Approved
Enbridge Line 6B MP 608
Marshall, Ml Pipeline Release
Waste Treatment, Transportation and Disposal Plan
Prepared for United States Environmental Protection Agency
Enbridge Energy, Limited Partnership
Submitted: August 2, 2010
Revised: August 8, 2010
Supplemental Revision: August 9, 2010
Supplement October 28, 2010
Revised: March 4, 2011
Response: March 23, 2011
Response: May 2, 2011
Response: May 13, 2011
Conditional Approval: May 17, 2011
Response: May 20, 2011
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Table of Contents
1.0 Plan Objectives 1
1.1 Work Plans 1
2.0 Waste Identification 3
3.0 Waste Characterization 4
3.1 TCLP and O&G Analyses 4
3.2 Soil and Sediment 5
3.3 Liquid Waste Water 6
3.4 Oil Impacted Media and Debris 7
3.4.1 Roll-off Sampling Procedures 8
3.4.2 Control Point Sampling Procedures 8
3.4.3 Timber Mat Sampling Procedures 10
3.5 Municipal Solid Waste 11
3.6 De Minimis Hazardous Waste 11
4.0 Waste Transportation 12
4.1 Soils and Sediment Waste 13
4.1.1 Best Management Practices 13
4.1.2 Soil and Sediment Stabilization 14
4.2 Liquid Waste Water 15
4.3 Oil Impacted Media and Debris 16
4.4 Municipal Solid Waste 17
4.5 De Minimis Hazardous Waste 18
5.0 Waste Disposal 19
6.0 Documentation Reporting 21
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6.1 Daily Waste Load Summary Report 21
6.2 Manifest Daily Report 21
6.3 Oil Recovery Estimation Report 21
6.4 Monthly Waste Report Submitted to USEPA titled Waste Disposal - Process &
Activity Summary 21
6.4.1 Introduction 21
6.4.2 Waste Generation and Shipment Information 21
6.4.3 Oily Debris 22
6.4.4 Non-Impacted Debris 22
6.4.5 Soil 22
6.4.6 Miscellaneous Small Quantity Waste Streams 22
6.4.7 Non-Hazardous Precipitation 23
6.4.8 Recovered Oil Calculations 23
7.0 Notifications 25
TABLE
Table 1 Soil Solidification Agents
ATTACHMENTS
Attachment A Soil Staging Flowchart
Attachment B Oily Debris Flowchart
Attachment C Oily Waste Water Flowchart
Attachment D Free Liquids Paint Filter Test Log Sheet
Attachment E Daily Waste Load Summary
Attachment F Manifest Daily Report
Attachment G Oil Recovery Estimation Report
Attachment H Transfer of Operations from Site A to Frac Tank City Plan
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LIST OF ACRONYMS
BMPs
Best Management Practices
CERCLA
Comprehensive Environmental Response, Compensation, and Liability
Act
CP
Control Point
Dolo
Dolomitic Limestone (synonym Dolomite)
DKD
Dolomitic Limestone and Dolime
DRO
Diesel Range Organics
Enbridge
Enbridge Energy, Limited Partnership
FTC
FracTank City
GRO
Gasoline Range Organics
HiCal
High Calcium
ICP
Incident Command Post
ID
Identification
IL
Illinois
IN
Indiana
Inc.
Incorporated
KY
Kentucky
Lime
Calcium hydroxide
Line 6B
The pipeline owned by Enbridge Energy, Limited Partnership that runs
just south of Marshall, Michigan
MDEQ
Michigan Department Environmental Quality
Ml
Michigan
MSDS
Material Safety Data Sheet
MSW
Municipal Solid Waste
O&G
Oil and Grease Analysis
OH
Ohio
ORO
Oil Range Organics
PCBs
Polychlorinated Biphenyls
PFT
Paint Filter Test
POTW
Publically Owned Treatment Works
PPE
Personal Protective Equipment
RCRA
Resource Conservation and Recovery Act
SVOCs
Semivolatile Organic Compounds
SWAT
SWAT Consulting Inc.
T&D
Transportation and Disposal
TCLP
Toxicity Characteristic Leaching Procedure designed to determine the
mobility of both organic and inorganic analytes present in liquid, solid,
and multiphasic wastes
TSD facility
Treatment, Storage, or Disposal facility
USEPA
United States Environmental Protection Agency
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LIST OF ACRONYMS (CONTINUED)
USEPA Order
USEPA Removal Administrative Order Under Section 311 (c) of the
Clean Water Act, issued on July 27, 2010 to Enbridge Energy
Partners, L.P., Docket Number: CWA 1321-5-10-001
VOCs
Volatile Organic Compounds
WMP
Water Management Plan
WTTD
Waste Treatment, Transportation and Disposal
yd 3
Cubic Yards
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1.0 Plan Objectives
This document presents an updated Work Plan entitled Waste Treatment, Transportation
and Disposal (WTTD) plan to address waste generated in association with the Enbridge Line
6B MP 608, Marshall, Michigan pipeline release. This WTTD plan describes the procedures
that are used to manage waste treatment, transportation and disposal (T&D) related to spill
response activities under United States Environmental Protection Agency (USEPA) Order ID
number MIK752366161. Waste streams generated include but are not limited to oily water,
debris (e.g., impacted sorbents, boom, pads, plastic, personal protective equipment (PPE),
vegetation), river sediment, soil, timber debris, household trash, and miscellaneous other
small volume materials.
1.1 Work Plans
The original WTTD Plan was established to comply with Federal, State, and County waste
regulation, and to prevent or minimize human health and environmental risks associated
with managing petroleum contaminated media. The original WTTD Plan was completed and
approved early in the spill response on August 2, 2010 and August 9, 2010 respectively.
Waste management and disposal procedures have been modified as needed or requested
during the cleanup, pending Federal, State, and County approval.
This revision incorporates and updates the following previously approved WTTD plan and
subsequent supplements that apply to waste treatment, transportation and disposal
activities:
• Waste Treatment, Transportation and Disposal Plan-August 2, 2010 (Revised
August 8, 2010 per U.S. EPA August 7, 2010 Notice of Approval with Modifications)
• Oil Recovery and Oily Debris Disposal refers to the document entitled Supplemental
Notification of Approval with Modification of Enbridge Energy, Limited Partnership's
Waste Treatment, Transportation and Disposal Plan - August 2, 2010 (Revised
August 9, 2010 per USEPA August 7, 2010 Notice of Approval with Modifications)
• Supplement to the Waste Treatment, Transportation and Disposal - October 28,
2010
This WTTD plan revision includes updates to reflect procedures to be used to manage the
waste volumes as the response effort moves toward response and/or remediation activities
at discreet locations along Talmadge Creek and the Kalamazoo River. This WTTD plan also
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includes procedures being utilized for managing the various types of waste streams being
generated.
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2.0 Waste Identification
The solid waste streams generated can be separated into two categories: oil impacted and
non-impacted wastes. The oil impacted solid wastes identified for proper management are
excavated soils, river sediment, decontamination area solids, frac tank sludge, impacted
timber mats and other miscellaneous debris (e.g., impacted sorbents, boom, pads, plastic,
PPE, vegetation). The non-impacted waste streams are considered municipal solid waste
(MSW) and are listed as non-impacted timber mats, and general refuse (garbage) from any of
the site locations. Site locations include the command center, the wildlife center, river access
areas, staging areas, and other locations used during site activities.
The disposal of soil and debris will be approved by both the USEPA and Michigan Department
of Environmental Quality (MDEQ) upon review of the analytical results. Where permitted,
direct disposal to the landfill will minimize the need for soil stockpiles within Site A or Frac
Tank City (FTC). Attachment H presents a Transfer Plan which outlines the transfer of soil
staging operations from Site A to FTC. Attachment A presents the Soil Staging Flowchart of
procedures for proper soil treatment, characterization, and disposal.
Oil impacted debris generated includes but is not limited to impacted timber mats, wood chips,
control point (CP) river debris and miscellaneous oily debris (e.g., impacted sorbents, boom,
pads, plastic, PPE, vegetation). Attachment B is the Oily Debris Flowchart.
MSW is non-impacted waste or non-oily debris generated that includes but is not limited to
timber mats, wood chips, general refuse, and miscellaneous other small volume materials.
Liquid waste streams generated include but are not limited to oily water, decontamination
water, precipitation water (in both soil staging cells and non-used decontamination sumps),
and well drilling water. Attachment C is the Oily Waste Water Flowchart.
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3.0 Waste Characterization
The WTTD plan details the general characterization requirements and sampling procedures
for each waste stream generated as a result of response and cleanup activities. All
impacted solid waste streams must be characterized for disposal as described in the
following subsections of Section 3.0. In addition, Oil and Grease (O&G) analysis is required
for oil recovery calculations. Required analyses are described in Section 3.1. Analyses for
Gasoline Range Organics (GRO), Diesel Range Organics (DRO), and Oil Range Organics
(ORO) are not Resource Conservation and Recovery Act (RCRA) characteristic parameters
and are not required by the waste disposal facilities currently approved to accept these
wastes; therefore, these analyses are not required to fulfill characterization requirements.
Additionally, analysis of polychlorinated biphenyls (PCBs), flash point, or pH of solids is not
required to fulfill these characterization requirements. PCBs are not contaminants of
concern in the spilled crude oil. Flashpoint and pH are not applicable to solid wastes
generated at this site (per Code of Federal Regulations Title 40, Part 261.21 and 261.22).
It is anticipated that the Toxicity Characteristic Leaching Procedure (TCLP) and O&G
analyses will be sufficient to fully characterize each waste stream. However, if the proposed
waste characterization is not enough to support compliance with RCRA and local disposal
requirements, additional characterization will be conducted in order to meet all regulatory
criteria. Additional characterization is also required for any waste stream that is likely to
have been impacted by constituents that are not captured by the methods described herein.
All characterization outside the scope of Sections 3.1, 3.2, 3.3 and 3.4 must be approved by
the USEPA prior to sample collection in order to fulfill waste characterization requirements.
Sampling and analysis will be performed in accordance with the approved Quality Assurance
Project Plan (Enbridge Line 6B MP 608 Marshall, Michigan, Quality Assurance Project Plan,
prepared August 2, 2010, Revised August 15, 2010).
3.1 TCLP and O&G Analyses
TCLP will be performed on waste materials and the leachate analyzed for heavy metals
(arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver), volatile organic
compounds (VOCs) and semi-volatile organic compounds (SVOCs). O&G analysis will be
conducted using a modified USEPA Method 1664A. This modified method substitute's
methylene chloride for hexane as a solvent to enhance crude oil recovery. A paint filter test
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(PFT) will be performed for soil and sediment waste to ensure that free liquids are not
present.
3.2 Soil and Sediment
The purpose for collecting soil and sediment samples is for waste characterization and/or
O&G analysis to meet USEPA's and MDEQ's disposal requirements and oil recovery
calculations. All soil and sediment generated as waste must be characterized for volatiles
per USEPA's Method 8260 list of agreed upon analytes. Soil and sediment waste is also
required to meet all characterization requirements for the local disposal facility receiving the
waste. The analysis of solid waste characterization samples must include the following:
¦ TCLP metals (USEPA Methods SW-846 1311 and 6020 + 7470)
¦ TCLP VOC (USEPA Methods SW-846 1311 and 8260)
¦ TCLP SVOC (USEPA Methods SW-846 1311 and 8270)
¦ Oil & Grease (USEPA Method SW-846 1664A modified)
¦ Paint Filter Liquids Test (USEPA Method SW-846 9095B)
Per Section 3.0, additional analyses may be necessary to fulfill characterization
requirements.
If soil staging within a cell is necessary, the sampling plan (Appendix A of the Supplement to
Waste Treatment, Transportation, and Disposal Plan, October 28, 2010 - Revised Safety-
Kleen Soil Pile Management Plan-Enbridge Energy, Marshall, Ml. Crude Oil release, Rev. 04)
identifies the sampling procedure for characterization of the soil pile within the staging cell.
Any soil consolidation and solidification shall be conducted in lined cells in Staging Area A or
FTC for stabilization as necessary. Testing for free liquids using PFT will be required as
described below.
All excavated materials will be visually inspected for free liquids. A PFT will be conducted in
the field at each excavation site for both excavated soil and stabilized soil at a minimum of
once per day. The person conducting the PFT will be competently trained to sample the soil
and conduct the PFT at the excavation site. USEPA Method 9095B, Paint Filter Liquids Test
will be modified to use a sample jar instead of a graduated cylinder and the sample will be
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tested at ambient temperature. A minimum of one representative sample will be collected
for PFT per excavation site on the basis of visual inspection by a designated individual.
Additional PFT samples will be collected as needed based on further visual inspection and in
coordination with USEPA or its representative. In the event free liquids are observed in an
excavation, excavated material will be placed in a rock box or lined cell for stabilization. A
rock box is a reinforced steel constructed box with gussets and a pull bar for use in
conjunction with an excavator for the handling of solid materials. A rock box will be utilized
to comingle excavated soils (with varying levels of saturation) with an approved stabilizing
agent using an excavator. Prior to transport, stabilized material must not contain free
liquids. USEPA and MDEQ approval is mandatory prior to the use of any stabilization
agents utilized to meet compliance requirements for soil and sediment transport or disposal.
Soil and sediment stabilization is discussed in further detail in Section 4.1.2.As described in
Appendix A of the Supplement to Waste Treatment, Transportation and Disposal Plan
(dated October 28, 2010), REVISED Safety-Kleen Soil Pile Management Plan-Enbridge
Energy, Marshall, Ml. Crude Oil release, Rev. 04, composite samples for waste
characterization will be collected.
Solid waste characterization samples will be submitted for a 72-hour lab result turn-around-
time.
3.3 Liquid Waste Water
Currently, all liquid waste streams are characterized as non-hazardous. New liquid waste
streams or existing waste streams that are suspected of exceeding RCRA non-hazardous
criteria are required to undergo characterization sampling. This characterization sampling
must include the following:
¦ Benzene (USEPA Method SW-846 8260)
¦ Oil & Grease (USEPA Methods SW-846 1664A modified)
¦ pH (USEPA SW-846 Method 9040)
Per Section 3.0, additional analysis may be necessary to fulfill characterization
requirements.
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The FTC frac tanks that contain accumulated water from the decon water collection system,
soil cell sumps, and river water (including river water decanted from control point [CP]
debris) will be sampled at a frequency of once every 100,000 gallons. The O&G analytical
results will be used to calculate recovered oil from the decontamination water.
Water from the storm water sump collection systems will be sampled at an interval of once
every 50,000 gallons for the Battle Creek Publicly Owned Treatment Works (POTW) or at a
frequency required by an alternate facility approved by USEPA and the MDEQ for benzene,
O&G and pH.
Any new liquid waste stream identified will be sampled using standard RCRA waste
characterization analyses, as listed above for liquid waste, and at a minimum frequency of
once per year to confirm the initial characterization. Additional samples will be collected for
O&G analysis for every 100,000 gallons as a sampling frequency to validate the oil recovery.
Hazardous waste water will be sent to the Dynecol facility or an alternate facility approved by
the USEPA and MDEQ.
If waste water is suspected to have high concentrations of petroleum contaminants, the
waste water will be isolated in a frac tank and analyzed for all RCRA waste characterization
methods (listed above) prior to shipment as either non-hazardous or hazardous waste.
All waste water streams will be re-characterized using standard RCRA waste
characterization analysis, as listed above for liquid waste, at a minimum frequency of once
per year to confirm initial characterization. Samples for O&G analysis will continue for every
100,000 gallons as a sampling frequency to validate the oil recovery
3.4 Oil Impacted Media and Debris
The recovered media, debris, CP river debris, liner, timber mats and miscellaneous
materials used and impacted by the oil spill will be disposed of in roll-off containers. The
debris material is either collected in clear plastic bags or, if too large, is placed loosely in
lined 20 yd3 roll-off containers. The roll-off containers are staged in designated areas until
they are fully loaded or the excavation site work is complete. Roll-off containers are then
transported to FTC and every tenth roll-off is held for sampling to conduct O&G analysis.
Waste characterization analyses will be conducted at a frequency of every 50 roll-off
containers. The analysis of solid waste characterization samples must include the following:
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¦ TCLP VOC (USEPA Methods SW-846 1311 and 8260)
¦ TCLP SVOC (USEPA Methods SW-846 1311 and 8270)
¦ Oil & Grease (USEPA Methods SW-846 1664A modified)
TCLP metals analysis is not required since the source material did not fail for TCLP metals
and the debris waste stream has not failed for TCLP metals for the duration of this project.
Per Section 3.0, additional analysis may be necessary to fulfill characterization
requirements.
3.4.1 Roll-off Sampling Procedures
The sampling of the debris contained in roll-off boxes will be in accordance with the USEPA
Guidance Document USEPA530-D-02-002, Waste Sampling Technical Guidance as
described below.
• Homogeneous waste: Collect six (6) sample aliquots from each roll-off container
and combine into one composite sample per roll-off. Depending on the matrix of
the waste (absorbent boom, plastic sheeting, PPE, etc.), the waste may require
cutting to obtain samples of sufficient size to fit into the sample container.
Representative sampling will be based upon the percentage of the type of waste
debris collected and will be representative of the oil impacts.
• Heterogeneous waste: Collect six (6) sample aliquots from each component
contained in the roll-off box. The quantity of each component sampled within the
sample container is based on the estimated quantity of that component in the
entire roll-off box (i.e., percentage of waste in the roll-off will correspond with
percentage of that waste placed in the sample container sent to the
laboratory)and will be representative of the oil impacts observed on each
material.
• To the maximum extent possible, the samples shall completely fill the laboratory
sample container with no or minimal head space.
