • ADEC. 27 August 2000. 18 AAC 78 Underground Storage Tanks as Amended Through August 27, 2000. • ADEC. 28 October 2000. 18 AAC 75 Oil and Other Hazardous Substances Pollution Control as Amended Through October 28 2000. Florida DEC. 25 April 1997. Letter to Universal Environmental Technologies, Inc. DRAFT Soil Treatment Operations Plan 10 Cascade Environmental 20 June 2001 • Jennie. Sharpe, CEO Soil Processing Inc. 207 E. Northern Lights Blvd. Suite 103 -A Anchorage, AK 99503 Dear Ms. Sharpe OFFICE of the MANAGER 710 Mill Bay Road . Kodiak, Alaska 99615 Phone (907) 486 -9301 Fax (907) 486 -9374 E- mail: 1whiddon@kib.co.kodiak.ak.us March 28, 2003 RE:. KIB .Permit Review of SPI Kodiak Operation. I am writing in response to your letter of March. 26, 2003 requesting my office to initiate the review process stipulated to in our agreement letter of November 14, 2002. I would incorporate by reference the attachments in support of my finding that you are in compliance with existing permits and operational requirements. As you know, my finding is contingent on a final inspection and approval by the State Fire Marshall's office prior to beginning operations. Based on my review of your application and supporting letters, I conclude you are in compliance with KIB requirements and may proceed. This letter assumes and requires you maintain full compliance with all applicable laws and maintain your approved permit status with ADEC during the operational timeframe. Thank you for your patience with the review process and please let me know if you have any questions. Sincerely Kodiak Island Borough Pat Carlson, Manager Attachments: Letter SPI of 3/26/03 Fire Marshall Inspection. Letter ADEC of 3/19/2003 approving operations plan. Letter ADEC of 3/17/03 confirming permit to operate. Cc: ADEC Bob Cannone, Compliance Supervisor ADEC Jim Prechione, Enviromental Manager BEI Mike Martin, President JKIB Duane Dvorak, Community Development \\dove \users \pcarlson\SPI Letter 32003.doc Page 1 of 1 PROCESSING INCORPORAL1) PORTABLE THERMAL UNITS • OILFIELD SERVICES • ENVIRONMENTAL CLEANUP Patrick S. Carlson Kodiak Island Borough 710 Mill Bay Road Kodiak, AK 99615 March 26, 2003 Mr. Carlson, RE: Continuation of Soil Remediation Permit Review As per, the letter dated November 14, 2002, Soil Processing Inc. (SPI) is submitting to a permit review to the Kodiak Island Borough (KIB) prior to beginning operations at the Brechan Industrial site. SPI will request Andy Nault to inspect the LPG fuel storage and fire suppressant' equipment. SPI will install a barrier next to the LPG tankers on the driveway side. SPI will continue to provide test results to KIB. SPI, will continue to comply with the rules and regulations in the General Permit 4 and Air Quality Permit, both issued by the Alaska Department of Environmental Conservation. If you have any questions, please don't hesitate to call. 207 E. Northern Lights Blvd., Suite 103A • Anchorage, AK 99503 Telephone (907) 274-3000 FAX (907) 274-9295 itati\S[liKc ifF\ ("FRANK H. MURKOWSKI, GOVERNOR 555 Cordova Street Anchorage, AK 99501-2617 Phone: (907) 269-7658 Fax: (907) 269-7649 http://www.state.ak.us/dec/ DEPT. OF ENVIRONMENTAL CONSERVATION DIVISION OF SPILL PREVENTION AND RESPONSE CONTAMINATED SITES PROGRAM March 19, 2003 George Cline Soil Processing, Inc. 207 East Northern Lights 103A Anchorage, AK 99503 RE: Soil Processing Inc. - Treatment Facility Tract A, Block 3, Bells Flats Alaska Subdivision, Kodiak Island Borough, Alaska Dear Mr. Cline: The Department has received a request from your company for a letter regarding the status of the operations plan approval issued on July 19, 2002 for the Bells Flats soil treatment facility. Based on the information to date, Soil Processing Inc (SPI) has complied with the terms and conditions of the 2002 operations plan and with 18 AAC 75.365 and 18 AAC 78.273 regulations during their period of operation. It is-our understanding that SPI plans to continue soil treatment operations at the Bells Flats site during the 2003 field season. Please note that the operations plan was approved for a period of one year - from the date that the facility first received soil. Even though the plan approval was issued in July 2002, the Department's decision was appealed resulting in an informal review of the process. An August 29, 2002 decision determined that the process was valid and approved the facility to operate. It is the August 29, 2002 date that serves as the beginning of the one year time period to operate. However, if you did not receive soil until some time after this date and you have documentation to substantiate this fact, the date of operations might be extended to account for this matter. If this is the case, please provide this information to the Department so we could review it. It should also be noted that the July 2002 operations plan approval letter recognized that the Department would be reviewing the SPI facility for compliance during the first year of operation and make a decision regarding its continued operation at the Bells Flats site. The right to .extend the period of operation and/or modify the plan approval conditions was reserved until the facility was evaluated in accordance with the terms and conditionsof the operations plan and the regulations: It is our intent to inspect the facility periodically during the 2003 operating season and determine compliance with the operations plan and the regulations governing this activity. 1.4,1 Printed on Recycleti 03/17/03 10:21 FAX 90743; 7 ADEC AWQ PBE9 A J ,1\W DBM OF AAA R AiND WATTEER QUASUTY ,ATION March 17, 2003 Mr. George a Cline Soil Processing Incorporated 207 B Northam Tighe Blvd., Suite 103 Anchorage, AK 99503 Dear Mr. Cline: P.FJ1 001/001 FRANK MNIRKOWSIO, GOVERNOR 610 Univcreity Ave=R= Fairbanks, hit 99709.3643 Directors Offcc:(907) 269 -7636 Fairbanks Otticer (907) 451.2360 Pox: (907) 431 -2117 httpIlrrww.s de.akuildaer RECEIVED MAR '17 2003 KIB MANAGER I stn responding to your March 17, 2003 verbal request seeking confirmation that ow November 13, 2002 letter is still valid. The November 13, 2402 letter indicated that the department had accepted the result of your latest source test and that you were able to operate under the terms of General Permit 4. I have reviewed this letter and find it ie still valid. Please contact Severely Williams at (907) 269 -7574 if you have any questions concerning this matter. Sincerely, irkt/ Robert P. Cannone Air Permit Compliance Supervisor cc: Kodiak Borough, 710 Mill Bay Rd, Kodiak AK 99615 Bev Witham, ADEC/APP /Compliance! Anchorage 900.16.082 Air, Clean Water 03/17/03 16:07 FAX 907451T ADEC AWC1 FBAS IL= DEPT. OF ENVIRONMENTAL CONSERVATION DIVISION OF AIR AND WATER QUALITY Mr. George 11. Cline Soil Processing Incorporated 207 E Northern Lights BlycL, Suite 103 Anchorage, AK 99503 :Dear Mr. Cline; March 17, 2003 1Z1 o o FRANK MURKOWSKI, GOVERNOR 610 University Avenue Fairbanks, AK 99709-3643 Director's Office:(907) 269-766 Fairbanks Office: (907) 451-2360 Fax: (907) 451-2187 http://www.state.ak.uskieci I am responding to your March 17, 2003 verbal request seeking confirmation that our November 13, 2002 letter is still valid_ The November 13, 2002 letter indicated that the department had accepted the result of your latest source test and that you were able to operate under the Willis of General Permit 4. I have reviewed this letter and find it is still valid. Please contact Beverely Williams at (907) 269-7574 if you have any questions concerning this matter. Sincerely, Robert P. Cannone Air Permit Compliance Supervisor cc: Kodiak Borough, 710 Mill Bay Rd. Kodiak AK 99615 Bev Williams, ADEC/APP/Compliance/ Anthorage 900.16.082 Clean Air, Clean Water DEPT. OF ENVIRONMENTAL CONSERVATION DIVISION OF SPILL PREVENTION AND RESPONSE CONTAMINATED SITES PROGRAM KENAI AREA OFFICE George Cline Soil Processing, Inc. 207 East Northern Lights 103A Anchorage, AK 99503 August 13, 2002 TONY KNOWLES, GOVERNOR 43335 K-Beach Road Suite 11 Red Diamond Center Soldotna, Alaska 99669 Phone: (907) 262-5210 Fax: (907) 262-2294 .11ECEIIVIE 11 AUG 1 6 2002 woman DEVELOPMENT DEPAR1TVENT RE: Soil Processing Inc., Soil Treatment Facility Tract A, Block 3, Bells Flats Alaska Subdivision, Kodiak Island Borough, Alaska Conditional Approval to Receive and Treat Soil Dear Mr. Cline: On July 12, 2002, the Kenai Area Office of the Alaska Department of Environmental Conservation (ADEC) received the May 2002 Category C Facility Operations Plan, Thermal Remediation of Petroleum-Contaminated Soils at Brechan Enterprises Inc. Industrial Site, Bells Flats, Kodiak, Alaska. This Operations Plan was prepared by Soil Processing Inc. (SPI), and included engineering plans for containment structures, which were prepared by George Wilson, P.E. The Operations Plan provides the information required under 18 AAC 75.365 and 18 AAC 78.273 for a Category C soil treatment facility. The Operations Plan describes the soil management and treatment processes and the standard operating procedures that will be used in order to contain contaminated soil and water. It also outlines the general operation and maintenance provisions for this facility. ADEC issued conditional approval of this Operations Plan, for purposes of constructing the facility, with its letter dated July 19, 2002. Since July 12, 2002, ADEC has received the following, required deliverables: • On August 9, 2002, the Kenai Area Office of the Alaska Department of Environmental Conservation (ADEC) received written verification from George Wilson, P.E., that the soil storage cell for your subject soil treatment facility had been constructed in substantial compliance with the original ADEC approved plans. We also received two record drawings, sealed and signed by Mr. Wilson, dated August 8, and 9, 2002. • On August 9, 2002, we received written confirmation from Ms. Jeannie Fabiano that the background assessment sampling had been completed under the contaminated soil storage cell. • On August 12, 2002, we received written confirmation from Mark Blakeslee, P.E., that the background assessment sampling had been completed at the discharge auger and treated soil stockpile locations. • On August 12, 2002, we also received three surveyed plan drawings and a cover letter sealed and signed by Mr. Mark St. Denny, RLS, of the contaminated soil storage cell. The three drawings were labeled Original Grade, Top of Sub Grade, and Finish Grades, and provide the elevation control for the construction of the soil storage cell. SPI — Kodiak Soil Treatment Facility 2 August 13, 2002 SPI's Bells Flats, Kodiak soil treatment facility is hereby approved to receive and treat contaminated soils in accordance with the six (6) conditions of approval identified in ADEC's July 19`h, conditional approval letter. Please note that we have not received a pre- operations, background site assessment report for this facility. We understand that the samples have been collected, and we will await the receipt of this- report,- signed;,by Ms. Fabiano or Mr. Blakeslee. ;5 ; i'3 °Also; "we °heve°no received an application for a nondomestic wastewater permit authorization under ADEC Wastewater General Permit No. 0240- DB001. Therefore SPI has no ADEC approval or authorization to dispose of nondomestic wastewater to the land or waters of the State (this comment refers to the disposal, of the settling pond water described in Section 7.3 of - the.Operations4Plan). Mr. Oran Woolley in ADEC's Soldotna office (262 -5210 x227) should be !', r con'tat ted' nkiitervfo `o_ itain _this_permit_authorization. _ A fee of approximately $230.00 is required prior to the issuance o the permit authorization. ADEC reserves the right to require modifications, or additions, to this Operations Plan as statutes, regulations, test methods, or other circumstance warrants. Any operational changes to this plan must be approved by ADEC prior to implementation, with any subsequent revisions and updates submitted as an addendum to the plan. Access to the facility by ADEC representatives shall be provided promptly and at any reasonable time, in order to conduct inspections or tests to determine compliance with this Operations Plan, and State environmental laws and regulations. ADEC will place your Kodiak facility on a list of approved soil treatment facilities. Failure to manage and process soils, and operate in compliance with .your conditionally approved Operations Plan may result in the withdrawal of ADEC approval to receive or process petroleum contaminated soils, and removal of your facility from this list. Feel free to contact us if there are any questions regarding this correspondence, or any other aspect of your Operations Plan or soil treatment facility. Sincerely, Paul- Horwath, P.E. Environmental Engineer pdh.SPlAugustl3, 2002 Accept&Treat Approval.doc C: Jim Frechione, ADEC, Anchorage Cynthia Pring -Ham, ADEC, Juneau George Wilson, P.E., Anchorage Duane Dvorak; Kodiak - Island- Borough - Community Development-Department -� hc' FA\ cD DEPT. OF ENVIRONMENTAL CONSERVATION DIVISION OF SPILL PREVENTION AND RESPONSE CONTAMINATED SITES PROGRAM July 19, 2002 George Cline Soil Processing, Inc. 207 East Northern Lights 103A Anchorage, AK 99503 RE: Soil Processing Inc., Soil Treatment Facility Tract A, Block 3, Bells Flats Alaska Subdivision, Kodiak Island Borough, Alaska Soil Treatment Facility Operations Plan, Conditional Approval TONY KNOWLES, GOVERNOR 555 Cordova Street Anchorage, AK 99501 PHONE: (907) 269-7566 FAX: (907) 269-7649 http://www.state.ak.usidec/home.htm Dear Mr. Cline: On July 12, 2002, the Kenai Area Office of the Alaska Department of Environmental Conservation (ADEC) received the May 2002 Category C Facility Operations Plan, Thermal Remediation of Petroleum-Contaminated Soils at Brechan Enterprises Inc. Industrial Site Bells Flats, Kodiak, Alaska. This Operations Plan was prepared by Soil Processing Inc. (SPI), and includes engineering plans for the containment structures, which have been prepared by George Wilson, P.E. The Operations Plan provides the information required under 18 AAC 75.365 and 18 AAC 78.273 for the proposed Category C soil treatment facility. The Operations Plan describes the soil management and treatment processes and the standard operating procedures that will be used in order to contain the contaminated soil and water. It also outlines the general operation and maintenance provisions for this facility. This Operations Plan is hereby approved for purposes of construction, contingent upon compliance with the following conditions: 1) The Operations Plan is approved for a period of one year from the date that contaminated soils are first received at the facility. ADEC will monitor the facility during this period of time and reserves the right to extend and/or modify the approval of its operation. 2) Within 45 days of completion of construction of the soil storage cell (also described as Contaminated Soil Temporary Stockpile Slab Design on Figure 6 of the Operations Plan), record-drawings, sealed and signed by a professional engineer, must be submitted verifying that the soil storage cell has been constructed in accordance with the ADEC approved plans. Record drawings are defined as the original plans prepared for construction and department approval, revised to reflect how the soil containment structure was actually installed. SPI — Kodiak Soil Treatment Facility 2 July 19, 2002 3) A background assessment report, signed by the 'qualified' impartial third party performing the work, must be submitted to the ADEC within 45 days of the date that the associated soil samples are collected. 4) The ADEC may require periodic sampling work to be performed and reported by a qualified impartial third party, in order to monitor for secondary contamination at this treatment facility. This may be required annual (or more frequent) sampling and may require the collection and analysis of soil samples, groundwater and/or surface water samples. 5) SPI shall not leave contaminated soil stored at the facility for a period exceeding 30 consecutive days if contaminated soil is not being treated. Written ADEC approval is required for any exceptions to this condition. 6) Prior to the disposal of nondomestic wastewater (settling pond water) proposed and described in Section 7.3 of the Operations Plan, SPI must obtain a permit authorization under ADEC Wastewater General Permit No. 0240-DB001. Mr. Oran Woolley in the ADEC's Soldotna office (262-5210 x227) should be contacted in order to obtain this permit authorization. A fee of approximately $230.00 is required for the issuance of the permit authorization. This letter does not constitute ADEC approval to accept and treat contaminated soil at this facility. Prior to the ADEC issuing approval to accept and treat contaminated soil from the ADEC project manager(s), SPI must provide the following documentation: A) Written verification from a registered professional engineer that the soil treatment cell was constructed in substantial compliance with the approved plan, or the final record drawings must be submitted to the ADEC. The written verification approach could serve as an, interim verification of the sufficiency of the constructed cells in order to obtain ADEC approval to begin placing contaminated soil in the cell during the interim period between completion of construction-of the-cell and-the time that formal record-drawings can be prepared and submitted to the ADEC. 13) Written confirmation that the background assessment has been conducted (the required background assessment soil samples have been collected). The ADEC reserves the right to require modifications, or additions, to this Operations Plan as statutes, regulations, test methods, or other circumstance warrants. Any operational changes to this plan must be approved by the ADEC prior to implementation, with-any subsequent revisions and updates submitted as an addendum to the plan. Access to the facility by an ADEC representatives shall be provided promptly and at any reasonable time, in order to conduct inspections or tests to determine compliance with this Operations Plan and/or State :.,-zenvIttlffijelifanTws;and-r-e-gulations. • *.• SPI — Kodiak Soil Treatment Facility July 19, 2002 Upon ADEC issuance of an approval to accept and treat contaminated soils,-we will place your facility on a list of approved soil treatment facilities. Failure to manage and process soils, and operate in compliance with your conditionally approved Operations Plan may result in the withdrawal of ADEC approval to accept or process contaminated soils and removal of your facility from this list. In accordance with 18 AAC 15.185, any person who disagrees with this decision may request an informal agency review by the director of the department's division of Spill Prevention and Response. A request for informal review must be made within 15 days after receiving the department's decision reviewable under this section, and should be addressed to Larry Dietrick, Department of Environmental Conservation, 410 Willoughby Avenue, Suite 105, Juneau, Alaska 99801-1795. In addition, any person who is aggrieved by this decision may request an adjudicatory hearing under 18 AAC 15.200 — 18 AAC 15.920. If any person wishes to request an adjudicatory hearing, the request should be submitted to the Commissioner, Department of Environmental Conservation, 410 Willoughby Avenue, Suite 105, Juneau, Alaska 99801-1795, within 30 days after the date of issuance of this letter, or within 30 days after the department issues a final decision under 18 AAC 15.185. If a review is not requested within 15 days, or if a hearing is not requested within 30 days, the right to appeal is waived, and the decision becomes final. Please contact me at (907) 269-7658 or Paul Horwath at (907) 262-5210 (Ext. 250) if there are any questions regarding this correspondence or any other aspect of your Operations Plan or soil treatment facility. • Jim Frechione, - Contaminated Sites Section Manager cc: Larry Dietrick, Director, SPAR Steve Bainbridge, ADEC Paul Horwath, P.E., ADEC, Soldotna Oran Woolley, ADEC, Soldotna George Wilson, P.E.,Anchorage ipnane Dvorak Kodiak Island Borough ConurninitylDeVelopmentDepartnient Alex Swiderski, AGO DEPT. OF ENVIRONMENTAL CONSERVATION / DIVISION OF SPILL PREVENTION AND RESPONSE CONTAMINATED SITES PROGRAM July 19, 2002 RE: Soil Processing Inc. Bells Flats, Kodiak, Alaska To Whom It May Concern: TONY KNOWLES, GOVERNOR 555 Cordova Street Anchorage, AK 99501 PHONE: (907) 269 -7566 FAX: (907) 269 -7649 http://www.state.ak.usidec/home.htm The Department-ofEnvironmental Conservation, Contaminated- Sites- Program,- has - reviewed an- - - operations plan submitted by Soil Processing Inc. to treat petroleum contaminated soil at a location described as the Brechan Industrial Site, Tract A, Block 3, Bells Flats Alaska Subdivision. Based on the information presented in the applicant's operations plan and in accordance with 18 AAC 75.365 and 18 AAC 78.273, the operations plan is conditionally approved to operate at this location subject to the terms and conditions of the Department's July 19, 2002 approval letter. We recognize the concerns expressed by the local residents in the area regarding this facility and have considered the comments submitted either verbally at the public meeting or those submitted via email and telephone. However, many of the issues raised were related to local zoning and safety rules that are not governed by the Department. These are matters that should be addressed through the local planning and zoning laws. The other issues related to possible environmental impacts from the facility were considered and incorporated as conditions in the approval letter. Also, as a condition of the operations plan approval, the Department has only authorized the facility to operate for a one year period of time (versus three years normally associated with this type of facility). This will allow us to review the facility operations during this time and evaluate their compliance with state laws and regulations. Please be informed that the decision to approve of the operations plan is subject to the administrative appeals procedures under 18 AAC 15.200 - .920. This process allows an aggrieved person to request an informal review within fifteen (15) days from receipt of the decision or a formal adjudicatory hearing within thirty (30) days from receipt of the decision. The Department's approval letter outlines the process and time frames subject to the appeal regulations. If you have any questions or wish to contact me regarding this matter, please call (907)269 -7658 or email at jim frechione @envircon.state.ak.us. Sincerely, Y Jim Frechione Contaminated Sites Section Manager Alaska Department of Environmental Conservation Request for Public Comment on Proposed Soil Remediation Facility to be located at Brechan Enterprises, Inc.'s industrial site, Kodiak, Alaska Comments must be received by (Georze: Insert date one week from date of last publication) The Alaska Department of Environmental Conservation (ADEC) is requesting public comments on an Operations Plan from Soil Processing Incorporated, Inc., (SPI) for DEC approval of a petroleum contaminated soil remediation facility to be located on off Salmonberry Drive on Brechan Enterprises' industrial site property on Block 3, Bell's Flats Subdivision. SPI proposes to construct a soil remediation facility at this site in order to receive and treat contaminated soils under an ADEC approved Operations Plan, in accordance with the provisions of 18 AAC 75.365 and 18 AAC 78.273 (Offsite Treatment Facilities). Soils would be trucked to the facility from surrounding areas for storage; pending treatment using themial desorption technology. The soil processing equipment heats the soil to temperatures that drive off the petroleum contaminants, which are subsequently destroyed (oxidized) in a secondary afterburner. After soil sampling confirms that the treated soils meet ADEC required cleanup levels, the soils will be transported back to the place of origin or disposed at the soil treatment site. Facility construction activities are scheduled to begin this spring (2002) and soil treatment could continue for three or more seasons. In order to comment on SPI' S proposed soil remediation facility, ask questions about the proposed project, or to revidw,any ADEC file information regarding this project, please contact: CP-aul'HorWath- ADEC Contaminated Site Program 43335 Kalifomsky Beach Road, Suite 11 • . ;$014otna, Alaska,99669„, Phone (907) 262752-10;.eXt, .4o;,:t#:: 262-2294 E-mail Pau! Horwath()envirco state ak us FIRE DEPARTMENT 219 LOWER MILL DAY ROAD, KODIAK, ALASKA 99615 July 22, 2002 Soil Processing Inc's Anchorage,- AK 99615 Dear Sir; TELEPHONE (907) 496 -8040 FA)c (907) 486-8048 E C I U U 1 AIL 2 2 r �r COMMUNITY DEVELOPMENT DEPARTMENT In reviewing the information presented during our meeting, the Kodiak Fire Marshal office has approved the procedure plan in dealing with the transfer of propane and the use of the soil burner located in the Bells Flat area. An inspection will be required once all propane systems are in place and prior to start up. Sincerely, Andrew Nault Fire Marshal 07/19/2002 14:46 FAX 907 269 7649 1, /b M u u ADEC ANCHORAGE A rot 1 I jL\ \\ „ IA\ LN DEPT, OF ENVIRONMENTAL CONSERVATION DIVISION OF SPILL PREVENTION AND RESPONSE CONTAMINATED SITES PROGRAM July 19, 2002 George Cline Soil Processing, Inc. 207 East Northern Lights 103A Anchorage, AK 99503 0002/005 TONY KNOWLES, GOVERNOR 555 Cordova Street Anchorage, AK 99501 .PHONE: (907) 269-7566 FAX; (907) 269-7649 htigitarw.,9tate.ak.usidec/honle.h)m RE: Soil Processing Inc., Soil Treatment Facility Tract A, Block 3, Bells Flats Alaska Subdivision, Kodiak Island Borough, Alaska Soil Treatment Facility Opera tons Plan, Conditional Approval Dear Mr. Cline: On July 12, 2002, the Kenai Area Office of the Alaska Department of Environmental Conservation (ADEC) received the May 2002 Category C Facility Operations Plan, Thermal Rernedi ation of Petroleum-Contaminated Soils at Brechan Enterprises Inc. Industrial Site, Bells Flats, Kodiak, Alaska. This Operations Plan was prepared by Soil Processing Inc_ (SPI), and includes engineering plans for the containment structures, which have been prepared by George Wilson, PE _ The Operations Plan provides the infon-nation required under 18 AAC 75.365 and 18 AAC 78.273 for the proposed Category C soil treatment facility. The Operations Plan describes the soil management and treatment processes and the standard • operating procedures that will be used in order to contain the contaminated soil and water. It also outlines the general operation and maintenance provisions for this facility. This Operations Plan is hereby approved for purposes of construction, contingent upon compliance with the following conditions: 1) The Operations Plan is approved for a periocl of one year from the date that contaminated soils are first received at the facility. ADEC will monitor the facility during this period of time and reserves the right to extend and/or modify the approval of its operation.. 2) Within 45 days of completion of construction of the soil storage cell (also described as Contaminated Soil Temporary Stockpile Slab Design on Figure 6 of the Operations Plan), record-drawings, sealed and signed by a professional engineer, must be submitted verifying that the soil storage cell has been constructed in accordance with the ADEC approved plans. Record drawings are defined as the original plans prepared for construction and department approval, revised to reflect how the soil containment structure was actually installed. 07/19/2002 14:46 FAX 907 269 7649 ADEC ANCHORAGE SPI -. Kodiak Soil Treatment Facility IJ 003/005 2 July 19, 2002 3) A background assessment report, signed by the `qualified' impartial third party performing the work, must be submitted to the ADEC within 45 days of the date that the associated soil samples are collected. 4) The ADEC may require periodic sampling work to be performed and reported by a qualified impartial third party, in order to monitor for secondary contamination at this treatment facility_ This may be required annual (or more frequent) sampling and may require the collection and analysis of soil samples, groundwater and/or surface water samples. 5) SPI shall not leave contaminated soil stored at the facility for a period exceeding 30 consecutive days if contaminated soil is not being treated. Written ADEC approval is required for any exceptions to this condition. 6) Prior to the disposal of nondomestic wastewater (settling pond water) proposed and described in Section 73 of the Operations Plan, SPI must obtain a permit authorization under ADEC Wastewater General Permit No. 0240- DE001. Mr. Oran Woolley in the ADEC's Soldotna office (262 -5210 x227) should be contacted in order to obtain this permit authorization. A fee of approximately $230.00 is required for the issuance of the permit authorization. This letter does riot constitute ADEC approval to accept and treat contaminated soil at this. facility. Prior to the ADEC issuing approval to accept and treat contaminated soil from the ADEC project manager(s), SPI must provide the following documentation: A) ' Written verification from a registered professional engineer that the soil treatment cell was constructed in substantial compliance with the approved plan, or the final record drawings must be submitted to the ADEC. The wiitten verification approach could serve as an interim verification of the sufficiency of the constructed cells in order to obtain ADEC approval to begin placing contaminated soil in the cell during the interim period between completion of construction of the cell and the time that formal record drawings can, be prepared and submitted to the ADEC. B) Written confirmation that the background assessment has been conducted (the required background assessment soil samples have been collected). The ADEC reserves the right to require modifications, or additions, to this Operations Plan as statutes, regulations, test methods, or other circumstance warrants. Any operational changes to this plan must be approved by the ADEC prior to implementation, with any subsequent revisions and updates submitted as an addendum to the plan. Access to the facility by an ADEC representatives shall be provided promptly and at any reasonable time, in order to conduct inspections or tests to determine compliance with this Operations Plan and/or State environmental laws and regulations. 07/19/2002 14:46 FAX 907 269 7649 SP! — Kodiak Soil Treatment Facility ADEC ANCHORAGE U1004/005 3 July 19, 2002 Upon ADEC issuance of an approval to accept and treat contaminated soils, we will place your facility on a list of approved Soil treatment facilities. Failure to manage and process soils, and operate in compliance with your conditionally approved Operations Plan may result in the withdrawal of ADEC approval to accept or process contaminated soils and removal of your facility from this list. In accordance with 18 AAC 15.185, any person who disagrees with this decision may request an informal agency review by the director of the department's division of Spill Prevention and Response. Areque,st for informal review must be made within 15 days after receiving the department's decision reviewable under this section, and should be addressed to Larry Dietrick, Department of Environmental Conservation, 410 Willoughby Avenue, Suite 105, Juneau, Alaska 99801-1795. In addition, any person who is aggrieved by this decision may request an adjudicatory hearing under 18 AAC 15200 — 18 AAC 15.920. If any person wishes to request an adjudicatory hearing, the request should be submitted to the Commissioner, Department of Environmental Conservation, 410 Willoughby Avenue, Suite 105, Juneau, Alaska 99801-1795, within 30 days after the date of issuance of this letter, or within 30 days after the department issues a final decision under 18 AAC 15.185. If a review is not requested within 15 da.ys, or if a hearing is not requested within 30 days, the right to appeal is waived, and the decision becomes final. Please contact me at (907) 269-7658 or Paul Horwath at (907) 262-5210 (Ext. 250) if there are any questions regarding this correspondence or any other aspect of your Operations Plan or soil treatment facility. Jim Frechione, Contaminated Sites Section Manager cc: Larry Dietrick, Director, SPAR Steve Bainbridge, ADEC Paul Horwath, P.E., ADEC, Soldotna Oran Woolley, ADEC, Soldotna George Wilson, P.E., Anchorage Duane Dvorak, Kodiak Island Borough Community Development Department Alex Swiderski, AGO CATEGORY C FACILITY OPERATIONS PLAN THERMAL REMEDIATION . OF PETROLEUM-CONTAMINATED SOILS AT BRECHAN ENTERPRISES INC. INDUSTRIAL SITE BELLS FLATS, KODIAK, ALASKA Prepared by, SOIL PROCESSING INC. •' 207 East Northern Lights 103A Anchorage, AK 99503 (907)274-3000 SOIL PROCESSING INC. OPERATIONS PLAN TABLE OF CONTENTS. 