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RkanHarbor Work Plan Hazardous Waste Removal January 28, 2025 BACKGROUND AND SUMMARY The work to be completed is at Republic Services -Forward Landfill Facility, located at 9999 S. Austin Road, Manteca, CA 95336. The scope of work consists of the excavation, segregation, screening out concrete, sampling and offsite disposal of PCB Aroclor 1242 waste. The target material,which is mainly concrete, is comingled within a 3,864 cubic yard stockpile,which will be segregated into approximately 20 discrete stockpiles, each approximately 200 CY in size.Nearly all of the PCB liquid generated from the release was containerized within a 5-gallon bucket and not placed within the roll off container disposed of at Republic Landfill. Please Refer to Attachment 1 —Target Concrete Cleanup Photos and the corresponding lab analytical. During the segregation of each stockpile, any concrete observed within the stockpile will be removed and placed within a roll off container. The subsequent soil surrounding the concrete will also be placed within the roll off container to be disposed of offsite. Each stockpile will then be sampled for PCB Aroclor 1242 by a 3rd party consultant to be analyzed on an expedited Tum-around-time(TAT). Based on the analysis, all stockpiles with a non-detect(ND) will be combined and placed to the side and Clean Harbors will continue segregation, screening and sampling process until the entire stockpile is complete. Stockpiles that have concentrations of PCB Aroclor 1242 and any soil and screened concrete will be loaded into either end dumps or roll off container(s),manifested, transported and disposed at Clean Harbors' Grassy Mountain facility, located in Utah. If the screening process is unsuccessful in identifying the concrete material, the analytical results from each screened pile will determine if removal and off-site disposal will be required. PLANNING AND DOCUMENTATION HEALTH AND SAFETY PLAN A Site-Specific Health and Safety Plan(HASP)will be developed for this project to protect workers, the public, and the environment by Clean Harbors' Health& Safety Manager and it will incorporate facility and scope specific requirements and required tasks. The HASP identifies the specified work tasks, associated equipment and the risks associated with each activity. Prior to the commencement of work, all project personnel will review HASP to understand the contaminants of concern,job related hazards and the potential emergency situations. All employees working in direct contact with contaminated soils will have completed the OSHA 40-hour health& safety training program, an 8-hour annual refresher program and participate in a medical monitoring program in accordance with CFR 1910.120. The most important statistic for any job is zero incidents or injuries. All Clean Harbors personnel from top management to the field personnel are committed to this outcome. A daily safety tailgate meeting will be conducted onsite each morning,which will include review of corresponding Job Hazard Analysis (JHA) corresponding to the scheduled tasks of the day, as well as the completion of the Clean Harbors Hazardous Work Permit. Copies of these documents will be kept with the project files. 1 ✓SAFETYFIRST1