3.4.2 Control Point Sampling Procedures
In addition to the oil-impacted debris contained in roll-offs discussed above, debris is also
collected daily at six CPs from the boom maintenance along Talmadge Creek and the
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Kalamazoo River by the SWAT Consulting Inc. Team (SWAT). SWAT collects debris
materials (contained within clear plastic bags) from each CP and transports them to FTC.
The procedures described below are detailed in the April 15, 2011 supplement to the Roll
Off-Debris TPH and QAQC Waste Characterization Sampling Plan, Rev-01 8/26/2010 EQ -
Debris Waste Sampling Plan.
The type of debris and approximate amount collected are:
• Vegetative or organic material is 90 to 95 percent.
• Windblown buoyant household garbage is 4 to 9 percent.
• River foam or oily mousse foam is 0 to 1 percent.
• Decanted water (varies)
Laboratory analysis will be performed on both the debris and the decanted water for O&G
analysis only. Sampling procedures for CP debris and waste water are as follows:
• The water from each debris bag is decanted into a bottle that has quarter gallon
demarcation, measured, and transferred into a bulk container such as a 55-gallon
drum or a poly tank on a daily basis. The bulk liquid storage containers are within
secondary containment and capped after being filled to prevent precipitation from
entering.
• After decanting the water, the debris bags are weighed to the nearest pound. The
accuracy of the scale is checked each day using a 10-pound and a 20-pound
weight.
• Each day, the first bag, and every tenth bag thereafter are set aside from each
CP. The bags are taped, location labeled, and staged in lined cubic yard (cubi)
sacks located on a secondary containment liner with berms. The cubi sacks are
covered with either its own cover or a liner to prevent precipitation from entering
the cubi sacks.
• The remaining bags are placed into a lined roll-off container dedicated to the
specific CP debris.
• Every Wednesday morning, the sampling team collects a composite sample by
taking one sample aliquot from each of the bags set aside within the cubi sacks.
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The sample represents debris collected from the control points on Wednesday
through Tuesday of the previous week. These debris bags are then added to the
roll-off for disposal.
• Sampling and handling is performed in a manner to prevent spillage outside the
containment. Plastic kiddy pools and sheets of poly are used to prevent
contamination of the gravel pad at the sampling area.
• Aliquots for the debris composite sample are placed into a clean poly bag and
homogenized. Two 32-ounce jars of the homogenized composite sample are
collected for O&G analysis.
• A water sample is collected from the bulk liquid storage container for O&G
analysis. If more than one bulk storage container of decanted water has
accumulated during the week, the sample will be collected from only one of the
bulk storage containers which represents greater than 10% of the total volume of
liquid collected.
• The debris roll-off will be disposed of in the same manner as the other oil-
impacted media and debris generated at this site.
• The decanted water is vacuumed out and consolidated into the bulk frac tank
containers for disposal with the decon water waste stream.
• O&G results for the composite debris samples and the decanted water samples
are used to calculate recovered oil.
3.4.3 Timber Mat Sampling Procedures
The oil impacted timber mats/debris waste stream management and sampling plan is as
follows:
• The impacted timber mats will be placed in a soil cell.
• The impacted timber mats will be dismantled/crushed within the active soil cell
creating a stockpile. The length will be reduced within the soil cell to fit within a roll-
off container.
• One composite sample will be collected per 200 yd3 of mats as determined prior to
crushing of the mats. The sample will be collected by selecting the smaller pieces of
wood chips generated during the crushing operations. Sample collection will include
a representative proportion of the inner clean and the outer impacted woody material.
The sample will be analyzed for O&G analysis only.
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• Impacted mats will be disposed of as "crude oil contaminated media and debris."
The O&G results will be used to calculate recovered oil for the impacted mats.
3.5 Municipal Solid Waste
The non-impacted waste material and debris is considered MSW and will not be sampled for
waste characterization or O&G analyses.
Non-impacted debris includes but is not limited to timber mats, silt fence, and garbage which
have not been impacted by oil based on known history and visual inspection.
3.6 De Minimis Hazardous Waste
De minimis hazardous waste such as spent bug repellent, spent degreasers, spent
mechanical or automotive products, spent batteries, etc. will be manually collected, staged
within the Incident Command Post's (ICP) designated location in sealed, leak proof containers
and disposed of properly in accordance with all applicable federal, state, and local regulations.
Enbridge is not a household hazardous waste generator and as such, regulations applicable to
household hazardous waste do not apply.
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4.0 Waste Transportation
The off-site T&D activities will be conducted in accordance with all applicable local, state, and
federal regulations. Copies of all disposal documentation (profiles, facility waste approvals,
Bills of Lading, manifests, weight tickets, etc.) will be provided to Enbridge. Enbridge will
subcontract to an experienced waste broker for all T&D activities and will provide a list of the
approved disposal facilities for each waste stream.
Bill of Lading waste papers are used for shipment of non-hazardous waste between the work
sites (excavation area and adjacent support areas) and the staging areas (Site A and FTC)
where material may be accumulated prior to disposal. The appropriate waste manifests are
utilized for transportation directly to the off-site disposal facilities. These waste manifests must
be signed by an authorized Enbridge representative.
The manifests have the following common names for shipments of their respective waste
types along with the current offsite disposal facility;
• The Non-Hazardous Special Waste Manifest is used for (1) the impacted soil from
the pipeline release and (2) crude oil contaminated media and debris that is
transported to Republic Services C & C Landfill in Marshall, Ml.
• Although all liquid waste streams are currently characterized as non-hazardous
wastes, the use of Hazardous Waste manifests is required for the shipment of liquid
industrial waste. If the source is decontamination water or decanted CP water, then
it is transported to Dynecol in Detroit, Ml. If the source is precipitation collected from
a storm water sump, it is transported to The City of Battle Creek Waste Water
Treatment Facility in Battle Creek, Ml.
Waste shipments are recorded on a tracking table that summarizes the volume of each
waste stream generated from spill response activities, the facility shipped to, and the
cumulative amount of waste generated to date.
A copy of the tracking log and all manifests for waste transportation and disposal are included
in the Monthly Progress Report submitted to the USEPA and to the MDEQ by the 27th of
each month for activities completed during the prior month. Copies of hazardous waste
manifests are sent to the MDEQ by the 10th day of each month for the previous month.
Returned manifest copies from the disposal facility are matched up with the original manifest
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copies within 45 days from the date of shipment. Original manifest copies are maintained by
the Enbridge documentation group and will be retained on file for a minimum of five years.
4.1 Soils and Sediment Waste
This procedure is used to manage the transportation of solid phase wastes such as excavated
soils, sediment, frac tank sludge, and similar materials. Direct disposal to the landfill will
minimize the need to stockpile soils within Site A or FTC (see Transfer Plan in Appendix H).
Adding approved soil stabilization agents at the excavation sites is proposed to ensure that the
soil being transported shall have no free liquids to comply with the Michigan Department of
Transportation (MDOT) free liquids regulation.
4.1.1 Best Management Practices
Best Management Practices (BMPs) will be implemented to contain the solid materials and
minimize any incidental release of materials during the handling processes from the
excavation site to the transportation to the landfill. These BMPs include:
• Contacting waste management personnel for roll-off delivery, pick up, sampling and
transportation for either direct load disposal or consolidation in Soil Staging Area A.
• Excavating soils and transporting directly from the excavation sites to minimize
stockpiling of materials near waterways.
• Implementing appropriate stockpile spill prevention procedures for temporary onsite
staging including lining, sloping, berming, and tarping to prevent runoff.
• Excavated soils will be loaded into transportation vehicles by qualified operators to
minimize the potential for truck overfills or incidental spillage. If overfill or overspill
occurs, the material will be immediately collected and properly disposed.
• The use of poly lined cubi sacks to transport excavated soils from inaccessible areas
to roll-off containers.
• Partial solidification of soil with backfill to minimize sloshing.
• Placement of a rock box within the temporary on-site staging area to facilitate
transfer of saturated soil and solidification with approved materials. The stabilization
material will be covered when not in use.
• Dry soils can be transferred directly to lined trucks or roll-offs without solidification.
• Soil may be transported to the temporary staging area for characterization and
disposal as appropriate.
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As the current plan for soil management at the source area relies partially on transportation of
solidified soils in lined roll-off containers from the source area to a temporary soil staging area,
quality control checks will be implemented to ensure that no free liquids are placed into trucks
or roll-off containers. Quality control will be performed using a PFT to ensure that no free
liquids are placed into trucks or roll-off containers at a minimum of one per day and visual
inspections thereafter by a competent person. A PFT log sheet will be maintained by
Enbridge's representative and the documentation recorded at the completion of the excavation
site work. The date, time, location, sampler, etc. will be included on the log sheet as shown in
Attachment D. The documentation will be provided to the USEPA and MDEQ upon request.
4.1.2 Soil and Sediment Stabilization
USEPA and MDEQ approval is mandatory prior to the use of any stabilization agents utilized
to meet compliance requirements for soil and sediment transport or disposal. Table 1
identifies the waste characterization requirements for use of soil stabilization agents. These
requirements include one of the following: a letter from vendor describing the source of
material, the manufacturer's Material Safety Data Sheet (MSDS), or a TCLP metals analysis
for approval from the USEPA and MDEQ before receiving the materials on-site. The type of
analyses used for characterization of the stabilization agents is dependent on the origin and
type of stabilization agent and will vary with each. The specific type of characterization
analyses to be performed will be approved by the USEPA and MDEQ prior to use.
For impacted soil removed from a source area, solidification of soils will be completed prior to
transport through the addition of a solidification enhancing material that is NOT considered a
dust concern. Currently, soils are being solidified with sawdust and sand. Any free fluids not
contained through the mixing and solidification process are being absorbed directly with
sawdust.
Soil stabilization agents for use at the soil staging area consist of dolomite (DKD/lime) or an
alternate DKD approved by USEPA and the MDEQ. Currently dolomite is being used at Site
A. Additional stabilization agents are listed in Table 1, although the preferred agents are
sawdust, InstaZorb (amorphous aluminum silicate), Sodium Polyacrylate, or a sand/clay/soil
backfill along stream banks at the excavation sites, although these agents are not limited to
these sites as they can also be utilized at the soil staging area. Soil stabilization agents
derived from coal-fired power plants will NOT be utilized.
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Any stabilizing agent's requiring dust suppression will only be used at approved centralized
locations. The current centralized location is Site A soil cells and a pending centralized
location is FTC soil cells. The pile will be covered when not in use.
If required as above the stabilizing agent's pile will be monitored daily for dust suppression
during storage and during the solidification process. Note that the dolomite agent is planned
for use only at the soil staging area and procedural issues such as wind speeds causing a
visible plume to migrate beyond the approved centralized soil solidification area will require
that soil solidification operations cease.
The mixing operator will wear half face respiratory protection with a P100 cartridge when
using soil stabilization agents identified in Table 1 which require respiratory protection.
Temporary safety fencing will be placed downwind to alert personnel from entering the area.
Personnel may enter the area without respiratory protection in a motor vehicle provided they
keep the windows of their vehicles closed. Onsite ambient particulate monitoring will be
conducted during soil stabilization mixing activities and during delivery of stabilization agent
which require respirator protection. An additional option is the use of cubi sacks or another
closed container to prevent the creation of dust during the solidification process.
The MSDS's health and safety issues for the stabilizing agents used will be reviewed with all
operating personnel prior to their use and any applicable regulations/exposure limits
communicated to the workers and nearby residents who may be affected by the use of
stabilization agents. This effort will be coordinated with Safety personnel from both Enbridge
and the USEPA. All PPE required during the use of solidification agents will be determined
prior to use of the agent and work sites will be monitored for the proper use of the required
PPE. The MSDS is available at the ICP and at each work site where the agents are used
and the location of such MSDS shall be made known to all persons who may contact the
agents.
4.2 Liquid Waste Water
The following procedures are used to manage the transportation of liquid industrial waste,
such as oily wastewater and decontamination water generated from the decontamination /
cleaning of equipment. The approved Water Management Plan (WMP) is a comprehensive
plan submitted to the regulatory agencies on January 18, 2011. The WMP includes the
water processes involved with storm water collection sites, soil staging areas, excavation
sites along the river and FTC's decontamination collection system. The National Pollutant
15
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Approved
Discharge Elimination System (NPDES) Permit MI0058861 does not allow any discharge to
groundwater or venting of contaminated groundwater to surface waters during response
and/or remediation efforts. The WMP has the protective methods for preventing any oily
releases from the site.
The waste water transportation procedure is to use vacuum or water hauling vehicles
(tankers) to collect material and to transfer material in and out of staging frac tanks at FTC or
various excavation sites. The attendant will visually observe the liquid transfer during both
the transfer in and out of frac tanks.
The staged frac tanks are visually inspected twice per shift during operation to identify
issues such as leaks. If a tank is found to be leaking, attempts will be made to tighten the
hatch. If tightening isn't applicable, the tank will be emptied using vacuum trucks and the
tank taken out of service. The leak must be reported to the area supervisor to record the
incident.
The treatment options available to reduce the amount of water in the recovered oil include:
• Placing the recovered oil /water mixture into frac tanks to allow for separation or use
a hot oiler system in conjunction with the frac tanks to heat the mixture and promote
further separation.
• As necessary and practical, use carbon treatment.
• Any residual waters from the excavation soils and soil stabilization process at
Staging Site A and FTC will be collected in frac tanks and properly transported to the
appropriate waste water treatment facility.
4.3 Oil Impacted Media and Debris
The recovered media, debris, liner, timber mats, vegetation and miscellaneous materials
used and impacted by the oil spill are disposed of in roll-off containers. The roll-off
containers are staged in designated areas until they are fully loaded or the site work is
complete. Designated areas include Site A, FTC, active cleanup sites, boat launches, and
staging areas. Roll-off containers ready for disposal are either transported directly to the
approved disposal facility as non-hazardous waste or transported to Site A or FTC and every
tenth roll-off is held for sampling. Transportation to staging areas will be completed using a
Bill of Lading. Transport directly to the disposal facility will be completed using a signed
16
-------
Approved
manifest. The procedure used to manage the roll-off container's transportation of oily debris,
and vegetation is as follows:
• Segregate oily debris from non-oily debris.
• Collect and store oily debris in lined, 20 yd3 roll-off boxes.
• Oily debris roll-off boxes can be transported and emptied into staging cells in Staging
Area A / FTC (upon approval) and kept in the roll-off for sampling.
• Transport as non-hazardous waste using a Non-Hazardous Waste Manifest.
4.4 Municipal Solid Waste
MSW (non-oily trash) generated at field locations is managed in lined 20 yd3 roll-off
containers. Trash does not need to be sampled and is not included in recovered oil
calculations. The non-hazardous designation for the trash is based on generator knowledge.
As has been the procedure on this project, the non-hazardous waste manifest with the
description "crude oil contaminated media and debris-MSW" will be used to indicate that
they are not impacted for the purpose of oil recovery.
Non-impacted mats will be dismantled/crushed outside of the soil cells and will be disposed
of as MSW. As has been the procedure on this project, the non-hazardous waste manifest
with the description "crude oil contaminated media and debris-MSW" will be used to indicate
that they are not impacted for the purpose of oil recovery.
The non-impacted office trash, and debris is shipped using bill of lading, and is not
tracked/accounted or reported in the daily waste summary. This waste stream does not use
a manifest.
Miscellaneous small waste streams may be generated. These wastes have primarily been
stored in drums and include, but are limited to, used oil, batteries, and lab samples. These
have been characterized individually, manually collected, staged within ICP's designated
location in sealed, leak proof containers, and are disposed of properly in accordance with all
applicable federal, state, and local regulations.
17
-------
Approved
4.5 De Minimis Hazardous Waste
De minimis hazardous waste such as spent bug repellent, spent degreasers, spent
mechanical or automotive products, spent batteries, etc. will be manually collected, staged
within ICP's designated location in sealed, leak proof containers and disposed of properly in
accordance with all applicable federal, state, and local regulations.
18
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Approved
5.0 Waste Disposal
Prior to disposal, waste will be sampled for disposal characterization analysis and profiled
for acceptance to the approved disposal/recycling facilities once analysis is complete. An
Enbridge designated representative will:
• complete the profile paperwork;
• submit to Enbridge for review and signature;
• submit the signed profile to the disposal facility;
• communicate with the facility during the approval process;
• receive approval and provide a copy to Enbridge Document Control;
• assist with the schedule for waste pick-up and disposal;
• review the required shipping paperwork and obtain signature of Enbridge's
authorized representative on shipping paper work;
• track delivery of waste to designated facility;
• receive certificate of disposal/recycling once waste has been treated/disposed
of/recycled and provide a copy to Enbridge;
• compile all documentation associated with disposal of each waste stream and submit
copies to Enbridge and to the MDEQ by the 10th of each month.
Returned manifest copies from the disposal facility are matched up with the original manifest
copies within 45 days from the date of shipment. Original manifest copies are maintained by
the Enbridge documentation group and will be retained on file for a minimum of five years.
19
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Approved
The waste disposal contractors currently used are detailed in the Waste Stream Disposal
Facilities Table below.
Waste Stream Disposal Facilities
Waste Stream
Shipped to:
Non-Hazardous Soil
Westside Recycling
Three Rivers, Ml
Non-Hazardous Soil
C&C Landfill
Marshall, Ml
Hazardous Soil
Envirosafe Services
Oregon, OH
Geotube Sediment
Westside Recycling
Three Rivers, Ml
Hazardous Water
Dynecol
Detroit, Ml
Non-Hazardous Water
Dynecol
Detroit, Ml
Non-Hazardous Water
(precipitation)
POTW
Battle Creek, Ml
Non-Hazardous Debris
C&C Landfill
Marshall, Ml
Wildlife Center Sharps
Stericycle
Clinton, IL
Lab PPE and sampling
equipment.
Safety Kleen
Smithfield, KY
Stockbridge, Ml Terminal
Hydrotest Water
Environmental Quality Co.