1. INTRODUCTION 1 -1 2. SITE DESCRIPTION 2 -1 3. DETAILED PROCESS DESCRIPTION 3 -1 3.1 Overview 3 -1 3.2 Production 3 -2 3.3 Specification of the Processing Equipment 3 -2 3.4 Fuel Requirements 3 -2 3.5 System Controls and Instrumentation 3 -2 3.6 Secondary Combustion Chamber 3 -3 3.7 Particulate Emission Control 3 -3 3.8 Additives 3 -3 3.9 Settling Pond Cleanup 3 -3 3.10 Permitting and Air Emissions 3 -3 4. CONTROL AND CONTAINMENT OF CONTAMINATED SOIL 4 -1 4.1 SPI Requirements for Acceptance of Contaminated Soil 4 -1 4.2 Delivery and Handling of Soil at the Site 4 -2 4.3 Control and Tracking of Soils 4 -2 4.4 Design of Soil Storage Cell for Untreated Soil 4 -3 4.4.1 New Cell Construction 4 -3 4.4.2 Cover 4-4 4.4.3 Treated Soil Stockpile Area 4-4 4.5 Disposal of Treated Soils 4-4 5. SITE MONITORING PROCEDURES 5 -1 5.1 General 5 -1 5,2 Excess. Water at Storage Cell 5 -1 5.3 Equipment Fuel Storage and Handling 5 -1 6. SAMPLING, TESTING, AND REPORTING 6 -1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN TABLE OF CONTENTS (continued) 7. SITE CLOSURE 7 -1 7.1 Background Assessment 7 -1 7.2 Closure 7 -1 7.3 Sample Schedule 7 -2 7.4 Final Report 7 -3 LIST OF ATTACHMENTS A QUALIFYING DOCUMENTS BEI Letter Re: Permission to Operate Air Quality Operating Permit ADEC Relocation Permit Public Notification Letter B FIGURES C CONTINUOUS EMISSION MONITORING SYSTEM MATERIAL SPECIFICATION SHEETS FORMS F ASPHALT PAVEMENT MIX DESIGN G AERIAL PHOTO WITH MEASURED DISTANCES TO SURROUNDING DEVELOPMENTS II May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 1. INTRODUCTION This Operations Plan was prepared by Soil Processing Inc. (SPI) for the thermal remediation of hydrocarbon-contaminated soil at the Brechan Enterprises, Inc. (BEI), Industrial Site, Bells Flats, Kodiak, Alaska. As site owner, BEI has given SPI permission (Attachment A) to stockpile and treat soil from "others" through November 30, 2005, subject to approval of an operations plan by the Alaska Department of Environmental Conservation (ADEC). SPI has an Air Quality Operating Permit for this soil remediation unit, and an ADEC Relocation Permit to operate at the Bells Flats location. The public will also be notified about the intent to use the thermal soil remediation unit, and given an opportunity to ask questions or express concems to ADEC. These three documents are provided in Attachment A. SPI intends to accept and treat only petroleum-contaminated soil from underground storage tanks orOther contaminated sites. All soil received at the facility will be treated and removed within 90 days, but no later than November 30, 2005. The exception would be if previous arrangements have been Made to use the soil for leveling at the BEI site. Prospective clients, who have contacted SPI, have quantities of contaminated soil ranging from 100 to 6,000 tons. The soil comes from multiple sites across Kodiak Island. Mobilizing and setting up a remediation plant at any individual client's site cannot be justified due to the small quantities and small areas. SPI is requesting the ADEC to approve this plan to temporarily operate a soil remediation unit on Kodiak Island. This should provide a cost-effective way for clients with small quantities to have soil treated and obtain closure from ADEC. SPI plans to construct a new cell for temporary storage of contaminated soil to be treated at the facility during 2002. Design for the new cell is described in more detail in Section 4. Upon closure of the facility in 2005, a complete assessment will be performed 1-1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 2. SITE DESCRIPTION This proposed location is at BEI's Industrial Site between Middle Bay Drive and Salmonberry Drive in Bells Flats. The site is 12 miles from the City of Kodiak. A site location map is provided as Figure 1; Figure 2 shows the site vicinity (see Attachment B for all figures referenced in this plan). There are two gates off of Salmonberry Drive (unpaved portion) that will be locked and not used. Access to the facility will be off of Salmonberry Drive (paved portion). This is the primary entrance to the Brechan Industrial Site. Signs will be posted at the gate with contact telephone numbers for permission to enter or for information. The BEI site is relatively flat in grade. There is no runoff water from this site. There is surface water (old gravel pit) within 336 feet of the set-up area. This area is in the process of being backfilled by BEI. Bob Hale, (BEI) told SPI that the well was installed with a backhoe and draws the water from the water table which is the same level as the pond. The elevation of the water is 12.5 feet below the well casing cap inside BEI's pump house. Water for plant operations will be obtained from this well. SPI will monitor this elevation to determine the effects on the water level from daily •usage. The Fire Station has a commercial water well and is approximately 1000 feet from the set-up area. A commercial storage building is within approximately 666 feet of the set-up area. There is a occupied trailer on site. A meat packing plant/ smokehouse is approximately 2,100 feet from the set-up area. The closest house to the set-up area is approximately 500 feet. This house is located at the intersection of Salomonberry Drive and Middle Bay Road. It is located on a bluff/hill, and set back approximately 75 feet from the road. Two other houses on the same bluff/hill are 702 feet and 732 feet from the set-up area. The distances were taken using a range finder from the set-up location Contaminated soil awaiting treatment will be stockpiled at the designated Contaminated Soil Temporary Stockpile (CSTS) area. The paved CSTS area, 80 feet by 90 feet, will be configured as shown in Figure 3. The SPI working area is approximately 250 feet by 225 feet. SPI's proposed location is approximately 100 feet from BEI's Asphalt Plant. This area is covered by %-inch minus material. The Asphalt Pad will be constructed within the 250-by-225- foot working area. 2-1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 3. DETAILED PROCESS DESCRIPTION This section gives a detailed description of the treatment process for: air, water, and solid waste process streams; startup and shutdown procedure; process flow rates; air pollution control systems; and water treatment systems. A detailed description of the Continuous Emission Monitoring System (Attachment C), a Flow Diagram of Operation (Figure 4), and a conceptual Diagram of the Thermal Treatment Plant (Figure 5), are' included at the end of this section. 3.1 Overview During a typical production cycle, the contaminated soil is placed into a small surge stockpile that is used to feed the processor. The contaminated soils are removed from the surge stockpile by a front-end loader and placed in the feed hopper. All material over 1 inch in size is crushed to %-inch minus before entering the thermal processing stream. The presorted soils are then transported by weigh belt conveyor to the infeed auger where they are fed into the rotating, negative pressure, primary chamber of the processor. Crushing unit and weigh conveyor areas are lined with a Nova-Thene 20 mil RB88X-6HD (Attachment D) containment membrane. The membrane is to ensure no contamination from spillage. A 2.5 million BTU burner in the primary chamber raises the temperatures ranging from 500 to 800° F to drive off the moisture and contaminants. Most cleanup levels are achieved at +1- 500°F (Diesel 380° to 450°F, Crude 011 4950 to 510°F). During this thermal process, the hydrocarbon contaminants are volatized to .a gaseous state and then oxidized by direct contact with the open flame in the secondary combustion chamber. Gas retention is 0.6 seconds at 1650 to 1800° F. The secondary combustion chamber also has a 2.5 million BTU burner. Continued rotation of the dryer drum furnishes sufficient agitation and exposure to the soil to reduce the contaminants within the specified cleanup limits. As the soil tumbles in the drum it passes directly through the burner flame in the last 3 feet of the drum. This ensures complete remediation of the contaminated soil. Depending upon the moisture content of the soil, soil will typically be retained in the kiln for appr9ximately 15 minutes. After the thermal cycle is complete, the treated soil exits the rear of the rotating drum by a closed auger system. Treated material goes from the hot auger into a lined, bermed, surge pit approximately 15 feet x 15 feet x 3 feet. This pit is lined with a Nova-Thene 20 mil liner (Attachment D) with the AMOCO 4510 Geofabric on top of and under the liner (Attachment D). To protect against punctures, an 18" layer of fine (%-inch) material is placed over the Geofabric. A 4 foot by 8 foot by % inch steel plate is placed on the fine material. There is a %" steel plate welded to the bottom plate vertically to protect the liners. The steel plates ensure that the loader can not 3-1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN damage the liner. The exit auger will dump soils on top of the 3/" bottom plate for removal by the loader. All soils are contained in this area until approximately 10 to 20 tons have been stockpiled. Soils are mixed with any free standing water before being removed. Particulates removed from the off-gas in the scrubber are also deposited in the exit auger and mixed with the treated soil. A light spray of clean water cools the exiting material and at the same time provides dust control during the final discharge. Material is periodically moved from the exit soil pile to the treated soil stockpile area with a front-end loader. 3.2 Production Actual production throughput varies, but 8 to 10 tons per hour is typical. The main variables include the contaminant type and concentration, the cleanup levels, the soil type, and the moisture level. SPI's Soil Remediation Unit (SRU) is permitted to operate at 12 tons per hour. A typical shift is 24 hours per day , 7 days per week. During continuous operation, the process equipment is available for treatment about 20 hours per day, with 4 hours down time for preventive maintenance. 3.3 Specification of the Processing Equipment The thermal process is multiphase. Initially the soil is raised to allow vaporization of moisture and contaminants. The effluent gases then cross over to the secondary combustion chamber where the gas is oxidized to produce carbon dioxide and water. The off-gas waste stream is cooled and particulates are removed from the off-gases prior to discharge to the atmosphere. 3.4 Fuel Requirements The primary and secondary bumers in the kiln collectively consume approximately 4,379 cubic feet per hour of natural gas or 85 gallons of liquefied petroleum gas (LPG) per hour. Electricity for the facility is supplied by a diesel-powered 125 KW generator. 3.5 System Controls and Instrumentation The entire system is controlled by an Allen Bradley Series 5 programmable logic controller. Information about the operational status of the process is displayed on a color monitor in the control house. The system has a single button start up mode, which automatically supervises the main burner lighting, secondary combustion . bumer, combustion air, and a variety of other control points. The fully computerized system graphically displays the range set points and deviation indicators. Necessary start/stop stations are included. All systems components are safety interlocked. 3-2 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 3.6 Secondary Combustion Chamber The system auto ignites the hydrocarbon vapors as they pass from the primary chamber into the secondary combustion chamber. The gaseous waste stream is volatized by a 2.5 million BTU bumer as it passes through the chamber. The destruction removal efficiency (DRE) is 99.9999. 3.7 Particulate Emission Control The patented Heliclone TM effluent cooler reduces exhaust heat and increases the particulate and moisture separation by injecting water into the exhaust waste stream, Water consumption is approximately 3 to 4 gallons per minute. 3.8 Additives Soda ash is periodically added to the water in the settling pond to maintain a pH balance of 7 (Attachment D). 3.9 Settling Pond Cleanup A lined cell approximately 45 feet by 45 feet by 4 feet deep will be constructed alongside the processor for water storage. Water used during the process treatment is stored in a settling pond and recycled through the scrubber system. Approximately 2 to 3 gallons per minute is used to quench the processed soil and to eliminate fugitive dust. The water supply to the pond willbe stopped near completion of soil treatment to allow the water level to drop. The water and fines in the pond will be sampled and tested for contaminants. After analytical results verify they are clean, remaining fines will be mixed with treated soils and the remaining water will be sprayed over the ground at the site There will be no discharge of processor water to lands or, waters of-the State of Alaska. Liners will be removed and disposed of at an approved facility. The area under the pond will be assessed for leakage by a qualified third party and filled back to the original grade. 3.10 Permitting and Air Emissions SPI has met all the air quality standards required so that the maximum tonnage per hour can be processed. SPI's unit has a continuous emissions monitoring system (CEMS; Attachment C) for off gasses as required by ADEC (see Attachment A). The unit has been tested and is currently in compliance. 3-3 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 4, CONTROL AND CONTAINMENT OF CONTAMINATED SOIL SPI will use the following procedures and forms to provide for complete containment for the contaminated soil before, during, and after treatment until the contaminated soil meets the applicable cleanup levels. 4.1 SPI Requirements for Acceptance of Contaminated Soil 4.2 Delivery and Handling of Soil 4.3 Control and Tracking Soils at the Site 4.4 Design of Soil Storage Cell for Untreated Soil 4.5 Disposal of Treated Soils 4.1 SPI Requirements for Acceptance of Contaminated Soil The client must provide the following information before SPI will allow contaminated soil to be delivered to the BEI site: 1. Copy of Spill Report submitted to ADEC. Identify if regulated UST and LUST # or Contaminated Site # assigned by ADEC. 2. Written approval from ADEC Project Manager to transport and treat soil at the BEI site. 3. Address/location of spill. 4. Estimated quantity of contaminated soil (cubic yards) to be delivered to SPI. 5. Type(s) of contaminant; SPI will only accept petroleum-contaminated soils. 6. Concentrations of contaminant with copies of laboratory analysis results as reported to ADEC. 7. Type(s) of soil (peat, gravel, sand, etc.). 8. Contaminated soil mustbe covered and transported in compliance with 18AAC 50.0500(f) to minimize the possibility of a loss of material during delivery. SPI will not allow any soil to enter the BEI site if the above requirements have not been met. The client is responsible for removing all wood, metal, Plastic, and other non-treatable material from the contaminated soil prior to delivery at the SPI site. Any non-treatable Material removed 4-1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN at the SPI site will be put in a suitable container and disposed of in an approved facility at the client's expense. The client must remove the treated soil within 24 hours after receiving notice from SPI, unless SPI and the client have mutually agreed to other arrangements. 4.2 Delivery and Handling of Soil at the Site An SPI Tracking Record must be completed and accepted by SPI before any soil can be delivered to the site. The client is responsible for transporting the soil. Soil must be delivered in dump trucks. The trucks will back onto a ramp covered with a removable "tire liner" and stop at the edge of the storage cell so all of the contaminated soil will be dumped inside the cell. The tire liner will be 20 mil Nova-Thene HDPE fabric (Attachment D) and covered with AMOCO style 4510 Geofabric (Attachment D), detailed later in this section. SPI personnel will ensure any dirt on the tailgate, rear of the truck, and tires are cleaned before the truck leaves the tire liner area. Contaminated soil will be stockpiled with 3 foot minimum setback from the perimeter berm. If the liner shows signs of deterioration, it will be repaired or replaced with a new liner. Contaminated liners will be disposed of at an approved facility. After all of the client's soil is delivered, the tire liner will be removed and placed inside the paved cell (CSTS Slab Design; see Figure 6). SPI will place barriers of clean soil between each client's soil. The barrier soil will be removed from the storage cell with the adjacent client soil and fed into the hopper. 4.3 Control and Tracking of Soils Examples forms used for control and tracking of soils are provided in Attachment E. Clients must fill out a BEI Indemnification Clause and an SPI Tracking Record before their soil is delivered to the site. SPI will assign a unique Job Number to each clients' soil. This number will be used to track the soil from arrival, during treatment, sampling, and departure. A Release Record will be used if soils must be removed from BEI's site. There will be no more than two clients' soils stored in the cell at one time. Soil barriers will be placed between each client's soil to ensure soils are not mixed. One client's soil will be treated to completion before starting another client's soil. 4-2 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN A certified truck scale will weigh trucks entering the BEI facility. A weigh belt will be used for reporting to the ADEC and billing purposes. A two-part scale ticket will be generated hourly. As treated soil exits the processor, each client's soil will be placed in a separate pile(s) on the area designated "Treated Soil Stockpile Area" (Figure 3). Each stockpile will be marked with the job number, date received, date treatment was completed, sample date, and analytical results. Each stockpile location will be shown on a grid map located in the processor control house. 4.4 Design of Soil Storage Cell for Untreated Soil 4.4.1 New Cell Construction An Alaskan-registered professional engineer or assistant will inspect and document the installation process of the new asphalt paved storage cell. Figure 3 depicts the soil storage cell and work area design. The new soil storage cell and work area will be constructed with an asphalt perimeter containment berm as described below: 1) Lay out area of approximately 80 feet by 90 feet for asphalt pad. 2) Establish reference elevation and set grade on stakes at the four comers of the new cell. 3) Grade existing %-inch minus material at 2% to drain toward the sump in the northwest comer. 4) Field screen and collect necessary laboratory samples from upper 12 inches of soil in prepared area as per detail in Figure 7. 5) Remove sharp rocks and deleterious material from the surface. 6) Compact the 80 foot by 90 foot sub grade pad to provide a smooth firm surface; conduct as built survey of the pad elevations. 7) Place AMOCO 4510 Geofabric (Attachment D) on finished grade. 8) Lay a new 100 foot by 100 foot, 20 mil Nova-Thene RB88X-6HD (Attachment D) factory- seamed liner over AMOCO 4510 Geofabric, 9) Install 2 foot by 2 foot sump on the liner. Top of sump to be 2 inches below finished asphalt grade. Place AMOCO 4510 on top of 20 mil liner. (See Figure 8) 10) Place 18 inches of %-inch minus material on top of the AMOCO 4510 (No heavy equipment will operate on the liner before the 18 inches of material is in place) 11) Conduct as built survey elevations of %-inch minus layer. 4-3 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 12) Roll and compact the %-inch material to provide a firm surface. 13) Machine pave the 80 foot by 90 foot pad with 3 inches of asphalt (see Asphalt Pavement Mix Design, Attachment F). Finish roll, making sure the entire pad drainsto sump area. A 12-inch asphalt berm will be continuously constructed while the pad is being paved. Berm is to be compacted with weighted hand compaction plate. 14) SPI will provide as-built drawings to the ADEC signed and sealed by a professional engineer, registered in the state of Alaska under AS 08.48 The crusher/feed system will be set up beside the asphalt containment cell. An AMOCO 4510 Geotextile liner will be placed on the original ground; the Nova-Thene RB88X-6HD will be placed orttop of the Geotextile. The two liners will be continuous over the asphalt berm of the contaminated cell. A %-inch plywood will be placed on top of the 20 mil liner before setting the crusher/feed system. This will make for easy cleaning and protect the liner. The lined area will be graded so any water will collect at one point where it can be pumped into a Granular Activated 'Carbon (GAC) filter (Attachment D). 4.4.2 Cover The entire contaminated soil storage and work area will be covered with • 12 mil Canvex CB12WB (Attachment D), except when soil is being delivered or the processor is operating. The top cover will extend outside of the cell perimeter berm and be secured with Super Sacks. The active portion of the cell will be covered only when it is raining. To minimize the amount of cell exposed to rain, untreated soil from the sump half of the cell may be moved to a "surge pile" near the feed hopper, allowing the soil stockpiles and half of the lined work area to be covered. 4.4.3 Treated Soil Stockpile Area Treated soil will be stockpiled in the northeast corner of the pad (Figure 3). Stockpile sizes will be constructed as per the sampling plan. Alaska Test Lab will be contracted to collect samples when adequate tons have been processed for testing (usually 1 week). 4.5 Disposal of Treated Soils After cleanup levels have been met per ADEC, SPI will notify the client to remove their soil. Removal must take place within 24 hours of notification unless SPI and the client have mutually agreed to other arrangements. The client is responsible for final disposition of the treated soil. SPI will document the quantity, date, time, and hauling contractor for soil removed by each client on the Release Record (Attachment E). 4-4 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 5. SITE MONITORING PROCEDURES 5.1 General SPI personnel are responsible for continual monitoring and "housekeeping" around the contaminated soil storage cell and under the feed system, crusher, and processor. Any contaminated soil that falls on the ground around the storage cell or feed system will be cleaned up and placed back in the cell or in the feed hopper for treatment. Personnel will monitor the stockpile covers to ensure they are secure and not damaged. Damaged covers will be repaired • or replaced as necessary to protect the soil from the weather. If no one is working at the facility, personnel will periodically monitor the facility to ensure the stockpile covers are secure and no excess water is present in the storage cell, especially after heavy rain and/or strong wind. 5.2 Excess Water at Storage Cell If excess water is observed in the cell or sump, the water will be pumped from the sump to a 1,000 gallon poly tank, and from the poly tank through a GAC filter (Attachment D). After the water cycles through the GAC filter, it will be recycled with the processor's scrubber water. If there is free-standing water within the cell, any water on top of the cover will be removed, pumped to the settling pond and recycled. The top cover will extend over the outside berm and weighed down to allow water to drain off. Otherwise, water on the cover will be manually controlled and the water level in the settling pond will be monitored to ensure the pond does not overflow. When operating at full capacity, the processor uses 7,000 to 10,000 gallons of water per day. The settling pond has a normal freeboard capacity of 10,000 gallons more than adequate to handle the quantity of excess water from the cell. 5.3 Equipment Fuel Storage and Handling All fuels (diesel, gasoline, and oil) will be stored within a lined cell large enough to hold the volume of any spills. All fueling systems have automatic shut off valves as well as % tum manual valves that are in the closed position when the fueling equipment is not being used. Absorbent material will also be available during equipment fueling. If a fuel spill occurs outside the containment cell, the impacted soil will be immediately cleaned up, until no fuel odor is detectable, and thermally treated. Any spills less than 10 gallons will be reported to the plant operator on shift and logged into the daily log and Foreman's Report. The spill time, location, quantity, and cleanup will be documented. A spill larger than 10 gallons will be reported to the ADEC and assessed by a 5-1 May 2002 SOIL.PROCESSING INC. OPERATIONS PLAN qualified third party in accordance with Regulation 18AAC75, Article 3. The impacted area will not be filled until the qualified third party determines ADEC Method 1 Category A cleanup levels have been met. There will be a minimum of two LPG tankers on site which will be connected to the processor. The tankers will be set back a minimum of 50 feet from the processor. During fuel transfer from the delivery tankers to the on site tankers, the processor will be shut down, any welding operations will cease, and equipment will not be operated within 50 feet of the transfer area. Only trained personnel will transfer fuel. Fire extinguishers are always located at the transfer site. 5-2 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 6. SAMPLING, TESTING, AND REPORTING All soils accepted for treatment must first have been reported to ADEC and the results of characterization samples, analyzed by an ADEC- approved laboratory, must be provided to SPI. SPI will hire an impartial qualified third party to sample, analyze, interpret and report to the ADEC project manager on a project by project basis. In accordance with the UST Procedures Manual, the following site activities will be conducted /reported: 1) assessing for background contamination before initial startup of the facility: 2) confirming that treated soil meets the applicable cleanup levels; 3) assessing after cleaning up on site fuel spills larger that 10 gallons; and 4) assessing after treatment to demonstrate no secondary contamination occurred. Tracking of post- treated stockpiles will show the location, tonnage, date and time completed, date and time tested and the end results. A Site Plan will be in the Control hours with the above information. To ensure soils are represented vertically and horizontally throughout the stockpile, samples will be hand dug three feet into the soil from the top, middle and bottom. A photoionization detector (PID) will be used to determine the locations from which to obtain post treatment laboratory samples. The highest PID reading will be sent to Analytica's lab for analysis. Location of each sample site will be noted and kept by the third -party. A copy will also be kept on file in the Control House. Reference will be made to a fixed / permanent object (e.g. road, fence, rebar set as a monument) to ensure accurate measurements. This will be in the control house for site closure, testing and reporting. Per Client 1. One sample on the first 1- 50 tons 2. One sample on the next 75 tons 3. One sample on the next 100 tons 4. One sample on the next 500 tons and each successive 500 tons until completion. Soils will be tested for the contaminant(s) indicated in the Client's Analytical Report and the SPI Tracking Record (Attachment E) 6 -1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN All final verification samples for treated soil will be sent to Analytica,'Alaska in Anchorage for analytical testing. Three day turnaround will be requested. Samples will be analyzed for the contaminant(s) to be determined by the qualified third party based on soil characterization information contained in the cleanup assessment report submitted to ADEC. Confirmation soil sampling will be submitted to the lab for analyses for concentrations of the contaminants of potential concern (COPCs). Samples will be analyzed for the following compounds by the appropriate test methods based on site specific COPCs: • GRO using laboratory method AK101 DRO using laboratory method AK102 • RRO using laboratory method AK103 • BTEX using EPA method 8021B • Table 1: Reference Guide to Sample Collection and Laboratory Analysis, Part A • Table 2: Determination of Sampling & Laboratory Analysis for Soil & Groundwater • Table 2A: Indicator Compounds for Petroleum Contaminated Sites The qualified third party will submit assessment reports and original analytical results to the ADEC Manager. Copies of each assessment report and analytical results will be provided to the client and to BEI. SPI will also keep one report on file in the control house at the site. Treated soil stockpiles will not be moved until approved by the qualified third party. All soils will be remediated to the ADEC-applicable cleanup level. Any treated soil that does not meet that client's applicable level will be retreated and re-tested. No soils will be re-treated without gaining the prior approval of a soil re-treatment plan from the ADEC project manager. The sod test results associated with portion of soil failing to meet the cleanup level will be provided to , and discussed with, the ADEC project manager so that a decision can be made regarding appropriate soil re-treatment. 6-2 may 2002 Table 1: Reference Guide to Sarni,' _ lection and Laboratory Analysis (MQ .1 fl" ) Part A: Solis, Sediments, Sludges, and Fill Materials I°araorerer I'reparaliun/ Analytical Method' Mctluid l)elccliou - Limit' Practical Quanlilalion I.irnit' Container Description (Mlnimum) 'Clear glass may be substituted for amber if samples are protected from espusure lu light, this exceptlon does 001 apply metals' Preservation/ 11olding Time (iasnline !Nog,: ongrmcs AK III I • 2.0 nig'kg 20 mg/kg 4 oz. arnber glass, TLS Methanol preservative, <25 "C: 28 days Diesel range organics A1: 11)2' 2.0 mg/kg 20 mg/kg 4'oz. amber glass. TI.0 Cool 4" t 2 °C 1 14 days to extraction, less than 40 drys to analysis of extract. Residual range organics A): 103• 10 mg/kg 100 mg /kg 4 uz. amber glass, TLC ('oul 4° t 2 "C / 14 days to extraction, less than 40 days to analysis of extract ... .. . rubber septum seal • c nr prescrva rve ys rom samp mg ' ' ' • , .. . .. .. .. • rubber septum seal . . plinb ' I — Nu / I1 days less 10 days • liphrcic iliLsd I.rngc or garrix s A K IO2AA"" .4 rng•'kg ,..y'k 1 .,c. ,.;dc ono yi,us jm,'l'1.(' p,e9ewative to Gxlrut.iion, than to analysis of extract t ° extract • . .. .. .. l0 4 TLC .. . , t .. •. lysin-- e��+sxuact -- : \11pliroc is idnrl rdngt. wgrnics AK 103, A } III gA 1, „i ,/k6 ere. wink mewde amber Sloss jar. " TLC ' '. Annnarit 11.-7.1 . ngt urbnrits 7 \K1tl)AA:'• 1 III 10 rrrg/kg 4',', v' nn' r. :vudr m.rin.rgiussj +=r, :. . ... • : , • .. sis of cxtracl Benzene AK 1011 or ,• 826011 0.007. nig/kg 0.07 mg/kg 4 uz. amber glass, TLS Methanol preservative. <25°C./ 28 clays Toluene AK 1011 or 826013 0.1817 nrg/kg (1.117 mg/kg ' 4 oz. amber glass, TLS Methanol preservative, <25 °C / 28 days IiuhyRxnrrnc AK 101' or 826(111 0,1)07 mg/kg 11.07 nrg/kg 4 oz. amber glass, TLS Methanol preservative, <25 "C / 28 days Total xylencs . AK 1011 or 826011 (1.1)07 mg/kg 0.07 mg/kg 4 oz. amber glass, TLS Methanol preservative, <25 °C / 28 days 'fatal ITI'IiX AK 1011 or 8260)3 0.1)07 mg/kg 0.07 mg/kg 4 oz. amber glass, TLS Methanol preservative, <25 °C / 28 days Pulynucicar Aromatic I lydrocarbons (PAI I) 8270C or 8310 0.1 mg/kg 1.0 mg/kg 4 oz. amber glass, TLS Cool 4" 1 2T / 14 days to extraction, Icss than 40 days to analysis of extract Total Volatile (ldurinatedSolvents•' 8260B 0.008 mg/kg 0.08 mg/kg 4 uz. amber glass, TLS ' . Cool 4" t 2 "C / 14 days Polychlorinated biphenyls (PCBs) 8081 A ur 8082 0.01 mg/kg 0.05 rng/kg 4 uz amber glass, TLC Cool 4° t 2 °C / 14 days to extraction, Icss than 40 days to analysis of extract Total Arsenic . 