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Fmm:Hamid S.Petery Harold S.Peters:PE RF_N 91598D S To:Bob Huntley at Steckfon P148n0 Pape 2of4 T.Ww.Mw W.1M 8:14:08 PM Closure of PBR Treatment System for Stockton Plating Closure of the treatment system begins after all process liquid wastes have been sent to the treatment system. Pipes from process area to treatment area. Flush the lines from the process areas to the treatment system system for one hour using fresh water at a rate between 50% and 75% of the normal flow rate to the system. The flush water must enter the treatment system at the southern most section of piping to the treatment system. Have all of the flush water flow through the one line at a time. This will flush and provide treatment for the waste that is in the piping system at the beginning of the shutdown. Test the water at the discharge end of the pipe. The water should contain less than 25 ppm of total metals. The cyanide line should contain less than 2 ppm of cyanide. If not, continue flushing the problem line for an additional one hour and repeat the testing. Repeat flushing and testing as required. Install a plug equipped with a 1h" or Bb" air hose connection and valve in the inlet of the pipe. Connect a compressed air hose to the valve in the plug. Physically secure the air hose so that the hose could not whip if the plug were to come out of the pipe. Rapidly open the valve and blow air through the pipe for 5 minutes and then shut off the air. Observe the discharge end of the pipe when the air is shut off. Leave the air off for 5 minutes and repeat the air purging two more times. If there is still a liquid discharge from the pipe at the end of the final air purge, repeat the purge until no additional liquid discharge is observed. Using a backhoe, carefully expose the tops of the pipes the full distance from the process area to the treatment area. If there is any indication of leakage from the pipes by soil discoloration or other visual clue, mark both the pipe and the spoil area with a 2' tall wooden stake. Approximately every 20', dig a 4' to 6' long, V to 2' deep excavation beside the pipes. These areas will be used as a work area to cut the pipe for removal of that section of pipe. Remove the pipes starting at the south end. Remove all three pipes at each section. Hand dig under the pipes so that a collection pan can be placed under the location of the cut. Cut the pipe using a hand saw or a reciprocating saw. Remove the pipe carefully using the back hoe to lift the exposed end of the pipe toward the collection pan. See attached sketch for details. Take any removed sections of pipe inside the Stockton Plating yard any time the area will be unattended for more than 30 minutes. The pipes will be visually inspected to determine if a test for hazardous waste evaluation is justified. If there is visible scaling or solids, the pipes will be managed as hazardous waste. If the pipes are relatively free of solids, the pipes will be sampled to confirm that they can be managed as hazardous waste. Sampling will be performed by Harold Peters. The samples will be analyzed for copper, nickel and chromium. If the samples are acceptable by TMC criteria, the pipe will be disposed to the municipal landfill. If the pipe fails the T'17-C, the pipe will be disposed as hazardous. Pipe may be cut into appropriate sizes for disposal.