Detroit, Ml
Griffith, IN Terminal
Oil/Water Mixture
Clean Harbor's
Rock Island, IL
Notes:
Ml = Michigan OH = Ohio
KY = Kentucky POTW = Publicly Owned Treatment
IN = Indiana Works
IL = Illinois PPE = Personal Protective Equipment
20
-------
Approved
6.0 Documentation Reporting
6.1 Daily Waste Load Summary Report
An example of the Daily Waste Load Summary Report is provided in Attachment E.
6.2 Manifest Daily Report
An example of the Manifest Daily Report is provided in Attachment F.
6.3 Oil Recovery Estimation Report
An example of the Oil Recovery Estimation Report is provided in Attachment G.
6.4 Monthly Waste Report Submitted to USEPA titled Waste
Disposal - Process & Activity Summary
The following sections provide an example of a typical monthly waste report. The report is
modified slightly to exclude the analytical attachments and redundant tables which are
provided above.
6.4.1 Introduction
This section describes the procedures that were used to manage wastes generated from
spill response activities. Waste streams generated include but are not limited to
contaminated water, debris, soil, trash, and miscellaneous other small volume materials.
Laboratory analytical reports of samples that were taken and received in March 2011 are
provided in attachments (not included). Laboratory analytical reports received in March
2011 for samples taken prior to March 2011 are also provided in attachments (not included).
All laboratory analytical results received in April will be submitted with the April progress
report.
Hazardous and non-hazardous waste manifests received in March 2011 are also found in
attachments (not included).
6.4.2 Waste Generation and Shipment Information
A summary of waste shipments is reported daily and monthly. The shipments are split out
by waste type. The processes that generate each waste stream are discussed further in the
sections that follow. The Summary of Waste Shipment table (see Section 6.4.8) provides a
list of transporters and disposal facilities that were used for each waste.
21
-------
Approved
6.4.3 Oily Debris
Oily debris were segregated from non-oil debris and stored in lined, 20 cubic yard roll-off
boxes. Various methods have been used to manage oily debris roll-offs during the course of
the response. Previously, oily debris roll-offs were transported to Site A and dumped into soil
cells. The debris was either mixed with soil or managed as a separate waste stream and
loaded onto trucks from the soil cells.
Beginning on November 8, 2010, roll-offs were transported directly to C&C landfill in
Marshall for disposal. This change was intended to reduce the volume of material being
delivered to the soil cells and to expedite the decommissioning of select cells.
One out of every 10 roll-off boxes was sampled for O&G and one out of every 50 boxes was
sampled forTCLP analysis.
6.4.4 Non-Impacted Debris
Non-impacted (non-oily) debris generated at field locations was transported to Republic
Service's C&C Landfill in Marshall in lined 20 cubic yard roll-off boxes. Non-impacted debris
was not sampled and was not included in recovered oil calculations. The non-hazardous
designation for the debris is based on generator knowledge.
6.4.5 Soil
Crude oil impacted soil was brought from various locations along the Talmadge Creek and
Kalamazoo River to soil staging cells constructed in Site A. The soil was homogenized and,
if necessary, solidified using stabilizing agents approved by the USEPA and MDEQ. Once
complete, soil piles were sampled following established protocol. Disposal arrangements
were made based on analytical data. Non-hazardous soil is being disposed of at the
Republic Services/C&C landfill in Marshall. Waste Management's landfill in Three Rivers is
an alternate location for soil disposal. Hazardous soil was not generated during March,
2011.
6.4.6 Miscellaneous Small Quantity Waste Streams
Miscellaneous small waste streams have been generated throughout the project. These
wastes have primarily been stored in drums and include, but are not limited to, used oil,
batteries, small quantities of medical waste, and lab samples. These have been
characterized individually and disposed of at approved facilities.
22
-------
Approved
6.4.7 Non-Hazardous Precipitation
Accumulated precipitation is transported to the City of Battle Creek's POTW for treatment and
discharge. Precipitation is primarily collected in sumps from areas that currently do not have
active operations. The sump at site CO.5 was decommissioned and eliminated on March 25,
2011. One water sample is collected for every 50,000 gallons shipped and analyzed for
Benzene and O&G. The results are forwarded to the Battle Creek POTW.
6.4.8 Recovered Oil Calculations
The quantity of oil contained in waste materials has been calculated since the onset of the
project. The quantity of oil is based on the concentration of oil in the waste and the total
amount of waste shipped. Recovered oil values are determined for each waste stream
individually. An example of a recovered oil summary is provided. (Attachment G of this
WTTD plan)
23
-------
Approved
Summary of Waste Shipment
Waste Stream
Disposal Company
US EPA ID
Number
Treatment Option
Wastewater
Dynecol, Inc.
MID 074 259 565
Wastewater
(Hazardous)
Treatment
Wastewater
EQ Detroit, Inc.
MID 000 724 831
Stabilization, Fuel
(Hazardous)
MID 980 991 566
Blending,
Incineration
Wastewater (Non-
Dynecol, Inc.
MID 074 259 565
Wastewater
Hazardous)
Treatment
Wastewater (Non-
EQ Detroit, Inc.
MID 980 991 566
Recycle/Reclaim
Hazardous)
Wastewater (Non-
Liquid Industrial
MID 006 546 121
Wastewater
Hazardous)
Waste Services
Treatment
Wastewater (Non-
Plummer's
MIK 111 229 563
Wastewater
Hazardous)
Environmental
Services
Treatment
Wastewater (Non-
Marshall POTW
Wastewater
Hazardous)
Muskegon POTW
Kalamazoo POTW
Battle Creek POTW
Treatment POTW
Hazardous Solids
Envirosafe Services
OHD 045 243
Landfill
(Dumpsters and
of OH
706
Soils)
Hazardous Solids
EQ Michigan
MID 048 090 633
Landfill
(Dumpsters and
Soils)
Disposal
Non-Hazardous
Republic Services
MID 985 618 420
Landfill
Waste Solid
C&C Landfill
Non-Hazardous
Waste Management
Landfill
Soil
Landfill - Three
Rivers
Notes:
ID = identification OH = Ohio
Inc. = Incorporated POTW = Publicly owned treatment works
24
-------
Approved
7.0 Notifications
The following procedures and requirements are included in the WTTD plan. Each is proposed
to be ceased, either due to the infrequency of the activity, or because the information will be
communicated via the monthly reports to the regulatory agencies.
• Prior to shipping material to a disposal facility, the WTTD plan requires that Enbridge
request a compliance check from the USEPA to assess the disposal facility's compliance
with the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) Off-Site Rule. The Company e-mailed a written request to Mr. William
Damico, USEPA Region V, for a compliance check prior to shipping material to a
disposal facility. USEPA's onsite T & D group is copied on this e-mail exchange. Upon
approval, facilities that are used for disposal must be approved by the U.S. EPA, in
accordance with the Administrative Order issued by U.S. EPA on July 27, 2010, pursuant
to §311(c) of the Clean Water Act (Docket No. CWA 1321-5-10-001) and Supplement to
the Administrative Order issued by USEPA on September 23, 2010.All wastes generated
during the response shall be handled, treated and disposed of in accordance with all
laws and regulations applicable to the specific waste generated. This includes, but is not
limited to, disposal of wastes at facilities permitted to accept the specific type of waste.
• Enbridge or designee will notify the USEPA of all disposal facilities receiving wastes from
the response, as well as each facility's permit status.
• The Enbridge notification requirements to the USEPA can be modified if approved by the
USEPA after issuance of the revised WTTD Plan.
25
-------
Table
-------
TABLE 1: Soil Stabilization Agents
Product
Dust Hazard
Waste Characterization
Use
Sawdust (untreated wood;
No
Letter from supplier
All locations
sawmill only)
Speedy Dry
Yes if bulk (greater
than 80 pound bags)
MSDS
Soil cells, rock
box, remote and
centralized
Clay
Yes if bulk (greater
than 80 pound bags)
MSDS
Soil cells, rock
box, remote and
centralized
Bentonite
Yes if bulk (greater
than 80 pound bags)
MSDS
Soil cells, rock
box, remote and
centralized
Dolomite/DKD/Lime Kiln Dust
Yes
Omni Material, Inc. has
been approved to
provide DKD, no
exceedances were
experienced last year
Centralized soil
cells
Portland
Yes if bulk (greater
than 80 pound bags)
MSDS
Centralized soil
cells
Lime
Yes if bulk (greater
than 80 pound bags)
MSDS
Centralized soil
cells
Caliciment Dolo
Yes
Mintek Resources, Inc.
provided analytical, one
initial waste
characterization sample
will be collected of the
first delivery from
Mintek.
Centralized soil
cells
Caliciment Hi Cal
Yes
Mintek Resources, Inc.
provided analytical, one
initial waste
characterization sample
will be collected of the
first delivery from
Mintek.
Centralized soil
cells
Sodium Polyacrylate
No
MSDS
All locations
Instazorb
No
MSDS
All locations
Backfill/soil/loam/sand/clay
No
Letter from supplier
All locations
Organic Cationic Emulsion -
No
MSDS
Flocculent; water
Solve 137
discharged
subject to NPDES
Permit
requirements
-------
TABLE 1: Soil Stabilization Agents
Product
Dust Hazard
Waste Characterization
Use
Organic Cationic Coagulant -
Solve 426
No
MSDS
Flocculent; water
discharged
subject to NPDES
Permit
requirements
Straw
No
Letter from supplier
All locations
Notes:
All locations = In excavation, in dredging area behind containment, at remote and centralized soil
stabilization areas.
Centralized soil stabilization area = Site A, Frac Tank City soil cells, or other agency approved areas.
DKD = Dolomitic Limestone and Dolime
Dolo = Dolomitic Limestone (synonym Dolomite)
Hi Cal = High calcium
MSDS = Material Safety Data Sheet
NPDES = National Pollutant Discharge Elimination System
-------
Attachment A
Soil Staging Flowchart
-------
Soil Staging Flow Chart
May 13, 2011
-------
Attachment B
Oily Debris Flowchart
-------
Oily Debris Flow Chart
May 13, 2011
-------
Attachment C
Oily Waste Water Flowchart
-------
Oily Waste Water
Flow Chart
May 13, 2011
-------
Attachment D
Free Liquids Paint Filter Test Log Sheet
-------
ALS Laboratory Group Fr66 Liquids Book 1466
Date
Analyst
Sample ID
Weight Used
mL Through Filter
After 5 Minutes
Present/Absent
Comments
Batch ID
FreeLiquids.xls.xls
-------
Attachment E
Daily Waste Load Summary
-------
Enbridge Energy Partners sent 5/2/2011
Daily Waste Load Summary
Date Shipped
Waste Stream
Haz /
NonHaz
4/19/2011
4/20/2011
4/21-
4/25/11
4/26/2011
4/27/2011
4/28/2011
4/29-
5/1/2011
Total Qty
Shipped as
of 5/1/11
Oil
Recovery
Other Mat'I
Recovery
UOM
Comment
WS-01 c
Soil -
(Non-Hazardous)
Terra / C & C
Non-Haz
0
0
0
0
0
0
0
9,175
cubic
yards
WS-02 B
Debris -
(Roll Off Boxes with Impacted
Sorbents, boom, pads, plastic,
PPE, vegitation, and biomass)
Terra / C & C
Non-Haz
15.60
55.27
72.57
64.11
87.50
0.00
0.00
1,918
tons
WS-02 C
Debris -
(Non-oily Household Trash)
Terra / C & C
Non-Haz
0.00
1.55
0.00
0.00
28.49
33.57
1.35
734
tons
WS-03 C
Non Haz Water
Dynecol
Non-Haz
8,440
8,191
30,153
0
20,103
17,520
8,520
671,177
gallons
WS-04 B
Non Haz Water
(FTC Inactive Decon sump)
Battle Creek POTW
Non-Haz
0
0
11,000
17,000
0
0
18,000
861,420
gallons
Collected rainwater not passing through
Frac Tank City. C0.5sump
decommissioned and eliminated 3/25/2011
Discontinued Waste Streams, Facilities, and/or Processes
WS-01 A
Soil -
(Benzene Impacted Soil)
Safety Kleen / Envirosafe
Haz
--
--
--
--
--
--
--
19,644
cubic
yards
WS-01 B
Soil & Debris -
(Non-Hazardous)
Safety Kleen / Westside
Rpnvnlinn
Non-Haz
--
--
--
--
--
--
--
64,815
cubic
yards
WS-02 A
Debris -
(Roll Off Boxes with Impacted
Sorbents, boom, pads, plastic,
PPE, vegitation, and biomass)
EQ/ Michigan Disposal
Haz
--
--
--
--
--
--
--
12,075
cubic
yards
WS-03 A
Haz Water
Dynecol
Haz
--
--
--
--
--
--
--
3,594,579
gallons
WS-03 B
Treated Non Haz Water
Dynecol
Non-Haz
--
--
--
--
--
--
--
150,700
gallons
WS-04 A
Treated Non Haz Water
Battle Creek POTW
Non-Haz
--
--
--
--
--
--
--
1,968,700
gallons
Shipment amounts based on the treatment
system's totalizing flow meter.
WS-05
Oil/Water
RPP to Griffith
Non-Haz
--
--
--
--
--
--
--
2,171,813
766,288
1,405,525
gallons
WS-06
Treated Water Non Haz
Liquid Industrial Waste
Services, Inc.
Non-Haz
--
--
--
--
--
--
--
370,200
gallons
WS-07
Treated Water Non Haz
Plum me rs
Non-Haz
--
--
--
--
--
--
--
4,976,140
gallons
WS-08
Treated Effluent at A-1
Non-Haz
--
--
--
--
--
--
--
662,900
gallons
System is shutdown; decommissioned.
WS-09
New Age Lab - Water
Safety Kleen
Haz
--
--
--
--
--
--
--
825
gallons
Laboratory off site.
WS-10
Treated Effluent at
Ceresco Dam
NA
--
--
--
--
--
--
--
14,324,000
gallons
System is shutdown; decommissioned.
WS-11
Ceresco sediment
(GeoT ubes)
Non-Haz
--
--
--
--
--
--
--
5,562
cubic
yards
As of 11/9 GeoTube removal completed.
-------
Attachment F
Manifest Daily Report
-------
WasteStream
Waste Stream ID Printed
on Manifest
Manifest/BOL
Number
Receiving Facility
Receiving Facility
EPA ID
Transporter 1
Transporter 1 EPA ID/
State Transporter's ID
Waste Codes (Haz-D018,
Haz-D001, Non-Haz)
Amount Shipped
UOM
No. of
Containers
on Manifest
Date Shipped
Container Info
Location
TPH Sample
Number
SK Load Wt
(Tons)
MANIFEST
DOC # SK
NON-HAZ
uate
Received
Manifest
Copy from
Designated
Facility
Date
Manifest
Mailed to
State
Comments
Debris
Non-Hazardous Solid
658167
C&C Landfill
NA
Terra Contracting
NA
Non-Haz MUNICIPAL
9.09
tons
1
4/18/2011
Box #171
C0.5
9.09
30 cubic yards
Debris
Non-Hazardous Solid
625341
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
3.39
tons
1
4/18/2011
Box #20-10
Site A
3.39
20 cubic yards
Debris
Non-Hazardous Solid
658151
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
6.43
tons
1
4/19/2011
Box #20-12
Site A
6.43
Debris
Non-Hazardous Solid
625328
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
4.3
tons
1
4/19/2011
Box #171
Site A
4.3
Debris
Non-Hazardous Solid
625329
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
4.87
tons
1
4/19/2011
Box #20-16
Site 3.2
4.87
A Site
Non-Hazardous Water
007677549JJK
Dynecol, Inc.
MID074259565
Terra Contracting
MIK768689127
Non-Haz 029L
8440
gallons
1
4/19/2011
Site A
A Site
Non-Hazardous Water
007677547JJK
Dynecol, Inc.