60100, 6020, 70611A, or 7061A 1 mg/kg 10 mg/kg 4 oz amber glass, TLC Cool 4" t 2 °C / 6 months Total Cadmium 601011, 6020. 7130, or 7131A' 1 mg/kg 10 mg/kg 4 az amber glass, TI.0 Cool 4" t 2 "C / 6 months Total Chromium 601011, 6020, 7190, or 7191 1 ,,g/kg 10 mg/kg 4 oz amber glass. TLC Cool 4" t 2 "C / 6 months 'Tuts( Lead 6010, 61120, 7420, 7421 1 utg/kg 10 nrgrkg 4 oz amber glass. TLC Cool 4° t 2"C / 6 months :1111) 11111Illllles v )b 27 Determination of Sampling and Laboratory Analysis for Soil(S) and Groundwater(GW) Petroleum Product . C6-C10 C10-C25 C25-C36 BTEX PA :1'2 Metals Solvents Legend: GRO = Gasoline Range Organics {using AK 101 or AK 101AA)- DRO = Diesel Range Organics (using AK 102 or AK 102AA} PRO = Residual Range Organics {using AK 103 (for soil) or AK 103AA (for soil and groundwater)} BTEX = refers to individual indicator compounds to be analyzed: benzene, toluene, ethylbenzene, xylenes. would be required for all y"o"="". releases, unless the sum of the "`~ c eanup standards for individual petro eu '..° " ,°~ ' .ov ° `^'• . - e" or the the corresponding Method 2 - ` ' ". ' oir 75. ]40 isrquu nr cs ':*-^'. ~: '^" " or iv ethod| referenced bn|O/AC75348. " " ^~ • ^~"ouuds listed io Table ZA would be re.0 ed f. ^^^ `'- and total ^ ` site by applyrng -- ! • •.° xcept " • :.V°. TI n "�r^ ^^' ^. '^' "" o less the . oo ect manager .:. gasoline and fuel spill anal eeetttires-othcrxor. � ` . .'' '.° .. �'.—' �-. ��'. .°, , . . . ,, • vanadium. ^ Volatile chlorinated solvents andother additives listed in Table 2A must be performed if required by the project manager. ' • • • • ' " • • • • .. • .• • • . ` For sampling groundwater for RRO use the "aromatic resdual range organics' fraction parameter rnethod listed mTable 1. Part B. ofthis manual. 49 go`/ 5111 �� TABLE 2A (Nfloclirt:e8) INDICATOR COMPOUNDS FOR PETROLEUM CONTAMINATED SITES • Volatiles (BTEX) benzene toluene ethyl benzene total xylene olynuclear Aromatic Hydrocarbon ( Hs)* - Carcinogens* benzo(a)pyrene chrysene deno(1.,2,3-cd). ene be o (k)fluo ..ene benz b)flur. • ithene benzo a 11 acene dibanzo h)anthracene • • Polynuclear Aro aric • drocarbons (PAHs)* - N carcino ens a acene cenaphthene pyrene naphthalene fluorene Metals as required on a case by case basis Arsenic Barium Cadmiurn Chromium Lead Nickel Vanadium Others as needed on a case by case basis ethylene dibromide (EDB) 1,2 dichloroethane (EDC) methyl 1 tert-butylether (MTBE) volatile chlorinated solvents so gev. 5/7)99 SOIL PROCESSING INC. OPERATIONS PLAN 7. SITE CLOSURE Before initial startup (background) and after completion of the treatment (closure), an impartial qualified third party will assess under areas where untreated soil is stored or handled. These areas are the 1) contaminated soil storage cell, 2) feed system, and 3) exit soil pile (Figure 7). 7.1 Background Assessment The background assessment will include: 1) Layout sampling grid, Figure 7. 2) Reference the sample grid to the perimeter fence or other permanent features. 3) Collect field screen samples at 3 to 6 inches below surface and test with PID. 4) Collect second sample 1 foot deeper if PID reading is more than the background. 5) Test 1/10 of samples with Dexsill PetroFLAG analysis system if PID readings are low and if hydrocarbon odor is detected. 6) Collect analytical samples at locations with highest PID or PetroFLAG reading. 7) Analyze samples for diesel range organics (DRO), gasoline range organics (GRO) and benzene, toluene, ethylbenzene, and xylenes (BTEX), and RRO 8) Provide report to ADEC. 7.2 Closure After all the contaminated soil has been treated and removed from the site the following will take place: 1) Soil storage cell will be dismantled by SPI and documented by the third party. SPI will remove the 3 -inch asphalt pad and dispose it on BEI's site. The third party will field screen the 18 inches of 3/ inch material that is on top of the liner. If contamination is not detected, the 3/ inch material will be removed and piled on site. 2) The liner will be cleaned and removed. The third party will field screen the soil 6 to 9 inches below' the liner. Any contaminated soils will be removed and treated until field screening indicates the contaminant levels are -the same or no greater than initial startup (background) concentrations. Then discrete laboratory samples will be collected. 7 -1 May 2002 , - SOIL PROCESSING INC. OPERATIONS PLAN 3) The third party will be on site immediately after the liners are removed at the treated soil stockpile area, process area, exit soil pile and settling pond for purpose of closure assessment. 4) The exit soil pile liner will be removed, and the third party will field screen underneath. 5) The feed system will be dismantled, liner removed, and the third party will field screen undemeath. 6) The settling pond will be emptied and cleaned. 7) Analyze samples for DRO, GRO and BTEX, and RRO 8) Contaminated liners will be disposed in an approved facility. 7.3 Sample Schedule The qualified third party will field screen the areas listed above (section 7.2) according to the following schedule. The number of analytical samples shown is for the initial background assessment. Field screen locations for closure will be the same as the initial background assessment. Area Description Area (feet) Field Screening Samples Minimum Laboratory Samples 1 Contaminated Soil Storage Cell 80 x 90 16 6 II Feed System 30 x 8 3 2 III Exit Soil Pile 15 x 15 2 1 Treated Stockpile 50 x 50 9 4 Contaminated soil detected under the storage cell, exit pile, or feed system will be cleaned up and run through the processor, and used to fill the cleanup location. If the field screen results are "non-preferential," discrete samples will be collected from representative locations selected by the third party. If some locations have elevated readings but appear to be less than Level A, discrete analytical sample(s) will be collected from the location(s) with the highest concentrations. Settling Pond water and sediment will be sampled for DRO, GRO and BTEX. After analysis results verify the water and sediment are clean, the water will be discharged on the ground and 7-2 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN the sediment will be placed on a treated soil stockpile. The pond liner will be removed and cleaned for reuse or disposed of at an approved facility. The qualified third party will be present when the liner is removed and assess the soil beneath the liner for evidence of leaking. If hydrocarbon concentrations in the sediment exceed Level A for soil, the material will be removed and run through the processor. If water analysis results exceed the groundwater cleanup levels for DRO, GRO or BTEX in Table C (18AAC75.345), the water will be treated using the GAC filter and disposed of on site, if approved by the ADEC staff. 7.4 Final Report When all areas have been cleaned up, assessed and sampled, the qualified third party will report the post-closure assessment results to the ADEC staff at the Kenai Area Office and provide one copy for SPI and one for BEI. BEI representatives will conduct a final inspection of the site after SPI has dismantled all equipment. Subject to satisfactory inspection results and ADEC approval of the final report, BEI will issue a release of liability letter to SPI. 7-3 May 2002 ATTACHMENT A QUALIFYING DOCUMENTS BEI Letter Re: P9rmission to Operate Air Quality Operating Permit ADEC Relocation Permit Public Notification Letter Ail GENERAL CONTRACTORS May 1, 2002 BRECHAN ENTERPRISES, INC / GENERAL CONTRACTORS 2705 MILL BAY ROAD • KODIAK, ALASKA 9961 5 Mr. Paul Horwath, P. E. State of Alaska, Department of Environmental Conservation Contaminated Site Program 43335 Kalifonsky Beach Road, Suite 11 Soldotna, Alaska 99669 Re: Soil Processing Inc. Portable Thermal Unit Soil Processing To Whom It May Concern: This is to confirm that Brechan Enterprises, Inc. has agreed in principle to provide one acre of land at our industrial site on Kodiak Island (Block 3, Tract A, Bells Flat Alaska Subdivision) for the above referenced use. This agreement is contingent upon ADEC approval of the Category C Facility Operations Plan submitted under separate cover from Mr. George Cline, president of Soil Processing, Inc. Upon approval of that plan, Brechan Enterprises will permit stockpiling material and thermal unit burning from "others" in strict accordance with the approved plan. It is understood that we will receive a copy of all records, transmittals, test reports, etc. required and specified in this plan. Receipt of a signed ADEC approval of this plan is required prior to any soil processing from others. In addition Brechan Enterprises will require a separate signed indemnification clause from each party entering the project site. This agreement will remain in effect for the period specified in the plan, unless canceled by written notification. If you have any questions or comments, please contact the undersigned. Very Truly Yours, Brechan In c. W. E. Oliver Vice President PHONE: 907.486.3215 • FAX: 9 07.486.4889 ALASKA BUSINESS #00 1 858 • ALASKA CONTRACTORS #AA44 1 We Are An Equal Opportunity Employer GP4 — Soil Remediation Unit General Permit ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION AIR QUALITY OPERATING PERMIT Permit No. GP4 The Department of Environmental Conservation, under the authority of AS 46.03, AS 46.14, and 18 AAC 50.350, issues an Air Quality Operating Permit for: Permitted Facilities: Qualifying Soil Remediation Units. This permit authorizes the operation of facilities for which the Department finds in writing: • Equipment meets the criteria established on page 2 of this permit; and • The department has received a complete application. For the department to find.the application complete, the application must provide all of the information described in the application form issued with this permit for all equipment to be operated under this permit. This permit expires on Mayl, 2003. To renew this permit, the owner or operator must submit a renewal application between November 1, 2001 and November 1, 2002. John M. Stone, Chief Air Quality Maintenance Section May 1, 1998 May 1, 1998 FINAL GP4 - Soil Remediation Unit General Permit ATTACHMENT 2. Portable Facility Relocation/Operation Notification Submit the information specified below to the Department's'Air Quality Maintenance Section, thirty days before moving the plant to any new location, and before startup. Name of Finn: SOIL PROCESSING INC. Contact Person: Telephone: JENNIE D. SHARPE (907) 274-3000 New plant location (include site maps): N 57° 42.692 / W152° 34.805 BELLS FLATS, KODIAK, ALASKA Approximate startup and shutdown dates: MAY 20, 2002 / NOVEMBER ' 2002 Comments: SOIL PROCESSING INC. WILL BE OPERATING FROM INSIDE BRECHAN ENTERPRISES, INC.'S INDUSTRIAL SITE. I hereby certify that the information contained in this notification is to the best of my knowledge and is true, com le nd ac Si Ti Lire: C.E.O. May 1, 1998 -75_ JENNIE D. SHARPE Printed Name: Telephone: 9 07 ) 27 4 -300 0 FINAL Alaska Department of Environmental Conservation Request for Public Comment on Proposed Soil Remediation Facility to be located at Brechan Enterprises, Inc.'s industrial site, • Kodiak Alaska Comments must be received by May 22, 2002 The Alaska Department of Environmental Conservation (ADEC) is requesting public comments on an Operations Plan from Soil Processing Incorporated, Inc., (SPI) for DEC approval of a petroleum contaminated soil remediation facility to be located on off Salmonberry Drive on Brechan Enterprises' industrial site property on Block 3, Bell's Flats Subdivision. SPI proposes to construct a soil remediation facility at this site in order to receive and treat contaminated soils under an ADEC approved Operations Plan, in accordance with the provisions of 18 AAC 75.365 and 18 AAC 78.273 (Offsite Treatment Facilities). Soils would be trucked to the facility from surrounding areas for storage; pending treatment using thermal desorption technology. The soil processing equipment heats the soil to temperatures that drive off the petroleum contaminants, which are subsequently destroyed (oxidized) in a secondary afterburner. After soil sampling confirms that the treated soils meet ADEC required cleanup levels, the soils will be transported back to the place of origin or disposed at the soil treatment site. Facility construction activities are scheduled to begin this spring (2002) and soil treatment could continue for three or more seasons. In order-to comment on SPI's proposed soil remediation facility, ask questions about the proposed project, or to review any ADEC file information regarding this project, please contact: Paul Horwath• ADEC Contaminated Site Program 43335 Kalifornsky Beach Road, Suite 11 Soldotna, Alaska 99669 Phone: (907).262-5210, ext. 250, Fax: 262-2294 • E-mail: Paul Horwath@envircon.state.alc us ATTACHMENT B FIGURES Figure 1 Site Location Map Figure 2 Vicinity Map Figure 3 Site Plan Figure 4 Flow Diagram of Operation Figure 5 Thermal Soil Treatment Diagram Figure 6 Contaminated Soil Temporary Stockpile Slab Design Figure 7 Background Sampling Grid ePQ • 1 ,r r 0 4� 4 Pillar Creek Q Reservoir se N , Gy& ` a 0 Saunntil Point 1nnq r Woody 1 Island �Atekaashkina • " Eiephnn; Stt.:.MAP, Lake Long Island to oaten Broad Poirit er. ) : 1. ' Lake Lee Heilman Lake Kalsln Island 'Queer Island Heitman Mountain 0 0 SOIL PROCESSING INC. 207. E. Northern. Lights Blvd., Suite 103A Anchorage, AK 99503 (907) 2743000 FAX: (907) 274-9295 Figure 1 Site Location Map Source: ACS, 2001 - Eagle Eye Maps Kodiak, Alaska Kodak, pies SW-. PROCESSING INC. 2p7. g. NAt Blvd., Suite 1o3A 07127`�g2g5 nciota e, x x — x — z .--- x FENCE BUTANE TANKER AREA (MINIMUM 50' FROM PROCESSOR) 500 CAL LINED DIESEL TANK STORAGE AREA GEN SET . LINED AREA • GAC , L1ER w WATER LOADER TRAVEL AREA ,. u 0 TRUCK RAMP 130' 1 225' v SETTLING POND 12 Mall LINED LINED AREA CRUSHER FEED SYSTLY LEASE .1)09HDARY BRECHAN ASPHALT PLANT'AREA SEE FIGURE 2A FOR DETAILS OF SAMPLE LOCATIONS 50' 50' DISPOSAL AREA FOR CLEAN SOILS (LEVEL. A) 250' APPROX. 41O -100' ACCESS �DRIYCWAY NOT TO SCALF ' SALMON/3E RRY OR SOIL PROCESSING INC. 207 E. NORTHERN UCKTS BLVD.. SUITE 1034 ANCH0RACC, AK 99503 ,1 (907) 274 -3000, FAX: (907) 274 -9295 FILE: K1105102 DRAWN: C /SC: 1:1 CD: SOILrROC DAIS: 5/1/01 CHECK: GEORGE FIGURE 3. SITE PLAN KODIAK ALASKA CONTAMINATED sOIL to2 SCREEN SHREDDER CLASSIFIER *3 'VARIABLE SPEED FEEDER FLOW DIAGRAM OF OPERATION •*•*CONF/DENTIAL**rP. SOIL/TEX #17 275°F *9 CLEAN AIR--- INLET BOX to5 R• 0 T. A R D R 1J T 0 L E C FURNACE BURNER #1 #16 PARTICULATE PATH 1 1410 Ct. ue Nes 1741 N15 R v E C L E #10 RECIRCULATOR BLOWER 1600°F 300°F E N C #13 #14 450° - 800°F OpTFEED AFTER BURNER BURNER *7 CLEAN SOIL 8 WATER 5 H A R #12 . CLONG Sift Z tzrVa.CLO FIGURE 4. FLOW DIAGRAM OF OPERATION PAJC.O IJISTfSEPITEP 5011. CELL L N ye,JoRIC A lc EA TRUCKS EXIT 5 a. 0 z (.4 T 0 1-1 ou se EXHAUST R STACK w/CEMS 0 0 LOADER Figure 5. THERMAL SOIL TREATMENT PLANT DIAGRAM New Cell Construction 1. Lay out area of approximately 80 feet by 90 feet for asphalt pad. 2. Establish reference elevation and set grade on stakes at the four comers of new cell. 3. Grade existing %-inch minus material at 2% to drain toward the sump in the northwest corner. 4. Field screen and collect, necessary laboratory samples from upper 12 inches of soil in prepared area as per detail in Figure 7. 5. Remove sharp rocks and deleterious material from the surface. 6. Compact the 80 foot by 90 foot sub grade pad to provide a smooth firm surface; conduct as-built survey of the pad elevations. 7. Place AMOCO 4510 Geofabric (Attachment D) on finished grade 8. Lay a new 100 foot by 100 foot, 20 mil Noira-Thene RB88X6HD (Attachment D) factory-seamed liner over AMOCO 4510 Geofabric. 9. Install 2 foot by 2 foot sump on the liner. Top of sump to be 2 inches below finished asphalt grade. Place AMOCO 4510 on top of liner (See Figure 8) . 10. Place 18 inches of %-inch minus material on top of the AMOCO 4510. (No heavy equipment will operate on the liner before the 18 inches of material is in place) 11. Conduct as-built survey elevations of 3/4inch minus layer. 12. Roll and compact the %-inch material to provide a firm surface. 13. Machine pave the 80 foot x 90 foot pad with 3 inches of asphalt (see Asphalt Mix Design, Attachment F). Finish roll making sure the entire pad drains to the sump area. A 12 inch asphalt berm will be continuously constructed while the pad is being paved. Berm is to be compacted with weighted hand compaction plate. 14. SPI will provide as-built dravitings to the ADEC signed and sealed by a professional engineer , registered in the State of Alaska under AS 08.48 Soil Processing, Inc. CONTAMINATED SOIL TEMPORARY STOCKPILE SLAB DESIGN CROSS SECTION LAYER SEQUENCE: 1. Min 3 Inch Compacted Asphalt Concrete Slab 2. Min 18 Inch Graded and Compacted Bedding Material 3. Amoco 4510 Non Woven Geofabric 4. Nova -Thene RB 88 X 6 HD Polyethylene Liner (20 mil) 5. Amoco 4510 Non Woven Geofabric 6. Compacted and Graded Ground Surface 20 mil Geomembrane Liner Material Bedding Material to Cover AC Berm a Minimum of J 6 Inches Sump Area Drains to Center. Plastic Bucket 2 Feet Deep Placed into Sump. Sump Area Shall be Overexcavated to Accommodate Bucket. Liner Under Sumo Continuous With Slab Liner. (See Attached / Amoco Style 4510 Geofabric for Protection Against Foot Traffic 18' Lift of 3/4 Minus Material Graded & Compacted 12' Min Original Ground Compacted and Graded to Drain 2% Toward Sump Corner Prior to Placing Geofabric and Liner TYPICAL SECTION OF BERM CONSTRUCTION Asphalt Concrete Berm Extends 12 Inches Above AC -Slab Berm is Continuous With Slab Nova -Thene RB 8.13..\ X6HD20mil Lliner With Geofabric Directly Above and Below} Notes: 1. Subgrade shall be graded and compacted at a 2% slope draining toward sump corner. Surface shall be free from sharp objects or rocks protruding more than 1/2 inch. 2. Amoco Style 4510 geotextile fabric shall be placed on original ground surface prior to liner placement. 3. Joints in geofabric shall overlap a minimum of 15 inches. 4. Nova -Thene RB 88 X 6 HD 20 mil liner shall be used as shown. Liner shall be one piece or factory seamed. Field seaming is not permitted. 5. Amoco Style 4510 geotextile fabric shall be placed directly above and below 20 mil liner. 6. 3/4 inch minus granular material will be used for bedding material as shown on drawings. 7. Bedding material will be rolled with a static roller then graded with a blade. Final surface will be static rolled prior to asphalt placement. 8. A minimum of 3 inches of compacted asphalt concrete will be placed directly on the bedding material. Berms will be FIGURE 6. CONTAMINATED SOIL TEMPORARY STOCKPILE SLAB DESIGN NOT TO SCALE FINAL SPI SLAB DESIGN.xls DETAILS AND NOTES • Compacted Soil Equipment Access L. Ramp PLAN VIEW OF ASPHALT CONCRETE SLAB X - x x [TREF • x BUTANE R AREA (MINIMUM SO FROM PROCESSOR) CON[ROL HOUSE 30' cc • • 0 a' LEGEND • SAMPLE LOCATION NOTE: PERIMETER FENCE AND SET REAR TO DE USED FOR SAVRIC TIES TO _SAMPLE LOCATIONS so' 50 • LLN}1J EXIT AREA SETTLING PONO LAO AA CRUSHER FEED SYSTEM ASPHALT PAD CONTAMINATED SOIL TEMPORARY STOCKPILE TREATED SOIL STOCKPILE AREA MONITORING TE5Y RESULTS NOT TO SCALE SOIL PROCESSING INC. 207 E. NORTHERN LIGHTS BLVD., SUITE 1034 ANCKDRAGE AK 99503 (907) 274-3000, FAX (907) 274-92115 ME: Kat/5102A CAC: 1:1 DATE: 5/1/02 DRAWN: SSR CO: SOILPRDC CHECK: GEORGE FIGURE 7. BACKGROUND SAMPLING GRID KODIAK ALASKA oo, SUMP LOCATION 2X SLOPE ASPHALT RAND GRADED TO SLOPE TO SUMP (ALL SIDES Or SUMP) r 2• WATER TO G.A.C. FILTER 1r 3/4' MINUS AMOCO STYLE 4510 FABRIC 20 MIL LINER AMOCO STYLE 4510 FABRIC NOT TO SCALE 5 GAL PLAST1C BUCKET APPROX. rx2' .•%■* ts% 2X SLOPE 0R1GIIlAL GROUVD 4 41 PE9F1JRAnOHS �•/ ♦� 000 STYLI 10 FABRIC 20 MIL LINER AMOCO STYLE 4510 FABRIC vAtact1 OF...•. 9 0 G•orge R. Wilson a- �..........�''" k�' SOIL PROCESSING INC_ 207 E. NORTHERN LIGHTS BLVD., SURE 103A ANCHORAGE, AK 99203 (907) 274 -3000. rAX: (907) 274 -9225 FILE: K0031302 C /SQ 1:1 DATE: 5/15/02 DRAWN: SSR CD: S0ILPROC CHECK OEDROE FIGURE 3 SUMP DESIGN CROSS SECTION VIEW ROFESSI°141 KODIAK ALASKA ATTACHMENT C ... CONTINUOUS EMISSION MONITORING SYSTEM 1.0 INTRODUCTION . Soil Processing, Inc. (SPI) is currently operating a P.D.I.Soil/TEK Model 3000 Thermal Soil Remediation Processor. This unit is used to thermally remediate soil contaminated with petroleum hydrocarbons. The P.D.I unit thermally desorbs the pet-oleum hydrocarbons in a direct-fired rotary drum dryer. The hydrocarbon emissions are controlled by thermal destruction in a secondary combustion chamber. Particulate emissions are controlled by a series of wet scrubbers and a power-assisted rotary cyclone (Heliclone0). The P.D.I unit is trailer mounted and capable of moving from site to site. 1.1 MONITORING PROGRAM RATIONALE Soiling Processing, Inc. obtained an Air Quality Permit to Operate from the Alaska Department of Environmental-Conservation (ADEC) File No. 9421-AA002. The ADEC permit established air quality ernission standards for the operation of the unit Standards were established for particulate matter and carbon monoxide (CO). Compliance with the particulate standard was initially determined by an emission test performed by an independent testing firm Particulate testing may be required again at the discretion of ADEC, probably at the renewal date of the permit Compliance with carbon monoxide standard is to be demonstrated by the installation and operation of a continuous emission monitoring system (CEMS). 1.2 MONITORING PROGRAM OBJECTIVES The continuous emission monitoring system is to monitor the efficiency of hydrocarbon destruction in the secondary combustion chamber. A high concentration of carbon monoxide in the emission gases is an indication of poor hydrocarbon destruction_ The ADEC emission standard for CO, stipulated by the SPI air permit, is 100 parts per million (ppm) corrected to 7 percent oxygen (02). The objective of the CEMS program is to comply with ADEC permit conditions. This includes the installation and initial certification of the system, and the successful operation and maintenance of the monitoring system to insure the collection of representative and accurate emissions data ADEC requires that the CEMS program be operated in accordance with US Environmental Protection Agency (USEPA) regulations relative to equipment performance specifications and quality coatrol/quality assurance (QC/QA) guidelines. This manual is to provide information and standard operating procedures for the CEMS program. 1.3 REFERENCES The information provided in this manual was gathered from a number of sources, theADEC air quality permit, federal regulations, USEPA documents, and instrument mantiRls. All documents used in the - CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) 2 preparation of this manual are listed below. Soil Processing, Inc., Air Quality Control Permit to Operate, File No. 9421-AA002, Alaska Department of Environmental Conservation, March 24, 1994. Performance Specification 4—Specifications and Test Procedures for Carbon Monoxide Continuous Emission Monitoring Systems for Stationary Sources, Title 40, Code of Federal Regulations, Part 60, Appendix B, as revised July 1, 1996. Performance Specification 3—Specifications and Test Procedures for 02 and CO2 Continuous Emission Monitoring Systems for Stationary Sources, Title 40, Code of Federal Regulaticms, Part 60, Appendix B, as revised July 1, 1996. • Performance Specification 2—Specifications and Test Procedures for SO2 and NO Continuous Emission Monitoring Systems for Stationary Sources, Title 40, Code of Federal Regulations, Part 60, Appendix B, as revised July 1, 1996. Procedure 1—Quality Assurance Requirements for Gas Continuous Emission Monitoring Systems Used for Compliance Determinations, Title 40, Code of Federal Regulations, Part 60, Appendix F, as revised July 1, 1996. Quality Assurance Guidelines for Air Pollution Measurement Systems, Volume I Principles, US Environmental Protection Agency, EPA-600/9-76-005, December1984. Quality Assurance Guidelines for Air Pollution Measurement Systems, Volume III, Stationary Source Specific Methods, US Environmental Protection Agency, EPA-600/4-77- 027b, August 1988. Soil Processing Inc. Continuous Emission Monitoring System—Combined Instrument ManuaLs, PACE Environmental Products Inc., August 1991. 2.0 DESCRIPTION OF THE MONITORING SYSTEM The continuous emission monitoring system (CEMS) installed on the P.D.L Soil/TEK rernediation imit is a multi-component extractive type monitoring system. The CEMS consists of three subsystems; the stack interface and sample gas conditioning system, the gas analyzers, and the data acquisition system_ The following section provide a brief description of these subsystems. 2.1 STACK INTERFACE AND SAMPLE GAS CONDITIONING The stack interface and the sample.gas conditioning system extract emission gases from the Soil/TEK exit stack and prepare the gases prior to entry into the gas analyzers. This subsystem was designed and manufactured by PACE Environmental Products, Inc. The emission gases are aspirated from the stack through a stainless steel probe into a heat-traced Teflon sample line. The sample line conveys the emission gases from the stack into the Soil/TEK process control room and the instrument rack containing the remaining components of the system. The sample gases pass from the heated sample line into a multi-component gas conditioning system. The conditioning system , consists a water knockout to remove any free water and a VIA Model MAK 2 thermo-electric cooler. This component cools the sample gases resulting in the condensation of water vapor from the sample stream. The moisture is reduced to less than 2 percent This is sufficient to prevent intrusion of liquids into the gas analyzers. A drain pump is provided to remove the condensation. Should the VIA sample gas conditioner fail, the unit is equipped with a liquid sensor which will enunciate an alexia As previously mentioned, the sample gases are drawn through the entire sample system. This is achieved by aspiration. A compressor provides instrument air that is blown through an eductor. This creates a negative pressure on the sample system pulling emission gases from the stack through the entire system. The eductor pulls a much greater volume of sample gas than is needed by the gas analyzers. The excess sample gas is vented to the outside atmosphere. Once the sample gases are cleaned and the moisture removed, the gas analyzers are allowed to draw the necessary volume of gas for pollutant measurements. 2.2 GAS ANALYZERS The sample gases are analyzed using two instruments, a carbon monoxide (CO) analyzer and an oxygen (02) analyzer. The CO analyzer is used for the determination of the pollutant concentration. The 02 analyzer is to measure the concentration of diluent gas in the emissions and to standardize the CO concentration to 7 percent 02. This Sumdardization is to prevent an operator from increasing the excess air in the combustion process and thereby, diluting the pollutant concentration. 2.2.1 Carbon Monoxide Analyzer The CO concentration is measured using a Thermo Environmental, Inc. Model 48 CO analyzer. This instrument operates on the principle known as Gas Filter Correlation (GFC) Spectroscopy. This technique uses a infrared light source, a system of optics, a gas filter, an infrared detector, and a micro-processor to measure the CO concentration in the sample gas. Although, further explanation of this analytical technique is beyond the scope of this manual; it should be noted, that this measurement technique has distinct advantages over other types of infrared analyzers. The Model 48 instrument response is very accurate, precise, and stable which minimizes calibration drift. An internal pressure and temperature transducer provides information to the micro-processor for automatic correction in sample flow. The CFC technique all but eliminates interference from moisture and carbon dioxide (CO2) in the sample gas. The instrument is equipped with circuitry to perform diagnostic tests on the infrared light source, detector, and other internal electronics. The Model 48 provides a digital readout on the • front display, as well as, an analog output. The measurement range selected for the Soil Processing Inc. CEMS is 0.0 to 500 ppm which is represented by an output signal 0.00 to 10.00 volt direct current (VDC). 2.2.2 Oxygen Analyzer The 02 analyzer used in the Soil/TEK CEMS is a Model ZFK Zircornat Oxygen Analyzer manufactured by the COSA Instrument Corporation. The principle of operation for this instrument is relatively simple 'as compared to the CO analyzer. A zirconia (ZRO2) and yttria (Y203) sensor is heated to a temperature above 500 degrees Celsius. - At this point the sensor is conductive to 02 ions in the sample gas. This produces an electromotive force between two electrodes which is proportional to the concentration of 02 in the sample �. This instrument is typically used as an in -stack sensor. For this application the instrument was modified and the sensor mounted in the CEMS instrument rack The sensor was sealed in a containment and a sample transport scheme designed to allow sample gases to flow across the surface of the sensor. The instnunent provides an LED display on the front panel and an analog output. Calibration of the instnunent is achieved by potentiometer adjustments on the front panel. The measurement range on the COSA Zircomat 02 is from 0.0 to 25.0 percent by an output signal of 4 to 20 milli -amps. 2.3 DATA ACQUISITION SYSTEM The Data Acquisition System (DAS) provide a means of polling the output signals from the analyzers, 5 converting the signals into engineering units, processing the data into hourly averages, and providing a hard copy record of the data As with the other CEMS systems the DAS is a multi-component system consisting of a electronic data logger, a personal computer and printer, data processing and communication software, and a strip chart recorder. 2.3.1 Electronic Data Logging System The main component of the electronic data logging system is a Model DSM 3260 data logger manufactured by Odessa Engineering, Inc. The micro-processor based DSM 3260 polls the input sirals from the gas analyzers once every second and storing that information in its internal memory and in a removable memory cartridge. The analog data is averaged into 6 minute averages and then into 1 hour averages. The data logger is equipped with an input status function which can flag the data as invalid during periods of calibration and maintenance. The data is stored but is not included in averaged data The data logger perfcirms an analog to digital conversion providing the data as engineering units, parts per million (ppm) for the CO and percent (%) for the 02. The DSM 3260 data logger is connected to an IBM compatible personal computer. The computer is equipped with a letter quality printer to produce a hard copy of the averaged ciRta The downlink from the data logger to computer is achieved using a communication and data processing software known as DSMTALK developed again by Odessa Engineering, Inc. The menu driven software allows the computer the download the emissions data from the data logger and to print hourly and daily reports. 