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Mr.Aragon November 21, 2008 Page 4 of 9 they were stockpiled and then loaded into transport trucks for disposal/recycling at the Teichert Aggregates facility in Tracy, California. After the asphalt was removed, subsurface utility location operations were conducted. 2.3.2 Utility Identification It was anticipated that underground utilities might be located within the footprint of the SPCC Containment Structure area. As such, PG&E notified Underground Service Alert (USA) a minimum of 48 hours in advance of excavation operations at the Site. No underground utilities were observed. 2.3.3 Excavation and Loading of Impacted Material A total of 387.10 tons of MGP-impacted material was removed during the excavation for the SPCC Containment Structure in the areas identified in Figure 3. Table 1 provides a breakdown of the quantities of material removed by truckload. To avoid stockpiling of the soil, the impacted material was managed using two methods: 1) direct loading of impacted material into roll-off bins for storage, pending receipt of analytical data for soil characterization, or 2) direct loading of impacted materials into end dump trucks for off-site disposal after characterization was complete. All roll-off bins and end dump trucks were tarped or closed to prevent potential wind blown migration of impacted materials. 2.3.3.1 Health and Safety/Engineering Controls Safety for on-Site personnel, the surrounding community, and the environment was of primary concern at this Site. For this reason, health and safety measures and engineering controls were implemented during the excavation activities associated with the SPCC Containment Structure. A safety orientation meeting was held at the onset of Site operations to clarify all potential on- Site issues/hazards that were anticipated during Site operations, and their mitigation measures. In addition, daily tailgate meetings were held each day to reiterate the need for safe completion of work and to identify any potential hazards that were encountered during the previous day's events, and/or not anticipated as part of the pre-work safety orientation meeting. Site work was conducted in modified level D personal protective equipment, which consisted of a hard hat, American National Safety Institute-approved safety glasses, a reflective vest, leather and/or chemically resistant nitrile gloves (for handling of impacted materials and soil sampling), and steel toed boots. Sensitive issues associated with the project included the following: health and safety for personnel and the surrounding community, vapor and dust emissions, noise, and stormwater pollution prevention. The following paragraphs provide a detailed description for the completion of the excavation of the SPCC Containment Structure area in a safe and efficient manner with respect to the sensitive issues outlined above. Vapor Monitoring The proper management of dust/vapors/odors that could have emanated from the excavation area was critical to the completion of the project and to ensure that on-Site personnel, the surrounding community, and the environment were protected. To do this properly, the following series of steps, in hierarchical order, were initiated as necessary to control potential emissions: ■ Continuous application of water for dust control; ■ Covering of roll-off bins when material was not actively being removed or added to the bins; and