MID074259565
Terra Contracting
MIK768689127
Non-Haz 029L
8191
gallons
1
4/20/2011
Site A
Debris
Non-Hazardous Solid
658172
C&C Landfill
NA
Terra Contracting
NA
Non-Haz MUNICIPAL
1.55
tons
1
4/20/2011
Box #20-19
Frac Tank City
1.55
Debris
Non-Hazardous Solid
658164
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
3.62
tons
1
4/20/2011
Box # 264
SWAT
Soil Cells
Non-Hazardous Solid
658170
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
12.01
tons
1
4/20/2011
Truck H58
Cell 5 Pile 3
TPH 599
12.01
timber mats
Soil Cells
Non-Hazardous Solid
658168
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
10.02
tons
1
4/20/2011
Truck H52
Cell 5 Pile 3
TPH 600
10.02
timber mats
Soil Cells
Non-Hazardous Solid
658169
C&C Landfill
NA
Hendrickson T rucking
NA
Non-Haz
10.02
tons
1
4/20/2011
Truck H58
Cell 5 Pile 3
TPH 601
10.02
timber mats
Soil Cells
Non-Hazardous Solid
658173
C&C Landfill
NA
Hendrickson T rucking
NA
Non-Haz
10.01
tons
1
4/20/2011
Truck H58
Cell 5 Pile 3
TPH 603
10.01
timber mats, tonnage
rec'd 4-26-11
Soil Cells
Non-Hazardous Solid
658171
C&C Landfill
NA
Hendrickson T rucking
NA
Non-Haz
9.59
tons
1
4/20/2011
Truck H52
Cell5 Pile 3
TPH 602
9.59
timber mats, tonnage
rec'd 4-26-11
Debris
Non-Hazardous Solid
658178
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
1.99
tons
1
4/21/2011
Box # 20-08
A Site
1.99
Soil Cells
Non-Hazardous Solid
658174
C&C Landfill
NA
Hendrickson T rucking
NA
Non-Haz
8.31
tons
1
4/21/2011
Truck H52
Cell 5 Pile 3
TPH 604
8.31
timber mats
Soil Cells
Non-Hazardous Solid
658175
C&C Landfill
NA
Hendrickson T rucking
NA
Non-Haz
8.94
tons
1
4/21/2011
Truck H58
Cell 5 Pile 3
TPH 599
8.94
timber mats
Soil Cells
Non-Hazardous Solid
658176
C&C Landfill
NA
Hendrickson T rucking
NA
Non-Haz
11.07
tons
1
4/21/2011
Truck H52
Cell5 Pile 3
TPH 600
11.07
timber mats
Soil Cells
Non-Hazardous Solid
658177
C&C Landfill
NA
Hendrickson T rucking
NA
Non-Haz
11.39
tons
1
4/21/2011
Truck H58
Cell 5 Pile 3
TPH 601
11.39
timber mats
Soil Cells
Non-Hazardous Solid
658179
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
9.35
tons
1
4/21/2011
Truck H52
Cell 5 Pile 3
TPH 602
9.35
timber mats
Soil Cells
Non-Hazardous Solid
658182
C&C Landfill
NA
Hendrickson T rucking
NA
Non-Haz
11.12
tons
1
4/21/2011
Truck H58
Cell5 Pile 3
TPH 603
11.12
timber mats
Soil Cells
Non-Hazardous Solid
658183
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
10.4
tons
1
4/21/2011
Truck H58
Cell 5 Pile 3
TPH 604
10.4
timber mats
Frac Tank City
Non-Hazardous Water
007968399JJK
City of Battle Creek
Wastewater T reatment
Facility
MIG000017308
Terra Contracting
MIK768689127
Non-Haz 029L
5500
gallons
1
4/21/2011
FTC Sump
Frac Tank City
Non-Hazardous Water
007968395JJK
City of Battle Creek
Wastewater T reatment
Facility
MIG000017308
Terra Contracting
MIK768689127
Non-Haz 029L
5500
gallons
1
4/21/2011
FTC Sump
Frac Tank City
Non-Hazardous Water
007677534JJK
Dynecol, Inc.
MID074259565
Terra Contracting
MIK768689127
Non-Haz 029L
10035
gallons
1
4/21/2011
Frac Tank City
A Site
Non-Hazardous Water
007677543JJK
Dynecol, Inc.
MID074259565
H.M. Environmental
MIR000017079
Non-Haz 029L
10118
gallons
1
4/21/2011
A Site
A Site/Frac Tank
City
Non-Hazardous Water
007677546JJK
Dynecol, Inc.
MID074259565
S&C T ran sport
MIDI 86804399
Non-Haz 029L
10000
gallons
1
4/21/2011
A Site/Frac Tank City
5998 gal from A Site
4002 gal from FTC
Frac Tank City
Non-Hazardous Water
007968400JJK
City of Battle Creek
Wastewater T reatment
Facility
MIG000017308
Terra Contracting
MIK768689127
Non-Haz 029L
8500
gallons
1
4/26/2011
FTC Sump
Frac Tank City
Non-Hazardous Water
007968401JJK
City of Battle Creek
Wastewater T reatment
Facility
MIG000017308
Terra Contracting
MIK768689127
Non-Haz 029L
8500
gallons
1
4/26/2011
FTC Sump
Soil Cells
Non-Hazardous Solid
658185
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
11.19
tons
1
4/26/2011
Truck 58
Cell 5 Pile 3
TPH 599
11.19
timber mats
Soil Cells
Non-Hazardous Solid
658186
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
9.87
tons
1
4/26/2011
Truck 49
Cell 5 Pile 3
TPH 600
9.87
timber mats
Soil Cells
Non-Hazardous Solid
658180
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
9.32
tons
1
4/26/2011
Truck H58
Cell 5 Pile 3
TPH 601
9.32
timber mats
Soil Cells
Non-Hazardous Solid
658188
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
9.43
tons
1
4/26/2011
Truck 49
Cell 5 Pile 3
TPH 602
9.43
timber mats
Soil Cells
Non-Hazardous Solid
658187
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
11.88
tons
1
4/26/2011
Truck H58
Cell 5 Pile 3
TPH 603
11.88
timber mats
Soil Cells
Non-Hazardous Solid
658181
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
12.42
tons
1
4/26/2011
T ruck 49
Cell 5 Pile 3
TPH 604
12.42
timber mats
Frac Tank City
Non-Hazardous Water
007677535JJK
Dynecol, Inc.
MID074259565
H.M. Environmental
MIR000017079
Non-Haz 029L
11332
gallons
1
4/27/2011
Frac Tank City
Frac Tank City
Non-Hazardous Water
007677536JJK
Dynecol, Inc.
MID074259565
Terra Contracting
MIK768689127
Non-Haz 029L
8771
gallons
1
4/27/2011
Frac Tank City
Soil Cells
Non-Hazardous Solid
644363
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
9.4
tons
1
4/27/2011
T ruck 49
Cell 5 Pile 3
TPH 603
9.4
timber mats
Soil Cells
Non-Hazardous Solid
644364
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
9.46
tons
1
4/27/2011
Truck 58
Cell 5 Pile 3
TPH 604
9.46
timber mats
Soil Cells
Non-Hazardous Solid
644362
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
12.46
tons
1
4/27/2011
Truck 58
Cell 5 Pile 3
TPH 602
12.46
timber mats
Soil Cells
Non-Hazardous Solid
644361
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
12.81
tons
1
4/27/2011
Truck 49
Cell 5 Pile 3
TPH 601
12.81
timber mats
Soil Cells
Non-Hazardous Solid
658189
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
15.37
tons
1
4/27/2011
T ruck 49
Cell 5 Pile 3
TPH 599
15.37
timber mats
Soil Cells
Non-Hazardous Solid
658190
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz
13.32
tons
1
4/27/2011
T ruck 58
Cell 5 Pile 3
TPH 600
13.32
timber mats
Debris
Non-Hazardous Solid
644369
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
1.68
tons
1
4/27/2011
Box # 26
A Site
1.68
Debris
Non-Hazardous Solid
644366
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
2.76
tons
1
4/27/2011
Box # 264
FTC SWAT
2.76
CP SWAT
Debris
Non-Hazardous Solid
644365
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
8.19
tons
1
4/27/2011
Box #171
A Site
8.19
Debris
Non-Hazardous Solid
644367
C&C Landfill
NA
Terra Contracting
NA
Non-Haz
2.05
tons
1
4/27/2011
Box # B51
A Site
2.05
Debris
Non-Hazardous Solid
644370
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz MUNICIPAL
8.22
tons
1
4/27/2011
T ruck 49
A Site
8.22
Non-impacted timber
debris
Debris
Non-Hazardous Solid
644335
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz MUNICIPAL
9.99
tons
1
4/27/2011
T ruck 58
A Site
9.99
Non-impacted timber
debris
Debris
Non-Hazardous Solid
644368
C&C Landfill
NA
Hendrickson Trucking
NA
Non-Haz MUNICIPAL
10.28
tons
1
4/27/2011
T ruck 49
A Site
10.28
Non-impacted timber
debris
-------
Attachment G
Oil Recovery Estimation Report
-------
ENBRIDGE™
Enbridge Energy
Line 6B MP 608 Oil Recovery Estimation Report
March 17, 2011
Oil Recovery Estimate
Waste Stream
3/28/2011
4/4/2011
4/11/2011
4/18/2011
4/25/2011
lotal Oil
Recovery
Estimate
(gallons)
Comment
Soil -
(Impacted Soil & Debris )
C&C Landfill
346
191
14
0
0
1,015
Soil -
(Impacted Soil & Debris )
Envirosafe/Westside RDF
-
-
-
-
-
278,665
Geotube Sediment -
(Impacted Sediment)
Westside RDF
-
-
-
-
-
1,298
Process discontinued November 2010
Debris -
(Roll Off Boxes with Impacted
Sorbents, boom, pads, plastic,
PPE, vegitation, and biomass)
-
344
18
8
25
26,003
Not all O&G results available at the time of report
preparation
Frac Tank City
Influent to Carbon Filtration
System
-
-
-
-
-
8,109
Frac Tank City Pre-treatment system decommissioned on
10/30/10.
Frac Tank City
Water to Dynecol
39,895.6
0.1
14.2
17.8
0.3
39,928
Totals have been updated with current analytical data
Battle Creek
Non-Hazardous rain water
Ceresco Dredge and C05
Inactive Decon Pad
-
-
-
-
-
--
O&G analytical results non-detect, <5,000 ug/L, oil
concentration <1 gallon per 350,000 gallons water.
Wildlife Rec Center
Non-Hazardous water to
Plummers
-
-
-
-
-
--
As per Recovered Oil Tracking Supplemental Rev August
9_10, "The oily water collected from the animal recovery
facility is not included in this report due to the relatively
low volume."
Ceresco Pretreatment System
-
-
-
-
-
90
Process discontinued November 2010
A-1 Pretreatment System
-
-
-
-
-
9
Discontinued 8/25.
Oily Water
RPP to Griffith
-
-
-
-
-
766,288
Value updated by Paul Wandzura 10.14.10 email.
1,121,404 TOTAL ESTIMATE
Summary Table - Totals
Page 1 of 1
-------
Attachment H
Transfer Plan - Transfer of Operations from Site A to Frac Tank City
-------
Approved
Enbridge Line 6B MP 608
Marshall, Ml Pipeline Release
Transfer of Operations from Site A to Frac Tank City
Prepared for United States Environmental Protection Agency
Enbridge Energy, Limited Partnership
Prepared: April 18, 2011
Revised: May 13, 2011
Approved: May 12, 2011
-------
Approved
Transfer of Operations from Site A to Frac Tank City
Enbridge Energy, Limited Partnership
Line 6B Incident, Marshall, Michigan
May 13, 2011
Introduction
The following plan has been developed to outline the intent and execution of the
combining of the two support facilities Site A and Frac Tank City (FTC). The plan is
intended to provide a summary of the initial activities performed at the two temporary
waste handling facilities used for the Line 6B Incident and the proposed phased transfer
of functions from Site A to FTC. This will be accomplished in a three-phased approach
guided by the findings of the river reassessment. The completion of each phase of work
and decision to progress to the next phase will be agreed upon by Enbridge Energy,
Limited Partnership (Enbridge), United States Environmental Protection Agency
(USEPA) and Michigan Department of Environmental Quality (MDEQ). A confirmatory
email will be sent from Enbridge to USEPA and MDEQ when the next phase will begin.
History
Site A is used for solid waste and soil staging while FTC is used for liquid staging. At the
peak of the release the two facilities were necessary to handle the extensive quantity of
soils, sediments, and oily water.
The current and near-term forecasts of clean-up activities do not warrant the ongoing
operation and maintenance of both Site A and FTC facilities. The decision to
decommission (i.e. remove from service) Site A and to retain FTC was based on the
ability of FTC to support all necessary functions of current and projected response
activities.
The intent of the plan is to transfer all operations currently performed at Site A to either
existing facilities at FTC and/or newly created facilities at FTC. This will be conducted in
a phased approach such that no operational capacity at Site A will be omitted prior to
transferring the task to FTC.
The implementation of this plan will reduce the overall footprint of the Line 6B Incident
support facilities. Specific benefits will include:
• A significant reduction in waste water collection and disposal from precipitation
events.
• Large reduction in trucking from liquid disposal.
• Reduce impacts to local wildlife and the environment.
• Improved operational efficiency with the use of 1 centralized facility.
• Restoration of Site A property.
Current Conditions
The following outlines the current activities at both Site A and Frac Tank City. See
Figures 1 and 2 attached.
Site A
• Soil and debris staging cells
o Cell 2: Active, proposed for decommissioning
o Cell 4: Active
o Cell 5: Active
1
-------
Approved
o Cells 1, 3, 6, 7, 8: Decommissioned
• Decontamination Areas: In the process of being decommissioned
• Oily debris roll off(s)
• Equipment staging
Frac Tank City
• Decontamination Areas(2)
o The northern decontamination pad is currently inactive.
• The southern pad is active.
• Roll offs
o Control point oily debris roll off
• Household debris roll offs
• Truck Lining Station
o Relocated to FTC from Site A
• Frac Tank Water Storage (Figures 2 and 3)
• Equipment Staging (yellow iron, boom, frac tanks, etc...)
Transfer of Functions
Enbridge operations is planning a phased approach in the transfer of functions from Site
A to FTC. This will be a 3 phased approach guided by the findings of the reassessment
of the Kalamazoo River and Talmadge Creek
Phase I
Assure all operational functions can be performed by FTC including soil staging, liquid
staging and decontamination activities then constructed.
FTC Activities
1.) Consolidate all water storage to Frac Tanks at FTC.
2.) Transfer truck lining station from Site A to FTC.
3.) Transform northern decon pad at FTC to 2 soil staging cells with the capacity to
hold approximately 2,000 cubic yards each (Figure 3 - Future Layout).
4.) Implement Traffic Management Protocol (Figure 3) includes:
• T raffic flow
• Signage
Site A Activities
1.) Decommission decon pads at Site A in accordance with the Soil Staging,
Decontamination and River Access Site Closure Plan (Attachment A).
Phase II
The second phase of the plan further transfers the functions of Site A to FTC. As
previously indicated, the decision to move to Phase II will be agreed upon by Enbridge,
USEPA and MDEQ prior to implementation.
FTC Activities
1.) All solid waste staging will occur at FTC.
2.) All liquid waste staging will occur at FTC.
3.) Continue the transformation of FTC to the primary equipment storage area.
2
-------
Approved
Site A Activities
1.) Decommission Cell 2 at Site A. The decommissioning of Cell 2 will be done in
accordance with the Soil Staging, Decontamination and River Access Site
Closure Plan.
2.) Cells 4 and 5 will be maintained at Site A.
Phase III
The third phase of the plan pertains to the decommissioning of Site A. This will be
dictated by the conclusions made from the results of the reassessment.
The findings of the river reassessment will provide sufficient information for Enbridge,
USEPA, and MDEQ to determine the necessary waste capacity for future activities and
thus the need for Site A. However, if approval to direct-load and dispose of soil and
debris is obtained, the need for the soil storage capacity of Site A will be greatly
reduced. If either or both of the above conditions are satisfied, the following actions will
take place:
FTC Activities
1.) All waste staging activities will occur at FTC as laid out in Figure 3.
Site A Activities
1.) Decommission Cells 4 and 5 in Site A in accordance with the Soil Staging,
Decontamination and River Access Site Closure Plan.
2.) Remove all associated mat roads in Site A in accordance with the Talmadge
Creek Swamp Mat Removal Sampling Plan (Attachment B).
3.) Restore the area to its original condition.
Closing
Upon completion of the three phases, FTC will be capable of handling all operational
functions currently handled at both locations. FTC will remain in operation until the
determination is made that it is no longer needed. This determination will be agreed
upon by Enbridge, USEPA and MDEQ. All decommissioning activities will be conducted
in accordance with the Enbridge Line 6B MP 608 Pipeline Release - Marshall, Michigan
Soil Staging, Decontamination and River Access Site Closure Plan.
3
-------
Figures
-------
Decommissionec
tDecon 23B|
Area
Map Location
Legend
Figure 1:
SITE A
CURRENT LAYOUT
W Michigan Ave
Parcel Boundary
NBRIDGE AZCOM
Decommissioned Soil Staging Area
Active Soil Staging Area
Drawn: BC 4/28/2011
ENBRIDGE LINE 6B M 608
PIPELINE RELEASE
MARSHALL. Ml
DeconArea: Roll-Off Storage
Approved: BA 4/28/2011
Project#: 60162778
Z:\Work\GIS\Frac Tank CityxSite A Current Layout,mxd Aerial Photo Date: October 2010
-------
Legend
Frac Tank Boundary IV/A Equipment Storage Area
~ Parcel Boundary V77X
177A
Northern Decon Area
Southern Decon Area
NOTE: Structures and
features are not to scale.
Z:\Work\GIS\Frac Tank City\Frac_Tank_Area withNAIP2010_CurrentLayout_Fig2_051811 .mxd
A
Figure 2:
CURRENT LAYOUT
FRAC TANK CITY
ENBRIDGE LINE 6B M 608
PIPELINE RELEASE
MARSHALL, Ml
cSENBRIDGE
Drawn: JW 5/18/2011
Approved: DL 5/18/2011
Project#: 60162778
Aerial Photo Source: NAIP 2010
-------
Z:\Work\GIS\Frac Tank City\Frac_Tank_Area withNAIP2010_Future Layout_Fig3_051811 .mxd
Aerial Photo Source: NAIP 2010
-------
Enbridge Line 6B MP 608 Pipeline Release
Marshall, Michigan
Soil Staging, Decontamination and River Access Site Closure Plan
January 11, 2011
-------
Enbridge Line 6B MP 608 Pipeline Release
Marshall, Michigan
Soil Staging, Decontamination and River Access Site Closure Plan
Prepared: January 11, 2011
Table of Contents
1.0 Introduction 1
1.1 Overview 1
2.0 Soil Staging and Decontamination Areas 3
2.1 Closure Schedule 3
2.2 Closure Activities 4
2.3 Verification Soil Sampling 4
2.3.1 Soil Staging Area A (Cells 1-8) 6
2.3.2 Soil Staging Area Yard 4 (Cells 9, 10, 11, 12) 7
2.3.3 Frac Tank City Decon Area 8
2.3.4 Frac Tank City 8
2.3.5 CO.5 Decon Area 9
2.3.6 CO.5 Submerged Oil Dredging, Water Treatment and Geotube Area at Ceresco Dam 9
3.0 River Access and Other Work Sites 11
3.1 Phase I Site Environmental Evaluation Activities 11
3.1.1 Review of General Information 12
3.1.2 Review of Records 13
3.1.3 Visual Site Inspections 13
3.1.4 Interviews 14
3.2 Phase II Site Environmental Investigation Activities 14
3.2.1 Verification Soil Sampling Plan 14
3.3 Closure Schedule 17
4.0 Data Evaluation 19
5.0
Reporting
20
-------
List of Tables
Table 1 Anticipated Closure Schedule
Table 2 Soil Analytical Parameters
Table 3 SSAA Grid Spacing and Samples
Table 4 Yard 4 Grid Spacing and Samples
Table 5 FTC Grid Spacing and Samples
Table 6 CO.5 Grid Spacing and Samples
-------
List of Figures
Figure 1 Site Location
Figure 2 Locations of Soil Staging and Decon Areas
Figure 3 SSAA Sample Locations
Figure 4 Yard 4 Sample Locations
Figure 5 Frac Tank City Decon Area Sample Locations
Figure 6 CO.5 Decon Area Sample Locations
Figure 7 Frac Tank City Sample Locations
Figure 8 CO.5 Submerged Oil Dredging, Water Treatment and Geotube Area Sample Locations
List of Attachments
Attachment A List of River Access and Other Work Sites
Attachment B River Access Site Aerial Photo Maps
Attachment C Site Closure - Site Environmental Evaluation Form
-------
1.0 Introduction
In support of the management of contaminated soil and debris generated during remediation activities
relating to the of the Enbridge (the Company) Line 6B crude oil release near Marshall, Michigan (see
Figure 1), two soil staging areas were constructed. Soil staging area A is located east of Talmadge
Creek, south of Division Drive, and east of Interstate 69. The soil staging area in Yard 4 is located
north of Talmadge Creek and west of Interstate 69. Decontamination (decon) areas were also
constructed in Frac Tank City (FTC) and Area CO.5. Figure 2 shows the locations of the two soil
staging areas and the decon areas within FTC and Area CO.5.