2.3.2 Strip Chart Recorder The strip chart recorder included in the Soil Processing Inc. CEMS provides a continuous trace of the gas analyzer signals. This unit is a LR 4120 series two pen, programmable, strip chart recorder manufactured by the Yokogawa Electric Corporation. Any DC voltage, thermocouple, or RTD input rnay be selected for either of the 2 channels. Input parameters are loaded into the recorder memory to provide. continuous LED readings displayed in engineering units. This is in addition tattle continuous chart traces. The Yokogawa recorder will receive output signals directly from the Q0 and 02 analyzers providing a redundant means of data collection should the electronic data logger faiL The redundant data record also provides a method for comparing data sets between the chart record and the data lo er. The Yokogawa recorder will be programmed specifically for the output parameter from the gas analyzers and the chart speed is to be set at 3 inches per hour: With the exception of the personal computer and the associated printer, all technical information for the individual components of the Soil Processing CEMS were compiled into a integrated manual by PACE Environmental Products, Inc. 3.0 STANDARD OPERATING PROCEDURES The data collected by the Soil Processing CEMS unit is to determine compliance with ADEC air permit conditions. Because this data is collected for compliance purposes the data must be of an accuracy and quality that the data is considered LEGALLY DEFENSIBLE. To insure the collection of accurate, quality data, the following standard operating procedures are to be implemented for the operation and maintenance of the Soil Processing, Inc. CEMS. These standard operating procedures are comprised of quality control procedures and quality assurance procedures. Quality control (QC) procedures refer to routine daily, weekly, and monthly procedures performed by the SoilTI'EK unit operators. Quality assurance (QA) procedures are conducted on a quarterly and an annual basis. The QA procedures are to be performed by a qualified person independent of the day to day operation of the CEMS. The following sections provide detailed information and step by step instructions for the performance of the required procedures. 3.1 STARTUP AND SHUTDOWN PROCEDURES Because the Soilfr'EK unit may be periodically shutdown for process and generator maintenance, the monitoring system must also be shutdown. Startup and shutdown procedures are to be performed in the correct sequence to avoid contaminating the sample systems with moisture and to minimize maintenance problems with other system components. The procedures are listed below. Startup Procedures: 1. Tum on the Pace 1400 Heated -Line Controller. The set point of the controller should be maintained at 225° F. Allow the sample line to come up to temperature. 2. Tum on the instrument air compressor that provides air to the eductor. Adjust the eductor pressure to 30 psi. 7 3. Actuate the remaining power switches for the Pace Stack Interface paneL 4. Open the cover to the strip chart recorder and with a felt tip pen mark the chart with the exact time, date, and initials of the operator. Close the cover and actuate the record power switch Make sure the instrument is responsive and the diart speed is set to 3 inches per hour on the LED reading on the right paneL 5. Turn on the computer terminal, video monitor, and printer. The communication software is programmed to come up automatically. 6. Since the DSM 3260 is typically left on, check the current time in the LED display. If incorrect reset Push the memory storage module into to place-and make sure it is properly seated. IMPORTANT NOTE: If the data logger battery is in functional, the memory storage may be left in place all the time. If not the module must be pulled out before electrical power is shutdown, as is done during generator maintenance. 7. Enable the averaging function on the data logger through the computer terminal. 8. Tum on the power to the CO gas analyzer and the 02 analyzer. Make sure both units are responsive and sample flow can be observe on the CO rotometer (flowmeter) 0.5 to 1.5 1pm. The CEMS is collecting dgin Shutdown Procedures: 1. Disable the averaging fimction on the Hail logger through the computer terminal. 2. Tum the calibrate mode switch to position 4. This will allow the gas analyzer to purge with room air. 3. Turn off the power to the instrument air compressor. This will discontinue sample flow from the stack_ 4. After 3 to 5 minutes, tum the calibrate mode switches back to the Sample position. 5, Turn the power switches on the gas analyzers to Off 6. If electrical power is to be lost from a generator shutdown, pull the memory storage module out of its seated position. There is no need to pull it all the way out. 7. Tum off the strip chart recorder and mark the chart to indicate shutdown with the time and date. 8. Tum off all power switches on the Pace Stack Interface Panel. 3.2 DAILY QC PROCEDURES Daily QC procedures are conducted to evaluate the operation and accuracy of the stack interface, sample gas conditioner, gas analyzers, and DAS. The results of these daily checks MUST BE RECORDED ATTACHMENT D MATERIAL SPECIFICATION SHEETS Nova-Thene RB88X-6HD Canvex CB12WB AMOCO Style 4510 MSDS GAC MSDS — Soda Ash i MON 11:25 AM CEO /ENV . FAX :907 562 70 PAGE 4 RIVE POLYOLEFIN FAQ ICS KY: RS88X -6FID DATA SHEET Heavyweight material for geomembranes, coated with high density polyethylene for greater chemical resistance. FABRIC SPECIFICATIONS WEAVE Nominal 16 by 16 ppi woven black HDPE scrim using 1600 denier tapes, and using a special weave pattern to enhance flatness and tear properties (63 x 63 tapes per 10 cm) COATING 2.5 mil average, two sides HDPE (59 g %m5, two sides) COLOUR black coating standard, other colors may be available after trials and testing WEIGHT 10 oz/yd2 (340 g /m2) +/- 5 % THICKNESS 20 mils (0.51 mm) AST1v1 D5199 PERFORMANCE GRAB TENSILE WIDE TENSIL -E(1 inch /25.4 rnm) TONGUE TEAR MULUEN BURST Warp 350 lb 1556 N eft 3501b 1556 ASTM D5034 rp 2161b 961 N Warp 100 lb 445 N We 222 1b 988 N ASTN D4885 650 psi 4485 kPa 182 lb 811N PUNCTURE RESISTANCE I—DIMENSIONAL STABILITY PERMITTIVITY VOL.ATILES Warp -1.6% �2a 10 -6s -1 0.11 °4) 100 lb 445 N ASTM D2261 Weft -1.3% ASTM D3785 ASTM D4833 ASTM D1204 AST 9 ASTN D1203 ROLL SPECIFICATIONS CORES 4 inch (101.6 mm) or 5 inch (127 mm) 1.0. WIDT1.1 Up to 150 inches ( -0 , +0.5) as ordered, 381 m ( -0 , 4-12 mm) LENGTH Minimum 250 yds/roll (229 rn); up to 1000 ydshoil (914 m) The above physical test results are representative data collected from developmental trials. Results for an individual roll (based on at least th-ee specunens) may vary from the average by +/ -'l0 %. D51(P,888X -6HD) Rev 2 21/03,99 intertape polymer group anx 36c, 5) Abbey Avenue, Truro. Nova Scotia. Canada B2.; 500 Tot: (C2) 695.1686 , ;; (0021 893-479C ;l W)l`i 11 26 AIi GEO /Er, FAX:907 562 7003 PAGE 5 NOVA -THEME RB88X -6HD SEAMING DATA SHEET The data below represents achievable factory seam strengths and is compiled front results from hot air, hot wedge and propane welded seams, Other techniques such as extrusion welding may be considered at users discretion. Seaming with natural gas is not recommended. SEAM STR2ENGTH (Grab Method) SEAM STRF,NGTEI (2" Strip) SEAM STRENGTH (Dead Load) SEAM PEEL STRENGTR 320 lb 380 1b12" No seam failure after 24 hours at constant load of > 50% of seam grab strength, with no lass of ultimate break' strength. ASTM D-751 (Modified as in NSF,54) ASTM D -751 NSF Std. 54 Appendix A Pt 10. Modified gab method. 23" C, 73" 1' 5 lb per inch ASTM D -75 1 Seam Strength Retention Under Environmental Conditions See Nova -Thene RB88X -61-ID Environmental Resistance Data Sheet The values are typical data based on laboratory and .factory tests to provide user information. They are not limiting specifications of field performance guarantees. DS I (RBERX -5HD Seaming) Rev New 0825/98 r.,"..i,•3ner -:iC3r: T' V E(ix 358. ri.x: 1,962) JUN.- 29 -01. FRI 02 FAX :907 562 7003 PAGr Product Name and Part # Canvex CB12WB Product Description: Part # CB12WB Camrex CB12W8 Is tightly woven from high density polyethylene to achieve exceptional Lear resistance, It is then coated on both sides with a low density polyethylene. This construction allows the ribbons to shift and 'bunch up" in response to any tearing force, therefore stopping the tear. Basic Use: mossosinsamaismaini Canvex CB12WB performs exceptionally well in outdoor applications because of the carbon black content in both the ribbon reinforcement and the black outer • coating. The white side is protected with ultra violet inhibitors. Canvex CB12WB offers the versatility of either a white side to reduce condensation and heat build up or the black side for even longer life. Suggested Applications: • Pit Liners • Temporary Erosion Control • Remediation Covers • Railroad Car Covers • Under Slab Vapor Barriers Size Range: • Remediation Liners Long Term Storage • Ditch Linings • Cargo Load Covers • Decorative Ponds 600 square foot panels up to 70,000 square foot panels in a variety of widths and lengths. Packaging: Canvex CB12WB is available in a wide range of sizes neatly accordion - folded and rolled on a heavy duty core. This allows for easier handling and time saving installation. RAVEN 1ND.USTRIE5 Flextb(e Films Deportment CANVEX DISTR16UTED BY: 041.31:0 'ZULU 10:11. 9iJ/5621b03 STYLE 4510 POLAR.EUPPLY CO INC PAGE Si Amoco Fabrics and Fibers Company ' 260 The Bluffs. Austell, GA 30168 PH: (770) 944-4569 FX: (770) 944-4584 Amoco Style 4510 is a polypropylene nonwoven. needlepunched fabric. This engineered geotextile is stabilized to resist degradation slue to ultraviolet exposure. It is resistant to commonly encountered soil chemicals, mildew and insects, and is non - biodegradable. Polypropylene is stable within a pH range of 2 to 13, malting it one of the most stable polymers available for geotextiles today. We wish to advise that Amoco Style 45].Q meets the following minimum average, roll values: Property Test Method ' ASTM -D -5261 ! Minimum Avcrego Roll Value (English) 10 oz/yd2 Minimum Average Roll Value (Metric) 339 g/m2 Unit Weight Grab Tensile ASTM- D-4632 I 250 Ib 1.11 kN Grab Elongation ASTM -D -4632 1 50 % 50 % Mullen Burst ASTM -D -3786 ! 550 psi 3790 kPa Puncture ASTM- D-4833 ; 165 Ib 0.730 IN Trapezoidal Tear ASTM -D -4533 ! 100 lb 0.445 kN UV Resistance ASTM -D -4355 1 70 % at 500 hrs 70 % at 500 hrs AOS ASTM- D-4751 100 sieve .15 mm Permittivity ASTM- D.4491 ! 1.2 sect 1.2 sec-' Flow Ritz ASTM -D -4491 85 gal/min/it2 3460 LJrnin /m2 Coefficient of Permeability ASTM-D-4491 1 0.20 cm/sec 0.20 cmiscc Thickness . ASTM -D -5199: 85 mils 2.15 mm Amoco Fabrics and Fibers Cow1any manufacturers the nonwoven fabric indicated above. The values listed are a result of testing conducted in on -site laboratories. A letter certifying the minimum average roll values will be issued from the manufacturing plane by the Quality Control Manager at the time shipment is made. DATE ISSUED: 01 /07/00 • The information presented herein, while nor guarsr:teed, la to the best of our knowledge true and aoeuiatc. Except when agreed to in writing for specific conditions of use, no warranty cc guarantee expti=ssed or implied it made regarding the performance of any protium, since the manner elute said handling are beyond uur coolroL Nothitig contained ]erein is to be =Arced ued as permission or as a recornmendtion 10 infringe any patent. Part of the BP Amoco Group C EANAI R E ALASKA LTD. 230 E. Potter Dr. #10 * Anchorage, AK 99518 907-561-2735 * 800-478-2735 * Fax 907-563-5678 MATERIAL SAFETY DATA SHEET DATE or ISSUE. Jan 2, 2000 • Activated Carbon SECTION 1 - IDENTIFICATION \I:\.WFACTI.:RER NAME:- Cameron Environmental. Inc 310-212-0610 20741 Manhattan Place, Torrance, CA 90501 SYNONYMS: .-kctivalcd Carbon, Activated Charcoal, GAC, TRADE NAMES: CAS-R, CAS-COL, CAS-YAW, CAS-VCN (clean Air Store- Carbon) CI EM ICAL FAM I Y : Amorphous Carbon: CAS NO. 7440-440 FORMULA: Gabon atom in a crystallite structure has an infinite molecular weight. Anthracite Coal. Bituminous Coal. Coconut Shell, Peat. Wood. - Steam Activated SECTION 11 - HAZARDOUS INGREDIENTS CHEMICAL NAMES: (Inuredients) re, TLV (Units)1: No Hazardous Iniaedients HAZARDOUS MIXTURES OF OTHER LIQUIDS, SOLIDS OR GASSES [io •LV (Unit)]: LIMA Dy Act ivated Carbons that have adsorbed volatile organics or non-carbon liquids or gasses may lo\■er raise the ignition point and must be laboratory checked for ignition point when expended. SECTION 111 - PHYSICAL DATA 130ILING POINT 4200 deg F VAPOR PRESSURE. (nun Kg. At 20 (.') N/A VAPOR DENSITY (AIR-1) N/A IGNITION TEMPERATURE: 600 deg C SPECIFIC GRAVITY (1-120-1) 1.8 - 2.1 PERCENT VOLATILE BY VOLUME N.:\ EVAPORATION RATE: (Ethyl Ether) N.A APPEARANCE: Black granular. tree flow dr■ ODOR: Negligible Odor ODOR THRESHOLD (ppm) N :\ SECTION IV - FIRE HAZARD & EXPLOSIVE DATA ti.,AsH POINT: AUTOIGNATION TEMPERATi.R L \ \ IN AIR: I.ovi el. Explosive Limit: N,`A lipper Explosk Limit: !'\';.A XTINGUSI-i ING Use media Tor Class A tires. Foam. multipurpose dry chemical and w.tiki. extinguishers. SPECIAL FIRE FIGHTING INSTRUC'TIONS: Since wet activated carbon adsorbs oxyLten. do not enter closed essels \\it'll/lit self-contained breathing apparatus. • NUSLAI. FIRE & EXPL.OSION HAZARDS: Provide for the handling of dry flowing solids in grounded equipment to prevent build-up of static electric charge, especially when explosive dust or \ apor mixtures may exist in confined areas. Also provide for pressure relieldevices IA \V NFI'A Explosion Preventing Guide NI: PS68- 1854. SECTION - HEALTH YrIAZARD DATA 111 I<N".1 MI .1) 1.1N1 IT VALUE: Avoid exposure to dust levels above 1 Smg per cubic meter K( )1 ON EXPOSURE & EFFECTS: Continued exposure or mueous membranes to dust ina■ cause temporary drying of exposed areas and minor nose and throat irritation. Avoid chrome inhalation FIRST AID PROCEDURES: Wash mouth with water. No other treatment required SECTION VI - REACTIVITY DATA STABILITY: UNSTABLE --- -- STABLE -4 X CONDITIONS TO AVOID: Activated Carbon is chemically inert. INCOMPATABILITY: (Materials to avoid): None HAZARDOUS DECOMPOSITION PRODUCTS: None POLYMERIZATION: None SECTION VII - PROTECTION INFORMATION RESPIRATORY PROTECTION: Respiratory classification table G -2 part 1910.93 (OSHA) Rules & Regulations. VENTILATION: Adequate dust collection or exhaust system should be used to avoid formation of dust aerosol PERSONAL PROTECTIVE EQUIPMENT: - (Eye): Safety Goggles for airborne dust (Gloves): None required (Respirator): Dust Mask must be worn. (Other): None needed. SECTION VIII - DISPOSAL PROCEDURES SPILL, LEAK OR RELEASE: Spilled powder may be collected by shoveling or sweeping. Respirator and eye protection must be worn. Care should be taken to prevent high dust concentrations in the air. WASTE DISPOSAL: Recycle & Reactivate .- Product is suitable for incineration. Solid waste disposal. SECTION IX - SPECIAL PRECAUTIONS STORAGE & HANDLING CONDITIONS: Packaged carbon is not resistant to weather or outside storage. Store indoors in type I & type II storage facilities. Precautions for finely divided flammable dust should be followed when handling large quanity of dry material. Use adequate dust collection equipment: Insure all equipment is properly grounded to prevent static discharge. Keep dust away from flame, heat or spark. Store away from volatile organic solvents and moisture (to preserve media) OTHER PRECAUTIONS: Check oxygen content of atmosphere of any vessel containing activated carbon before allowing entry of personnel. SECTION X - PRECAUTIONARY LABEL (IF APPLICABLE) DOT CLASSIFICATION: NMFC 40560 / DOT MARKING: N/A / DOT PLACARD: N/A The information contained herein is based on data considered accurate in light of current formulation. However, no warranty is expressed or implied regarding the accuracy of this data or the results to be obtained from the use thereof. CLEANAIRE ALASKA Ltd. 230 East Potter Dr. #10 Anchorage, AK 99518 PHONE: 907 -561 -2735 800 - 478 -2735 FAX: 907 -563 -5678 CAMERON ENVIRONMENTAL, Inc. 20711 Manhattan Place Torrance, CA 90501 PHONE: 310- 212 -0610 FAX: 310 -212 -7222 GARNESS INDUSTRIAL INC. 6317 Nielson Way Anchorage, Alaska 99518 Tel Fax:(907)563 -4579 MATERIAL SAFETY DATA SHEET PRODUCT IDENTIFICATION PRODUCT NAME: SODIUM CARBONATE FORMULA Na2CO3 DESCRIPTION: WHITE POWDER NORMAL HANDLING PROCEDURES CAS NO. 497 -19 -8 PRECAUTIONS TO BE TAKEN IN HANDLING & STORAGE: DO NOT GET IN EYES, ON SKIN, OR ON CLOTHING. DO NOT TAKE INTERNALLY. AVOID BREATHING DUST. STORE IN A COOL, DRY PLACE. PROTECTIVE EQUIPMENT VENTILATION REQUIREMENTS EYES: GOGGLES LOCAL EXHAUST VENTILATION REQUIRES GLOVES: BUTYL RUBBER WHERE EXPOSURES TO DUST MIGHT OCCUR. OTHER: COVERALLS & BOOTS NONE: HAZARDOUS INGREDIENTS FIRE & EXPLOSION HAZARD DATA FLASH POINT: N/A OSHA CLASSIFICATION: NON - COMBUSTIBLE SOLID. EXTINGUISHING MEDIA: N/A SPECIAL FIRE HAZARD & FIRE FIGHTING PROCEDURES: USE NIOSH /MSHA APPROVED SELF - CONTAINED BREATHING APPARATUS WHERE THIS MATERIAL IS INVOLVED IN A FIRE. HEALTH HAZARD DATA THRESHOLD LIMIT VALUE: NOT ESTABLISHED. SYMPTOMS OF OVER EXPOSURE: SKIN, EYE & MUCOUS MEMBRANE IRRITATION. SKIN: WASH WITH WATER FOR 15 MINUTES, CALL A PHYSICIAN. EYES: WASH WITH WATER FOR 15 MINUTES, CALL A PHYSICIAN. INGESTION: WASH MOUTH OUT THOROUGHLY; GIVELARGE AMOUNTS OF WATER TO DRINK. - UN 4 LATION: REMOVE VICTIM TO FRESH AIR. TOXICOLOGY DATA ACUTE ORAL LD 50 > 4g/kg (RATS) CARCINOGENIC NOT KNOWN TO BE CARCINOGENIC. ACUTE DERMAL LD 50 UNKNOWN MUTAGENIC NOT KNOWN TO BE MUTAGENIC. ACUTE INHALATION LD 50 UNKNOWN EYE IRRITATION IRRITANT, PRIMARY SKIN IRRITATION IRRITANT. PRINCIPAL ROUTES OF ABSORPTION: ORAL. EFFECTS OF ACUTE EXPOSURE:IRRITATION OF EYES, SKIN, & MUCOUS MEMBRANES. EFFECTS OF CHRONIC EXPOSURE: NONE EXPECTED AT INDUSTRIAL USE LEVELS. SPILL OR LEAKAGE PROCEDURES (CONTROL PROCEDURES) STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED: WEAR NIOSH /MSHA APPROVED DUST RESPIRATOR. FOLLOW OSHA REGULATIONS FOR RESPIRATOR USE. (SEE 29CFR 1910.134). WEAR GOGGLES, BUTYL RUBBER GLOVES & BOOTS. SHOVEL, OR SWEEP UP & PLACE IN AN APPROVED D.O.T. CONTAINER & SEAL. WASH ALL CONTAMINATED CLOTHING BEFORE REUSE. WASTE DISPOSAL METHOD: DISPOSE OF CLEAN -UP DEBRIS, CONTAMINATED MATERIAL & RESIDUES, IN A MANNER APPROVED FOR THIS MATERIAL. CONSULT APPROPRIATE FEDERAL, STATE & LOCAL REGULATORY AGENCIES TO ASCERTAIN PROPER DISPOSAL PROCEDURES. IN THE EVENT OF A MASSIVE SPILL, USE THIS EMERGENCY PHONE NUMBER (203)356 -2345 REACTIVITY DATA STABILITY: STABLE CONDITIONS OT AVOID: NIA INCOMPATIBILITY(MATERIAL TO AVOID): N/A HAZARDOUS DECOMPOSITION PRODUCTS: N/A PHYSICAL DATA MELTING POINT: 851 C VAPOR PRESSURE: N/A VOLATILES: NIA BOILING POINT: DECOMPOSES SOLUBLE IN WATER. EVAPORATION RATE: N/A SPECIFIC GRAVITY (H20 =1): 2.5 pH 1% SOLUTION = 11.5 VAPOR DENSITY (AIR =1): N: A . ALL INFORMATION, RECOMMENDATIONS & SUGGESTIONS APPEARING HEREIN CONCERNING THIS PRODUCT IS BASED UPON TEST & DATA BELIEVED TO BE RELIABLE; HOWEVER, IT IS THE USER'S RESPONSIBILITY TO DETERMINE THE SAFETY, TOXICITY & SUITABILITY FOR HIS OWN USE OF THE PRODUCTS DESCRIBED HEREIN. SINCE THE ACTUAL USE BY OTHERS IS BEYOND OUR CONTROL, NO GUARANTEE, EXPRESSED OR IMPLIED, IS MADE BY GARNESS INDUSTRIAL fNC. AS TO THE EFFECTS OF SUCH USE, THE RESULTS TO BE OBTAINED OR THE SAFETY & TOXICITY OF THE PRODUCTS NOR DOES GARNESS INDUSTRIAL INC. ASSUME ANY LIABILITY ARISING OUT OF USE BY OTHERS. OF THE PRODUCTS CONTAINED HEREIN. THE INFORMATION HEREIN IS NOT TO BE CONSTRUED AS ABSOLUTELY COMPLETE SINCE ADDITIONAL INFORMATION MAY BE NECESSARY OR DESIRABLE WHEN PARTICULAR OF EXCEPTIONAL CONDITIONS OR CIRCUMSTANCES EXIST OR BECAUSE OF APPLICABLE LAWS OR GOVERNMENT REGULATIONS. NOTHING HEREIN CONTAINED IS TO BE CONSTRUED AS A RECOMMENDATION TO INFRINGE ANY PATENT ATTACHMENT E FORMS SPI Soil Tracking Record Treated Soil Release Record BEI Indemnification Clause Soe PROCESSING INCORPORATED PORTABLE THERMAL UNITS • OILFIELD SERVICES • ENVIR01414ENTAL CLEANUP TRACKING RECORD JOB # 943- Client Name: Address: Phone Contact ADEC SPILL Number Date Reported. Physical Location Hauling Contractor #DEC arprovttl -1-o +rdn5fort Con+,5n;linal.exi $0*/1 Date Hauled Soil Description (Gravel,Sand, Peat) Cell # Start Finish Date Treated Start Finish Tons Treated Stockpile Location Date Tested Chain of Custody # By Test Results Date Received Dati'm Removed 207 E. Northern Light Blvd., Suite 103A • Anchorage, AK 99503 Telephone (907) 274:3000 FAX (907) 274-$295 LOJECT WORK ITEM RELEASE RECORD — SOii Processing Inc. DATE SPI JOB # 99- SOURCE DESTINATION CONTRACTOR TRUCK. TRUCK TRUCK. MFGR: MFGR: MFGR. DRIVER. DRIVER. DRIVER. LOAD DUMP LOAD TOTAL TOTAL TOTAL I certify that all materials hauled from the source were delivered to the destination recorded above. DRIVER NAME (PRINT) SIGNATURE ADL NUMBER DRIVER NAME (PRINT) SIGNATURE DRIVER NAME (PRINT) SIGNATURE ",erufy all the loads recorded were delivered by these trucks to the above destination. ADL NUMBER ADL NUMBER INSPECTOR NAME (PRTNT) SIGNATURE ORGANIZATION •1 GENERAL CONTRACTORS BRECHAN ENTERPRISES, INC / GENERAL CONTRACTORS 2705. MILL BAY ROAD •. KODIAK, ALASKA 996 1 5 THERMAL SOIL REMEDIATION OF PETROLEUM CONTAMINATED SOILS AT BRECHAN ENTERPRISES, INC. INDUSTRIAL SITE BELLS FLAT, KODIAK, ALASKA INDEMNIFICATION CLAUSE The undersigned VENDOR/CONTRACTOR agrees to hold harmless Brechan • Enterprises, Inc., its shareholders, officers, agents and employees from, and to defend them against any'and all claims arising from the purchase, construction, installation and/or use of the equipment ,, articles and /or materials or services which are furnished, used or provided by the VENDOR/CONTRACTOR under this order. VENDOR/CONTRACTOR assumes all risk of damages, injury or death to VENDOR/CONTRACTORS own employees, property or persons acting for or on behalf of the VENDOR/CONTRACTORS for whatever cause. Nothing herein.shall be construed to relieve Brechan Enterprises, Inc. from liability arising solely as a result of its own gross negligence. VENDOR/CONTRACTOR NAME (PRINTED) SIGNATURE DATE VENDOR/CONTRACTOR DEC Permit Number PHONE: 907.486.3 215 • FAX: 907.486.4889 ALASKA BUSINESS #D0 1 858 •• ALASKA CONTRACTORS #AA441" We Are An Equal Opportunity Employer ATTACHMENT F Asphalt Pavement Mix Design •- •.U. U4,0LIrU 1J.J1 r, AA yui ,Icai400V li1th :uuAN 1:NLEI <Y1USb INC. 4)OO5 AALASKA T E S T L A E A D i v i s i o n of O O W L L L C W.O. A29667 Date April 24, 2002 Brechan Enterprises 2705 Mill Bay Road Kodiak, Alaska 99615 Attention: Jim Graham/Bob Hale Subject: Asphalt Pavement Mix Design, ADOT &PF Type 1113 Dear: Mr, Graham: Asphalt aggregate was received in our laboratory on April 22, 2002. A Marshall rnethod mix design was performed in accordance with the ADOT &PF' ATM T -17. Aggregate quality results are listed on the attached mix design sheet. The test standards followed during the laboratory test program are listed below. AASHTO T84, AASHTO T85, AASHTO T166, AASHTO T 209, ATM T -7, ATM T -13 ATM T -9 AASHTO T104 AASHTO T 96 ATM T -9 ASTM D4867 . WAQTC TM 1 "Specific Gravity and Absorption of Fine Aggregate" "Specific Gravity and Absorption of Coarse Aggregate" "Bulk Specific Gravity of Compacted Bituminous Mixtures Using Saturated Surface Dry Specimens" "Maximum Specific Gravity of Bituminous Paving Mixtures" "Sieve Analysis of Fine and Coarse Soils and Aggregates" ".Aggregate Degradation" "Flat — Elongated Pieses" "Soundness of Aggregates by Usc of Sodium Sulfate" "Resistance to Abrasion of Small Size Coarse Aggregate be Use of the I,os Angeles Machine" "Flat or Elongated Particles in Coarse Aggregate" "Effect of Moisture on Asphalt Concrete Paving lvfixture" "Determining the Percentage of Fracture in Coarse Aggregate" Mix Design Technique ATI, helped you develop a job mix formula (JMF) to conform to the ADOT &PF Type I1 B specifications. A three pile mix was crushed and separated by you and we sampled the each pile of aggregate and performed a gradation. Duc to the short time frame to perform the asphalt mix design there was only about 3 days of crushing data that we could base a JMF from. Based on the - infonnation to date the aglzregate blend was 32 percent coarse, 20 percent intermediate aggregate, 48 percent fine aggregate. We separated the aggregates into each specification sieve size range. The separate sizes were recombined to make specimens with the IMF. Coarse and fine aggregate specific gravities were measured on specimens batched to match the JMF. Five different asphalt contents were tested for the mix design. For each asphalt content, four specimens were'prepared for determination of density, flow, and stability. The theoretical maximum specific gravity was measured at an asphalt content of 5.8 percent. 1040 13 STREET • ANCHORAGE • ALASKA • 95503 • 907/662.2000 • PAX 07/563.3963 1. kid: 1,4 .L" PriA U 4 tn.; -ItStiS 2002Asphalt Mix Designs Date Page 2 BRECHAN ENTERPRISES INC Zja08 • Asphalt Cement The asphalt cements used for this mix design were PG 52-28 manufactured by Tesoro Alaska, North Pole, AK. The manufacturer's submittal for each asphalt product is attached. ADOT&PF Type II B Asphalt Concrete Mix Design Mix Design: A copy of the Type II B asphalt concrete mix design is attached. Asphalt content az our percent air voids in the total mix was 6.2 percent. The asphalt content at maximum density and maximum stability was 5.0 percent and 6.1 percent respectively. The optimum asphalt content was selected to be 5.8 percent. The properties of the mix at 5.8 percent asphalt are all within the project specification ranges. Aggregate Gradation: The aggregate gradation selected for the job mix formula is shown on, the attached gradation curve. Specific Gravity: The aggregate and mix specific gravities arc tabulated below. The coarse aggregate is defined as the fraction retained on the No. 4 sieve. rCoarse Aggregate Fine Aggregate F1MA Mixture Bulk Specific Gravity 2.670 2.651 Apparent Specific Gravity 2.726 2.739 Absorption 0.9 1.2 Effective Specific Gravity 2,730 Anti-Strip Requirements: A 0.25 anti-strip was placed in the binder. Density: The density versus asphalt content curve peaks at an asphalt content of 6.1 percent with a maximum density of 148.0. The optimum asphalt content of 5.8 percent yields a density of 147.9 pd. Stability: The stability versus asphalt content curve peaks at an asphalt content of 5.0 percent with a maximum stability of 22221b. The stability at the design asphalt content is 2000 lb. Flow: The flow tends to remain constant or slightly decrease with increasing asphalt content. The tow is 15 at the design asphalt content of 5,8. • J . a l . 4.10 0 v /.4 0 u 4 00 OKILLAJAPI hiNTLIOXISES INC 410117. 2002Asplialt Mix Designs Date Page 3 Air Voids Total Mix: • The asphalt content at 4 perccnt air voids is 6.3. The optimum asphalt content was chosen CO be at 5.8 percent to yield 4.6 percent air voids. Voids Filled with Asphalt: Seventy one percent of the voids were filled with asphalt at the design asphalt content VMA: The voids in the mineral aggregate (VMA) are 16.0 percent at the design asphalt content. The minirr.un ViviA. required by the specifications is 13 percent. Verification of the Laboratory Mix: The laboratory mix design should be verified by hot mix asphalt actually produced from your plant. In some cases the voids and density of plant mix asphalt pavement are slightly different than the laboratory mixed material: If the plant mix is significantly different than the lab batched mix, it may be warranted to adjust the design asphalt content to bring the properties of the mix more in line with the project specifications. • Ia.s I., VA. 1114 1.111A.11./.1. 4 &LAU VIA V 1 Li tla la, please call me. Sincerel ALA TEST DaT. L. Andersen, E. General Manager attachments -Asphalt Mix Design Aggregate Gradation Curve Asphalt Cement Data N,_ •: V -(. _l.V- 1V. JV 1'11.1 Vt./1400403e Ad4 ALASKA T.2 6 T L A B A D i v i s i o n of O O W L L L C l :ent: 13rechan Enterprises Specification: ADOT &PF Type 11 B Product Use: Asphalt Cement Pavement Project:. tilthl.;LIAN L•N'1t;hYK1Sr'S ;NC: Sieve Size JMF* + j Narrow Band Soundness Loss ( %) Coarse Aggregate Fine Aggregate Broad Band 3'4 100 i 100 98 100 1/2 87 Abrasion resistance Loss (L',.',) 81 -93 19 75 -90 3/8 76 ' 70 -82 mil.- Elongated Pieces 60 -84 Nu. 4 56 50 -62 33 -70 No. 8 38 '. 32 -44 19 -56 No. 16 26 1 21 -31 10-44 No.30 18 14 -22 8 -16 5 -11 J 7 -34 5 -24 4 -16 No. 50 12 No. 100 8 No. 200 5.8 = 3.8 -7.8 3 -7 Asphalt (_ lutrnt •' -y weight Mix) 5.8 5.4 -6.2 Aggregate Suitability Value Value Specification Soundness Loss ( %) Coarse Aggregate Fine Aggregate ! i 0.3 9 max 9 max Single Face Fracture ( %) ? 98 80 min. Double Face Fracture ( %) 71.1 Abrasion resistance Loss (L',.',) VMA ( %) 19 45 max. Degradation (%) 147.9 18 25 min. mil.- Elongated Pieces 1.6 8`.' /o max. Aggregate Blend 32% Coarse, 20% Intermediate, line r\-- L. Andersen, P.E. CJ.ner-al Manager :00U3 AASHTO ACCREDITED CONSTRUCTION MATERIALS TESTING LABORATORY Marshall :Method Mix Design. ADOT &PF ATM T-17 - April 24, 2002 Properties at Optimum* Value Specification Stability (Ih) 2000 1200 Flow 15 8 -16 Air Voids ( %) 4.6 3 to 5 Voids Filled ( %) 71.1 65-78 VMA ( %) 16.0 12 Unit Weight (pct) 147.9 Dust / Asphalt Ratio 1.02 Marshall Compaction (Blows per Face) 50 Specific Gravity Aggregate Apparent Specific Gravity 2.733 • Aggregate Bulk Specific Gravity 2.659 Aggregate Effective Specific Gravity 2.73 Maximum Specific Gravity of Mixture (ASTM D2041) al 5.8% AC 2.487 Asphalt Specific Gravity 1,0159 - Asphalt Properties Asphalt Binder (Tesoro Alaska) PG 52 -28 Laboratory Mixing Temp. 283 Laboratory Compaction Temp. 262 Antistrip (ASTM D4867/D4867M) Rjuirement 0.25 * Laborator• r �� - T1 l \ e Side of this Form. ,aC3 B STREET • ANCHORAGE • ALASKA • 99503 • 90 ± AX 907/563.3953 lz):ali MA 3O74dii4tb 9 BRECHAN ENTERPRISES INC 16004 Brechan Enterprises ADOT1F Type II B 149.0 148.5 148.0 c 147,5 K 147.0 146.5 1) 146.0 145.5 145.0 144.5 144.0 4.0 5.0 6.0 7.0 2300 2200 2 2100 P. 2000 7 1900 1800 1700 4.0 5.0 6.0 7.0 17.0 16.0 15.0 14.0, 13.0 12.0 11.0 10.0 Laboratory Mix Design Data prepared by ALASKA TESTLAB April 24, 2002 Air Voids ( %) 10.0 9.0 8.0 7.0 6.0 5.0 4.0 3.0 2.0 1.0 4.0 5.0 6.0 7.0 80. •-• 70 1 60 50 40 4.0 5.0 6.0 7.0 4.0 5.0 6.0 7.0 Aspbalt.Conteut by Weight of Mix ("/0) ; 17 16 15 • J 4.0 5.0 6.0 7.0 Asphalt Content by Weight of Mix (%) ATTACHMENT G AERIAL PHOTO 0000 010HLJ 7 V,' k/ Soap PROCESSING Inc. STATEMENT OF QUALIFICATIONS SOIL PROCESSING INC. 207 EAST NORTHERN LIGHTS BOULEVARD SUITE 103 -A ANCHORAGE, ALASKA 99503 (907) 274 -3000 (907) 274 -9295 FAX cy�!e il F.-reuse' viagf:-'60:17Celdstv w!ting. in Tg.rqps .„_ VPV-INNAW)17,<AVItem e0-fe ir6 STATEMENT OF QUALIFICATIONS Soil Processing Inc. (SPI) was formed and incorporated in the State of Alaska on November 26, 1990. The goal was to develop a system to treat hydrocarbon-contaminated soils on drilling sites in Alaska that would meet the approval of the Alaska Department of Environmental Conservation (ADEC). SPI's low temperature soil remediation unit (SRU) meets all State of Alaska and State of Washington Air Quality requirements. SPI specializes in set up and operation in remote, hard-to-access sites. The SPI unit is unique due to its transportability. The unit requires no special permits for highway transportation, has been barged to most work sites, and is Hercable with minor modifications. Barging is made simple as all equipment and support items are trailer-mounted for easy loading and off-loading. Fuels such as propane and butane for the processor, and diesel for the generator and loaders — are also on trailers. Our compact, trailer-mounted unit helps minimize the mobilization and, demobilization costs. All of SPI's key personnel have been with us since the start of the company. All personnel are physically certified and have current 40- hour HAZWOPER and North Slope Training Cooperative (NSTC) certification. Since the inception of SPI, we have treated over 120,000 tons of contaminated soil ranging from crude oil, Bunker C, diesel, gasoline, Jet A 250, polychlorinated biphenyls (PCBs) below 50 parts per million (ppm), glycol, and drilling muds (see Table 1). SPI's clients range from major oil companies to private businesses (see Table 1). A listing of clients and state regulators is provided for references in Table 2. SOIL PROCESSING INC. " 207 EAST NORTHERN LIGHTS BLVD,, SUITE 103-A ANCHORAGE, ALASKA 99503 (907) 274-3000 0 (907) 274-9295 FAX -‘! Table 1. Soil Processing Inc. Project History. " - „-- '1`Q.al:... - -. .. . , '1 -v - .L,Qqation Lewis River Node o : -- ' Transport : Barged ' Fue Used. .. . .:' - -`, 1.. Natural Gas •,-,,-:...7, , . . - - -, ,:-., - . - ' , con'. oina .., .