During the oil release response activities, approximately 70 separate work sites were established
along both sides of the Kalamazoo River along the length of the response area from the confluence of
the Talmadge Creek to Morrow Lake Dam. These "river access sites" were occupied by response
personnel for equipment and material staging, decontamination, waste staging and similar activities.
The river access sites are privately-owned, Enbridge-owned, Enbridge-leased lands and certain
public lands. In addition, there are several work sites occupied by response personnel that were not
used for purposes other than river access. These, "other work sites" include Staging Yards 1, 2, 3
and 5. Attachment A is a list of river access and other work sites. Finally, there are numerous sites
identified as potential work sites and that were secured with Right-of-Way agreements with the land
owner but which were never developed for work. These sites were visited and evaluated to verify
that they were not used.
This Closure Plan is intended to define conditions at the Sites occupied and used by Enbridge. The
Plan is not intended to address impacts that are directly related to the pipeline release, but to address
secondary impacts that may have occurred during response activities. Each site closure will be
contingent upon the analytical results generated from the soil sampling detailed in this Plan. The
analytical results will be compared to applicable Part 201 generic residential cleanup criteria to
determine if the site may be considered closed. Once the site is determined to be closed, remediation
activities will no longer be deemed necessary.
1.1 Overview
The objectives of this Soil Staging Decontamination and River Access Sites Closure Plan (the Plan)
are to describe the actions that will be implemented and the estimated schedule for closing the
following locations:
1
-------
• Soil Staging Area A (SSAA), cells 1- 8, and oily mat storage and decon areas.
• Soil Staging Area in Yard 4 (Yard 4), cells 9-11 and cell 12 (decon area).
• Frac Tank City (FTC).
• CO.5 Work Areas.
• River Access Sites.
• Other Work Sites.
More specifically, this Plan describes:
• The actions required to close the two soil staging areas, FTC and CO.5.
• The soil sampling activities that will be performed within the two soil staging areas, FTC and
CO.5, following removal of constructed features and underlying soils (if necessary).
• Interim measures to be implemented for areas not anticipated to be closed until 2011.
• The anticipated priority and schedule for closure.
• The river access and other work site environmental evaluation and soil sampling plans to
address impacts, if any, to these sites associated with Enbridge's occupation of the site.
This Plan does not describe the landscape restoration activities that may be implemented by the
Company after the soil staging, decon areas, river access and other work sites have been closed,
sampled, backfilled or permanently closed. Gravel imported for use during response activities will
be removed and properly disposed. This imported gravel will not be evaluated as part of this Plan.
Also, all containment liners will be removed from areas before environmental evaluations and
sampling are completed.
Closure activities described in this work plan including soil sampling will not be performed at work
sites that Enbridge plans to use throughout the winter or to reactivate in the spring except as noted
below.
2
-------
2.0 Soil Staging and Decontamination Areas
It is anticipated that the project will continue to need a centralized area throughout the fall of 2010
and into 2011 for staging and stockpiling contaminated soil and debris pending arrangements for off-
site disposal. Three cells (Cell 2, 4, and 5) in SSAA will be winterized and remain open during the
winter or winterized (as described below) in 2010 and will re-open in early 2011. Prior to winter
these three cells will be relined with a double bottom liner and a timber mat floor will be placed over
the liners. These three cells will be emptied and covered or will be maintained with a minimum
amount of soil in order to enable a cover liner to shed precipitation from the cell. In either event, the
three cells and the decon area at FTC will be maintained over the winter for use in 2011 and will be
secured for the winter with snow fencing.
The following section describes the anticipated closure schedule, activities related to closure, and
verification soil sampling to be conducted in 2010 and 2011.
2.1 Closure Schedule
Based on input from the on-site disposal vendor (Safety-Kleen), and other on-site contractors
responsible for various activities in the soil cells and decon areas the anticipated closure schedule is
shown in Table 1. As indicated in Table 1 it is anticipated that some sites will be closed in 2010 and
some sites will be closed in 2011. Those sites that are planned for use in 2011 will be winterized.
Table 1
Anticipated Closure Schedule
Soil Staging and Decon
Areas
Anticipated Date to Start
Closure Activities
Soil Staging Area A
Cell 1
As early as mid-October 2010
Cell 2, 4, 5 and decon areas
2011
Cell 3
As early as mid-October 2010
Cell 6
As early as mid-October 2010
Cell 7
As early as mid-October 2010
Cell 8
As early as mid October 2010
Yard 4 Staging Area
Cell 9
As early as mid-October 2010
Cell 10
As early as mid-October 2010
Cell 11
As early as mid-October 2010
Cell 12/decon area
As early as mid-October 2010
3
-------
Soil Staging and Decon
Areas
Anticipated Date to Start
Closure Activities
Frac Tank City
FTC decon area
2011
Area C0.5
CO.5 decon area
As early mid-November 2010
2.2 Closure Activities
Following emptying of each cell, roads, parking areas, and/or support areas, a series of closure
activities will be conducted in 2010 and 2011, including:
• Removal and disposal of the underlying liner and perimeter berms for the cells.
• Removal and disposal of contaminated mat roads, if present.
• Dismantling, removal and disposal of the decon areas at each soil staging area, at FTC and
CO.5.
• Removal and disposal of contaminated soil, if any, from below the cell or decon area
footprint.
• Conducting verification soil sampling and comparing the analytical results to Part 201
generic residential criteria for soil (appropriate Michigan Department of Natural Resources
and Environment (MDNRE) criteria).
• Backfilling and closing locations based on the results of verification soil sampling.
A field representative, designated by the Company, will be on-site to classify and visually screen soil
to confirm that excavation below the soil cell and decon area footprints removed obviously impacted
soil. All field screening and soil and debris sampling for disposal will be conducted in accordance
with the Sampling and Analysis Plan prepared for Michigan Department of Natural Resources and
Environment (MDNRE) and the Waste Treatment, Transportation and Disposal Plan (WTTDP).
Following completion of the field screening activities, a snow fence will be placed around the cell or
decon area footprint prior to conducting verification soil sampling and will remain in place until
restoration activities are completed.
2.3 Verification Soil Sampling
Following the removal of constructed features and any contaminated soil beneath the soil cells and
decon area footprints, verification soil samples will be collected for laboratory analysis. MDNRE
4
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will be notified of each sampling event and samples will be collected when a representative from the
MDNRE is present. The target soil analytical parameters are shown below in Table 2. Samples will
be analyzed in accordance with the Quality Assurance Project Plan prepared for MDNRE and the
results will be compared to Part 201 generic residential criteria. Soil sampling will be conducted in
accordance with the Sampling and Analysis Plan (SAP). The sampling approach for SSAA, Yard 4,
FTC and CO.5 are summarized in the following sections.
For the metals listed in Table 2, the cleanup criteria against which the data will be compared will
include state-wide default background concentrations. Also, Enbridge may develop site-specific
background concentrations for these metals.
The soil samples will be collected by hand with an auger or trowel. Samples will be preserved,
shipped and analyzed as specified in the SAP. Surface soil samples will be collected from 0-6 inches
below the surface. The global positioning system coordinates of each sample and field observations
will be recorded. The borings will be backfilled with adjacent soil. The results of the soil sample
analysis will be tabulated and used to direct possible future investigation and interim response
activities pursuant to Michigan regulations.
Should excavations proceed to a depth of two feet or greater, a minimum of four sidewall samples
will be collected from each excavation. For "small" site areas, the four sidewall samples will be
added to the total number of samples collected. For medium or large site areas, the MDNRE
Sampling Strategies and Statistics Training Materials document will be used to calculate the
appropriate number of sidewall samples.
5
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Table 2, below, is the list of analytical parameters for soil samples from former storage areas at the
river access sites.
Table 2
Soil Analytical Parameters
Parameter
EPA Analytical Method 1
Volatile Organic Compounds (VOCs)2
8260B
Polynuclear Aromatics (PNAs)
8270
Metal Parameters
Beryllium
6020
Molybdenum
6020
Vanadium
6020
Percent Moisture
ASTM D-2216
(1) Analytical methods based on Draft QAPP dated November 11, 2010.
(2) Methanol preservation required.
2.3.1 Soil Staging Area A (Cells 1 - 8)
SSAA consists of eight separate soil/debris staging cells, an oily mat storage area, and an equipment
decontamination cell, along with the accompanying access roads, parking areas, and office trailers.
As stated previously, Cells 2, 4, and 5 will be maintained until site activities are completed in 2010
and re-opened in 2011.
In late fall, prior to winter, cells 2, 4 and 5 will be emptied and relined. After cells are emptied and
the old liner removed two soil samples will be collected from surface soil and analyzed prior to
installation of a new liner. These two soil samples locations will be biased toward the middle of the
cell footprint and biased toward locations where soil staining was observed and removed prior to
sampling.
As shown in Table 3 below, the various areas of SSAA fall into either the small or medium site
category as described in the MDNRE Sampling Strategies and Statistics Training Materials for Part
201 Cleanup Criteria (2002). Following the formula presented on page 4.33 of that document,
applicable grid intervals were calculated for the individual areas within SSAA. The total area of
SSAA, however, falls into the large site category, yielding an expanded grid interval applicable to the
areas used for roads, parking, and other support activities. Within each area targeted for closure, 25
percent of the grid locations were then randomly selected for verification sampling. As shown on
Figure 3, this approach results in a total of 160 sample locations within SSAA.
6
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Table 3
SSAA Grid Spacing and Samples
Approximate
Area (square
MDNRE Category
Calculated Grid
Approx. No. of
Location
feet)
Size
Spacing (ft)
Samples
Cell 1
11,840
Medium
15.3
14
Cell 2
15,791
Medium
17.7
16
Cell 3
15,680
Medium
17.7
12
Cell 4
5,686
Small
21.3
4
Cell 5
12,087
Medium
15.5
14
Cell 6
12,063
Medium
15.5
14
Cell 7
7,680
Small
24.7
4
Cell 8
21,647
Medium
20.8
14
Oily Mat Storage Area
5,482
Small
20.9
4
Equipment Decon Area
12,819
Medium
16.0
15
Balance of Total Area -
SSAA
368,611
Large
39.6
49
2.3.2 Soil Staging Area Yard 4 (Cells 9, 10, 11, 12)
Soil staging area in Yard 4 consists of three separate soil/debris staging cells and a decon area (cell
12), along with the accompanying access roads, and parking areas. As shown in Table 4 below, the
three soil cells, cell 12, and support areas of Yard 4 fall into the small or large site category as
described in the MDNRE Sampling Strategies and Statistics Training Materials for Part 201 Cleanup
Criteria (2002). Following the formula presented on page 4.33 of that document, applicable grid
intervals were calculated for the combined areas. Within each area targeted for closure, 25 percent of
the grid locations were then randomly selected for verification sampling. As shown on Figure 4, this
approach results in a total of approximately 51 sample locations within Yard 4. Prior to
implementing the sampling program in Yard 4, the disturbed areas of the property will be surveyed
and the number of samples will be adjusted if necessary.
Table 4
Yard 4 Grid Spacing and Samples
Location
Approximate
Area (square
feet)
MDNRE
Category
Size
Calculated Grid
Spacing (ft)
Approx. No. of
Samples
Cell 9
7,464
Small
24.4
4
Cell 10
8,368
Small
25.8
4
Cell 11
7,465
Small
24.4
4
Cell 12/decon area
9,042
Small
26.8
4
Support areas
159,536
Large
33.0
35
7
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2.3.3 Frac Tank City Decon Area
The FTC decon area is anticipated to be utilized until site activities are completed in 2011.
Therefore, this area will be winterized and secured with snow fencing following completion of
activities in 2010. The approach to soil verification sampling anticipated in 2011 is outlined below.
As shown in Table 5 below, the decon area of FTC falls into the medium site category as described
in the MDNRE Sampling Strategies and Statistics Training Materials for Part 201 Cleanup Criteria
(2002). Following the formula presented on page 4.33 of that document, an applicable grid interval
was calculated for the FTC decon area. Within this area, 25 percent of the grid locations were then
randomly selected for verification sampling. As shown on Figure 5, this approach results in a total
of 14 sample locations within the FTC decon area.
Table 5
FTC Area Grid Spacing and Samples
Location
Approximate
Area (square
feet)
MDNRE
Category Size
Calculated Grid
Spacing (ft)
Approx. No. of
Samples
Decon Area
27,959
Medium
23.6
14
Frac Tank
City
470,230
Large
27
173
2.3.4 Frac Tank City
Frac Tank City (FTC) consists of large numbers of frac tanks, decon areas (see above), an activated
carbon water treatment system, equipment storage areas, a fueling area, roads, parking areas and
office trailers. The FTC area is anticipated to be required until site activities are completed in 2011.
Therefore, this area will be winterized and secured following completion of activities in 2010. The
approach to soil verification sampling anticipated in 2011 is outlined below.
As shown in Table 5, above, the FTC falls into the large site category as described in the MDNRE
Sampling Strategies and Statistics Training Materials for Part 201 Cleanup Criteria (2002).
Following the formula presented on page 4.33 of that document, an applicable grid interval was
calculated for the FTC. Within this area, 25 percent of the grid locations were then randomly
selected for verification sampling. As shown on Figure 7, this approach results in a total of 173
sample locations within the FTC area.
8
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2.3.5 CO.5 Decon Area
The CO.5 decon area is anticipated to be utilized until site activities are completed in 2011. The area
will be winterized and secured with snow fencing following completion of activities in 2010. The
approach to soil verification sampling anticipated in 2011 is outlined below.
As shown in Table 6 below, the CO.5 decon area falls into the large site category as described in the
MDNRE Sampling Strategies and Statistics Training Materials for Part 201 Cleanup Criteria (2002).
Following the formula presented on page 4.33 of that document, an applicable grid interval was
calculated for this area. Within the CO.5 decon area, 25 percent of the grid locations were then
randomly selected for verification sampling. As shown on Figure 6, this approach results in a total
of 62 sample locations within the CO.5 decon area.
Table 6
C0.5 Grid Spacing and Samples
Location
Approximate
Area (square
feet)
MDNRE
Category
Size
Calculated
Grid Spacing
(ft)
Approx.
No. of
Samples
Decon Area
352,400
Large
39
62
Submerged Oil Dredging,
Water Treatment and Geotube
Area
159,933
Large
32
45
The grid spacing and number of samples presented in Table 6 above may change depending on the
use of the two CO.5 areas in 2011.
2.3.6 CO.5 Submerged Oil Dredging, Water Treatment and Geotube Area
at Ceresco Dam
The submerged oil dredging, water treatment and geotube area at CO.5 consists of a geotube laydown
area for filtering the dredged material prior to water treatment (area sized for a dozen or more
geotubes), a water treatment system for water from the dredged material that includes three bag filter
and carbon filter treatment systems and adjacent access roads. This water and oil treatment system
location is anticipated to be required until site activities are completed in 2011. The area will be
winterized and secured with snow fencing following completion of activities in 2010. The approach
to soil verification sampling anticipated in 2011 is outlined below.
As shown in Table 6, above, the oil/water treatment and geotube area falls into the medium site
category as described in the MDNRE Sampling Strategies and Statistics Training Materials for Part
9
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201 Cleanup Criteria (2002). Following the formula presented on page 4.33 of that document, an
applicable grid interval was calculated for this area. Within the treatment area, 25 percent of the grid
locations were then randomly selected for verification sampling. As shown on Figure 8, this
approach results in a total of 45 sample locations within the treatment area.
10
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3.0 River Access and Other Work Sites
The River Access and Other Work Site Closure Plan in Section 3.0 is a work plan to complete Phase
I Site Environmental Evaluations (SEE) and Phase II Site Environmental Investigations (SEI) for
river access and other work sites occupied by Enbridge in response to Line 6B MP 608 release in
Marshall, Michigan. Attachment A includes a list of river access and other work sites. Attachment
B includes a set of aerial photos showing each site location.
Enbridge is utilizing property that is Enbridge-owned, privately-owned, Enbridge-leased lands and
potentially certain public lands to provide for river access for equipment and material staging,
decontamination, waste staging and similar activities related to responses to the Line 6B MP 608
release. The following work plan will be completed to summarize available information related to
the environmental site conditions through all phases of occupation, including:
1) Pre-Occupation (before any mobilization to or work activities at sites)
2) Occupation (during work activities)
3) Post-Occupation (after demobilization and closure activities are completed)
In general it is anticipated that the SEEs and SEIs will be done after equipment, consumables and
liners are removed from the site, but before landscape restoration occurs, if possible. The SEE and
SEI activities performed under this work plan will not address impacts directly related to the
Enbridge release such as presence of crude oil that is visually apparent on soil, oiled tree trunks and
structures and oil-impacted surface water, sediments and stream banks. The work plan for River
Access Sites will address environmental conditions associated only with site occupation. If oil is
observed that is directly from the Line 6B release, the appropriate personnel will be notified to
address the oil.
3.1 Phase I Site Environmental Evaluation Activities
The objective of the SEE is to identify "recognized environmental conditions" at the sites that directly or
indirectly result from activities associated with Enbridge's occupation of the site. The SEE uses methods
similar to the ASTM Standard Practice E1527-05 and E1903-97 for Phase I Environmental Site
Assessments. However, the SEE was developed for a specific purpose and is not intended to be entirely
consistent with the ASTM methods.
11
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The following definition from the ASTM standards is important for understanding the approach.
recognized environmental conditions (REC) - the presence or likely presence of any hazardous
substances or petroleum products on a site under conditions that indicate an existing release, a
past release, or a material threat of a release of any hazardous substances or petroleum products
into structure on the site or into the ground, ground water, or surface water of the site. The term
includes hazardous substances or petroleum products even under conditions in compliance with
laws. The term is not intended to include de minimus conditions that generally do not represent a
material risk of harm to public health or the environment and that generally would not be the
subject of an enforcement action if brought to the attention of appropriate governmental agencies.
Conditions determined to be de minims are not recognized environmental conditions. However,
for purposes of Enbridge's site evaluations, any de minimus conditions observed will be
addressed as RECs.
As indicated above, the SEE will not include RECs directly related to the Enbridge release such as
presence of oil that is visually apparent on soil, oiled tree trunks and structures and oil-impacted surface
water, sediments and stream banks.
The SEE will also include an evaluation of impacts (dredge and fill) on wetlands and floodplains at the
sites. Dredging in the river will not be included in the evaluation.
A SEE will be completed for each occupied (or formerly occupied) site according to this work plan
to the extent practical within the project's limits, access, and other constraints. The SEE will include
the following four activities:
1. Review of general information (Section 3.1.1).
2. Review of records available from Enbridge such as aerial photos, other photographs,
inspection reports and operational and logistics activities that occurred at the site (Section
3.1.2).
3. Visual inspection of the Site (Section 3.1.3).
4. Interviews with persons familiar with activities that occurred at the site (Section 3.1.4).
A checklist to assist in this process is in Attachment C.
3.1.1 Review of General Information
General site information will be reviewed and evaluated as appropriate. General information about
the site will include:
• Site name, location (section, segment, and GPS coordinates),
• Site map and Enbridge aerial photographs
12
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• Information and Enbridge photographs regarding what the pre -use conditions were at the site
• Site use
• Where significant features were located at the site (e.g. Secondary containment, roll-offs,
decontamination pads, etc.)
• Wetland and floodplain boundaries, where known
If possible, site information will be collected from all three phases of occupation (pre-occupation,
occupation and post-occupation). This will not be possible at some sites.
3.1.2 Review of Records
Records will be reviewed from readily available Enbridge documentation such as inspections reports,
equipment used, consumables used and aerial photographs relating to occupation or demobilization
activities. The review will attempt to identify hazardous substances used (raw materials, operating supplies,
oil-containing equipment, etc.), generated, and/or released on the Sites.
3.1.3 Visual Site Inspections
Site inspections will be performed to look for visual signs of RECs or potential wetland and
floodplain concerns on or immediately adjacent to the Site.
The visual inspection will include:
• Observe accessible portions of the Site and the portions of adjacent parcels from the Site and
public roads for RECs, such as the improper storage or use of petroleum products, chemicals
or wastes, and the presence of tanks, oil-filled electrical equipment, stains, unusual odors,
filled areas, excavated areas and other indications of the potential presence of hazardous
substances of regulatory concern.
• Describe or list each identified large aboveground storage tank (AST) or underground
storage tank (UST) or other storage containers that is on the Site (except water tanks), and
identify observed exterior tanks on adjacent parcels that may present a significant
environmental risk if a release were to occur.
• Photograph relevant features (shorelines, launches, former decon areas, roll-off storage,
unusually discolored soil, or other significant features, etc.). Relevant features will be
marked on a site map. Areas with no recognized environmental conditions will also be
photographed.
• Complete an initial site investigation checklist (see Attachment C for blank checklist form)
13
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3.1.4 Interviews
Site operators or others familiar with operations at the site will be interviewed to identify RECs.
Information from interviewees will be recorded on the field form in Attachment C. In some cases it
will not be possible to identify an appropriate person to interview and this will be documented.
Some of the River Access Sites that have no RECs, no visual impacts associated with occupation and
where there was no material storage do not need to be further assessed and can be closed when
landscape restoration activities are completed. The determination that an access site does not need
further environmental evaluation or sampling will be based on information regarding use of the site
and visual inspections from the SEE activities. A determination that an access site does not require
sampling and the basis for that determination will be documented. A Phase II Site Environmental
Investigation (following section) will be completed for sites that do have RECs and that may require
sampling.
3.2 Phase II Site Environmental Investigation Activities
The significance of each identified REC will be assessed using professional judgment considering
such factors as its nature, magnitude, and known or potential impact upon the Site, and if associated
with an off-site source the location of that source with respect to the Site.
Generally, the scope of work for a SEI is determined after the SEE has been completed, and RECs
identified. SEIs will not be needed for all sites. The need for further site investigation will result
from an evaluation of the site information collected during the Phase I SEE. Additional site
investigation is generally warranted if an evaluation of the Phase I SEE reveals:
1) Soil staining or other RECs that appears to be caused by occupation activities.
2) A site already investigated undergoes new occupancy or use.
3) The presence of waste storage or hazardous substance storage containers that present the
potential for a release.
3.2.1 Verification Soil Sampling Plan
Verification soil samples will be collected from river access and other work sites where one or more
of the conditions listed above exist. All verification soil sampling events performed for river access
and other work sites will be biased sampling and will target the exact locations where staining exists
or there is a potential for a release (i.e. locations most likely to be impacted). In some instances
background samples for metals analyses may be collected and possibly compared to site-specific
14
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background criteria generated by a site-wide background study or a background study focused more
locally near the location of potential concern.
MDNRE will be notified of each sampling event and samples will be collected when a representative
from the MDNRE is present. Samples will be analyzed in accordance with the MDNRE
requirements (Op. Memo No. 2), and the results will be compared to Part 201 generic residential
criteria. For the metals listed in Table 2, the cleanup criteria against which the data will be compared
will include state-wide default background concentrations. Also, Enbridge may develop site-specific
background concentrations for these metals.
If the SEE identifies a REC related to site occupancy, the Environment representative will direct
excavation of visually impacted soils, if present, and will collect a sample once visual observation of
the excavation indicates that no visual impact remains. The objective of the Phase II SEI is to
collect and analyze sample(s) to determine if there has been a release at a site to the extent possible
based on limited sampling and analyses. The Phase II SEI is not intended to identify the extent of
contamination, only if contamination is present.
Soil samples will be collected by hand with an auger or trowel. Samples will be preserved, shipped
and analyzed as specified in the sampling and analysis plan prepared as a condition of the November
1, 2010 Administrative Consent Order and Partial Settlement Agreement. Surface soil samples will
be collected from 0-6 inches below the surface. Soil samples will be analyzed for parameters listed
in Table 2. The global positioning system coordinates of each sample will be recorded. The sample
holes will be backfilled with adjacent soil. The results of the soil sample analysis will be tabulated
and used to direct possible future investigation and interim response activities pursuant to Michigan
regulations.
In contrast to soil staging and decon area closures where unbiased grid samples are planned, the
sample locations at River Access Sites will be biased to locations where impacts are most likely to be
found. As such, this River Access Site work plan is not intended for larger or complex sites where
more extensive sampling to determine the extent of impacts is indicated. However, none of the River
Access Sites are large complex sites that require more extensive sampling.
The MDNRE's Sampling Strategies and Statistics Training Materials for Part 201 Cleanup Criteria
(2002) provides general guidelines for application of biased or grid sampling strategies to verify soil
remediation. The selection of biased or grid sampling is based on professional judgment considering
15
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the size of the areas used for managing wastes or other hazardous substances, the volume of wastes
managed and knowledge of the specific activities at the site.
Biased sampling is collection of soil sampling from areas most likely to be impacted. Biased
sampling is generally appropriate for areas less than 0.25 acres and when there is sufficient
knowledge of existing conditions, historic activities and field indicators to allow biased sampling
locations to be selected. This is the situation for most river access sites where the use of the site is
known and the areas used for managing wastes or other hazardous substances are known and are
individually less than 0.25 acres. Such waste management uses at the river access sites typically
were for roll off boxes, dumpsters, decontamination areas, light plant generators and fuel storage.
Grid sampling is generally appropriate where the areas are larger, activities were more complex and
the areas used to manage wastes or other hazardous substances are not well defined, the volumes of
wastes were large and historic activities are not as precisely documented.
Visual Impact Areas
Samples will be collected from visually impacted areas (stained soil). Visual impacts for this
purpose do not include stains or visual impacts that are related to the initial release of oil such as
oiled river banks, tree trunks, logs, rocks and structures. Visual impacts are intended to include
impacts related to site occupancy. At least one sample for every 100 square feet of stained soil will
be collected after the visually impacted soil has been removed.
Visually impacted soil will be excavated prior to sampling and will be segregated and transported to
the contaminated material staging area at a to-be-determined location where they will be prepared for
subsequent disposal. All wastes generated during the Phase II SEI will be managed in accordance
with the Waste Treatment, Transportation and Disposal Plan submitted on August 2, 2010 and
revised on August 8, 2010.
Where soil removal occurs to address visual staining and sampling has already occurred the soil
removal area will be immediately backfilled with a similar soil type and restored in a manner
consistent to prevent inadvertent soil erosion or sedimentation of nearby water bodies. Field
observations will be recorded and the limits of the soil removal area will be defined using GPS for
potential future reference
16
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Former Storage Areas
Potential impact locations include but are not limited to the footprints of the following work areas
and storage devices:
• Decontamination area
• Frac tanks
• Roll off boxes
• Dumpsters
• Fuel storage tanks
• Generators and waste oil tanks
• Boat ramps.
Storage areas for citrus-based cleaners and soil staining caused by citrus-based cleaners will not be
sampled. Review of the MSDSs for the citrus-based cleaners indicates that the chemicals in the
cleaners have no cleanup criteria.
Some general guidelines for the numbers and locations of samples follow; these are subject to
professional judgment and field conditions.
• Footprints of decontamination areas. Collected at least one sample for every 100 square
feet occupied by former decontamination areas. In general, locations on the downhill side
of former decontamination areas are more likely to be impacted and will be preferentially
sampled.
• Frac tanks. Collect two samples, each approximately 2 feet inside each end of the
footprint of the frac tank.
• Roll off boxes. Collect two samples, each approximately 2 feet inside each end of the
footprint of each roll off box.
• Dumpsters. Collect one sample from the lowest spot in the footprint of the dumpster.
• Fuel storage tanks. Collect one sample from the lowest spot in the footprint of the tank.
• Generators and waste oil tanks. Collect one sample from the lowest spot in the footprint
of the generator or tank.
• Roadways and driveways leading to and from boat ramps. Collect one soil surface
sample of the roadway or driveway where the surface is not concrete or asphalt.
The basis for the numbers and locations of samples will be documented in field logs.
3.3 Closure Schedule
The schedule for completing the Phase I SEE and Phase II SEI will vary for each site occupied as
part of this project. It is anticipated that the Phase I SEE and limited Phase II SEI will occur through
the end of 2010 for a majority of the sites. Some environmental evaluations may occur during the
17
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winter months of January and February, 2011. Evaluations will resume in the spring of 2011, if
necessary, to continue the SEE and SEI activities including potentially additional sampling of sites.
It may also be necessary to document site reactivation activities at those River Access Sites that
Enbridge chooses to reactivate. To accommodate this schedule, Enbridge has extended property
leases at many River Access Sites. It is anticipated that some sites will be closed in 2010 and some
sites will be closed in 2011. Those sites that are planned for use in 2011 will be winterized.
18
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4.0 Data Evaluation
Data collected in accordance with this Plan will be managed in accordance with the quality assurance
and project plan (QAPP) submitted to MDNRE for approval and compared in tabulated format to Part
201 Soil Generic Residential Cleanup Criteria (as wells as site-specific background concentrations
for metals, should Enbridge decide to develop such criteria). If the analytical results are below the
criteria for all of the randomly selected quadrants within a given grid, the location will be considered
suitable for backfilling with clean material (if necessary), landscaping (if necessary) and final
closure. If the reported data in one or more of the randomly selected quadrants within a grid exceed
Part 201 Soil Cleanup Criteria, additional soil removal will be completed in that quadrant, and then
the quadrant(s) will be re-sampled at the locations previously sampled. Should the follow-up
concentrations be below Part 201 Cleanup Criteria, the gridded area will be considered suitable for
backfilling with clean material (if necessary), landscaping (if necessary) and final closure.
19
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5.0 Reporting
A final report will be prepared after all tasks outlined in this Plan for all identified sites are
completed. The report will summarize field activities and will include analytical results in tables. In
the report, analytical data tables and an evaluation of results in relation to Part 201 soil generic
residential cleanup criteria, state default background levels and the U.S. EPA Region 5 Ecological
Risk Screening Levels for soil will be presented. Figures will be included where appropriate.
Information gathered during the Phase I SEE and Phase II SEI activities will be presented as well.
The report will be provided to U.S. EPA and MDNRE within five weeks of the completion of the
work. The report will serve as the basis for developing recommendations for additional actions, if
warranted.
20
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Figures
-------
MICHIGAN
Site Location
A Release Location
Line6B
©
Feet
500 0 500 1,000 1,500 2,000
Figure 1
SITE LOCATION
Enbridge Line 6B MP608
Pipeline Release
Marshall, Michigan
ENBRIDGE
-------
C0.5 Decon Area Locations
Kalamazoo
h Dcti
Yard 4
Locations
Division Dr
SSAA Locations
OB,]
~IP RRelease
Location
Frac Tank City
Locations
lagery: FSA2010
Ik Release Location
- - Line6B
Soil Staging or Decon Area
City Boundary
1,000
Feet
1,000 2,000
3,000 4,000
Figure 2
LOCATIONS OF SOIL STAGING AND
DECON AREAS
Enbridge Line 6B MP608
Pipeline Release
Marshall, Michigan
ENBRIDGE
-------
~ Soil Staging Area
Staging Area Quadrant
SSAA Cell
Staging Area Quadrant (25% Sample)
~ SSAA Cell (25% Sample)
City Boundary
Figure 3
SSAA SAMPLE LOCATIONS
Enbridge Line 6B MP608
Pipeline Release
Marshall, Michigan
ENBRIDGE
-------
~ Soil Staging Area
~ Stagi ng Area Quad rant
Staging Area Quadrant (25% Sample)
Yard 4 Cell
~ Yard 4 Cells (25% Sample)
©
Feet
25 0 25 50 75 100
Figure 4
YARD 4 SAMPLE LOCATIONS
Enbridge Line 6B MP608
Pipeline Release
Marshall, Michigan
ENBRIDGE
-------
Soil Staging Area
Staging Area Quadrant
Staging Area Quadrant (25% Sample)
Figure 5
FRAC TANK CITY DECON AREA
SAMPLE LOCATIONS
Enbridge Line 6B MP608
Pipeline Release
Marshall, Michigan
ENBRIDGE
-------
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H V fev&T Wlf
<]' ri-',: 'jfej.' .vH. ' ,'*[.,£ *£ l> '¦¦*- 'ft ' jjs '
frlefc-' Si ¦- %5'&*>\x<&) *&'¦ i a . ^
;¦ > t;4«r*• ¦ Ac '-;" '*%**/K .• ,#J, ,. ¦*>** >•' *
lit jM? v ' I' '¦•'" if «A»/Jb *:
^¦1^1 > J sflRM *#i8K
50
100
200
Scale in Feet
1 inch = 100 feet
N
A
Figure 6
CO 5 DECON AREA
SAMPLE LOCATIONS
Enbridge Line 6B MP 608
Pipeline Release
Marshall. Ml
NBRIDGE
Drawn: BS 12/01/2010
Approved: DL 12/01/2010
Project#: 60162778
-------
169J170I
|^22. | 23 I
1261
118 I 19NMIH 201
l24|^^sj
27 |^E2af2^^|
V
| 65 |
R67J
b~t
L4^-L1 I
i7mm
HI
H 94 | J 95 |
11001
Ew^Bo2£^Fip|l
106 107 y 1081
C09E1S01
||jlM
K§^
B3 8^H 13 9W14Q11*?!