- - ', L', "A; ' '?'-',--`, -% ''' iii9PrifoUPPWi emediratqd..--: ' ' ".-'''”' v '.'. ''1,5'.`!•':'-' 1991 Unocal Diesel . 8,099.50 Granite Point Barged Natural Gas Unocal Crude Oil/Tank Bottoms 5,344.06 1992 Anchorage Trucked Natural Gas NC Machinery Diesel/Motor oil 1,100.00 Anchorage Intl Airport Trucked Natural Gas Unocal Diesel/Gasoline 415.14 Granite Paint Barged Natural Gas Unocal Crude Oil/Tank Bottoms 5,011.44 1993 Fort Richardson Trucked Propane USACE/LSCC Diesel/Gasoline 4,049.93 Unalakleet Barged Propane Martech Diesel/PCBs 2,954.88 Trading Bay Barged Propane Stewart Petroleum Diesel/Crude Oil 2,242.41 1994 ' Valdez -. Trucked Propane Tesoro Diesel/Gasoline 2,796.01 Valdez Trucked Propane City of Valdez Diesel 173.29 Valdez .Trucked Propane Chevron Diesel 1,786.34 Kenai Trucked Natural Gas Tesoro Refinery Crude Oil 13,530.73 1995 Kenai Trucked Propane Tesoro Refinery Crude 911 6,076.01 Dog Fish Bay Barged Propane ENSR Diesel/Gasoline 2,364.37 Kenai EFDF Trucked Natural Gas Shell Onshore Crude Oil 573.47 Kenai EFDF Trucked Natural Gas Unocal Glycol/Tank Bottoms 814.10 Drift River ' Barged Propane Cook Inlet Pipe Line Company Crude Oil 5,044.88 1996 Cordova Barged Butane Orca Cannery Bunker C 1,382.89 Cordova Barged Butane BP Exploration .Bunker C 17,173.11 Table 1. Soil Processing Inc. Project History (Cont'd). 1997 1998 1999 2000 2001 Cordova Cordova Cordova Soldotna Soldotna Soldotna Kuparuk Kuparuk Kodiak Barged Barged Barged Trucked, Trucked Trucked Trucked Trucked Barged Butane Butane Butane Natural Gas Butane BP Exploration FAA/OHM City of Cordova Shannon & Wilson. University of Alaska Various ARCO Alaska PHILLIPS Alaska Jacobs Engineering Group Bunker C Diesel /Gasoline Diesel Diesel Oil Diesel Diesel /Jet A/Gasoline Crude Oil/Diesel Crude, Oil /Diesel Diesel /PCE/TCE Total Remediate To.D 17,009.00 1,699.00 128.57 818.00 672.00 6,928.65 9,247.45 10,000 1 Table 2. Soil Processing Inc. References. - c02acn3f.7:y-_i,,:";i-e4.:4;i' C'Jya-' n -rt'-'a,..tfr N' V a'-'-, n, e0r4;;: Bruce St Pierre ; . ` zw,J,4,.: - • ,:l ,4,, . - - - .*.. - - -,1, !;:, . 4.:t: 0e13119nPNurri:: ., 659-7242 Phillips Alaska Inc. Unocal Petroleum Products John Hammelman 776-3203 Tesoro Alaska Jeff Haffner 776-3587 BP Exploration (Alaska) Inc. Leslie Griffiths 564-4356 Shannon & Wilson Inc. Leanne Osgood 561-2120 Cook Inlet Pipe Line Company Ron Greene 776-6800 Ext. 130 University of Alaska Russel D. Shoeman 786-4912 AHTNA Development Corporation David J. Maiero 563-3322 Alaska Petroleum Contractors Dave O'Donell 659-7948 Jacobs Engineering Pete Hannon 522-3638 Clear Water Environmental Gary Lawley, Ph.D. 343-1533 Montgomery Watson Gundar Clemenson - 776-2506 Cross Timbers Operating Company Maurice Dunkley 269-7577 Alaska Department of Environmental Conservation (ADEC), Anchorage S. Ganapathy, Ph.D. 269-7500 John Halverson 563-6529 Louis R. Howard, Jr. 269-7575 Bill MacClarence, P.E. 349-7755 Robert M. Weimer 227-7661 ADEC' Valdez/Cordova Dan Lawn 835-2429 ADEC, Kenai District ''Alt telpphor*fignib&sarpjk6.4, cAdp.,907;".-...: Paul D. Horwath 262-5210 Scott Forgue 262-5210 Don Fritz 262-5210 Don Seagren 262-5210 SOIL PROCESSING INC. 207 EAST NORTHERN LIGHTS BLVD., SUITE 103-A ANCHORAGE, ALASKA 99503 (907) 274-3000 (907) 274-9295 FAX Unocal North American 011 & Gas Division Unocal Corporation P.O. Box 190247 Anchorage, Alaska 99519-0247 Telephone: (907) 276-7600 UNOCALG !nvironmenial Maim laska Region February 10, 1993 To Whom it May Concern: Unocal Corporation,- North American Oil and Gas Division employed Soils Processing Incorporated during the summers of 1991. and 1992 to thermally remediate hydrocarbon contaminated soils. - Soils Processing inc. operated • In a. very professional manner and met all parameters agreed upon. The target cleanup level for the remediated soil was 100 mg/kg (ppm), and all confirmation samples attained well below that level. Soil Processing inc. has been a leader in applying the thermal remediation technology in Alaska, and the crew is well versed in overcoming the challenges the Alaska climate can offer. • If you would like further information concerning, Unocal's working relationship with Soil Processing Inc., -you may contact me directly. at (907). 263-7615. BWS/ Sincerely, Bruce St. ie Environmental Coordinator j MARTECH September 24, 1993 To Whomever It May Concern: Martech USA, Inc. recently contracted with Soil Processing, Inc. to provide thermal remediation serviceSlor its U. S. Army Corps of Engineers, Unalakleet and North River DERP site remediation project. The project conditions were difficult as this is one of the most remote major remediation projects in the state of Alaska. Soil Processing, Inc. provided Martech with exceptional service, in time and in budget. Although not in the original plan, Martech is presently negotiating for Soil Processing, Inc. to return to the DERP site for a second year of thermal remediation services. We highly recommend the services of Soil Processing, Inc. We will *provide specific examples of their fine worlcupon request. Sincerely., David J. Maiero Vice President / Alaska Environmental Services Division MARTECH USA, INC. 300 East 54th Avenue Anchorage, AK 99518 (907) 561.1970 FAX (907) 563.0030 EINat November 30, 1995 Subject: Soil Processing, Inc. 207 East Northern Lights Suite 103-A Anchorage, Alaska 99503 To Whom it May Concern: ENSR Consulting and Engineering Suitt-, 22 4600 Businrss Park 131va A [who rug. A K 99503-7143 (907) 561-5700 FAX (907) 273-4555 During the summer of 1995, ENSR contracted Soil Processing Inc. (SPI) to remediate gasoline- and diesel-contaminated soil at a remote location on the Kenai Peninsula. The location was a former logging camp only accessible by air or water. SPI worked together with the barging companies, local contractors, and the landowners to ensure the project was completed as smoothly as possible. SPI was available on the date they committed to, despite other work, and completed the project on schedule. This is the third project ENSR has contracted to SPI, and each project was completed', according to the project contracts and schedules. SPI also has an excellent working relationship with the regulators, which is important when trying to keep a project on time and within budget. We at ENSR look forward to contracting SPI on our next soil remediation project. Sincerely, Peter A. Hannon Senior Project Manager J. BP EXPLORATION November 27, 1996 To Whom It May Concern: BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519 -6612 (907) 561-5111 BP Exploration (Alaska) Inc. (BPXA) contracted with Soil Processing Inc. to thermally remediate nearly 30,000 tons of hydrocarbon contaminated soils generated during cleanup of the former Copper River & Northwest Railroad roundhouse site in Cordova, Alaska. Throughout the process George Cline and his crew have operated in a very professional manner, working cooperatively with the on -site QA Inspector for - BPXA to meet the many challenges of the Roundhouse project. Soil conditions ranged from peat to coarse gravel with variable moisture and contaminant concentrations. Yet SPI consistently met the target cleanup levels for the remediated soil. We believe these results reflect the experience, technical expertise, and creativity in solving problems that SPI brought to the project. Technical issues were only part of the challenge on the Roundhouse project. Responding to public concerns about the remediation process was another significant challenge. Both George Cline and Michael Swart of SPI provided valuable technical assistance to BPXA in Cordova community meetings, going above and beyond expectations in addressing community concerns. In addition, Mr. Cline's reputation with the Alaska Department of Environmental Conservation, developed through years of successful operation in Alaska, played a large part in maintaining a very positive relationship with ADEC: throughout the process. Soil Processing Inc. is a proven leader in the thermal remediation field, and we at BPXA would not hesitate to contract with them again on future work. Sincerely, L Leslie Griffiths Cordova Roundhouse Project Manager PHILLIPS Alaska, Inc. A Subsidiary of PHILLIPS PETROLEUM COMPANY Leigh Gooding/Bruce St. Pierre P. 0. Box 196105 Anchorage, Alaska 99519-6105 (907) 659-7212 (907) 657-7712 Fax May 25, 2001 To Whom It May Concern: Phillips Alaska, Inc. (PAI) contracted Soil Processing, Inc. (SPI). to thermally remediate hydrocarbon contaminated soils at the Kuparuk Field during the summers of 1999 and 2000. SPI performed very well during the project. They followed the work plan and approached the tasks with professionalism. PAI has been very satisfied with the high level of cooperation and SPI's dedication to attaining the required cleanup levels. SPI will continue to be considered for future PAI projects. If you have any questions or need additional information, please feel free to call us at 659-7242. Sincerely, Bruce St. Pierre • Senior Environmental Coordinator 935/003.30a/bsp JE ®JACOBS Jacobs 4300 B Street, Suite 600 Anchorage, Alaska 99503 -5922 U.S.A. 1.907.563.3322 Fax 1.907.563.3320 April 16, 2002 To Whom It May Concern: Jacobs, on behalf of our client, the U.S. Army Corps of Engineers, Alaska District, contracted Soil Processing Inc. (SPI) to thermally remediate 10,000 tons of POL- contaminated soil at the Kodiak Airport in Kodiak, Alaska. This work.was conducted as part of the Total Environmental Restoration Contract (TERC). SPI's remediation portion of the project was completed on time and in a professional manner. All target cleanup levels were met. The workmanship and professionalism of the crew, and efficiency of the mechanical operation, is. commendable. As a result of their performance on this project, SPI received the 4th Quarter Safety Award from the U.S. Army Corps of Engineers, Alaska District. Jacobs was more than satisfied with the high level of performance of the SPI crew and would use SPI again on future similar projects, should the circumstances allow. If you have any questions or need additional information, please feel free to call me at (907) 751 - 3381. Sincerely, 'JACOBS Tom Beck, CPG Project Manager Cc:' M. TeVrucht, USAED K. Streveler, USAED 1: \KODIAK \05M30500\COMMON\E Ltr 21 Mar02.doc AKT- 107- 05M305- F01 -01 18 CATEGORY C FACILITY OPERATIONS PLAN , • THERMAL REMEDIATION OF PETROLEUM-CONTAMINATED SOILS AT. BRECHAN ENTERPRISES INC. INDUSTRIAL SITE BELLS FLATS, KODIAK, ALASKA Prepared by, SOIL PROCESSING INC. 207 East Northern Lights 103A • Anchorage, AK 99503 (907)274-3000 j i SOIL PROCESSING INC. OPERATIONS PLAN TABLE OF CONTENTS 1. INTRODUCTION 1 -1 2. SITE DESCRIPTION 2 -1 3. DETAILED PROCESS DESCRIPTION - 3 -1 3.1 Overview 3 -1 3.2 Production 3 -2 3.3 Specification of the Processing Equipment 3 -2 3.4 Fuel Requirements 3 -2 3.5 System Controls and Instrumentation 3 -2 3.6 Secondary Combustion Chamber 3 -3 3.7 Particulate Emission Control 3 -3 3.8 Additives .3-3 3.9 Settling Pond Cleanup 3 -3 3.10 Permitting and Air Emissions 3 -3 4. CONTROL AND CONTAINMENT OF CONTAMINATED SOIL 4 -1 4.1 SPI Requirements for Acceptance of Contaminated Soil 4 -1 4.2 Delivery and Handling of Soil at the Site 4 -2 4.3 Control and Tracking of Soils 4 -2 4.4 Design of Soil Storage Cell for Untreated Soil 4 -3 4.4.1 New Cell Construction 4 -3 4.4.2 Cover 4-4 4.4.3 Treated Soil Stockpile Area, 4-4 4.5 • Disposal of Treated Soils 4-4 5. SITE MONITORING PROCEDURES 5 -1 5.1 General 5 -1 5.2 Excess Water at Storage Cell 5 -1 5.3 Equipment Fuel Storage and Handling 5 -1 6. SAMPLING, TESTING, AND REPORTING 6 -1 May 2002 r I SOIL PROCESSING INC. OPERATIONS PLAN TABLE OF CONTENTS (continued) 7. SITE CLOSURE 7-1 7.1 Background Assessment 7.2 Closure 7-1 7.3 Sample Schedule 7-2 7.4 Final Report 7-3 LIST OF ATTACHMENTS A QUALIFYING DOCUMENTS BEI Letter Re: Permission to Operate Air Quality Operating Permit ADEC Relocation Permit Public Notification Letter B FIGURES C CONTINUOUS EMISSION MONITORING SYSTEM D MATERIAL SPECIFICATION SHEETS E FORMS •F ASPHALT PAVEMENT MIX DESIGN ji May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 1. INTRODUCTION This Operations Plan was prepared by Soil Processing Inc. (SPI) for the thermal remediation of hydrocarbon - contaminated soil at the Brechan Enterprises, Inc. (BEI), Industrial Site, Bells Flats, Kodiak, Alaska. As site owner,. BEI has given SPI permission (Attachment A) to stockpile and treat soil from 'others through November 30, 2002, subject to approval of an operations plan by the Alaska Department of Environmental Conservation (ADEC). SPI has an Air Quality Operating Permit for this soil remediation unit, and an ADEC Relocation Permit to operate at the Bells Flats location. The public will also be notified about the intent to use the thermal soil remediation unit, and given an opportunity to ask questions or express concerns to ADEC. These three documents are provided in Attachment A. SPI intends to accept and treat only petroleum- contaminated soil from underground storage tanks or other contaminated sites. All soil received at the facility will be treated and removed within 90 days, but no later than November 30, 2002. The exception would be if previous arrangements have been made to use the soil for leveling at the BEI site. Prospective clients, who have contacted SPI, have quantities of contaminated soil ranging from 100 to 6,000 tons. The soil comes from multiple sites across Kodiak Island. Mobilizing and setting up a remediation plant at any individual client's site cannot be justified due to the small quantities and small areas. SPI is requesting the ADEC to approve this plan to temporarily operate a soil remediation unit on Kodiak Island. This should provide a cost - effective way for clients with small quantities to have soil treated and obtain closure from ADEC. SPI plans to construct a new cell for temporary storage of contaminated soil to be treated at the facility during 2002. Design for the new cell is described in more detail in Section 4. 1 -1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 2. SITE DESCRIPTION This proposed location is at BEI's Industrial Site between Middle Bay Drive and Salmonberry Drive in Bells Flats. The site is 12 miles from the City of Kodiak. A site location map is provided as Figure 1; Figure 2 shows the site vicinity (see Attachment B for all figures referenced in this plan). The entire area is surrounded by chain link fence and gate. The gate will be locked and SPI personnel will control the access to SPI's site. Signs will be posted at the gate informing • people that soil remediation is being done at the site. Contact telephone numbers will be listed for permission to enter or further information. The BEI site is relatively flat in grade. There is no runoff water from this site. There is no surface water or drinking water well within 1,000 feet of this location. Contaminated soil awaiting treatment will be stockpiled at the designated Contaminated Soil Temporary Stockpile (CSTS) area. The paved CSTS area, 80 feet by 80 feet, will be configured as shown in Figure 3. The SPI working area is approximately 250 feet by 225 feet. SPI's proposed location is approximately 100 feet from BEI's Asphalt Plant. This area is covered by %-inch minus material. The Asphalt Pad will be constructed within the 250-by-225- foot working area, Water will be obtained from BEI's on-site industrial-use well. There are no public buildings within 2,000 feet of the facility boundary (perimeter fence). 2-1 May 2002 , r SOIL PROCESSING INC. OPERATIONS PLAN 3. DETAILED PROCESS DESCRIPTION This section gives a detailed description of the treatment process for: air, water, and solid waste process streams; startup and shutdown procedure; process flow rates; air pollution control systems; and water treatment systems. A detailed description of the Continuous Emission Monitoring System (Attachment C), a Flow Diagram of Operation (Figure 4), and a conceptual Diagram of the Thermal Treatment Plant (Figure 5), are included at the end of this section. 3.1 Overview During a typical production cycle, the contaminated soil is placed into a small surge stockpile that is used to feed the processor. The contaminated soils are removed from the surge stockpile by a front -end loader and placed in the feed hopper. All material over 1 inch in size is crushed to % -inch minus before entering the thermal processing stream. The presorted soils are then transported by weigh belt conveyor to the infeed auger where they are fed into the rotating, negative pressure, primary chamber of the processor. Crushing unit and weigh conveyor areas are Tined with a Nova -Thene 20 mil RB88X -6HD (Attachment D) containment membrane. The membrane is to ensure no contamination from spillage. A 2.5 million BTU burner in the primary chamber raises the temperatures ranging from 500 to 800° F to drive off the moisture and contaminants. Most cleanup levels are achieved at +1- 500 °F (Diesel 380° to 450 °F, Crude Oil 495° to 510 °F). During this thermal process, the hydrocarbon contaminants are volatized to a gaseous state and then oxidized by direct contact with the open flame in the secondary combustion chamber. Gas retention is 0.6 seconds at 1650 to 1800° F. The secondary combustion chamber also has a 2.5 million BTU burner. Continued rotation of the dryer drum furnishes sufficient agitation and exposure to the soil to reduce the contaminants within the specified cleanup limits. As the soil tumbles in the drum it passes directly through the burner flame in the last 3 feet of the drum. This ensures complete remediation of the contaminated soil. Depending upon the moisture content of the soil, soil will typically be retained in the kiln for approximately 15 minutes. After the thermal cycle is complete, the treated soil exits the rear of the rotating drum by a closed auger system. Treated material goes from the hot auger into a lined, bermed, surge pit approximately 15 feet x 15 feet x 3 feet. This pit is lined with a Canvex CB 12WB 12 mil liner (Attachment D),. To protect against punctures, a 1 -foot layer of fine (3/4 -inch) material is placed over the liner. A 4 foot by 8 foot by 3/ inch steel plate is placed on the fine material. All soils are contained in this area until approximately 10 to 20 tons have been stockpiled. Soils are mixed with any free standing water before being removed. 3 -1 May 2002 I' SOIL PROCESSING INC. OPERATIONS PLAN Particulates removed from the off-gas in the scrubber are also deposited in the exit auger and mixed with the treated soil. A light spray of clean water cools the exiting material and at the same time provides dust control during the final discharge. Material is periodically moved from the exit soil pile to the treated soil stockpile area with a front-end loader. 3.2 Production Actual production throughput varies, but 8 to 10 tons per hour is typical. The main variables include the contaminant type and concentration, the cleanup levels, the soil type, and the moisture level. SPI's Soil Remediation Unit (SRU) is permitted to operate at 12 tons per hour. A typical shift is 24 hours per day , 7 days per week. During continuous operation, the process equipment is available for treatment about 20 hours per day, with 4 hours down time for preventive maintenance. 3.3 Specification of the Processing Equipment The thermal process is multiphase. Initially the soil is raised to allow vaporization of moisture and contaminants. The effluent gases then cross over to the secondary combustion chamber where the gas is oxidized to produce carbon dioxide and water. The off-gas waste stream is cooled and particulates are removed from the off.-gases prior to discharge to the atmosphere. 3.4 Fuel Requirements The primary andiecondary burners in the kiln collectively consume approximately 4,379 cubic feet per hour of.natural gas or 85 gallons of liquefied petroleum gas (LPG)per. hour. Electricity for the facility is supplied by a diesel-powered 125 KW generator. 3.5 System Controls and Instrumentation The entire system is controlled by an Allen Bradley Series 5 programmable logic controller. Information about the operational status of the process is displayed on a color monitor in the control house. The system has a single button start up mode, which automatically supervises the main bumer lighting, secondary combustion bumer, combustion air, and a variety of other control points. The fully computerized system graphically displays the range set points and deviation indicators. Necessary start/stop stations are included. -All systems components are safety interlocked. 3.6 Secondary Combustion Chamber The system auto ignites the hydrocarbon vapors as they pass from the primary chamber into the secondary combustion chamber. The gaseous waste stream is volatized by a 2.5 million BTU burner as it passes through the chamber. The destruction removal efficiency (DRE) is 99.9999. I 3-2 May 2002 • SOIL PROCESSING INC. OPERATIONS PLAN (� 3.7 Particulate Emission Control The patented HelicloneTM effluent cooler reduces exhaust heat and increases the particulate and moisture separation by injecting water into the exhaust waste stream. Water consumption I ) is.approximately 3 to 4 gallons per minute. 3.8 Additives Soda ash is periodically added to the water in the settling pond to maintain a pH balance of 7 (Attachment D). 3.9 Settling Pond Cleanup Water used during the process treatment is stored in a settling pond and recycled through the scrubber. system. Approximately 2 to 3 gallons per minute is used to quench the processed soil and to eliminate fugitive dust. The water supply to the pond will be stopped near completion of soil treatment to allow the water level to drop. The water and fines in the pond will be sampled and tested for contaminants. After analytical results verify they are clean, remaining fines will . be mixed with treated soils and the remaining water will be sprayed over the ground at the site. Liners will be removed and disposed of at an approved facility. The area under the pond will be assessed for leakage by a qualified third party and filled back to the original grade. • 3.10 Permitting and Air Emissions SPI has met all the air quality standards required so that the maximum tonnage per hour can be processed. SPI's unit has a continuous emissions monitoring system (GEMS; Attachment C) for off gasses as required by ADEC (see Attachment A). The unit has been tested and is currently in compliance. SOIL PROCESSING INC. OPERATIONS PLAN 4. CONTROL AND CONTAINMENT OF CONTAMINATED SOIL SPI will use the following procedures and forms to provide for complete containment for the contaminated soil before, during, and after treatment until the contaminated soil meets the applicable cleanup levels. 4.1 SPI Requirements for Acceptance of Contaminated Soil 4.2 Delivery and Handling of Soil 4.3 Control and Tracking Soils at the Site 4.4 Design of Soil Storage Cell for Untreated Soil 4.5 Disposal of Treated Soils 4.1 SPI Requirements for Acceptance of Contaminated Soil The client must provide the following information before SPI will allow contaminated soil to be delivered to the BEI site: 1. Copy of Spill Report submitted to ADEC. Identify if regulated UST and LUST # or Contaminated Site # assigned by ADEC. 2. Written approval from ADEC Project Manager to transport and treat soil at the BEI site. 3. Address/location of spill. 4. Estimated quantity of contaminated soil (cubic yards) to be delivered to SPI. 5. Type(s) of contaminant; SPI will only accept petroleum-contaminated soils. 6. Concentrations of contaminant with copies of laboratory analysis results as reported to ADEC. 7. Type(s) of soli (peat, gravel, sand, etc.). 8. Contaminated soil must be covered and transported in compliance with 18AAC 50.0500(f) to minimize the possibility of a loss of material during delivery. SPI will not allow any soil to enter the BEI site if the above requirements have not been met. The client is responsible for removing all wOod, metal, plastic, and other non-treatable material from the contaminated soil prior to delivery at the SPI site. Any non-treatable material removed 4-1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN at the SPI site will be put in a suitable container and disposed of in an approved facility at the client's expense. The client must remove the treated soil within 24 hours after receiving notice from SPI, unless SPI and the client have mutually agreed to other arrangements. 4.2 Delivery and Handling of Soil at the Site An SPI Tracking Record must be completed and accepted by SPI before any soil can be delivered to the site. The client is responsible for transporting the soil. Soil must be delivered in dump trucks. The trucks will back onto a ramp covered with a removable "tire liner" and stop at the edge of the storage cell so all of the contaminated soil will be dumped inside the cell. The tire liner will be 20 mil Nova -Thene HDPE fabric (Attachment D) and covered with AMOCO style 4510 Geotextile (Attachment D), detailed later in this section. SPI personnel will ensure any dirt on the tailgate, rear of the truck, and tires are cleaned before the truck leaves the tire liner area. Contaminated soil will be stockpiled with 3 foot minimum setback from the perimeter berm. If the liner shows signs of deterioration, it will be repaired or replaced with a new liner. Contaminated liners will be disposed of at an approved facility. After all of the client's soil is delivered, the tire liner will be removed and placed inside the paved cell (CSTS Slab Design; see Figure 6). SPI will place barriers of clean soil between each client's soil. The barrier soil will be removed from the storage cell with the adjacent client soil and fed into the hopper. 4.3 Control and Tracking of Soils Examples forms used for control and tracking of soils are provided in Attachment E. Clients must fill out a BEI Indemnification Clause and an SPI Tracking Record before their soil is delivered to the site. SPI will assign a unique Job Number to each clients' soil. This number will be used to track the.. soil from arrival, during treatment, sampling, and departure. A Release Record will be used if soils must be removed from BEI's site. There will be no more than two clients' soils stored in the cell at one time. Soil barriers will be placed between each client's soil to ensure soils are not mixed. One client's soil will be treated to completion before starting another client's soil. 4 -2 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN A certified truck scale will weigh trucks entering the BEI facility. A weigh belt will be used for reporting to the ADEC and billing purposes. A two-part scale ticket will be generated hourly. As treated soil exits the processor, each client's soil will be placed in a separate pile(s) on the area designated "Treated Soil Stockpile Area" (Figure 3). Each stockpile will be marked with the job number, date received, date treatment was completed, sample date, and analytical results. Each stockpile location will be shown on a grid map located in the processor control house. 4.4 Design of Soil Storage Cell for Untreated Soil 4.4.1 New Cell Construction An Alaskan-registered professional engineer will inspect and document the installation process of the new asphalt paved storage cell. Figure .3 depicts the soil storage cell and work area design. The new soil storage cell and work area will be constructed with an asphalt perimeter containment berm as described below: 1) Lay out area of approximately 80 feet by 80 feet for asphalt pad. 2) Establish reference elevation and set grade on stakes at the four comers of the new cell. 3) Grade existing %-inch minus material at 2% to drain toward the sump in the northwest comer. 4) Field screen and collect necessary laboratory samples from upper 12 inches of soil in prepared area as per detail in Figure 7. 5) Remove sharp rocks and deleterious material from the surface. 6) Compact the 80 foot by 80 foot pad to provide a smooth firm surface; conduct as built survey of the pad elevations. 7) Place AMOCO 4510 Geotextile (Attachment D) on finished grade. 8) Lay a new 100 foot by 100 foot, 20 mil Nova-Thene RB88X-6HD (Attachment D) factory- seamed liner over AMOCO 4510 Geotextile. fl 9) Install 2 foot by 2 foot sump on the liner. Top of sump to be 2 inches below finished asphalt grade. Place AMOCO 4510 on top of 20 mil liner. 10) Place 18 inches of %-inch minus material with equipment traveling on a minimum 18- inch lift 11) Conduct as built survey elevations of %-inch minus layer. 4-3 May 2002 I SOIL PROCESSING INC. OPERATIONS PLAN 12) Roll and compact the %-inch material to provide a firm surface. 13) Machine pave the 80 foot by 80 foot pad with 3 inches of asphalt (see Asphalt Pavement Mix Design, Attachment F). Finish roll making sure the entire pad drains to sump area. A 12-inch asphalt berm will be continuously constructed while the pad is being paved. Berm is to be compacted with weighted hand compaction plate. 14) Provide as built survey drawings of new soil storage cell to ADEC. The crusher/feed system will be set up beside the asphalt containment cell. An AMOCO 4510 Geotextile liner will be placed on the original ground; the Nova-Thene RB88X-6HD will be placed on top of the Geotextile. The two liners will be continuous over the asphalt berm of the contaminated cell. A %-inch plywood will be placed on top of the 20 mil liner before setting the crusher/feed system. This will make for easy cleaning and protect the liner. The lined area will be graded so any water will collect at one point where it can be pumped into a Granular Activated Carbon (GAC) filter (Attachment D). 4.4.2 Cover The entire contaminated soil storage and work area will be covered with 12 mil Canvex CB12WB (Attachment D), except when soil is being delivered or the processor is operating. The top cover will extend outside of the cell perimeter berm and be secured with Super Sacks. - The active portion of the cell will be covered only when it is raining. To minimize the amount of cell exposed to rain, untreated soil from the sump half of the cell may be moved to a "surge pile" near the feed hopper, allowing the soil stockpiles and half of the lined work area to be covered. 4.4.3 Treated Soil Stockpile Area Treated soil will be stockpiled in the northeast corner of the pad (Figure 3). Stockpile sizes will be constructed as per the sampling plan. Alaska Test Lab will be contracted to collect samples when adequate tons have been processed for testing (usually 1 week). 4.5 Disposal of Treated. Soils After cleanup levels have been met per ADEC, SPI will notify the client to remove their soil. Removal must take place within 24 hours of notification unless SPI and the client have mutually agreed to other arrangements. The client is responsible for final disposition of the treated soil. SPI will document the quantity, date, time, and hauling contractor for soil removed by each client on the Release Record (Attachment E). 