Il52p J
Map Location
Legend
Frac Tank City Quadrant (25% Sample)
Frac Tank City Quadrant
Figure 7
FTC SAMPLE LOCATIONS
Enbridge Line 6B MP 608
Pipeline Release
Marshall. Ml
Drawn: BS 12/21/2010
Approved: DL 12/21/2010
Project#: 60162778
0J»
ENBRIDGE
-------
Legend
m Dredging Area Quadrant (25% Sample)
Dredging Area Quadrant
~ Feature Outline
50
100
200
Scale in Feet
N
A
Figure 8
SUBMERGED OIL DREDGING
WASTEWATER TREATMENT &
GEOTUBEAREA SAMPLE LOCATIONS
Eribridge Line 6B MP 608
Pipeline Release
Marshall, Ml
NBRIDGE
Drawn: BS 12/21/2010
Approved: DL 12/21/2010
Project#: 60162778
-------
Attachment A
-------
Attachment A
Line 6B; Marshall, Ml
List of River Access and Other Work Sites
River Access Site Name
Milepost
Access Point
Tract
Estimated
Number
of
Samples
Comment
Nov. 29 Update
Division C
CO.O Parking
2.2
CO.O
KN-C-085
11
CO.O
2.25
CO.O
TC-B-078
CO.O
2.25
CO.O
TC-B-078.001
Gildea
2.75
117 FRIENDSHIP LANE
KS-C-093
0
Boom tie-off only
Island Access
4.25
multiple
0
CO.3
4.75
CO.3
KS-C-115
TBD
Site still in use
CO.4
5.1
12420 C Dr N
KN-C-094
4
CO.5 Boom
5.4
CO.5
River
0
Is not a work site
CO.5 Boat Ramp
5.4
CO.5
KS-C-117
6
CO.5 Decon
5.4
CO.5
KS-C-117
62
Maybe used in
2011
CO.5 Dredge Spoil
5.5
CO.5
KS-C-117
40
Gridded sampling
CI Consumers Energy
5.8
CI
KS-C-123
19
CI Ceresco Power
5.8
CI
KS-C-124
CI Fowler access
5.8
CI
KN-C-110
CI Parking
5.8
CI
KS-C-127
CI Boom
6
CI
KN-C-113
CI Access
6
CI
KN-C-113
CI Descending Rt Bank
6.25
CI
KN-C-116
Cl.x Access
6.6
CI
KN-C-121
0
Site not used
C Driver Access
7.3
13858 11 Mile Road
KS-C131
0
Boom tie-off only
CI.5 Access
7.5
CI.5
KS-C-135
TBD
CI.5 Parking
7.5
CI.5
KS-C-134
CI.5 Ramp
7.5
CI.5
KS-C-132
C2 Access
9.15
C2
KN-C-125
2
C3 Access
9.4
C3
KN-C-125
8
C3 Access
9.4
C3
KN-C127/128
C3.2 Parking
9.8
C3.2
KS-C-156
TBD
C3.2 Access/Ramp
9.85
C3.2
KS-C-156
C3.7 Access
11.25
C3.7
KS-C-166
23
-------
Attachment A
Line 6B; Marshall, Ml
List of River Access and Other Work Sites
River Access Site Name
Helispot H3.8
Milepost
11.5
Access Point
H3.8
Tract
unknown
Estimated
Number
of
Samples
0
Comment
Nov. 29 Update
C3.x
11.8
2224 E Columbia Ave
KN-C-134
0
Site not used
C3.9
12.2
C3.9
KN-C-138
12
C4
12.55
848 S Raymond Rd
KS-C-176
0
C4
12.55
upstream of C-176
KS-C-174
C4.8 River
13.25
C4.8
KS-C-182
0
C4.8 Parking
13.25
C4.8
10-620-014-00
C4.85
14
C4.85
KS-C-195
0
C5
14.8
C5
KN-C-165/169
18
C6
15.4
C6
KS-C-283
1
C-vandenbrink
16.5
258 W Hamblin Ave
KS-C-304
0
Site not used
C-coppock
16.6
292 W Hamblin Ave
KS-C-305
0
Site not used
Division D
DO.5
17.6
842 Jackson St W
city property
2
D1 Sediment Curtain
18
898 Jackson St W
city property
9
D2 Boat Ramp
18.7
1364 Jackson St W
city property
14
D2.5 Access point
18.9
1502 Jackson St W
city property
25
D3 Boat Ramp
19.4
1724 Jackson St W
city property
20
D5 Boom Access
21.25
516 Custer Dr
road ROW
2
D5NW (C&M Const.)
21.25
TBD
Division E
E0.1 Containment Access
24.6
1936 River Rd W
railroad ROW
0
CNL. Boom tie-off
E0.5 Gabion Baskets
26.4
E0.5
river access
TBD
EO.5-2
26.8
E0.5
KN-E-344
0
Site not used
E0.5 Boom
26.9
E0.5
KN-E-347
19
E0.5 Decon
26.9
E0.5
KN-E-347
E0.5 Site Access
26.9
E0.5
KN-E-347
E0.6 Containment access
28.2
15038 River Rd
KS-E-411
0
CNL
E0.8 Containment access
28.8
436 Michigan 96
road ROW
0
CNL
El Boom Access
29.4
Church St
KN-E-378
7
E2 Boat Ramp
30
Fort Custer Rec Area
KS-E-431
16
E2.3 Containment access
34.35
Climax Drive
KS-E-462
0
Boom tie-off only
-------
Attachment A
Line 6B; Marshall, Ml
List of River Access and Other Work Sites
River Access Site Name
E2.4 Containment access
Milepost
34.55
Access Point
11572 E Michigan Ave
Tract
KN-E-396
Estimated
Number
of
Samples
0
Comment
Nov. 29 Update
Boom tie-off only
E3 Boat Ramp/Boom
35.2
186 E Michigan Ave
KN-E-406
9
E3.5 Containment access
36.55
S 35th St
road ROW
0
E4 Ramp/Boom access
37.75
9424 E Michigan Ave
KN-E-424
19
E4.5 Ramp
38.5
Plaza Avenue
unknown
TBD
E5 Dam access
39.85
Consumers Power Dr
unknown
TBD
Other Work Site Name
Milepost
Access Point
Tract
Estimated
Number
of
Samples
Comment
Nov. 29 Update
Staging Yard 1
NA
NA
NA
0
For storage only
Staging Yard 2
NA
NA
NA
TBD
In use by Youngs
Staging Yard 3
NA
NA
NA
6
Staging Yard 5
NA
C3.2
NA
TBD
To be used in
2011
B5
NA
NA
NA
0
Decon area -
Enbridge Owned
TBD = to be determined.
CNL = could not locate.
The number of samples listed in the right-most column are approximate and may change as more
information comes available.
-------
Attachment B
-------
Ridge wood Q r
C3.2 Parking
Gold*"
*i Wr pfil
'Staging Yard 3
C3 KN-C-127&128
Staging Yard 5
rpMyerona^F?d,
r Robins Ln
C1-CP |:|
C1 Parking (
C1-CE M
CO.5 Dredge
CO.5 Decon
Staging Yard 4
CO River TC-B-078.001
• TauuRd. - r '
Frac Tank City
Bl
ICeresco Daml
fmazomWi!y&
DIVISION B/C
I Incident
Command
Post
DIVISION A1 IB
Release Location]
DIVISION A|
Legend
DATE ISSUED: Dec. 16, 2010
Enbridge Energy, Limited Partnership
Kalamazoo River / Enbridge Spill Recovery
Temporary Facility Restoration and Demobilization Plan
Map 1 of 3
Enbridge Pipeline
River Centerline
Division Boundary
County Boundary
O Temporary Facility
® River Mile Point
§2t Release Location
DATE REVISED:
[HI atural
[fgfesources
Engineering Co.
715-395-5680
SCALE: 1:19,000
DRAWN BY: JAI/NMS
SERIES: Temp. Facility R&D
-------
«/larkhanv§tj
HarmoTiia Rd
Mptt'Rd
W@3j
DIVISION D / E
slmm
DIVISION C/D
Legend
DATE ISSUED: Dec. 16, 2010
Enbridge Energy, Limited Partnership
Kalamazoo River / Enbridge Spill Recovery
Temporary Facility Restoration and Demobilization Plan
Map 2 of 3
Enbridge Pipeline
River Centerline
Division Boundary
County Boundary
O Temporary Facility
® River Mile Point
§2t Release Location
DATE REVISED:
[HI atural
[fgfesources
Engineering Co.
715-395-5680
SCALE: 1:19,000
DRAWN BY: JAI/NMS
SERIES: Temp. Facility R&D
-------
I atural
esources
engineering Co.
715-395-5680
Legend
Enbridge Pipeline
River Centerline
Division Boundary
County Boundary
O Temporary Facility
® River Mile Point
§2t Release Location
Enbridge Energy, Limited Partnership
Kalamazoo River / Enbridge Spill Recovery
Temporary Facility Restoration and Demobilization Plan
Map 3 of 3
0.25 0.5 0.75
DATE ISSUED: Dec. 16, 2010
DATE REVISED:
SCALE: 1:19,000
DRAWN BY: JAI/NMS
ENBRIDGE
SERIES: Temp. Facility R&D
-------
I©®®©
18-340-078-00
KN-C -087
mmm
K.. »
A S®
• «rv
* ¦ TV 1: „ . ^ , t
T • -
S-»^ '
H- *
•s --5
5 . - w ' "£« s~, ¦>
i o
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
] Frac Tank
Fuel Area
] Light Generator
LJ Roll Off
^ Storage Area
Vac Truck
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan CO v2 010511 mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
|gfc. V-4 r 'Ml
6W«
I 1 . S9
¦ i f iSl
¦,rM
s&'ij
r* i , - u srft
, • ¦. .
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^CIS/BRIDGE AZCOM
Site: Gildea
Drawn: EC 1/5/2011
Decon Area
V7A Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan Gildea 01051 l.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
Site: Island Access
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C0_3N_lslandAccess_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
Drawn: EC 1/5/2011
W Michigan Ave
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization PIan\MXD\2OT1 01 05\SitePlan CO 3 010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
¦%
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Decon Area
V7A Chemical Storage
Containment Area
Storage Area
Vac Truck
Z:\Work\GIS\Site Demobilization Rlan\MXD\010311\SitePlan CO 4 010311 mxd
300
N
A
Enbridge Energy
Site: CO.4
Enbridge AZCOM
Drawn:
EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
River Aerial Photographed 9/27/10 Overlaid On an August 2010 Background Aerial
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: BS 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization PIan\MXD\20f1 01 05\SitePlan CO 5 010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
r fefui&l
Aifci J
HMIWa
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^ENBMDGE AICOM
Drawn: EC 1/5/2011
Decon Area
Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C0_5v2_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
16-307-021-00
¦KS-CTigW
16-301-015-00
¦festeii;i[8M
161300-027^00
KS-C-120
Dredging
16-300-024-00
16-300-033-00
CS-C-001
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
~ Parcels
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C_0_5_DredgingArea_010511 .mxd
River Aerial Photographed 9/27/10 Overlaid ori an August 2010 Background Aerial
Mfft
Enbridge Energy
Site: C-0.5 Dredging Area
^Jnbridgb AZCOM
Drawn: EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
Scale in Feet
-------
Map Location
Legend
Enbridge Energy
Quarter Mile Grid Segments
Feature Outline
Parcels
ENBRIDGE AZCOM
E Michigan
Drawn: EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site_Dernobilization_Plan\MXD\2011_01_05\SiteRlan_C1 v1_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
iISS
fH
'-t djr
Map Location
Legend
Enbridge Energy
Quarter Mile Grid Segments
Feature Outline
Parcels
ENBRIDGE AZCOM
E Michigan
Drawn: EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlari C1v2 010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
h 1
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^CIS/BRIDGE AZCOM
Drawn: EC 1/5/2011
Decon Area
V7A Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C1 v3_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
Drawn: EC 1/5/2011
Decon Area
Approved: EC 1/5/2011
Chemical Storage
Containment Area
Project#: 60162778
Z:\Work\GIS\Site Demobilization PIan\MXD\20f1 01 05\SitePlan C1 X 010511.mxd River Aerial Photographed 9/17/10 Overlaid on an August 2010 Background Aerial
-------
10-026-008-20
¦KSl£l1f32M
Driver Property
10-025-002-00
KS-C-131 .OUT001
Map Location
Legend
Enbridge Energy
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
] Frac Tank
Fuel Area
] Light Generator
LJ Roll Off
^ Storage Area
Vac Truck
NBRIDGE AZCOM
Site: C Driver Access
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization PIan\MXD\2Qf1 01 05\SitePlan C DriverAccess 010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
10-023-003-00
¦KNleliaal
10-026-008-10
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^CIS/BRIDGE AZCOM
Drawn: EC 1/5/2011
Decon Area
V7A Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C1_5_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Decon Area
Chemical Storage
Containment Area
Storage Area
Vac Truck
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan C2 010511.mxd
Enbridge Energy
CAMBRIDGE AZCOM
Site: C2
N
Drawn: EC 1/5/2011
A
Approved: EC 1/5/2011
r\
Project#: 60162778
River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^ENBMDGE AICOM
Drawn: EC 1/5/2011
Decon Area
Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C3_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^ENBMDGE AICOM
Drawn: EC 1/5/2011
Decon Area
Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C3v2_010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^ENBMDGE AICOM
Drawn: EC 1/5/2011
Decon Area
V7A Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C3_2_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan C3 7 010511.mxd
River Aerial Photographed 9/27/10 Overlaid ori an August 2010 Background Aerial
Enbridge Energy
Site: C3.7
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
~ Parcels
I I AST
Decon Area
Y/A Chemical Storage
Containment Area
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
cEENBRIDGE AZCOM
Drawn: EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
Scale in Feet
-------
Legend
Quarter Mile Grid Segments
Feature Outline
^ Parcels
Equipment Storage
] Frac Tank
Fuel Area
Enbridge Energy
Site: H3.8
eniBRIDGE
AICOM
1 1 AST
DeconArea
Y/A Chemical Storage
] Light Generator
||_J Roll Off
"j Storage Area
0
40
80
160
N
Drawn: EC
1/5/2011
i\
Approved: EC
1/5/2011
i\
^ Containment Area
Vac Truck
Scale in Feet
A
Project#: 60162778
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan H3 8 010511.mxd
River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
~ Parcels
I I AST
Decon Area
Y//1 Chemical Storage
Containment Area
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
Enbridge Energy
Site: C3.X
75
150
300
N
Scale in Feet
Abridge AICOM
Drawn: EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan C3 X 010511.mxd
-------
m wi
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
BRIDGE AICOM
Qchigarfri
Drawn: EC 1/5/2011
Decon Area
Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C3_9_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
ABRIDGE AZCOM
Drawn: EC 1/5/2011
Decon Area
Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C4_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Enbridge Energy
C^EN BRIDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
Drawn: EC 1/5/2011
Decon Area
Approved: EC 1/5/2011
Chemical Storage
Containment Area
Project#: 60162778
Z:\Work\GIS\Site Demobilization PIan\MXD\20f1 01 05\SitePlan C4 8 010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
'-UWU-I'QO-Ii
KS-C-193
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^CIS/BRIDGE AZCOM
Drawn: EC 1/5/2011
Decon Area
V7A Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011 _01_05\SitePlan_C4_85_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^CIS/BRIDGE AZCOM
Drawn: EC 1/5/2011
Decon Area
V7A Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan C5 010511.mxd
-------
3140-00^026-0
KSpJ283p!
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^CIS/BRIDGE AZCOM
Drawn: EC 1/5/2011
Decon Area
Y/A Chemical Storage
Containment Area
Columbia Ave W
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_C6_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
0390-00-158-0
KS-C-304
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
Site:
C-Vandenbrink and C-Coppock
£N BRIDGE AICOM
Drawn: EC 1/5/2011
Decon Area
Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_Cvandenbrink_Ccoppock_010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Legend
Quarter Mile Grid Segments
Equipment Storage
Feature Outline
Frac Tank
Parcels
Fuel Area
1 1 AST
Light Generator
N
A
Decon Area
Roll Off 0
75
150
300
Y//1 Chemical Storage
Containment Area
j Storage Area
Vac Truck
Scale in Feet
A
Enbridge Energy
Site: DO.5
Enbridge AZCOM
Drawn: EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan DO 5 010511.mxd
River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^CIS/BRIDGE AZCOM
Drawn: EC 1/5/2011
Decon Area
Chemical Storage
Containment Area
Columbia Ave W
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_D1_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Legend
Quarter Mile Grid Segments
Feature Outline
~ Parcels
I I AST
Decon Area
V77 Chemical Storage
Containment Area
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
75
150
300
Scale in Feet
N
A
Enbridge Energy
Site: D2
EHBRIDGE AZCOM
Drawn: EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan D2 010511.mxd
River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
^ENBMDGE AICOM
Drawn: EC 1/5/2011
Decon Area
V7A Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_D2_5_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Decon Area
Chemical Storage
Containment Area
Columbia A'/eW
Storage Area
Vac Truck
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan D3 010511.mxd
300
Enbridge
Energy
CNBRIDGE
AICOM
Site:
D3
N
Drawn: EC
1/5/2011
A
Approved: EC
1/5/2011
r\
Project#: 60162778
River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
^ Parcels
Equipment Storage
] Frac Tank
Fuel Area
Enbridge Energy
Site: D5
eniBRIDGE
AICOM
1 1 AST
ZJ Decon Area
K/J3 Chemical Storage
Light Generator
Roll Off
Storaae Area
0
50
100
200
N
Drawn: EC
1/5/2011
yw DickmanRd
A
Approved: EC
1/5/2011
"TIT \
Containment Area
"1 Vac Truck
Scale in Feet
A
Project#: 60162778
Z:\Work\GIS\Site Demobilization PIan\MXD\20f1 01 05\SiteP!an D5 1 010511.mxd
River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
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-------
Map Location
Legend
Quarter Mile Grid Segments
Parcels
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
ABRIDGE AZCOM
Site: D5NW (C&M Construction)
Decon Area
V7A Chemical Storage
Containment Area
Drawn: EC 1/5/2011
Storage Area
Approved: EC 1/5/2011
Vac Truck
Project#: 60162778
Equipment Storage
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_D5NWCMConst_01 0511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
sail
i*Rs-
04-25-180-011
l/t-l
©4-25-210-015
¦Iffi|2334'fl:
mj%&56-010.
KS-E-410
04-25-474-020
KS-E-410.001
04-25-390-010
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Enbridge Energy
^CIS/BRIDGE AZCOM
Site: E0.1 Containment Access
Light Generator
Roll Off
Drawn: EC 1/5/2011
Decon Area
V7A Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan E0 1 ContainmentAccess 010511 .rnxd River Aerial Photographed 9/27/10 Overlaid on August 2010 Background Aerial
-------
¦i» *¦"
M f, i -
U|(- »¦ '
£IS«®a®
04-26-380-010
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Enbridge Energy
C^EN BRIDGE AICOM
Drawn: EC 1/5/2011
Decon Area
Chemical Storage
Containment Area
Approved: EC 1/5/2011
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\010311\SitePlan_E0_5_010311.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan EO 6 ContainmentAccess 010511 rnxd
River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
Scale in Feet
Enbridge Energy
Enbridge fiZCOM
Site: E0.6 Containment Access
N
Drawn: EC 1/5/2011
A
Approved: EC 1/5/2011
r\
Project#: 60162778
Legend
Quarter Mile Grid Segments
Feature Outline
~ Parcels
I I AST
Decon Area
Chemical Storage
Containment Area
Equipment Storage
Frac Tank
Fuel Area
| Light Generator
Roll Off
Storage Area
Vac Truck
-------
04-34-418-013
KN-C-15j0pJjTOOj
3904-34-455-Olip
04-34-480-050
KS-E-425"00l1
04-34-468-019
KS-E-428
04-34-480-010
KS-E-425
3904-34;460-010
04-34-f470;0lD:
KS-E-429
3904-34-390-:0,1f2i
3904-34-465-010
3904-34-395-010
04-25-390-010
08-03-200-010
KS-E-430
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Enbridge Energy
BRIDGE AICOM
Qchigarfri
Site: E0.8 Containment Access
Light Generator
Roll Off
Drawn: EC 1/5/2011
Decon Area
Approved: EC 1/5/2011
Chemical Storage
Containment Area
Storage Area
Project#: 60162778
Vac Truck
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_E0_8_ContainmentAccess_010511 ,mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
] Frac Tank
Fuel Area
] Light Generator
LJ Roll Off
^ Storage Area
Vac Truck
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_E1_010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Erm
Map Location
Legend
Enbridge Energy
C^EN BRIDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
Drawn: EC 1/5/2011
Decon Area
Approved: EC 1/5/2011
Chemical Storage
Containment Area
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_E2_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
] Frac Tank
Fuel Area
] Light Generator
LJ Roll Off
Storage Area
Vac Truck
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization PIan\MXD\2OT1 01 05\SitePlan E2 3 010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
08-18-451-041
KN-E-398
Map Location
Legend
Enbridge Energy
BRIDGE AZCOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
] Frac Tank
Fuel Area
] Light Generator
LJ Roll Off
^ Storage Area
Vac Truck
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization PIan\MXD\2Qf1 01 05\SitePlan E2 4 010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
.
v
. .¦
mmn
5SS&' " . ifc._ : "_;
30? -- -1:--"
-JV-
hViik By
*r~- r |S «*
45te> "
Map Location
Legend
Quarter Mile Grid Segments
Equipment Storage
Feature Outline
~
Frac Tank
~| Parcels
Fuel Area
1 1 AST
~
Light Generator
] Decon Area
a
Roll Off
Y//\ Chemical Storage
~
Storage Area
] Containment Area
Vac Truck
50
100
200
Scale in Feet
N
A
Enbridge Energy
Site: E3
%
ENBRIDGE AZCOM
Drawn:
EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan E3 1 010511.mxd
River Aerial Photograph 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_E3_2_010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
[07/2^326-20
¦KN^SgW
;djg2a'305=o.i'g
¦i KN-E-421
JTi»-1
rCr Kifc^i'i j7a *+
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Drawn: EC 1/5/2011
Decon Area
Approved: EC 1/5/2011
Chemical Storage
Containment Area
Storage Area
Vac Truck
Project#: 60162778
Z:\Work\GIS\Site Demobilization Plan\MXD\2011 01 05\SitePlan E3 5 010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Storage Area
Vac Truck
Drawn: EC 1/5/2011
j] Decon Area
ZZ2\ Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_E4_010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
Legend
Enbridge Energy
^CIS/BRIDGE AZCOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
] Frac Tank
Fuel Area
] Light Generator
LJ Roll Off
^ Storage Area
Vac Truck
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_E4_5_010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
07-21-102-070
I07i2^i:02T080:
07-20-230-050
• ••
Map Location
1*7*. T
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Roll Off
Drawn: EC 1/5/2011
Decon Area
Approved: EC 1/5/2011
Chemical Storage
Containment Area
Storage Area
Vac Truck
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_E5_1_010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Map Location
1*7*. T
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
] Frac Tank
Fuel Area
] Light Generator
LJ Roll Off
^ Storage Area
Vac Truck
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_E5_2_010511 .mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Legend
Quarter Mile Grid Segments
Feature Outline
~ Parcels
I I AST
Decon Area
V77 Chemical Storage
Containment Area
Equipment Storage
Frac Tank
Fuel Area
| Light Generator
Roll Off
Storage Area
Vac Truck
Scale in Feet
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_StagingArea1_010511.mxd
"
Enbridge Energy
Site: Staging Yard 1
cEENBRIDGE AZCOM
Drawn: EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
Frac Tank
Fuel Area
Light Generator
Site: Staging Yard 2
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
J Roll Off
^ Storage Area
Vac Truck
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_StagingArea2_010511.mxd
-------
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
] Frac Tank
Fuel Area
] Light Generator
LJ Roll Off
] Storage Area
Vac Truck
Drawn: EC 1/5/2011
Site: Staging Yard 3
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\IVIXD\2011_01_05\SitePlan_StagirigArea_3_010511 .mxd
-------
Map Location
Legend
Quarter Mile Grid Segments
Feature Outline
~ Parcels
75
150
Scale in Feet
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_StagingYard5_010511.mxd
Staging Yard 5
300
N
A
Enbridge Energy
Site: Staging Yard 5
EHBRIDGE AZCOM
Drawn:
EC 1/5/2011
Approved: EC 1/5/2011
Project#: 60162778
River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
• I«v,'»
Map Location
Legend
Enbridge Energy
^ENBMDGE AICOM
Quarter Mile Grid Segments
Feature Outline
Parcels
Equipment Storage
] Frac Tank
Fuel Area
] Light Generator
LJ Roll Off
Storage Area
Vac Truck
Drawn: EC 1/5/2011
J) Decon Area
Chemical Storage
I Containment Area
Approved: EC 1/5/2011
Project#: 60162778
Z:\Work\GIS\Site_Demobilization_Plan\MXD\2011_01_05\SitePlan_B5_010511.mxd River Aerial Photographed 9/27/10 Overlaid on an August 2010 Background Aerial
-------
Attachment C
-------
Site Closure
Site Environmental Evaluation Form
Enbridge Line 6B MP 608 Pipeline Release
Site Name: Date:
Approximate Size & Location of the Site:
Inspectors:
~ Initial Inspection ~ Final Inspection
Others Present:
Site Supervisors/ Firm:
Interview
Name
Employer
Contact Information
Association with site
Date of interview
Activities at site
Identification of spills or other releases during use and occupancy based on interview (specify)
Current Owner/Occupant of the Site:
Historical Use of the Site:
Description of Access Ways:
Activities at Site (based on interview, visual inspection or other sources)
~ Decontammination ~ Earthwork ~ Fueling
~ Boat Launch ~ Access Roads (New) (If so, list types of containers (eg. ASTs, 5-gallon buckets) in
~ Boom Maintence ~ Secondary containment Section H
~ Roll Offs ~ Generators/ Light Plants ~ Chemical Storage
~ Porta Potties/Handwash ~ VAC Trucks (If so, list types & container sizes in Section H)
~ Mats/Geotextiles ~ Streambank Stabilization ~ Other (specify)
Any Remaining Equipment or consumables:
-------
Site Closure
Site Environmental Evaluation Form
Enbridge Line 6B MP 608 Pipeline Release
E) Site Visual Inspection
E.1) Observations related to site occupancy and use (Note Locations on map and take photograph)
E.2)
~ Soil Disturbance
~ Vegetation Disturbance
~ Litter
~ Evidence of release (staining, verbal communication)
~ Fill areas in flood plain, wetlands or river
~ Excavated areas in floodplain, wetlands or river
~ Brush/Stumps/Trees
~ Fencing damage
Observations related to release
~ Sheen on surface water
~ Oil on river/creek banks and rocks
~ Petroleum odor
~ Citrus odor
Notes
~ Evidence of release/staining in or around former decon
areas
~ Evidence of release/staining in or around former fueling
areas
~ Evidence of release/ staining in or around the former roll
off areas
~ Oil on tree trunks, vegetation, logs
~ Oil on structures (piers, bulkheads, bridges, culverts)
~ Other (specify)
E.3) Adjoining Properties
North:
South:
East:
West:
F) Records reviewed (Describe)
~ Aerial photographs (dates and source)
~ Other photographs (dates and source)
~ Inspection reports (date and source)
~ Other (specify)
~ Identification of spills or other releases based on records review (specify)
G) Recommendations:
H) Other Notes:
-------
Site Closure
Site Environmental Evaluation Form
Enbridge Line 6B MP 608 Pipeline Release
If Phase II Activities or remediation occured on-site provide the following information:
Date of Remediation Activities:
Location & Desciption of Area:
Size of Area Remediated (including square footage & depth):
Description of Activities Performed:
No. of Samples Collected:
Backfilling/Restoration Activities:
Notes:
-------
Attachment B
Talmadge Creek Swamp Mat Removal Sampling Plan
-------
EMBKIDGE™
Line 6b Incident - Talmadge Creek Swamp Mat Removal Sampling Plan
Purpose
The purpose of this plan is to identify the process by which the swamp mats adjacent to Talmadge Creek
will be removed, and how oil contaminated soil located under the swamp mats will be excavated.
Samples will be collected following excavation to document the condition following removal and to be
used to direct subsequent investigation and/or remediation efforts
The goal of this plan is to complete the removal of the swamp mat roads no later than the end of
October, 2010. It is not intended that this is the final process for the restoration of the Creek, but rather
an interim means to eliminate the safety hazards and land owner issues of leaving the swamp mat roads
in place over the winter and spring seasons, and to return the Creek to a more natural state in the
community. It is understood that further restorative and remediation work may be needed in the
future, and the means to do so will be evaluated at that time.
Overview of Process
The existing mat roads will be removed in a logical fashion. It is anticipated that mat removal will begin
at Division A5 and Division B4 on September 29, 2010. Mats will be removed based on traffic patterns,
completion of restoration activities, availability of equipment, and landowner limitations. The locations
where mat road removal occurs is expected to vary based on the above factors. To facilitate EPA and
MDNRE planning of resources, Enbridge will communicate to EPA and MDRE by noon each day the
locations that will be removed the following day. Enbridge will coordinate with the EPA and MDNRE
(and/or their designated onsite representatives) to make sure they are present at each mat clearing
location prior to conducting activities.
Contaminated mats will be segregated and transported to the contaminated material staging area at
Cell 1 where they will be chipped and added to the contaminated material stockpiles for subsequent
disposal at a landfill. Uncontaminated mats will be transported to staging areas in Yard 4 and near the
source area. Uncontaminated mats that are not needed for potential future use may be demobilized.
Areas of potential concern located near the confluence of Talmadge Creek and the Kalamazoo River as
well as the area immediately east of 16 Mile Road will be not be evaluated or addressed during mat
removal. Rather they will be evaluated during the subsequent MDNRE remedial investigation phase.
Logistics of Soil Identification and Sampling
Potential areas of oil contamination adjacent the mat roads were identified during the EPA clearing
process. These areas were identified as:
1. having free oil observed in the observation trench (located adjacent up bank of the Talmadge Creek)
2. locations where the X-tex fabric was placed in the excavation to segregate oil impacted soil from
clean fill material
3. where free oil was suspected of being under the mat roads based on observations and/or site
conditions
The attached figure and table indicates the known and suspected areas for oil contamination beneath
the mat roads.
During the mat removal process, an environmental representative will be on site to provide direction for
oil contaminated soil removal and verification sampling. This representative will observe the mat
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removal process and identify areas of oil impact. The representative will direct the excavation of oil
contaminated soil and will collect a sample once visual observation of the excavation indicates that no
oil remains. Soil samples will be collected from the floor of the excavated areas in general accordance
with the MDNRE guidance document entitled Sampling Strategies and Statistics Training Materials
(S3TM). To make the sample grid process simplified in the field, for excavations less than 60 lineal feet,
one soil sample will be collected from each 25-feet of linear excavation and submitted for laboratory
analysis. Excavations longer than 60 lineal feet may follow this 25-foot sampling frequency (which
exceeds S3TM requirements) or will have a sampling frequency calculated to follow the S3TM guidance
document. Samples will be analyzed for total petroleum hydrocarbons (TPH) parameters including
Gasoline Range Organics (GRO), Diesel Range Organics (DRO), and Oil Range Organics (ORO). Soil
samples will also be analyzed for volatile organic compounds (VOCs), polynuclear aromatic
hydrocarbons (PNAs), and select metals including barium, iron, nickel, vanadium, and molybdenum.
Once the soil sample has been collected from the excavation, the area will be immediately backfilled and
restored as per the MDNRE approved restoration work plan. The limits of the excavation, field
observations, and the location of the soil sample will be documented for future reference. The results of
the soil sample analysis will be tabulated and used to direct future investigation and interim response
activities.
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Legend
Areas
Roads
— Mat Roads
Talmadge Creek
Potential Areas of Concern
EWI Xtex Fabric Cells
~ Env Clearance Area
O
Feet
100 0 100 200
Figure X
Talmadge Creek
Swamp Mat Removal Plan
Sections 1, 2 & 3
Line 6B Release
Enbridge Energy
Marshall, Ml
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0)
CD
CD
Section 6
Section 4
Legend
Areas
Road
— Mat Roads
Talmadge Creek
Xtex Fabric Cells
~ Env Clearance Area
Potential Areas of Concern
O
Feet
100 0 100 200
Figure X
Talmadge Creek
Swamp Mat Removal Plan
Sections 3, 4, 5 & 6
Line 6B Release
Enbridge Energy
Marshall, Ml
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Section 10
Section 9
Section 8
Legend
Areas
Road
— Mat Roads
Talmadge Creek
IVS
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RESPONSE TO COMMENTS LOG
Re: U.S. EPA Notice of Conditional Approval of Enbridge Energy, Limited Partnership's
May 13, 2011, Waste Treatment, Transportation and Disposal Plan in response to the
Administrative Order issued by U.S. EPA on July 27, 2010, pursuant to§311(c) of the
Clean Water Act (Docket No.CWA 1321-5-10-001) and Supplement to the Administrative
Order issued by U.S. EPA on September 23, 2010.
Based on our review of your letter dated May 17, 2011, we have revised the Enbridge Line 6B
MP 608, Marshall, Ml Pipeline Release, Waste Treatment, Transportation and Disposal (WTTD)
Plan, Enbridge Energy, Limited Partnership, (initially dated August 2, 2010, revised: August 8,
2010, supplemental revision: August 8, 2010, Supplemental revision October 28, 2010, revised:
March 4, 2011, revised: March 23, 2011,revised: May 2, 2011, revised: May 13, 2011) as noted
below. The changes are provided in the attached revised WTTD Plan and discussed in the
following letter. Our modifications are outlined in bold and follow the agencies comments from
the letter.
Waste Treatment, Transportation and Disposal Plan
Specific comments are set forth below and shall be incorporated into a revised WTTD Plan.
a) Section 3.4.2 Control Point Sampling Procedure.
i) Second set of bullets, seventh bullet: please replace "Aliquots for the debris
composite aliquot sample are..." with "Aliquots for the debris composite sample
are...
Response: Corrected
b) Section 3.6 De Minimis Hazardous Waste
i) Please provide a detailed description of staging and handling of de minimis
hazardous waste prior to off-site disposal.
Response: Corrected/ De minimis hazardous waste such as spent bug
repellent, spent degreasers, spent mechanical or automotive products, spent
batteries, etc. will be manually collected, staged within ICP's designated
location in sealed, leak proof containers and disposed of properly in
accordance with all applicable federal, state, and local regulations.
c) Section 4.2 Liquid Waste Water
i) The referenced Water Management Plan (WMP) was previously approved.
Therefore, please change the status of the WMP to approved.
Response: Corrected
d) Section 4.3 Oil Impacted Media and Debris
i) Please remove "etc." from the third sentence.
Response: Corrected
e) Section 4.4 Municipal Solid Waste
i) Fourth paragraph: please provide a detailed description of staging and handling of
miscellaneous small waste streams prior to off-site disposal.
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RESPONSE TO COMMENTS LOG
Response: Corrected/ These have been characterized individually, manually
collected, staged within ICP's designated location in sealed, leak proof
containers, and are disposed of properly in accordance with all applicable
federal, state, and local regulations.
Attachments, Flow Charts
i) Please use a single term consistently to reference Enbridge's representatives
throughout the flow charts.
Response: Corrected
Attachment II, Transfer Plan - Transfer of Operations from Site A to Frac Tank City
i) Phase III, second paragraph: please change "EPA" to "USEPA."
Response: Corrected
ii) Figures 2 and 3: Please indicate the specific location within "Frac Tank City" where
fractionation tanks ("frac" tanks) and roll-off containers will be staged. Additionally,
please indicate if different areas will be used for frac tank/roll-off containers that are
in-use, versus staging for potential use.
Response: Corrected
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