4-4 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 5. SITE MONITORING PROCEDURES 5.1 General SPI personnel are responsible for continual monitoring and "housekeeping" around the contaminated soil storage cell and under the feed system, crusher, and, processor. Any contaminated soil that falls on the ground around the storage cell or feed system will be cleaned up and placed back in the cell or in the feed hopper for treatment. Personnel will monitor the stockpile covers to ensure they are secure and not damaged. Damaged covers will be repaired or replaced as necessary to protect the soil from the weather. If no one is working at the facility, personnel will periodically monitor the facility to ensure the stockpile covers are secure and no excess water is present in the storage cell, especially after heavy rain and/or strong wind. 5.2 Excess Water at Storage Cell If excess water is observed in the cell or sump, the water will be pumpedfrom the sump to a 1,000 gallon poly tank, and from the poly tank through a GAC filter (Attachment D). After the water cycles through the GAC filter, it will be recycled with the processor's scrubber water. If there is free-standing water within the cell, any water on top of the cover will be removed, pumped to the settling pond and recycled. The top cover will extend over the outside berm and weighed down to allow water to drain off. Otherwise, water on the cover will be manually controlled and the water level in the settling pond will be monitored to ensure the pond does not overflow. When operating at full capacity, the processor uses 6,000 to 7,000 gallons of water per day. The settling pond has a normal freeboard capacity of 10,000 gallons more than adequate to handle the quantity of excess water from the cell. 5.3 Equipment Fuel Storage and Handling All fuels (diesel, gasoline, and oil) will be stored within a lined cell large enough to hold the volume of any spills. All fueling systems have automatic shut off valves as well as 1/4 tum manual valves that are in the closed position when the fueling equipment is not being used. Absorbent material will also be available during equipment fueling. If a fuel spill occurs outside the containment cell, the impacted soil will be immediately cleaned up, until no fuel odor is detectable, and thermally treated. Any spills less than 10 gallons will be reported to the plant operator on shift and logged into the daily log and Foreman's Report. The spill time, location, quantity, and cleanup will be documented. A spill larger than 10 gallons will be reported to the ADEC and assessed bya 5-1 May 2002 1,7 ■ ii SOIL PROCESSING INC. OPERATIONS PLAN qualified third party person in accordance with Regulation 18AAC75, Article 3. The impacted area will not be filled until the qualified third party determines ADEC Method 1 Category A cleanup levels have been met. n • SOIL PROCESSING INC. OPERATIONS PLAN 6. SAMPLING, TESTING, AND REPORTING All soils accepted for treatment must first have been reported to ADEC and the results of characterization samples, analyzed by an ADEC-approved laboratory, must be provided to SPI. SPI will hire an impartial qualified third party to sample, analyze, interpret and report to the ADEC Kenai Area Office. In accordance with the UST Procedures Manual, the following site activities will be conducted/reported: 1) assessing for background contamination before initial startup of the facility: 2) confirming that treated soil meets the applicable cleanup levels; 3) assessing after cleaning up on site fuel spills larger that 10 gallons;. and 4) assessing after treatment to demonstrate no secondary contamination occurred. Treated soil will be field screened as outlined in the standard sampling procedure in Chapter 2 of the UST Procedures Manual. A photoionization detector (PID) will be used to determine the location(s) from which to obtain laboratory samples. The minimum number of grab samples for field screening and final verification of treated soil are set out in the following table, extracted from UST Regulations 18AAC78.605. Cubic Yards Soil (approx.) T ons Minimum Number of Field Screening Samples Minimum Number of Laboratory Samples 0-10 0-15 2 1 11-50 16-75 4 2 51-100 76450 . 6 101-500 151-750 10 5 501-1000 751-1500 14 7 1001-2000 1501-3000 20 10 All final verification samples for treated soil will be sent to Analytica, Alaska in Anchorage for analytical testing. Three day turnaround will be requested. Samples will be analyzed for the contaminant(s) to be determined by the qualified third party based on soil characterization information contained in the cleanup assessment report submitted to ADEC. 6-1 May 2002 ;-- SOIL PROCESSING INC. OPERATIONS PLAN Post treatment verification soil samples will be analyzed by test methods specified in the following tables (modified) from the UST Procedures Manual, unless the ADEC Project Manager provides written authorization to delete some test methods: • Table 1: Reference Guide to Sample Collection and Laboratory Analysis, Part A • Table 2: Determination of Sampling & Laboratory Analysis for Soil & Groundwater Table 2A: Indicator Compounds for Petroleum Contaminated Sites The qualified third party will submit assessment reports and original analytical results to the ADEC Manager. Copies of each assessment report and analytical results will be provided to the client and to BEI. SPI will also keep one report on file in the control house at the site. Treated soil stockpiles will not be moved until approved by the qualified third party. All soils will be remediated to the ADEC-applicable cleanup level. Any treated soil that does not meet that client's applicable level will be retreated and re-tested. SOIL PROCESSING INC. OPERATIONS PLAN 1. INTRODUCTION This Operations Plan was prepared by Soil Processing Inc. (SPI) for the thermal remediation of hydrocarbon-contaminated soil at the Brechan Enterprises, Inc. (BEI), Industrial Site, Bells Flats, Kodiak, Alaska. As site owner, BEI has given SP! permission (Attachment A) to stockpile and treat soil from "others" through November 30, 2005, subject to approval of an operations plan by the Alaska Department of Environmental Conservation (ADEC). SPI has an Air Quality Operating Permit for this soil remediation unit, and an ADEC Relocation Permit to operate at the Bells Flats location. The public will also be notified about the intent to use the thermal soil remediation unit, and given an opportunity to ask questions or express concems to ADEC. These three documents are provided in Attachment A. SPI intends to accept and treat only petroleum-contaminated soil from underground storage tanks or other contaminated sites. All soil received at the facility will be treated and removed within 90 days, but no later than November 30, 2005. The exception would-be if previous arrangements have been made to use the soil for leveling at the BEI site. Prospective clients, who have contacted SPI, have quantities of contaminated soil ranging from 100 to 6,000 tons. The soil comes from multiple sites across Kodiak. Island. Mobilizing and setting up a remediation plant at any individual client's site cannot be justified due to the small quantities and small areas. SPI is requesting the ADEC to approve this plan to temporarily operate a soil remediation unit on Kodiak Island: This should provide a cost-effective way for clients with small quantities to have soil treated and obtain closure from ADEC. - SPI plans to construct a new cell for temporary storage of contaminated soil to be treated at the facility during 2002.. Design for the new cell is described in more detail in Section 4. Upon closure of the facility in 2005, a complete assessment will be performed 1-1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 2. SITE DESCRIPTION This proposed location is at BEI's Industrial Site between Middle Bay Drive and Salmonberry Drive in Bells Flats. The site is 12 miles from the City of Kodiak. A site location map is provided as Figure 1; Figure 2 shows the site vicinity (see Attachment B for all figures referenced in this plan). The entire area is fenced and gated. The gate will be locked and SPI personnel will control the access to SPI's site. Signs will be posted at the gate informing people that soil remediation is being done at the site. Contact telephone numbers will be listed for permission to enter or for information. The BEI site is relatively flat in grade. There is no runoff water from this site. There is no surface water or drinking water well within 1,000 feet of this location. Contaminated soil awaiting treatment will be stockpiled at the designated Contaminated Soil Temporary Stockpile (CSTS) area. The paved CSTS area, 80 feet by 90 feet, will be configured as shown in Figure 3. The SPI working area is approximately 250 feet by 225 feet. SPI's proposed location is approximately 100 feet from BEI's Asphalt Plant. This area is covered by %-inch minus material. The Asphalt Pad will be constructed within the 250-by-225- foot working area. Water will be obtained from BEI's on-site industrial-use well. There are no public buildings within 2,000 feet of the facility boundary (perimeter fence). 2-1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 3. DETAILED PROCESS DESCRIPTION This section gives a detailed description of the treatment process for: air, water, and solid waste process streams; startup and shutdown procedure; process flow rates; air pollution control systems; and water treatment systems. A detailed description of the Continuous Emission Monitoring System (Attachment C), a Flow Diagram of Operation (Figure 4), and a conceptual Diagram of the Thermal Treatment Plant (Figure 5), are included at the end of this section. 3.1 Overview During a typical production cycle, the contaminated soil is placed into a small surge stockpile that is used to feed the processor. The contaminated soils are removed from the surge stockpile by a front -end loader and placed in the feed hopper. All material over 1 inch in size is crushed to 3/ -inch minus before entering the thermal processing stream. The presorted soils are then transported by weigh belt conveyor to the infeed auger where they are fed into the rotating, negative pressure, primary chamber of the processor. Crushing unit and weigh conveyor areas are lined with a Nova -Thene 20 mil RB88X -6HD (Attachment D) containment membrane. The membrane is to ensure no contamination from spillage. A 2.5 million BTU burner in the primary chamber raises the temperatures ranging from 500 to 800° F to drive off the moisture and contaminants. Most cleanup levels are achieved at +1- 500 °F (Diesel 380° to 450°F, Crude Oil 495° to 510 °F). During this thermal process, the hydrocarbon contaminants are volatized to a gaseous state and then oxidized by direct contact with the open flame in the secondary combustion chamber. Gas retention is 0.6 seconds at 1650 to 1800° F. The secondary combustion chamber also has a 2.5 million BTU burner. Continued rotation of the dryer drum fumishes sufficient agitation and exposure to the soil to reduce the contaminants within the specified cleanup limits. As the soil tumbles in the drum it passes,directly through the burner flame in the last 3 feet of the drum. This ensures complete remediation of the contaminated soil. Depending upon the moisture content of the soil, soil will typically be retained in the . kiln for approximately 15 minutes. After the thermal cycle is complete, the treated soil exits the rear of the rotating drum by a closed auger system. - Treated material goes from the hot auger into a lined, bermed, surge pit approximately 15 feet x 15 feet x 3 feet. This pit is lined with a Nova -Thene 20 mil liner (Attachment D) with the. AMOCO 4510 Geofabric on top of and under the liner (Attachment D). To protect against punctures, an,18" layer of fine (34-inch) material is placed over the Geofabric. A 4 foot by 8 foot by % inch steel plate is placed on the fine material. There is a3/4" steel plate welded to the bottom plate vertically to protect the liners. The steel plates ensure that the loader can not 3 -1 . May 2002 SOIL PROCESSING INC. OPERATIONS PLAN damage the liner. The exit auger will dump soils on top of the 1/4" bottom plate for removal by the loader. All soils are contained in this area until approximately 10 to 20 tons have been stockpiled. Soils are mixed with any free standing water before being removed. Particulates removed from the off-gas in the scrubber are also deposited in the exit auger and mixed with the treated soil. A light spray of clean water cools the exiting material and at the same time provides dust control during the final discharge. Material is periodically moved from the exit-soil pile to the treated soil stockpile area with a front-end loader. 3.2 Production Actual production throughput varies, but 8 to 10 tons per hour is typical. The main variables include the contaminant type and concentration, the cleanup levels, the soil type, and the moisture level. SPI's Soil Remediation Unit (SRU) is permitted to operate at 12 tons per hour. A typical shift is 24 hours per day , 7 days per week. During continuous operation, the process equipment is available for treatment about 20 hours per day, with 4 hours down time for preventive maintenance. 3.3 Specification of the Processing Equipment The thermal process is multiphase. Initially the soil is raised to allow vaporization of moisture and contaminants. The effluent gases then cross over to the secondary combustion chamber where the gas is oxidized to produce carbon dioxide and water. The off-gas waste stream is cooled and particulates are removed from the off-gases prior to discharge to the atmosphere. 3.4 Fuel Requirements The primary and secondary bumers in the kiln collectively consume approximately 4,379 cubic feet per hour of natural gas or 85 gallons of liquefied petroleum gas (LPG) per hour. Electricity for the facility is supplied by a diesel-powered 125 KW generator. 3.5 System Controls and InstruMentation The entire system is controlled by an Allen Bradley Series 5 programmable logic controller. Information about the operational status of the process is displayed on a color monitor in the control house. The system has a single button start up mode, which automatically supervises the main burner lighting, secondary combustion bumer, combustion air, and a variety of other control points. The fully computerized system graphically displays the range set points and deviation indicators. Necessary start/stop stations are included. All systems components are safety interlocked. 3-2 May 2002 3, SOIL PROCESSING INC. OPERATIONS PLAN 3.6 Secondary Combustion Chamber The system auto ignites the hydrocarbon vapors as they pass from the primary chamber into the secondary combustion chamber. The gaseous waste stream is volatized by a 2.5 million BTU burner as it passes through the chamber. The destruction removal efficiency (DRE) is 99.9999. 3.7 Particulate Emission Control The patented Heliclone TM effluent cooler reduces exhaust heat and increases the particulate and moisture separation by injecting water into the exhaust waste stream. Water consumption is approximately 3 to 4 gallons per minute. 3.8 Additives Soda ash is periodically added to the water in the'settling pond to maintain a pH balance of 7 (Attachment D). 3.9 Settling Pond Cleanup A lined cell approximately 45 feet by 45 feet by 4 feet deep will be constructed alongside the processor for water storage. Water used during the process treatment is stored in a settling pond and recycled through the scrubber system. Approximately 2 to 3 gallons per minute is used to quench the processed soil and to eliminate fugitive dust. The water supply to the pond will be stopped near completion of soil treatment to allow the water level to drop. The water and fines in the pond will be sampled and tested for contaminants. After analytical results verify they are clean, remaining fines will be mixed with treated soils and the remaining water will be sprayed over the ground at the site. There will be no discharge of processor water to lands or waters of the State of Alaska. Liners will be removed and disposed of at an approved facility. The area under the pond will be assessed for leakage by a qualified third party and filled back to the original grade. 3.10 Permitting and Air Emissions SPI has met all the air quality standards required so that the maximum tonnage per hour can be processed. SPI's unit has a continuous emissions monitoring system (GEMS; Attachment C) for off gasses as required by ADEC (see Attachment A). The unit has been tested and is currently in compliance. 3-3 May 2002 • F SOIL PROCESSING INC. OPERATIONS PLAN 4. CONTROL AND CONTAINMENT OF CONTAMINATED SOIL SPI will use the following procedures and forms to provide for complete containment for the contaminated soil before, during, and after treatment until the, contaminated soil meetsthe applicable cleanup levels. 4.1 SPI Requirements for Acceptance of Contaminated Soil 4.2 Delivery and Handling of Soil' 4.3 Control and Tracking Soils at the Site 4.4 Design of Soil Storage Cell for Untreated Soil 4.5 Disposal of Treated Soils 4.1 SPI Requirements for Acceptance Of Contaminated Soil The client must provide the following information before SPI will allow contaminated soil to be delivered to the BEI site: 1. Copy of Spill Report submitted to ADEC. Identify if regulated UST and LUST # or Contaminated Site # assigned by ADEC. 2. Written approval from ADEC Project Manager to transport and treat soil at the . BEI site. 3. Address/location of spill. 4. Estimated quantity of contaminated soil (cubic yards) to be delivered to SPI. 5. Type(s) of contaminant; SPI will only accept petroleum-contaminated soils. 6. Concentrations of contaminant with copies of laboratory analysis results as reported to ADEC. 7. - Type(s) of soil (peat, gravel, sand, etc.). 8. Contaminated soil must be covered and transported in compliance with 18AAC 50.0500(f) to minimize the possibility of a loss of material during delivery. SPI will not allow any soil to enter the BEI site if the above requirements have not been met. The client is responsible for removing all wood, metal, plastic, and other non-treatable material from the contaminated soil prior to delivery at the SPI site. Any non-treatable material removed 4-1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN at the SPI site will be put in a suitable container and disposed of in an approved facility at the client's expense. The client must remove the treated soil within 24 hours after receiving notice from SPI, unless SPI and the client have mutually agreed to other arrangements. 4.2 Delivery and Handling of Soil at the Site An SPI Tracking Record must be completed and accepted by SPI before any soil can be delivered to the site. The client is responsible for transporting the soil. Soil must be delivered in dump trucks. The trucks will back onto a ramp covered with a removable "tire liner" and stop at the edge of the storage cell so all of the contaminated soil will be dumped inside the cell. The tire liner will be 20 mil Nova-Thene HDPE fabric (Attachment D) and covered with AMOCO style 4510 Geofabric (Attachment D), detailed later in this section. SPI personnel will ensure any dirt on the tailgate, rear of the truck, and tires are cleaned before the truck leaves the tire liner area. Contaminated soil will be stockpiled with 3 foot minimum setback from the perimeter berm. rlf the liner shows signs of deterioration, it will be repaired or replaced with a new liner. Contaminated liners will be disposed of at an approved facility. After all of the client's soil is delivered, the tire liner will be removed and placed inside the paved cell (CSTS Slab Design; see Figure 6). SPI will place barriers of clean soil between each client's soil. The barrier soil will be removed from the storage cell with the adjacent client soil and fed into the hopper. 4.3 Control and Tracking of Soils Examples forms used for control and tracking of soils are provided in Attachment E. Clients _ must fill out a BEI Indemnification Clause and an SPI Tracking Record before.their soil is delivered to the site. SPI will assign a unique Job Number to each clients' soil. This number will be used to track the soil from arrival, during treatment, sampling, and departure. A Release Record will be used if soils must be removed from BEI's site. There will be no more than two clients' soils stored in the cell at one time. Soil barriers will be placed between each client's soil to ensure soils are not mixed. One client's soil will be treated to completion before starting another client's soil. 4-2 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN A certified truck scale will weigh trucks entering the BEI facility. A weigh belt will be used for reporting to the ADEC and billing purposes. A two -part scale ticket will be generated hourly. As treated soil exits the processor, each client's soil will be placed in a separate pile(s) on the area designated "Treated Soil Stockpile Area" (Figure 3). Each stockpile will be marked with the job number, date received, date treatment was completed, sample date, and analytical results. Each stockpile location will be shown on a grid map located in the processor control house. 4.4 Design of Soil Storage Cell for Untreated Soil 4.4.1 New Cell Construction An Alaskan - registered professional engineer will inspect and document the installation process of the new asphalt paved storage cell. Figure 3 depicts the soil storage cell and work area design. The new soil storage cell and work area will be constructed with an asphalt perimeter containment berm as described below: 1) Lay out area of approximately 80 feet by 90 feet for asphalt pad. 2) Establish reference elevation and set grade on stakes at the four comers of the new cell. 3) Grade existing 3/ -inch minus material, at 2% to drain toward the sump in the northwest comer. Field screen and collect necessary laboratory samples from -upper 12 inches of soil in prepared area as per detail in Figure 7. 5) Remove sharp-rocks and deleterious material from the surface. 6) Compact the 80 foot by 90 foot sub grade pad to provide a smooth firm surface; conduct as built survey of the pad elevations. 7) Place AMOCO 4510 Geofabric (Attachment D) on finished grade. 8) Lay a new 100 foot by 100 foot, 20 mil Nova -Thene RB88X -6HD (Attachment D) factory- seamed liner over AMOCO 4510 Geofabric. 9) Install 2 foot by 2 foot sump . on the liner. Top of sump to be 2 inches below finished asphalt grade. Place AMOCO 4510 on top of 20 mil liner. (See Figure 8) 10) Place 18 inches of % -inch minus material on top of the AMOCO 4510 (No heavy equipment will operate on the liner before the 18 inches of material is in place) 11) Conduct as built survey elevations of 3/ -inch minus layer. 4 -3 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 12) Roll and compact the %-inch material to provide a firm surface. 13) Machine pave the 80 foot by 90 foot pad with 3 inches of asphalt (see Asphalt Pavement Mix Design, Attachment F). Finish roll, making sure the entire pad drains to sump area. A 12-inch asphalt berm will be continuously constructed while the pad is being paved. . Berm is to be compacted with weighted hand compaction plate. 14) SPI will provide as-built drawings to the ADEC signed and sealed by a professional engineer, registered in the state of Alaska under AS 08.48 The crusher/feed system will be set up beside the asphalt containment cell. An AMOCO 4510 Geotextile liner will be placed on the original ground; the Nova-Thene RB88X-6HD will be placed on top of the Geotextile. The two liners will be continuous over the asphalt berm of the contaminated cell. A %-inch plywood will be placed on top of the 20 mil liner before setting the crusher/feed system. This will make for easy cleaning and protect the liner. The lined area will be graded so any water will collect at one point where it can be pumped into a Granular Activated Carbon (GAC) filter (Attachment D). 4.4.2 Cover The entire contaminated soil storage and work area will be covered with 12 mil Canvex CB12WB (Attachment D), except when soil is being delivered or the processor is operating. The top cover will extend outside of the cell perimeter berm and be secured with Super Sacks. The active portion of the cell will be covered only when it is raining. To minimize the amount of cell exposed to rain, untreated soil from the sump half of the cell may be moved to a "surge pile" near the feed hopper, allowing the soil stockpiles and half of the lined work area to be covered. 4.4.3 Treated Soil Stockpile Area Treated soil will be stockpiled in the northeast corner of the pad (Figure 3). Stockpile sizes will be constructed as per the sampling plan. Alaska Test Lab will be contracted to collect samples when adequate tons have been processed for testing (usually 1 week). 4.5. Disposal of Treated Soils After cleanup levels have been met per ADEC, SPI will notify the client to remove their soil. Removal must take place within 24 hours of notification unless SPI and the client have mutually agreed to other arrangements. The client is responsible for final disposition of the treated soil. SPI will document the quantity, date, time, and hauling contractor for soil removed by each client on the Release Record (Attachment E). 4-4 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN 5. SITE MONITORING PROCEDURES 5.1 General SRI personnel are responsible for continual monitoring and "housekeeping" around the . contaminated soil storage cell and under the feed system, crusher, and processor. Any contaminated soil that falls on the ground around the storage cell or feed system will be cleaned up and placed back in the cell or in the feed hopper for treatment. Personnel will monitor the stockpile covers to ensure they are secure and not damaged. Damaged covers will be repaired or replaced as necessary to protect the soil from the weather. If no one is working at the facility, personnel will periodically monitor the facility to ensure-the stockpile covers are secure and no excess water is present in the storage cell, especially after heavy rain and /or strong wind. 5.2 Excess Water at Storage CeII If excess water is observed in the cell or sump, the water will be pumped from the sump to a 1,000 gallon poly tank, and from the poly tank through a GAC filter (Attachment D). After the water cycles through the GAC filter, it will be recycled with the processor's scrubber water. If there is free - standing water within the cell, any water on top of the cover will be removed, pumped to the settling pond and recycled. The top cover will extend over the outside berm and weighed down to allow water to drain off. Otherwise, water on the cover will be manually controlled and the water level in the settling pond will be monitored to ensure the pond does not overflow.' When operating at full capacity, the processor uses 6,000 to 7,000 gallons of water per day. The settling pond has a normal freeboard capacity of 10,000 gallons more than adequate to handle the quantity of excess water from the cell. 5.3 Equipment Fuel Storage and Handling All fuels (diesel, gasoline, and oil) will be stored within a lined cell large enough to hold the volume of any spills. All fueling.systems have automatic shut off valves as well as % tum manual valves that are in the . closed position when the fueling equipment is not being used. Absorbent material will also be available during equipment fueling. If a fuel spill occurs outside the containment cell, the impacted soil will be immediately cleaned up, until no fuel odor is detectable, and thermally treated. Any spills less than 10 gallons will be reported to the plant operator on shift and logged into the daily log and Foreman's Report. The spill time, location, quantity, and cleanup will be documented. A spill larger than 10 gallons will be reported to the ADEC and assessed by a 5 -1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN qualified third party person in accordance with Regulation 18AAC75, Article 3. The impacted area will not be filled until the qualified third party determines ADEC Method 1 Category A cleanup levels have been met. 5-2 May 20p2 SOIL PROCESSING INC. OPERATIONS PLAN 6. SAMPLING, TESTING, AND REPORTING All soils accepted for treatment must first have been reported to ADEC and the results of characterization samples, analyzed by an ADEC- approved laboratory, must be provided to SPI. SPI will hire an impartial qualified third party to sample, analyze, interpret and report to the ADEC project manager on a project by project basis. In accordance with the UST Procedures Manual, the following site activities will be conducted /reported: 1) assessing for background contamination before initial startup of the facility: 2) confirming that treated soil meets the applicable cleanup levels; 3) assessing after cleaning up on site fuel spills larger that 10 gallons; and 4) assessing after treatment to demonstrate no secondary contamination occurred. Tracking of post- treated stockpiles will show the location, tonnage, date and time completed, date and time tested and the end results. A Site Plan will be in the Control hours with the above information. To ensure soils are represented vertically and horizontally throughout the stockpile, samples will be hand dug three feet into the soil from the top, middle and bottom. A photoionization detector (PID) will be used to determine the locations from which to obtain post treatment laboratory samples. The highest PID reading will be sent to Analytica's lab for analysis. Location of each sample site will be noted and kept by the third -party. A copy will also be kept on file in the Control House: Reference will be made to a fixed / permanent object (e.g. road, fence, rebar set as a monument) to ensure accurate measurements. This will be in the control house for site closure, testing and reporting. Per Client 1. One sample on the first 1- 50 tons 2. One sample on the 'next 75 tons 3. One sample on the next 100 tons 4. One sample on the next 500 tons and each successive 500 tons until completion. Soils will be tested for the contaminant(s) indicated in the Client's Analytical Report and the SPI Tracking Record (Attachment E) 6 -1 May 2002 SOIL PROCESSING INC. OPERATIONS PLAN All final verification samples for treated soil will be sent to Analytica, Alaska in Anchorage for analytical testing. Three day tumaround will be requested. Samples will be analyzed for the contaminant(s) to be determined by the qualified third party based on soil characterization information contained in the cleanup assessment report submitted to ADEC. Confirmation soil sampling will be submitted to the lab for analyses for concentrations of the contaminants of potential concem (COPCs). Samples will be analyzed for the following compounds by the appropriate test methods based on site specific COPCs: • GRO using laboratory method AK101 • DRO using laboratory method AK102 • RRO using laboratory method AK103 • BTEX using EPA method 8021B • Table 1: Reference Guide to Sample Collection and Laboratory Analysis, Part A • Table 2: Determination of Sampling & Laboratory Analysis for Soil & Groundwater • Table 2A: Indicator Compounds for Petroleum Contaminated Sites The qualified third party will submit assessment reports and original analytical results to the ADEC Manager. Copies of each assessment report and analytical results will be provided to the client and to BEI. SPI will also keep one report on file in the control house at the site. Treated soil stockpiles will not be moved until approved by the qualified third party. All soils will be remediated to the ADEC-applicable cleanup level. Any treated soil that does not meet that client's applicable level will be retreated and re-tested. No soils will be re-treated without gaining the prior approval of a soil re-treatment plan from the ADEC project manager. The soil test results associated with portion of soil failing to meet the cleanup level will be provided to , and discussed with, the ADEC project manager so that a decision can be made regarding appropriate soil re-treatment. 6-2 May 2002 'fable 1: Reference Guide to Sample Collection and Laboratory Analysis (M r.. f 1 ed Part A: Soils, Sediments, Sludges, and Fill Materials 1'ar'a111etrr Preparation/ Analytical Method' Method Detection I.ituit' Practical Quaiititation Limit' Container »escriptiun (Minimum) (Clear glass may be substituted for amber if samples are protected from exposure to fight, this exception does not apply rnetatsl Preservation/ llolding Time Gasoline ranee IIIganics AK III I4 ' 2.0 ntg)kg 20 org/kg g 4 oz. amber glass, TLS Methanol preservative, <25 "C / 28 days Diesel range tog.uucs AK IO2' 2.0 nig/kg 20 mg/kg 4'oz. amber glass, TLC Cool 4" t 2 °C / 14 days to extraction, lesi than 40 days to analysis u f extract Residual range ulgawe, AK 1034 10 nig/kg 100 mg/kg 4 uz. amber glass, TLC tool 4° t 2 "C / 14 days to extraction, less than 40 days to analysis of extract _ • rubber septum seal c n. preserva the ys rom samp mg ' . . . . • • • • • _ _ _ , • rubber septum seal . piing A A `` ^ I.t` ''s Ahpti.ttt4114Mrlang4 itiganica AK(02AA .4 cub. � y 4 ,..b/kt, 4.,z. mac mv..d, nm1,,.i gle..irjo,,'t .. . of extract *• 1 4 oz. jar, TLC NO 1 14 days to extraction, lass than 40 days to analysis of extract '‘'`"""ti` ,li "., "1 I.ulb.. , "6..I,i "a AK 102•AA .4 .,lb/146 nrg'kg widri muath -ambw glass pracorvativu i TIC ! :tltpiiatit tL'Sitl{IJI 3Jnge to gJ(itta Ail1(13AA i iSlbfkg 10 rnE /3.g .,i. x'rdL mw,tlromtier g(a:z: jar. .. " "" TLC 1 y / 14 40 dJya Attl111J1(1. i4SllliLli 1.11%L. lliganiit. AK I03AA 1 1o6A6 10 ,(. ./kb 4 ,It. w(Lk- Illwtb OM 71 6iu.T)°I, i�0 i,l..]LI VatiV, [Wyi Iu crild4t1ut1 Uf SJnppiC, ICia It1411 to analysis of extract lienzcne AK 1011 or 826011 0.007 mg/kg 0.07 mg/kg 4 oz. amber glass, TLS Methanol preservative. <25 °C / 28 days Tolueric AK 100 or 826011 0.007 mg/kg 0.07 mg/kg 4 oz. amber glass, TLS Methanol preservative, <25 °C / 28 days fithylbenzenc AK 101' or 826011 - 0.007 mg/kg 1):07 nig/kg 4 uz. amber glass, TLS Methanol preservative, <25 "C / 28 days fuiat xyknes AK 101' or 82601i 0.007 nig/kg 0.07 mg/kg 4 oz. amber glass, TLS Methanol preservative, <25 °C / 28 days Total ift'I:X - AK 101' or 826011 0.1107 mg/kg 0.07 mg/kg 4 uz. amber glass, TLS Methanol preservative, <25 °C / 28 days I'ulynucicar Aromatic. llydrocarbuns (PAII) 8270C or 8310 0.1 nig/kg 1.0 nig/kg 4 uz. amber glass, TLS Cool 4" t 2 °C / 14 days to extraction, less than 40 days to analysis of extract Total Volatile l •hlurinated Solvents' • 826013 (1.0118 trig /kg 0.08 mg i g 4 oz. anther glass, TLS Cool 4" t 2"C/ 14 days Polychlorinated biphenyls (PCBs) 8081 A or 8082 0.01 nig/kg 0.05 mg/kg 4 uz amber glass, TLC Cool 4° t 2 "C / 14 days to extraction, Icss than 40 days to analysis of extract Total Arsenic 6010(1, 6020• 7060A, or 7061A 1 mg/kg 10'mg/1.g . 4 uz amber glass, TIC Cool 4" t 2 "C / 6 months 'futai C'adnuunt 601011, 602(1• 7130, ut 7131 A 1 niy'kg 10 nig/kg 4 uz amber glass, Tt.0 - Cool 4' t 2"C / 6 months Total Chromium 60108, 6020, 7190, 90, or 719t 1 mg/kg 111 ing/kg .4 uz amber glass, TLC I'ool 4" t 2 "C / 6 months - 'fatal Leal 6010, 6020, 7420, 7421 I utg/kg 10 owls 4 oz amber glass, I LC Cool 4" t 2 "C / 6 months Legend and fuulnotcs follow I'arI 11 27 Table 2 (Wtod $-Fiect Determination of Sampling and Laboratory Analysis for Soil(S) and Groundwater(GW) Petroleum Product C6-C10 GRO CIO-C25 DRO C25-C36 RRO6 BTEX • Constituents . .. PAE.I.2 Metals iia4- Solvents Leaded Gasoline S & GW S & GW 5 & 014/ (S & GW)s Aviation Gasoline S & GW S & GW S & GW (S & GW)s Gasoline S & GW S & GW $ & GW JP-4 S & GW S & GW S & GW $ & G)V Diesel #1/Arctic Diesel S & GW S & GW S & GW $ & GW #2 Diesel . S & GW S & GW $ & GW #3 - #6 Fuel Oils S & GW S & GW S & GW S & GW JP-5. JP-8, Jet A S&GW S & GW S & GW $ & GW , ' Waste Oil (crankcase) S & GW S & GW ' S & GW S & GW $ & GW (S & GWV.' Kerosene S & GW S & GW S & GW S & GW Mineral Oil . S & GW S & GW GW $ & GW Dielectric Oils - S & GW S & GW GW S & GW Unknown S & GW S & GW ' S & GW S & GW S & GW (S & GWY'' Legend: . GRO = Gasoline Range Organic s {using AK 101 or AK 101AA} DRO = Diesel Range Organics {using AK 102 or AK 102AA} RRO = Residual Range Organics {using AK 103 (for soil) or AK 103AA (for soil and groundwater)) BTEX = refers to individual indicator compounds to be analyzed: benzene, toluene, ethylbenzene, and total xylenes. • - - _ ,- • - - . - • - oe anthracene, • e, benzo-a-anthracene .... . - .- -.- .:- 11 i - ' , perizo-s- uo an ene, •enzo-•- • • • • ' . - - • - 1.. • would be required for all petroleum releases, unless the sum of the a..I a cleanup'standards for individual petro eum '4.. - : :• • . - las • — - - • - - e. or the site by applying . the corresponding Method 2 — - - - - - • I * l■ 75.340 is equa or ess = e -- • - ,.,......2, ki-i at,._•___IL._isisis " • O 1 - a or LVethod 1 referenced in 18 AAC 75.340. • ' -, • • IS •ounds listed in Table 2A.would be re.uired f. • - • • -.. -- . •.0 xcept gasoline and 113-4 fuel spill anal . • ,,,, .. srm:---T 1 - • --r- : , - - . - • - • . 'less the • oject manager -...- . .envise. . .. .. . . •• vanadium. 4 Volarile chlorinated solvents and other additives listed in Table 2A must be performed it' required by the project manager. .1c-41.11i . vIett1 dila yb is to ea tidy 111111 bt pt..1 UIIII { y- t 1 ujCCt Lira agr. ' .. For sampling groundwater for RRO use the "aromatic residual range organics" fraction parameter method Ilisted in Table 1, Part B. of this manual. 49 TABLE 2A (Modi{fted) INDICATOR COMPOUNDS FOR PETROLEUM CONTAMINATED SITES • Volatiles (BTEX) benzene toluene ethyl benzene total xylene • olynuclear Aromatic Hydrocarbon Hs)* - Carcinogens* benzo(a)pyrene chrysene - deno(t.,2,3 -cd). ene be o(k)fluor••s.ene benz b)fl ur• ••thene benzo a is acene dibanzo h)anthracene Polynuclear Aro atic - drocarbons (PAHs)* - N carcino_ ens a acene cenaphthene pyrene naphthalene fluorene • • Metals as required on a case by case basis Arsenic Barium Cadmium Chromium Lead • Nickel Vanadium • Others as needed on a case by case basis ethylene dibromide (EDB) 1,2 dichloroethane (EDC) methyl 1 tert- butylether (MTBE) volatile chlorinated solvents 50 Rev, 5/71,9 SOIL PROCESSING INC. OPERATIONS PLAN 7. SITE CLOSURE Before initial startup (background) and after completion of the treatment (closure), an impartial qualified third party will assess under areas where untreated soil is stored or handled. These areas are the 1) contaminated soil storage cell, 2) feed system, and 3) exit soil pile (Figure 7). 7.1 Background Assessment The background assessment will include: 1) Layout sampling grid, Figure 7. 2) Reference the sample grid to the perimeter fence or other permanent features. 3) Collect field screen samples at 3 to 6 inches below surface and test with PID. 4) Collect second sample 1 foot deeper if PID reading is more than the background. 5) Test 1/10 of samples with Dexsill PetroFLAG analysis system if PID readings are low and if hydrocarbon odor is detected. 6) Collect analytical samples at locations with highest PID or PetroFLAG reading. 7) Analyze samples for diesel range organics ,(DRO), gasoline range organics (GRO) and benzene, toluene, ethylbenzene, and xylenes (BTEX). 8) Provide report to ADEC. 7.2 Closure • After all the contaminated soil has been treated and removed from the site the following will take place: 1) Soil storage cell will be dismantled by SPI and documented by the third party. SPI will remove the 3-inch asphalt pad and dispose it on BEI's site. The third party will field screen the 18 inches of % inch material that is on top of the liner. If contamination is not detected, the % inch material will be removed and piled on site. 2) The liner will be cleaned and removed. The third party will field screen the soil 6 to 9 inches below the liner. Any contaminated soils will be removed and treated untillield screening indicates the contaminant levels are the same or no greater than initial startup (background) concentrations. Then discrete laboratory samples vvill be collected. 7-1 May 2002 SQL PROCESSING INC. OPERATIONS PLAN ' 3) The third party will be on site immediately after the liners are removed at the treated soil stockpile area, process area, exit soil pile and settling pond for purpose of closure assessment. 4) The exit soil pile liner will be removed, and the third party will field screen undemeath. 5) The feed system will be dismantled, liner removed, and the third party will field screen underneath. 6) The settling pond will be emptied and cleaned. 7) Analyze samples for DRO, GRO and BTEX. 8) Contaminated liners will be disposed in an approved facility. 7.3 Sample Schedule The qualified third party will field screen the areas listed above (section 7.2) according to the following schedule. The number of analytical samples shown is for the initial background assessment. Field screen locations for closure will be, the same as the initial background assessment. Area Description - Area (feet) Field Screening Samples Minimum Laboratory Samples I Contaminated Soil Storage Cell 80 x 90 16 6 11 Feed System 30 x 8 3 2 111 Exit Soil Pile 15 x 15 2 1 Contaminated soil detected under the storage cell, exit pile, or feed system will be cleaned up and run through the processor, and used to fill the cleanup location. If the field screen results are "non-preferential," discrete samples will be collected from representative locations selected by the third party. If some locations have elevated readings but appear to be less than Level A, discrete analytical sample(s) will be collected from the location(s) with the highest concentrations. Settling Pond water and sediment will be sampled for DRO, GRO and BTEX. After analysis results verify the water and sediment are clean, the water will be discharged on the ground and the sediment will be placed on a treated soil stockpile. The pond liner will be removed and 7-2 may 2002 SOIL PROCESSING INC. OPERATIONS PLAN cleaned for reuse or disposed of at an approved facility. The qualified third party will be present when the liner is removed and assess the soil beneath the liner for evidence of leaking. If hydrocarbon concentrations in the sediment exceed Level A for soil, the material will be removed and run through the processor. If water analysis results exceed the groundwater cleanup levels for DRO, GRO or BTEX in Table C (18AAC75.345), the water will be treated using the GAC filter and disposed of on site, if approved by the ADEC staff. 7,4 Final Report •When all areas have been cleaned up, assessed and sampled, the qualified third party will report the post-closure assessment results to the ADEC staff at the Kenai Area Office and provide one copy for SPI and one for BE!. BEI representatives will conduct a final inspection of the site after SPI has dismantled all equipment. Subject to satisfactory inspection results and ADEC approval of the final report, BEI will issue a release of liability letter to SPI. 7-3 May 2002 ATTACHMENT A QUALIFYING DOCUMENTS BEI Letter Re: P9rmission to Operate Air Quality Operating Permit ADEC Relocation Permit Public Notification Letter id 1 GENERAL CONTRACTORS May 1, 2002 BRECHAN ENTERPRISES, INC / GENERAL CONTRACTORS 2705 MILL BAY ROAD • KODIAK, ALASKA 99615 Mr. Paul Horwath, P. E. State of Alaska, Department of Environmental Conservation Contaminated Site Program 43335 Kalifonsky Beach Road, Suite 11 Soldotna, Alaska 99669 Re: Soil Processing Inc. Portable Thermal Unit Soil Processing To Whom It May Concern: This is to confirm that Brechan Enterprises, Inc. has agreed in principle to provide one acre of land at our industrial site on Kodiak Island (Block 3, Tract A, Bells Flat Alaska Subdivision) for the above referenced use. This agreement is contingent upon ADEC approval of the Category C Facility Operations Plan submitted under separate cover from Mr. George Cline, president of Soil Processing, Inc. Upon approval of that plan, Brechan Enterprises will permit stockpiling material and thermal unit burning from "others" in strict accordance with the approved plan. It is understood that we will receive a copy of all records, transmittals, test reports, etc. required and specified in this plan. Receipt of a signed ADEC approval of this plan is required prior to any soil processing from others. In addition Brechan Enterprises will require a separate signed indemnification clause from each party entering the project site. This agreement will remain in effect for the period specified in the plan, unless canceled by written notification. If you have any questions or comments, please contact the undersigned. Very Truly Yours, Brechan Inc. W. E. Oliver Vice President PHONE: 907.486.3 215 • FAX: 907.486.4889 ALASKA BUSINESS #001858 • ALASKA CONTRACTORS #AA441 We Are An Equal Opportunity Employer GP4 — Soil Remediation Unit General Permit ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION AIR QUALITY OPERATING PERMIT Permit No. GP4 The Department of Environmental Conservation, under the authority of AS 46.03, AS 46.14, and 18 AAC 50.350, issues an Air Quality Operating Permit for: Permitted Facilities: Qualifying Soil Remediation Units. This permit authorizes the operation of facilities for which the Department finds in writing: . • Equipment meets the criteria established on page 2 of this permit; and • The department has received a complete application. For the department to find-the application complete, the application must provide all of the information described in the application form issued with this permit for all equipment to be operated under this pen-nit. This permit expires on May1, 2003. To renew this permit, the owner or operator must submit a renewal application between November 1, 2001 and November 1, 2002. John M. Stone, Chief Air Quality Maintenance Section May 1, 1998 May I, 1998 FINAL GP4 - Soil Remediation Unit General Permit ATTACHMENT 2. Portable Facility Relocation/Operation Notification Submit the information specified below to the Department's'Air Quality Maintenance Section, thirty days before moving the plant to any new location, and before startup. Name of Firm: SOIL PROCESSING INC. Contact Person: Telephone: JENNIE D. SHARPE (907) 274-3000 New plant location (include site maps): N 57° 42.692 / W152° 34.805 BELLS FLATS, KODIAK, ALASKA Approximate startup and shutdown dates: MAY 20 , 2002 / NOVEMBER 2002 Comments: SOIL PROCESSING INC. WILL BE OPERATING FROM INSIDE BRECHAN ENTERPRISES, INC.'S INDUSTRIAL SITE. I hereby certify that the information contained in this notification is to the best of my knowledge and . belief, is true, com le ac S" • ure: C.E.O. May 1, 1998 -25- JENNIE D. SHARPE Printed Name: Telephone: ( 907 ) 27 4 -3000 FINAL Alaska Department of Environmental Conservation Request for Public Comment on Proposed Soil Remediation Facility to be located at Brechan Enterprises, Inc.'s industrial site, Kodiak, Alaska Comments must be received by May 22, 2002 The Alaska Department of Environmental Conservation (ADEC) is requesting public comments on an Operations Plan from Soil Processing Incorporated, Inc., (SPI) for DEC approval of a petroleum contaminated soil remediation facility to be located on off Salmonberry Drive on Brechan Enterprises' industrial site property on Block 3, Bell's Flats Subdivision. SPI proposes to construct a soil remediation facility at this site in order to receive and treat contaminated soils under an ADEC approved Operations Plan, in accordance with the provisions of'18 AAC 75.365 and 18 AAC 78.273 (Offsite Treatment Facilities). Soils would be trucked to the facility from surrounding areas for storage; pending treatment using thermal desorption technology. The soil processing equipment heats the soil to temperatures that drive off the petroleum contaminants, which are subsequently destroyed (oxidized) in a secondary afterburner. After soil sampling confirms that the treated soils meet ADEC required cleanup levels, the soils will be transported back to the place of origin or, disposed at the soil treatment site. Facility construction activities are scheduled to begin this spring (2002) and soil treatment could continue for three or more. seasons. In order to comment on SPI's proposed soil remediation facility, ask questions about the proposed project, or to review any ADEC file information regarding this project, please contact: • Paul Horwath ADEC Contaminated Site Program 43335 Kalifornsky Beach Road, Suite 11 • Soldotna, Alaska 99669 Phone: (907) 262-5210, ext. 250, Fax: 262-2294 E-mail: Paul Horwath@envircon.state.ak.us ATTACHMENT B FIGURES Figure 1 Site Location Map Figure 2 Vicinity Map Figure 3 Site Plan Figure 4 Flow Diagram of Operation Figure 5 Thermal Soil Treatment Diagram Figure 6 Contaminated Soil Temporary Stockpile Slab Design Figure 7 Background Sampling Grid �PQ - �o- 43% C 0 � Pillar Creek 0 Reservoir i • 615 Lunn Lake ty /" Island e.kSashkina' Elepltnni i411YI' lake .. ieP Ar . Long Island n nE� it Oto f. 1 Bioad Point 'Queer land Lake Lee l Heitman • Lake Kalsin Island Heitman Mountain 0 0 SOIL PROCESSING INC. 207. E. Northern Lights Blvd., Suite 103A Anchorage, AK 99503 (907) 274-3000 FAX: (907) 274-9295 Figure 1 Site Location Map Source: ACS, 2001 - Eagle Eye Maps Kodiak, Alaska Kodiak, Alaska SOIL. PROCESSING INC, hts Blvd., Suite 103A 207. E. Northern aie, AK 99503 4 g295 Anchor, �9p7) 2730000 0 FAX: (907) 27 X FENCE x X - x BUTANC TANKER AREA (MINIMUM 50' FROM PROCESSOR) • 500 CAL LINED 0113L TANK STORAGE AREA GEN SCT LINED ARCA • CAC VLIER WATER UNE \ GATE LOADER, TRAVEL AREA , v // TRUCK RAWP: Bo' a. 225' /1'0lL RA ,711dr1ott st UNED DOI AREA oar Auoms v SETTLING POND 12 MILL LINED LINED AREA CRUSHER FEED srsro4 LEASE j05,1NOARY 1 0' DISPOSAL AREA FOR CLEAN SOILS (LEVEL A) 250' .,,astvaLcaNVegA4 Z3b% OF AL er .444. **** .19' te ININFIM.R• • George R. WI ck• Og 01 - 7553 /tk PRO FESSO" EIRECHAN ASPHALT PLANT. AREA SEE FIOURE ZA FOR DETAILS OF SAMPLE LOCATIONS APPROX. 50-100' ACCESS \DRIVEWAY \ NOT TO SCALE SALIIONBCRRY DRIVE SOIL PROCESSING INC. 207 C. NORTHERN UCHTS 3Lv0.. SUITE 103A ANcHoaAcc, A.K 99503 ( 07) 274-3000, FAX: (907) 274-1295 FILE: K 005 101 DRAWN: c/sc: 1:1 co: SOILPROC DAIE: 5/1/01 CHECK: GEORGE FIGURE 3. SITE PLAN KODIAK ALASKA ii CONTAMINATED SOIL SCREEN SHREDDER CLASSIFIER !t3 11'6 4, VARIABLE SPEED FEEDER FLOW DIAGRAM OF OPERATION ■ *••CONFIDENTIAL•,Pro SOIL /TE}X #16 PARTICULATE PATH #17 275 °F #9 CLEAN AIR--- INLET BOX R' 0 T. A R Y D R U 0 L• I T 0 L E E Y C L FURNACE URNER 450° - 800 °F OUTFEED rgeo out . 22 RIGS iri 1115 R v E c Y C •L E #10 RECIRCULATOR BLOWER 300 °F 1600 °F U E N C H 1113 AFTER BURNER BURNER N7 n n" _CLEAN SOIL #8 ATER #14 D I S C H A R 0 #12 i CYeLDNE SaPc¢asoa.F FIGURE 4. FLOW DIAGRAM OF OPERATION 1 J LOAPER A Pluss NoINJG LAI-5 CoNFIRMATIv:/) Figure 5. THERMAL SOIL TREATMENT PLANT DIAGRAM New Cell Construction 1. Lay out area of approximately 80 feet by 90 feet for asphalt pad. - 2. Establish reference elevation and set grade on stakes at the four corners of new cell. 3. Grade existing %-inch minus material at 2% to drain toward the sump in the northwest corner. 4. Field screen and collect necessary laboratory samples from upper 12 inches of soil in prepared area as per detail in Figure 7. 5. Remove sharp rocks and deleterious material from the surface. 6. Compact the 80 foot by 90 foot sub grade pad to provide a smooth firm surface; conduct as-built survey of the pad elevations. 7. Place AMOCO 4510 Geofabric (Attachment D) on finished grade 8.. Lay a new 100 foot by 100 foot, 20 mil Nova-Thene RB88X6HD (Attachment D) factory-seamed liner over AMOCO 4510 Geofabric. 9. Install 2 foot by 2 foot sump on the liner. Top of sump to be 2 inches below finished asphalt grade. Place AMOCO 4510 on top of liner (See Figure 8) 10. Place 18 inches of %-inch minus material on top of the AMOCO 4510. (No heavy equipment will operate on the liner before the 18 inches of material is in place) 11. Conduct as-built survey elevations of %-inch minus layer. 12. Roll and compact the 3/4-inch material to provide a firm surface. 13. Machine pave the 80 foot x 90 foot pad with 3 inches of asphalt (see Asphalt Mix Design, Attachment F). Finish roll making sure the entire pad drains to the sump area. A 12 inch asphalt berm will be continuously constructed while the pad is being paved. Berm is to be compacted with weighted hand compaction plate. 14. SPI will provide as-built drawings to the ADEC signed and sealed by a professional engineer , registered in the State of Alaska under AS 08.48 CONTAMINA CROSS SECTION LAYER SEQUENCE: 1. Min 3 Inch; Compacted Asphalt Concrete Slab 2. Min 18 Inch Graded and Compacted Bedding Material 3. Amoco 4510 Non Woven Geofabric 4. Nova -Then RB 88 X 6 HD Polyethylene Liner (20 mil) 5. Amoco 4510 Non Woven Geofabric 6. Compacted and Graded Ground Surface C 20 mil Geomembrane Liner Material Soil Processing, Inc. D SOIL TEMPORARY STOCKPILE SLAB DESIGN Sump Area Drains to Center. Plastic Bucket 2 Feet Deep Placed into Sump. Sump Area Shall be Overexcavated to Accommodate Bucket. Liner Under Sumo Continuous With Slab Liner. (See Attoched____, Amoco Style 4510 Geofabric for j Protection Against Foot Traffic 18' Lift of 3/4 Minus Material Graded & Compacted Bedding Material to Cover AC Berm a Minimum of 6 Inches Original Ground Compacted and Graded to Drain 2% Toward Sump Corner Prior to Placing Geofabric and Liner 12' Min TYPICAL SECTION OF BERM CONSTRUCTION Asphalt Concrete Berm Extends 12 Inches Above AC -Slab Berm is Continuous With Slab Nova -Thene RR 8\ X 6 HD 20 mil Lliner With Geofabric Directly Above and Below J Notes: 1. Subgrade shall be graded and compacted at a 2% slope draining toward sump corner. Surface shall be free from sharp objects or rocks protruding more than 1/2 inch. 2. Amoco Style 4510 geotextile fabric shall be placed on original ground surface prior to liner placement. 3. Joints in geofabric shall overlap a minimum of 15 inches. 4. Nova -Thene R8 88 X 6 HD 20 mil liner shall be used as shown. Liner shall be one piece or factory seamed. Field seaming is not permitted. 5. Amoco Style 4510 geotextile fabric shall be placed directly above and below 20'mil liner. 6. 3/4 inch minus granular material will be used for bedding material as shown on drawings. 7. Bedding material will be rolled with a static roller then graded with a blade. Final surface will be static rolled prior to asphalt placement. 8. A minimum of 3 inches of compacted asphalt concrete will be placed directly on the bedding material. Berms will be FIGURE 6. CONTAMINATED SOIL TEMPORARY STOCKPILE SLAB DESIGN NOT TO SCALE FINAL SP! SLAB DESIGN.xls DETAILS AND NOTES Compacted Soil Equipment Access l` Ramp J PLAN VIEW OF ASPHALT CONCRETE SLAB CE- 7553 f��`` BUTANE TANKER.' AREA (MINIMUM 50' FROM PROCESSOR) S0' so' LINED EXIT AREA SETTLING PQNO L E G E N D SO' • SAMPLE LOCATION NOTE: PERIMETER FENCE AND SET /MBAR TO BE USED FOR SAYNC TIES TO SAMPLE LOCATIONS LINED AREA CRUSHER FEED SYSTEM ASPHALT PAD CONTAMINATED SOIL TEMPORARY STOCKPILE TREATED SOL STOCKPILE AREA MONITORING TEST RESULTS NOT TO SCALE SOIL PROCESSING INC. 207 E. NORTHERN LIGNTS BLVD., SUITE 10SA ANCHORAGE AK 99503 (907) 274 -3000, FAX: (907) 274 -9295 FILE: K®5107A CAC: 1:1 DATE: 5/1/02 DRAWN: SSA CO: SOILPROC CHECK: GEORGE FIGURE 7. BACKGROUND SAMPLING GRID KODIAK ALASKA TO' 2% ASPHALT PAO 1 AMOCO STYLE 4510 FABRIC 20 NIL UNER- AM000 STYLE 4510 ream suuP LOCATION 2N SLOPE ASPHALT NAND GRADED TO SLOPE TO SUMP (ALL SOTS Or S11MP) 2' WATER TO G.A.C. FILTER AN000 STYLE 4510 FABRIC 20 MIL LINER AMOCO STYLE 4510 FABRIC 2' 5 GAL PLASTIC • BUCKET APPROX. 2'x2' i% NOT TO SCALE Wnor" rrfr4eaf4,NV • 1�f 2% SLOPE ORIGINAL GROUND 9. SOIL PROCESSING INC. 207 E. NORTHERN UGHTS BLVD., SUITE 105& ANCHORAGE, AK 99007 (907) Z74 -5000. FAX: (9W) 774-9295 FILE: K0D01302 C /SG` I:1 GATE: 5/13/02 DRAWN: SSR CD: SOILP90C CHECK OEOR0r FIGURE 3 SUMP DESIGN CROSS SECTION VIEW KODIAK ALASKA ATTACHMENT C CONTINUOUS EMISSION MONITORING SYSTEM 1.0 INTRODUCTION Soil Processing, Inc. (SPI) is currently operating a P.D.I SoiL'TEK Model 3000 Thermal Soil Remediati Processor. This unit is used to thermally remediate soil contaminated with petroleum hydrocarbons. The P.D.I unit thermally desorbs the petroleum hydrocarbons in a direct-fired rotary drum dryer. The hydrocarbon enissions are controlled by thermal destruction in a secondary combustion chamber. Particulate emissions are controlled by a series of wet scrubbers and a power-assisted rotary cyclone (Heliclone®). The P.D.I. unit is trailer mounted and capable of moving from site to site. 1.1 MONITORING PROGRAM RATIONALE Soiling Processing, Inc. obtained an Air Quality Permit to Operate from the Alaska Department of Environmental.Conservation (ADEC) File No. 9421.-AA002. The ADEC permit established air quality emission standards for the operation of the unit Standards were established for particulate matter and carbon monoxide (CO). Compliance with the particulate standard was initially determined by an emission test performed by an independent testing firm Particulate testing may be required agaiii at the discretion of ADEC, probably at the renewal &h of the permit Compliance with carbon monoxide standard is to be demonstrated by the installation and operation of a continuous emission monitoring system (CEMS). 1.2 MONITORING PROGRAM OBJECTIVES 1 The continuous emission monitoring system is to monitor the efficiency of hydrocarbon destruction in the secondary combustion chamber. A high concentration of carbon monoxide in the emission gases is an indication of poor hydrocarbon destruction. The ADEC emission standard for CO, stipulated by the SPI air permit, is lop parts per million (ppm) corrected to 7 percent oxygen (02). The objective of the CEMS program is to comply with ADECpermit conditions. This includes the installation and initial certification of the system, and the successful operation and maintenance of the monitoring system to insure the collection of representative and accurate emissions data ADEC requires that the CEMS program be operated in accordance with US Environmental Protection Agency (USEPA) regulations relative to equipment performance specifications and quality control/quality assurance (QC/QA) guidelines. This manual is to provide information and staildard operating procedures for the CEMS program. 1.3 REFERENCES The information provided in this manual was gathered from a number of sources, the ADEC air quality permit, federal regulations, USEPA documents, and instrument manuals. All documents used in the - CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) 2 preparation of this manual are listed below. Soil Processing, Inc., Air Quality Control Permit to Operate, File No. 9421-AA002, Alaska Department of Enviromnental Conservation, March 24, 1994. Performance Specification 4—Specifications and Test Procedures for,Carbon Monoxide Continuous Emission Monitoring Systems for Stationary Sources, Title 40, Code of Federal Regulations, Part 60, Appendix B, as revised July 1, 1996. Performance Specification 3—Specifications and Test Procedures for 02 and CO2 ' Continuous Emission Monitoring Systems for Stationary Sources, Title 40, Code of Federal Regulations, Part 60, Appendix B, as revised July 1, 1996. Performance Specification 2—Specifications and Test Procedures for S02 and NOx Continuous Emission Monitoring Systems for Stationary Sources, Title 40, Code of Federal Regulations, Part 60, Appendix B, as revised July 1,1996. Procedure 1—Quality Assurance Requirements for Gas Continuous Emission Monitoring Systems Used for Compliance Determinations, Title 40, Code of Federal Regulations, Part 60, Appendix F, as revised July 1, 1996. Quality Assurance Guidelines for Air Pollution Measurement Systems, Volume I Principles, US Environmental Protection Agency, EPA-600/9-76-005, December1984. Quality Assurance Guidelines for Air Pollution Measurement Systems, Volume III, Stationary Source Specific Methods, US Environmental Protection Agency, ITA-60014-77- 027b, August 1988. Soil Processing Inc. Continuous Emission Monitoring System—Combined Instrument mannais, PACE Environmental Products Inc., August 1991. 20 DESCRIPTION OF THE MONITORING SYSTEM The continuous emissionmonftoring system (CEMS) installed on the P.D.L Soil/TEK. remediation unit is a multi-component extractive type monitoring system. The CEMS consists of three subsystems; the stack interface and sample gas conditioning system, the gas analyzers, and the data acquisition system. The following section provide a brief description of these subsystems._ • 2.1 STACK INTERFACE AND SAMPLE GAS CONDITIONING The stack interface and the sample gas conditioning system extract emission gases from the Soil/TEK exit stack and prepare the gases prior to entry into the gas analyzers. This subsystem was designed and manufactured by PACE Environmental Products, Inc. The emission gases are aspirated from the stack through a stainless steel probe into a heat-traced Teflon sample line. The sample line conveys the emission gases from the stack into the Soil/TEK process control room and the instrument rack Containing the remaining components of the system The sample gases pass from the heated sample line into a multi-component gas conditioning system. The conditioning system consists a water knockout to remove any free water and a VIA Model MAK 2 thermo-electric cooler. This component cools the sample gases resulting in the condensation of water vapor from the sample stream. The moisture is reduced to less than 2 percent This is sufficient to prevent intrusion of liquids into thegas. analyzers. A drain pump is provided to remove the condensation. Should the VIA sample gas conditioner fail, the =it is equipped with a liquid sensor which will enunciate an alarm. As previously mentioned, the sample gases are drawn through the entire sample system. This is achieved by aspiration. A compressor provides instrument air that is blown through an eductor. This creates a negatiVe pressure on the sample systeiii pulling emission gases from the stack through the entire system. The eductor pulls a much greater volume of sample gas than is needed by the gas analyzers. The excess sample, gas is vented to the outside atmosphere. Once the sample gases are cleaned and the moisture removed, the gas analyzers are allowed to draw the necessary volume of gas for pollutant measurements. 2.2 GAS ANALYZERS The sample gases are analyzed using two instruments, a carbon monoxide (CO) analyzer and an oxygen (02) analyzer. The CO analyzer is used for the determination ofthe pollutant concentraticm. The 02 analyzer is to measure the concentration of diluent gas in the emissions and to standardize the CO concentration to 7 percent 02. This standardization is to prevent an operator from increasing the excess air in the combustion process and thereby, diluting the p011utant concentration. 2.2.1 CanMonoxideA±ialyzer The CO concentration is measured using a Thermo Environmental, Inc. Model 48 CO analyzer. This instnunent operates on the principle known as Gas Filter Correlation (GFC) Spectroscopy. This technique uses a infrared light source, a system of optics, a gas filter, an infrared detector, and a micro-processor to measure the CO concentration in the sample gas. [• 4 Although, further explanation of this analytical technique is beyond the scope of this manual, it should be noted, that this measurement technique has distinct advantages over other types of infrared analyzers. The Model 48 instrument response is very accurate, precise, and stable which minimizes calibration drift. An intemal pressure and temperature transducer provides information to the micro-processor for automatic correction in sample flow. The GFC technique all but eliminates interference from moisture and carbon dioxide (CO2) in the sample gas. The instrument is equipped with circuitry to perforrn diagnostic tests on the infrared light source, detector, and other internal electronics. The Model 48 provides a digital readout on the front display, as well as, an analog output. The measurement range selected for the Soil Processing Inc. CEMS is 0.0 to 500 ppm which is represented by an output signal 0.00 to 10.00 volt direct current (VDC). 2.2.2 Oxygen. Analyzer The 02 analyzer used in the SoilTIEK CEMS is a Model ZFK Zircomat Oxygen Analyzer manufactured by the COSA Instrument Corporation. The principle of operation for this instrument is relatively simple as, comparedto the CO analyzer. A zirconia (ZRO2) and yttria (Y203) sensor is heated to a temperature above 500 degrees Celsius. At this point the sensor is conductive to 02 ions in the sample gas. This produces an electromotive force between two electrodes which is proportional to the concentration of 02 in the sample gas. This instrument is typically used as an in-tack sensor. For this application the instrument was modified and the sensor mounted in the CEMS instrument rack. The sensor was sealed in a containment and a salople transport scheme designed to allow sample gases to flow across the surface of the sensor. The instrument provides an LED display on the front panel and an analog output. Calibration of the instrument is achieved by potentiometer adjustments on the front panel. The measurement range on the COSA Zircomat 02 analyzer is from 0.0 to 25.0 percelt which is represented by an output signal of 4 to 20 milli-amps. 2.3 DATA ACQUISITION SYSTEM The Data Acquisition System (DAS) provide a means of polling the output signals from the gas r 5 converting the signals into engineering - units, processing the data into hourly averages, and providing, a hard copy record of the data As with the other CEMS systems the DAS is a multi- component system consisting of a electronic data logger, a personal computer and printer, data processing and communication software, and a strip chart recorder. 2.3.1 Electronic Data Logging System The main component of the electronic data logging system is a Model DSM 3260 data logger manufactured by Odessa Engineering, Inc. The micro- processor based DSM 3260 polls the input signals from the gas analyzers once every second and storing that information in its internal memory and in a removable memory cartridge. The analog data is averaged into 6 minute averages and then,into 1 hour averages. The data logger is equipped with an input status function which can flag the data as invalid during periods of calibration and maintenance. The data is stored but is not included in averaged data The data logger performs an analog to digital conversion providing the data as engineering units; parts per million (ppm) for the CO and percent ( %) for the 02. The.DSM 3260 data logger is connected to an IBM compatible personal computer. The computer is equipped with a letter quality printer to produce a hard copy of the averaged data The downlink from the data logger to computer is achieved using a communication and data processing software known as DSMTALK developed again by Odessa Engineering, Inc. The menu driven software allows the computer the download the emissions data from the data logger and to print hourly and daily reports. 2.3.2 Strip Chart Recorder The stl iv chart recorder included in the Soil Processing Inc. CEMS provides a continuous brace of the gas analyzer signals. This unit is a LR 4120 series two pen, programmable, strip chart recorder manufactured by the Yokogawa Electric Corporation- Any DC voltage, thermocouple, or RTD inputmay be selected for either of the 2 charmeis. Input parameters are loaded into the recorder memory to provide continuous LED readings displayed in engineering units. This is in addition to the continuous chart traces. The Yokogawa recorder will receive output signals directly from the CO and 02 analyzers providing a redundant means of data collection should the electronic data logger fail.. The redundant data record also provides a method for comparing data sets between the chart record and the data logger. The Yokogawa recorder will be programmed specifically for the output parameter from the gas analyzers and the chart speed I 1. 6 is to be set at 1 inches per hour. With the exception of the personal computer and the associated printer, all technical infonnation for the individual components of the Soil Processing CEMS were compiled into a integrated manual by PACE Environmental Products, Inc. 3.0 STANDARD OPERATING PROCEDURES The data collected by the Soil Processing -CEMS unit is to determine compliance with ADEC air permit conditions. Because this data is collected for compliance purposes the data must be of an accuracy and quality that the data is considered LEGALLY DEFENSIBLE. To insure the collection of accurate, quality data, the following standard operating procedures are to be implemented for the operation and maintenance of the Soil Processing, Inc. CEMS. These standard operating procedures are comprised of quality control procedures and quality assurance procedures. Quality control (QC) procedures refer to routine daily, weekly, and monthly procedures performed by the SoWIEK unit operators. Quality assurance (QA) procedures are conducted on a quarterly and an annual basis. The QA procedures are to be performed by a qualified person independent of the day to day operation of the CEMS: The following sections provide detailed information and step by step instructions for the performance of the. required procedures. 3.1 STARTUP AND SHUTDOWN PROCEDURES Because the SoiliTEK unit may be periodically shutdown for process and generator maintenance, the monitoring system must also be shutdown. Startup and shutdown procedures are to be performed in the correct sequence to avoid contaminating the sample systems with moisture and to minimize maintenance problems with other system components. The procedures are listed below. Startup Procedures: 1. Turn on the Pace 1400 Heated-Line Controller. The set point of the controller should be maintained at 225° F. Allow the sample line to come up to temperature. 2. Turn on the instrument air compressor that provides air to the eductor. Adjust the eductor pressure to 30 psi. 7 3. Actuate the remaining power switches for the Pace Stack Interface paneL 4. Open the cover to the strip chart recorder and with a felt tip pen mark the chart with the exact time, date, and initials of the operator. Close the cover and actuate the record power switch. Make sure the instrument is responsive and the chart speed is set to 3 inches per hour on the LED reading on the right panel. 5. Turn on the computer terminal, video monitor, and printer. The communication software is programmed to come up automatically. 6. Since the DSM 3260 is typically left on, check the current time in the LED display. If incorrect reset. Push the memory storage module into to place and make sure it is properly seated, IMPORTANT NOTE: If the data logger battery is in functional, the memory storage may be left in place all the time. If not the module must be pulled out before electrical power is shutdown, as is done during generator maintenance. 7. Enable the averaging function on the data logger through the computer terminal. • 8. Tum on the power to the CO gas analy-zer and the 02 analyzer. Make sure both units are •responsive and sample flow can be observe on the CO rotometer (flowmeter) 0.5 to 1.5 1prn. The CEMS is collecting data Shutdown Procedures: 1. Disable the averaging function on the data logger through the computer %TrninaL 2. Turn the calibrate mode switch to position 4. This will allow the gas analyzer to purge with room air. Turn off the power to the instrument air compressor. This will discontinue sample flow from the stack. 4. After 3 to 5 minutes, tum the calibrate mode switches back to the Sample position. 5. Tum the power switches on the gas analyzers to OE 6. If electrical power is to be lost from a generator shutdown, pull the memory storage module out of it seated position. There is no need to pull it all the way out. 7. Tum off the strip chart recorder and mark the chart to indicate shutdown with the time and date. 8. Tum off all power switches on the Pace Stack Interface Panel. 3.2 DAILY QC PROCEDURES Daily QC procedures are conducted to evaluate the operation and accuracy of the stack interface, sample gas conditioner, gas analyzers, and DAS. The results of these daily checks MUST BE RECORDED ATTACHMENT D MATERIAL SPECIFICATION SHEETS Nova -Thane RB88X -6HD Canvex CB12WB AMOCO Style 4510 MSDS --GAC MSDS — Soda Ash Jn-C2 -01 MON 11:25 AM GEO /ENV FAX:907 562 703 WOVE OLYOLI FIN FAI I1; ,PAGE 4 RB88X-6HD DATA SHEET Heavyweight material for geornemb chemical resistance. , coated with high density polye! FABRIC SPECIFICATIONS ylene a WEAVE Nominal 16 by 16 ppi woven black HDPE scrim using 1600 denier Mpes, and using a spe;,iol weave pattern to enhance flatness and tear properties (63 x 63 tapes per 10 cm) . COATING 2i mil average, two sides HDPE (59 gim5, two sides) COLOUR • black coating standard, other colors, may be available after trials and testing WEIGHT 10 oz/yd'- (340 g/m2) +/- 5 % THICKNESS 20 mils (0.51 rant) ASTM D5199 PERFORMANCE GRAB TENS ILi: Warp 350 Ib 1556 N Weft 350 Ib 1556 N A.S.TM D5034 ASTM D4885 ASTM D2261 l WIDE TENSIL-E(1 inch/25.4 mm) 1 TONGUE TEAR Warp 216 Ib 961 N Warp 100 Ib 445 N Weft 222 Ib 98814 44$ N Weft 100 lb /s4ULL�EN 3URST . 650 psi 4485 kPa ASTM D3785 PUNCTURE RESISTANCE 182 Ib 811 N ASTM D4833 DIMENSIONAL STABILITY Warp -1.6% Weft -1.3% • ASTM DI204 PERMITTIVITY <2 a 10-6 s -1 ASTM D449 i VOL.&TILES 0.11% ASTM D120. ROLL, SPECIPICATIONS CORES .4 inch (101.6 mm) or 5 inch (127 mrn) C.D. WIDTH Up to 150 inebcs (-0., +0.5) as ordered, 381 m ( -0 , +12 mm) LENGTH Minimum 250 yds /roll (229 m); up to 1000 yds /roll (914 n1) -I ne above physical test results are representative data collected from developmental trials. Results for an individual roll (based on at least three specnnens) may vary from me average by +/- 1014. OS I(P,t388X -6HO) Rev' 21/03,99 intertape polymer group 0 e.-)a they Avenue, Truro, Nova Scotia, Canada B2N 506 Tel: (`C2) 895-1686 ,71,);: l9p2i X93 -4790 JUHO2-rJ1 MON 1126 AM GEO/ENV FAX:907 562 7O3 PAGE 5 . NOVA-THENE RB88X-6HD SEAMING DATA SHEET The data below represents ar,hievable factory seam strengths and is compiled from results frorn hot air, hot wedge and propane welded seams. Other techniques such as extrusion welding may be considered at users cUseretion. Seaming with natural gas is not recommended. SEAM STRENGTH - 320 lb (Grab Method) SEAM STRENGTH (2" Strip) SEAM STRENGTH (Dead Load) SEAM PEEL STRENGTH 380 lb/2" No seam failure after 24 hours at constant load of > 50% of seam grab strength, with no loss of ultimate break strength. ASTM D-751 (Modified as in NSF.54) ASTM D-751 NSF Std. 54 Appendix A. Pt 10. Modified gab method. 23". C, 73'' F 5 lb per inch ASTM D-751 Seam Strength Retention Under Environmental Conditions See Nova-Thene RB88X-6HD Environmental Resistance Data Sheet The values are typical data based on laboratory ,and facfary tests to provide user information. They are not limiting specifications of field performance tuarantces. DS 1 (RBSSX-611D Scaling) Rev Ncw 08/25/98 1 ( : Box 368, 5:.; *i -urn, :',/C.Pra 2'21%; r, fr, y.: 1902) , — JUN-2 r- 01 FRI 02.39 P G 0/ENV Product Name and Part # Canvex CB12WB Part # CB12WB Product Description: F :907 561 7003 -160 PAU Carivex-C812WB Is tightly woven from high density polyethylene to achieve exceptional tear resistance. It is then coated on both sides with a low density 'polyethylene. This construction allows the ribbons to shift and "bunch up" in response to any tearing force, therefore stopping the tear. Basic Use: imagwoomiasimmin Canvex CB12WEi performs exceptionally well in outdoor applications because of the carbon black content in both the ribbon reinforcement and the black outer coating. The white side is protected with ultra violet inhibitors. Canvex CB12W8 offers the versatility of either a white side to reduce condensation and heat build up or the black side for even longer life. Suggested Applications: • Pit Liners • Temporary Erosion Control • Remediation Covers 4-Railroad Car Covers o Under Slab Vapor Barriers • Remediation Liners • Long Term Storage ▪ Pitch Linings • Cargo Load Covers • Decorative Ponds Size Range: mirmiteasigsnamousua 600 square foot panels up to 70,000 square foot panel in a variety of widths and lengths. . Packaging: Canvex CB12WB is available in a wide range of sizes neatly accordion-folded and rolled on a heavy duty core. This allows for easier handling and time saving installation. RAVEN iNDLISTRI ES Flexible Rims Deportment CflNVEX DISTRIBUTED BY: CP- Se Jt:li altl lb:11 '3b/t6'21003 STYLE 4510 POLAR.EUPPL.Y CO INC - PAGE 01 Amoco Fabrics and Fibers Company • 260 The Bluffs Austell, GA 30168 PH: (770) 944.4569 FX: (770) 944-4584 Amoco Style 4510 is a polypropylene uonwpven needlepunched fabric. This engineered geotextile is stabilized to resist degradation due to ultraviolet exposure. It is resistant to commonly encountered soil chemicals, mildew and insects, and is non- biodegradable. Polypropylene is stable within a pH range of 2 to 13, making it one of the most stable polymers available for b otextiles today. We wish to advise that Amoco Style 4510 meets the following minimum average roll values: 1 Propeiry Test Method •. Minimum Avcrago Rotl Value (English) 10 ozyd2 Minimum Average Roll Value (Metric) 339 :lm Unit Weight ASTM -D -3261 ! Grab Tensile ASTM•D 4632 1 250 ib 1.11 kN Grab Elongation ASTM -T7 -4632 ! 50 % 50 % Mullen Burnt ASTM -D -3786 ! 550'psi 3790 kPe� Puncture ASTM- D-4833 ; 1651b 0.730 kN Trapezoidal Tear AS .4533 ! 100 lb 0.445 kN UV Resistance AST -4355 l 70 % at 500 hrs 70 % at 500 hrs AOS ASTM- D-4751 i 100 sieve .15 rnm Perrnittiviry ASTM- D.4491 !! 1.2 sec'L 1.2 sec'' Flow Rale ASTM- D.4491 ` 85 gaUruin/tt2 3460 Umirtltnt Coefficient of Pern>.eablllty ASTM- D-4491 ! 0.20 cm/sec 0.20 cnvscc Thickness . ASTM -D -5199: 85 mils 2.15 mxn Amoco Fabrics and Fibers Company manufacturers the nonwoven fabric indicated above. The values listed are a result of testing conducted in on -site laboratories. A letter certifying the minimum average roll values gill be issued from the manufacturing plant by the Quality Control Manager at the time shipment is made. DATE ISSUED: 01 /07 /00 The hsfoonation presented herein, whip OOI Qnu•.,r:Irnd, Is CO the best of out knowledge tress and accurate. Exeept when agreed to in writing for specific conditions of use, no warranty ar guarantee expr±:ssed or Implied it made regarding the per .xmauce of-any product, since the manner of use and handling are beyond our coorroL 14othiog contained bcretn is to be construed as pxmission or as a recommendation to infringe any patent. Part of the BP Amoco Group Th 1 230 E. Potter Dr.,#10 * Anchorage, AR 99518 9117-561-2735 * 800-478-2735* Fax 907-563-5678 . . MATERIAL SAFETY DATA SHEET DATE OF ISSUE. Jan 2, 2000 SECTION 1 - IDENTIFICATION R rR NAME: Cameron Environmental, inc 310-212-0610 2074 I Manhattan Place, Tormce,CA 950 1 SYNONYMS: Activated C'arbon, Activated Charcoal, GAC, FRADL NAMES: CAS-R, CAS-COL, CAS-VAW, CAS-VCN (Clean :kir Store- .CarbuM LI IEMICAL FAMILY: Amorphous Carbon: CAS NO. 7440-440 FORMULA.: Carbon now in a crystallite structure has an infinite molecular weight. Anthracite Coal.. Bitumint.ius.Cual. Coconut Shell, Peat. Wood. - Steam Activated CLEANAIRE ALASKA LTD. ' Activated Carbon SECTION II - HAZARDOUS INGREDIENrfS CHEMICAL NAMES: (Inusedients) [% TLV (Units)j: No Hazardous Ingredients HAZARDOUS MIXTURES OF OTHER LIQUIDS, SOLIDS OR GASSES rio TLV (Units)j: LIQUDS- Activated Carbons that have adsorbed volatile organics or non-carbon liquids or gasses may lo\■er 01 raise the ignition point and must be laboratory checked for ignition point when expended. SECTION 111 - PHYSICAL -DATA 130ILING POINT '4200 deg F \ •POR PRESSURE (min llg. At 20 C) N/A VAPOR DENSITY (AIR- I) N/A it.;NITIUN TEMPERATURE: 600 deg C' SPECIFIC.GRAVITY (1-120-1) 1.8 - 2.1 PERCENT VOLATILE BY VOLUME N.:\ EVAPORATION RATE: (Ethyl Ether) N.:\ APPEARANCE: Black granular. free 11 -0 \Still! Jr 000R: Negligible odor ODOR THRESHOLD,(ppm) N-A SECTION iv - FIRE HAZARD & EXPLOSIVE DATA N/A AUTOIGNATION TEMPER:VIVRE.: A FLAMMABLE LIMITS IN AIR: I..k.iwer Explosive Limit: N/A Upper Explosh e Limit: NIA Th-XTINOUSHING MEDIA: Use media for Class A fires. Foam, multipurpose dry chcmical and water tvp extinguishers. - SPI.7.:C1,AL FIRE FIGHTING INSTR.UCTIONS: Since wet activated carbon adsorbs oxygen. du not enter closed vessels without self-contained breathing apparat-us. L'NUSC:AL FIRE & EXPLOSION HAZARDS: Provide for the handling of dry flowing solids in 1.rounded equipment to prevent build-up of static electric charge, especially when explosive dust or \ apor mixtures may exist in confined areas. Also provide for pressure relief devices IAW NI-'PA Explosion Preventing Guide NEPS68-1854.. SECTION N? - HEALTH WIZARD. DATA -111<FSHOLD VALUE' Avoid exposure to dust levels above 15111 per cubic meter • ROI..11:S .01: EXPOSURE: &_ EFFECTS; Continued exposure of inueous membranes to dust ina■ cause temporary drying of exposed areas and 'minor nose and throat irritatiOn. Avid ehrOme inhalation o du,t FIRST .AID PRUCEDUR.ES: Wash mouth with water. No other treatment required SECTION VI REACTIVITY DATA STABILITY: UNSTABLE----) STABLE-- X CONDITIONS TO AVOID: Activated Carbon is chemically inert. INCOMPATABILITY: (Materials to avoid): None HAZARDOUS DECOMPOSITION PRODUCTS: None POLYMERIZATION: None SECTION VII PROTECTION INFORMATION RESPIRATORY PROTECTION: Respiratory classification table 0-2 part 1910.93 (OSHA) Rules & Regulations. VENTILATION: Adequate dust collection or exhaust system should be used to avoid formation of dust aerosol PERSONAL PROTECTIVE EQUIPMENT: (Eye): Safety Goggles for airborne dust (Gloves): None required (Respirator): Dust Mask must be worn. (Other): None needed. SECTION Vill - DISPOSAL PROCEDURES SPILL, LEAK OR RELEASE: Spilled powder may be collected by shoveling or sweeping. Respirator and eye protection must be worn. Care should be taken to prevent high dust concentrations in the air. WASTE DISPOSAL,: Recycle & Reactivate - • Product is suitable for incineration. - Solid waste disposal. SECTION IX - SPECIAL PRECAUTIONS STORAGE & HANDLING CONDMONS: Packaged carbon is not resistant to weather or outside storage. Store indoors in type 1 & type 11 storage facilities. Precautions for finely divided flammable dust should be followed when handling large quanity of dry material. Use adequate dust collection equipment'. Insure all equipment is properly grounded to prevent static discharge. Keep dust away from flame, heat or spark. Store away from volatile organic solvents and moisture (to preserve Media) OTHER PRECAUTIONS... Check oxygen content of atmosphere of any vessel containing activated carbon before allowing entry of personnel. • SECTION X - PRECAUTIONARY LABEL (IF APPLICABLE) DOT CLASSIFICATION: NMFC 40560 / DOT MARKING: N/A / DOT PLACARD: N/A The information contained herein is based on data considered accurate in light of current formulation. However, no warranty is expressed or implied regarding the accuracy of this data or the results to be obtained from the use thereof. CLEANAIRE ALASKA Ltd.- 230' East Potter Dr. #10. Anchorage, AK 99518 PHONE: 907-561-2735 800-478-2735 FAX: 907-563-5678 CAMERON ENVIRONMENTAL, Inc. 20711 Manhattan Place Torrance, CA 90501 PHONE: 310-212-0610 FAX: 310-212-7222 GARNESS INDUSTRIAL INC. 6317 Nielson Way Anchorage, Alaska 99518 Tel: (907)562 -2933 Fax: (907)563 -4579 MATERIAL SAFETY DATA SHEET PRODUCT IDENTIFICATION PRODUCT NAME: SODIUM CARBONATE ORMULA Na2CO3 DESCRIPTION: . WHITE POWDER NORMAL HANDLING PROCEDURES CAS NO. 497 -19 -8 _PRECAUTIONS TO BE TAKEN IN HANDLING & STORAGE: DO NOT GET IN EYES, ON SKIN, OR ON CLOTHING. DO NOT TAKE INTERNALLY. AVOID BREATHING DUST. STORE IN A COOL, DRY PLACE. PROTECTIVE EQUIPMENT VENTILATION REQUIREMENTS EYES: GOGGLES LOCAL EXHAUST VENTILATION REQUIRES GLOVES: BUTYL RUBBER WHERE EXPOSURES TO DUST MIGHT OCCUR. OTHER: COVERALLS & BOOTS NONE: HAZARDOUS INGREDIENTS FIRE & EXPLOSION HAZARD DATA ",FLASH POINT: N/A OSHA CLASSIFICATION: NON- COMBUSTIBLE SOLID. EXTINGUISHING MEDIA: N/A SPECIAL FIRE HAZARD & FIRE FIGHTING PROCEDURES: USE NIOSH/MSHA APPROVED SELF- -; CONTAINED BREATHING APPARATUS WHERE THIS MATERIAL IS INVOLVED IN A FIRE. HEALTH HAZARD DATA THRESHOLD LIMIT VALUE: ' NOT ESTABLISHED. SYMPTOMS OF OVER EXPOSURE: SKIN, EYE & MUCOUS MEMBRANE IRRITATION. { ' SKIN: WASH WITH WATER FOR 15 MINUTES, CALL A PHYSICIAN. EYES: WASH WITH WATER FOR 15 MINUTES, CALL A PHYSICIAN. INGESTION: WASH MOUTH OUT THOROUGHLY, GIVE LARGE AMOUNTS OF WATER TO DRINK. INHALATION: REMOVE VICTIM TO FRESH AIR. TOXICOLOGY DATA ACUTE ORAL LD 50 > 4g/kg (RATS) CARCINOGENIC NOT KNOWN TO BE CARCINOGENIC ACUTE DERMAL LD 50 UNKNOWN MUTAGENIC NOT KNOWN TO BE MUTAGENIC. ACUTE INHALATION LD 50 UNKNOWN EYE IRRITATION IRRITANT. PRIMARY SKIN IRRITATION IRRITANT. PRINCIPAL ROUTES OF ABSORPTION: ORAL. _ -EFFECTS OF ACUTE EXPOSURE:IRRITATION OF EYES, SKIN, & MUCOUS MEMBRANES. - •EFFECTS OF CHRONIC EXPOSURE: NONE EXPECTED AT INDUSTRIAL USE LEVELS. SPILL OR LEAKAGE PROCEDURES (CONTROL PROCEDURES) ' STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED: WEAR NIOSH/MSHA APPROVED DUST RESPIRATOR. FOLLOW OSHA REGULATIONS FOR RESPIRATOR USE. (SEE 29CFR 1910.134). WEAR GOGGLES, BUTYL RUBBER GLOVES & BOOTS. SHOVEL, OR SWEEP UP & PLACE IN AN APPROVED D.O.T. CONTAINER & SEAL. WASH ALL CONTAMINATED CLOTHING BEFORE REUSE. ' WASTE DISPOSAL METHOD: DISPOSE OF CLEAN-UP DEBRIS, CONTAMINATED MATERIAL & RESIDUES, IN A MANNER APPROVED FOR THIS MATERIAL. CONSULT APPROPRIATE FEDERAL, STATE & LOCAL REGULATORY AGENCIES TO ASCERTAIN PROPER DISPOSAL PROCEDURES. IN THE EVENT OF A MASSIVE SPILL, USE THIS EMERGENCY PHONE NUMBER (203)356-2345 REACTIVITY DATA STABILITY: STABLE CONDITIONS OT AVOID: NiA 1NCOMPATIBILITY(MATERIA TO AVOID): N/A HAZARDOUS DECOMPOSITION PRODUCTS: NIA PHYSICAL DATA -- MELTING POINT: 851 C VAPOR PRESSURE: N/A VOLATILES: N/A BOILING POINT: DECOMPOSES SOLUBLE IN WATER. -EVAPORATION RATE: NIA SPECIFIC GRAVITY (H20=1): 25 pH 1% SOLUTION = 11.5 VAPOR DENSITY (AIR=1): NA I I ALL INFORMATION, RECOMMENDATIONS & SUGGESTIONS APPEARING HEREIN CONCERNING THIS PRODUCT IS BASED UPON TEST & DATA BELIEVED TO BE RELIABLE; HOWEVER, IT IS THE USER'S RESPONSIBILITY TO DETERMINE THE SAFETY, TOXICITY & SUITABILITY FOR HIS OWN USE OF THE PRODUCTS DESCRIBED HEREIN, SINCE THE ACTUAL USE BY OTHERS IS BEYOND OUR CONTROL, NO GUARANTEE, EXPRESSED OR IMPLIED, IS MADE BY GARNESS INDUSTRIAL INC. AS TO THE EFFECTS OF SUCH USE, THE RESULTS TO BE OBTAINED OR THE SAFETY & TOXICITY OF THE PRODUCTS NOR DOES GARNESS INDUSTRIAL INC. ASSUME ANY LIABILITY ARISING OUT OF USE BY OTHERS. OF THE PRODUCTS CONTAINED HEREIN. THE INFORMATION HEREIN IS NOT TO BE CONSTRUED AS ABSOLUTELY COMPLETE SINCE ADDITIONAL INFORMATION MAY BE NECESSARY OR-DESIRABLE WHEN PARTICULAR OF EXCEPTIONAL CONDITIONS OR CIRCUMSTANCES EXIST OR BECAUSE OF APPLICABLE LAWS OR GOVERNMENT REGULATIONS. NOTHING HEREIN CONTAINED IS TO BE CONSTRUED AS A - RECOMMENDATION TO INFRINGE ANY PATENT • ATTACHMENT E FORMS SPI Soil Tracking Record Treated Soil Release Record BEI Indemnification Clause a, Client Name: Address: Phone Contact SOL r- ROCESS14a INCORPORATED PORTABLE li fEvMAI. uins • OILFIELD SERVICES • ENV1RONMiENTM. =AMP TRACKING RECORD JOB # 99 ADEC SPILL Number Date Reported Physical Location Hauling Contractor i7_afe of ADEC approved -10 +rc.nSPort con+arr;►na }ed 561 Date Hauled Start Finish Soil Description (Gravel,Sand, Peat) Cell # Date Treated Start Finish Tons Treated Stockpile Location Date Tested By Chain of Custody # Test,Results Date Received Date Re.rnoved 207 E. Northern Light Blvd., Suite 103A • Anchorage, AK 99503 - Telephone (907) 274 -3000 FAX (907) 274-9295 RELEASE RECORD — Soli Processing Inc. - PROJECT DATE WORK ITEM I ; .1 SPI J013 # 99- i SOURCE DESTINATION CONTRACTOR TRUCK.' TRUCK TRUCK MFGR: MFGR: MFGR: DRIVER- DRIVER- DRIVER: LOAD DUMP LOAD DUMP LOAD DUMP TOTAL TOTAL TOTAL I certify that all materials hauled from the source were delivered to the destination recorded above. DRIVER NAME (PRINT) SIGNATURE DRIVER NAME (PR SIGNATURE DRIVER NAME (PRINT) SIGNATURE I certify all the loads recorded were delivered by these trucks to the above destination. ADL NUMBER ADL NUMBER ADL NUMBER INSPECTOR NAME (PRINT) SIGNATURE ORGANIZATION rn• BRECHAN ENTERPRISES, INC BRECHAN ENTERPRISES, INC GENERAL CONTRACTORS 2705 MILL BAY ROAD • •KCIDIAK, ALASKA 99615 THERMAL SOIL REMEDIATION OF PETROLEUM CONTAMINATED SOILS AT BRECHAN ENTERPRISES, INC. INDUSTRIAL SITE BELLS FLAT, KODIAK, ALASKA INDEMNIFICATION CLAUSE The undersigned VENDOR/CONTRACTOR agrees to hold harmless Brechan Enterprises, Inc., its shareholders, officers, agents and employees from, and to defend them against any and all claims arising from the purchase, construction, installation and/or use of the equipment,, articles and /or materials or services which are furnished, used or provided by the VENDOR/CONTRACTOR under this order. VENDOR/CONTRACTOR assumes all risk of damages, injury or death to VENDOR/CONTRACTORS own employees, property or persons acting for or on behalf of the VENDOR/CONTRACTORS for whatever cause. Nothing herein shall be construed to relieve Brechan Enterprises, Inc. from liability arising solely as a result of its own gross negligence. -VENDOR/CONTRACTOR NAME (PRINTED) SIGNATURE DATE VENDOR/CONTRACTOR DEC Permit Number PHONE: 907.486.3215 • FAX: 907.486.4889 ALASKA BUSINESS #00 11358 • ALASKA CONTRACTORS #AA441 We Are An Equal Opportunity Employer. ATTACHMENT F Asphalt Pavement Mix Design Th I * UO,U4,4UU4 rtu t-itsti.icsov• ALASKA T E S T L A la A Division of DOWL LLC W.O. A29667 Date April 24,2002 Brechan Enterprises 2705 Mill Bay Road Kodiak, Alaska 99615 BREAMAN ENTEXPRISES INC 10.005 Attention: Jim Graham/Bob Hale Subject: Asphalt Pavement Mix Design, ADOT&PF Type II B Dear: Mr. Graham: Asphalt aggregate was received in our laboratory on April 22, 2002. A Marshall method mix design was perform.ed in accordance with the ADOT&PF ATM T-17. Aggregate quality results are listed on the attached mix design sheet. The test standards followed during the laboratory test program are listed below. AASHTO T84, "Specific Gravity and Absorption of Pine Aggregate" AASHTO T85, "Specific Gravity and Absorption of Coarse Aggregate" AASHTO T166, "Bulk Specific Gravity of Compacted Bituminous Mixtures Using Saturated Surface Dry Specimens" AASHTO T 209,, "Maximum Specific Gravity of Bituminous Paving Mixtures' ATM T-7, "Sieve Analysis of Fine and Coarse Soils and Aggregates" ATM T-13 • "Aggregate Degradation" ATM T-9 "Flat — Elongated Picscs" AASHTO T104 "Soundness of Aggregates by Usc of Sodium Sulfate" AASHTO T 96 •"Resistance to Abrasion of Small Size Coarse Aggregate be Use of the Los Angeles Machine" ATM T-9 "Flat or Elongated Particles in Coarse Aggregate" ASTM D4867 "Effect of Moisture on Asphalt Concrete Paving IN/fixture" WAQTC TM 1 "Determining the Percentage of Fracture in Coarse Aggregate" l‘fix Design Technique ATI, helped you develop a jub mix formula (JMF) to conform to the ADOT&PF Type 11 B specifications. A three pile mix was crushed and separated by you and we sampled the each pile of aggregate and performed a gradation. Due to the short time frame to perform the asphalt mix design there was. only about 3 days of crushing data that we could base a JMF from. Based on the information to date the aggregate blend was 32 percent coarse, 20 percent intermediate aggregate. _ 48 percent fine aggregate. We 'separated the aggregates into each specification sieve size range. The separate sizes were recombined to make specimens with the IMF. Coarse and fine aggregate specific gravities were measured on specimens batched to match the JMF. Five different asphalt contents were tested for the mix design. For each asphalt content, fotu specimens were prepared for determination of density, flow, and stability. The theoretical maximum specific gravity was measured at an asphalt content of 5.8 percent. 4040 a STREET • ANCHORAGE • ALASKA • 9911103 • 907/S82-200a • FAX 907/563.3963 v ua;u4,4uu‘ .L;6O MA' W.)74dU40tiU BXECHAN EN'L'LRPRISES INC 2002Asphalt Mix Designs Date Page 2 j - Asphalt Cement The asphalt cements used for this mix design were PG 52-28 manufactured by Tesoro Alaska, North 1-1 Pole, AK. The manufacturer's submirtal for each asphalt product is attached. ADOT&PF Type II B Asphalt Concrete Mix Design ■ Li Density: The density versus asphalt content curve peaks al an asphalt content of 6.1 percent with a maximum density of 148.0. The optimum asphalt content of 5.8 percent yields a density of 147.9 pd.. Stability: The stability verb-us asphalt content curve. peaks at an asphalt content of 5.0 percent with maximum stability of 22221b. The stability at the design asphalt content is 2000 lb. Mix Design: A copy of the.Type II B asphalt concrete mix design is attached. Asphalt contra; a; four percent air voids in the total mix was 6.2 percent. The asphalt content at maximum density and maximum stability was 5.0 percent and 6.1 percent respectively. The optimum asphalt content was selected to be 5.8 percent. The properties of the mix at 5.8 percent asphalt are all within the project specification ranges. Aggregate Gradation: The aggregate gradation selected for the job mix formula is shown on the attached gradation curve. Specific Gravity: The aggregate and mix specific gravities are tabulated below. The coarse aggregate is defined as the fraction retained on the No. 4 sieve. Anti-Strip Requirements: A 0.25 anti-strip was placed in the binder. Flow: The flow tends to remain constant or slightly decrease with increasing asphalt content. The flow is 15 at the design asphalt content of 5.8. Coarse Aggregate Fine Aggregate BMA Mixture Bulk Specific Gravity 2.670 2.651 Apparent Specific Gravity 2.726 2.739 Absorption 0.9 1.2 Effective Specific Gravity 2.730 Anti-Strip Requirements: A 0.25 anti-strip was placed in the binder. Flow: The flow tends to remain constant or slightly decrease with increasing asphalt content. The flow is 15 at the design asphalt content of 5.8. CV t“.•• 1140U400d 2002Asphalt Mix Designs Date Page 3 ISAI:AMAIN WiThltrliI5ES INC COU7 Air Voids Total Mix: The asphalt content at 4 perccnt air voids is 6.3. The optimum asphalt content was chosen to be at 5.8 percent to yield 4.6 percent air voids. Voids Filled with Asphalt: Seventy one percent of the voids were filled with asphalt at the design asphalt content. VMA: The voids in the mineral aggregate (VMA) are 16.0 percent at the design asphalt content. The minimum VMA required by the specifications is 13 percent. Verification of the Laboratory Mix: The laboratory mix design should be verified by hot mix asphalt actually produced from your plant. In some cases the voids and density of plant mix asphalt pavement are slightly different than the laboratory mixed material. If the plant mix is significantly different than the lab batched mix, it may be warranted to adjust the design asphalt content to bring the properties of the Mix more in line with the project specifications. please call me. Sincerel ifALA lEST Da L. Andersen, .13. General Manager . attachments -Asphalt Mix Design Aggregate Gradation Curve Asphalt Cement Data to, KW Si 0.4 41...1 "td 1.44Ne 1.1%,41.1/2 111.4 urta, o VitA dU t 400400:1 ALASKA T E B T L A El A Division of COWL LLC - Llient: Brechan Enterprises ' 8pecification: ADOT&PF Type 11 B Product Use: Asphalt Cement Pavement Project: OhLGHAN ENTEEPRISES 1 NC iOU3 Sieve Size - JMF* a . • Narrow Band Broad Band 3/4 100 9 max 9 max 100 100 1/2 87 Double Face Fracture (%) 81-93 75-90 3;8 - 76 Degradation (9/0) 70-82 60-84 ' Nu. 4 56 1.02 50-62 33-70 No. 8 38 . 32-44 19-56 No 16 - 26 1 21-31 1044 No. 30 18 ' 14-22 7-34 No. 50 12 8 :i- 8-16 5-11 - 5-24 4-16 No. 100 IN . 200 5.8 .8-7.8 3-7 Asphalt Cuntera (by weight o f Mix) 5.8 ! 5.4-6.2 Aggregate Suitability ! a . Specification Soundness Loss (%) Coarse Aggregate Fine Aggregate 1 i '0 3 ' 9 max 9 max Single Face Fracture (°/o) i 7.—• 98 ' 80 min. Double Face Fracture (%) Abrasion resistance Loss ( %) 65-78 19 - 45 max. Degradation (9/0) 1 18 25 min. Thin— Elongated ec s . 1.02 1.6 8% max. Ar,gregate Blend 32% Coarse, 20% Intermediate, 48vo Fine Javi L. dersen, P. Gcneral Manager AASIITO ACCREDITED CONSTRUCTION MATERIALS TESTIIN G LABORATORY Marshall Method Mix Design ADOT&PF ATM T-I 7 April 24, 2002 Properties at Optimum* Value Specification Stability (lb) 2000 1200 Flow 15 8-16 Air Voids (%) 4,6 3 to 5 Voids Filled (%) 71.1 65-78 VMA (%) , 16.0 12 Unit Weight (pcf) 147.9 Dust / Asphalt Ratio 1.02 Marshall Compaction (Blows per Face) 50 Specific Gravity Aggregate Apparent Specific Gravity .. 2.733 Aggregate Bulk Specific Gravity 2.659 Aggregate Effective Specific Gravity 2.7-2. Maximum Specific Gravity of Mixture (ASTM D2041) ® 5.8% AC . 2.487 Asphalt Specific Gravity g 1.0159 Asphalt Properties PG 52-28 Asphalt .Binder (Tesoro Alaska) 'Laboratory Mixing Temp. 283 Laboratory Compaction Temp. 262 Antistrip (ASTM D4867/D4867M), _Ityuirement 0.25 — e Side of this Foi-m. 4O4C E STREMT • ANCHORAGE • ALASKA • 99503 • AX 907/563-3953 ■1/4N.N.7%:%. . u . UL....Uu.: la:Jti raa .JU746U466S t3RECHAN ENTERPRISES INC Good • 13rechan Enterprises ADQT1F Type 1113 149.0 148.5 148.0 147.5 ? 147.0 t. 146.5 146.0 145.5 145.0 `,- 144.5 144.0 4.0 5.0 6 0 7.0 2300 2200 2100 2000 I. 1900 1800 1700 4.0 5.0 6.0 7.0 17.0 16.0 15.0 14.0 ' I w 13.0 12.0 11.0 10.0 Laboratory Mix Design Data prepared by ALASKA TESTLAB April 24; 2002 Air Voids ( %o) 10.0 9.0 8.0 7.0 6.0 5.0 4.0 3.0 2.0 1.0 4.0 5.0 6.0 7.0 80. 70 60 . 50 40 4.0 5.0 6.0 7.0 J. 17 16 15 4.0 5.0 6.0 7.0 i 4.0 5.0 6.0 7.0 Aaphnit Content by Weight of Mix ( %) j Asphalt Content by Weight of Mix ( %)