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DRAFT FINAL

Bayou Corne Sinkhole Containment SystemMaintenance and Contingency Plan

S u b m i t t e d b y :

Texas Brine Company L.L.C.

December 13, 2013


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Investig

Bayou Corne Sinkhole ContainmentSystem Maintenance and ContingencyPlan

Submitted by:

Texas Brine Company L.L.C.

4800 San FelipeHouston, Texas 77056

Prepared by:

4900 Pearl East Circle, Suite 300WBoulder CO 80301(303) 447-1823

Fax (303) 447-1836

Tetra Tech Project No. 114-010647

December 13, 2013


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Bayou Corne Sinkhole Containment System Maintenance and Contingency Plan Texas Brine Company L.L.C.

Tetra Tech December 13, 2013 i

TABLE OF CONTENTS

TABLE OF CONTENTS ..............................................................................................................i

1.0 Background ...................................................................................................................1

2.0 Introduction ...................................................................................................................43.0 Responsibility Matrix ....................................................................................................5

4.0 Surface Water Quality Monitoring ................................................................................6

5.0 Monitoring Sinkhole Growth And Levee Subsidence .................................................8

6.0 Containment System Inspection Activities................................................................11

7.0 Routine Maintenance Activities..................................................................................13

8.0 Corrective Measures for System Damage .................................................................14

9.0 Emergency Response Actions ...................................................................................16

10.0 Addressing Potential Impacts to Bayou Corne .........................................................17

LIST OF TABLES

Table 1 Materials and Supplies for Containment RepairTable 2 Consultants and Contractors Available to Assist with Repairs

LIST OF FIGURESFigure 1 Sinkhole Containment System Plan ViewFigure 2a Containment Berm and Sinkhole PlanFigure 2b Containment Berm and Sinkhole ProfilesFigure 3 Inclinometer, Tiltmeter and Water Level Instrument LocationsFigure 4 Proposed Southern Berm Relocation Option

LIST OF APPENDICES

Appendix A Surface Water Monitoring PlanAppendix B Sinkhole Water Quality Depth Profile Sampling Recommended Requirements

Document (RRD-Gas-02)Appendix C Geotechnical Engineering Stability Report (To be added when report has been

completed at the end of December 2013)Appendix D Storm Water Pollution Prevention PlanAppendix E Evaluation of the Bayou Corne Maximum Sinkhole Extent in Lateral Directions;

and Comments on Maximum Bayou Corne Sinkhole Extents


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Tetra Tech December 13, 2013 1

1.0 BACKGROUND

Directive 5 of the Fourth Amendment to the Declaration of Emergency and Directive issued bythe State of Louisiana Department of Natural Resources Office of Conservation (Directive 5)requires Texas Brine Company, L.L.C. (TBC) to initiate installation of a containment systemaround the Bayou Corne sinkhole. Directive 5 further requires the sinkhole containment systemto prevent to the greatest extent practicable any dissolved concentrations of total petroleumhydrocarbons (TPH), elevated chlorides, or total dissolved solids (TDS) in the surface waterwithin the sinkhole and surrounding area from migrating in such a manner that will damage theenvironment.

In response to Directive 5, an integrated containment system was developed and implementedby TBC. Since completion of the containment system, it has become apparent that naturalconditions also play a role in preventing the hydrocarbons and chlorides from escaping thesinkhole. As a result, the primary components of the containment system consist of:

The naturally occurring hydraulic gradient whereby surface waters flow from areas

surrounding the sinkhole towards, and then down into, the sinkhole. This hydraulic

gradient results from the connection between the sinkhole waters and the Mississippi

River Alluvial Aquifer (MRAA).

A network of floating hydrocarbon control booms positioned within the containment area

on the surface water to trap and contain any floating petroleum hydrocarbons that may

surface. The booms can be moved around within the containment area to achieve

maximum effectiveness. Petroleum hydrocarbons trapped by the booms are removed

using vacuum trucks and skimmers and transferred to tanks. The petroleum

hydrocarbons in the tanks are periodically transferred to tank trucks and transported to

FAS Environmental.

Earthen levees that surround the sinkhole area, separating surface water above and

adjacent to the sinkhole from the surrounding marsh areas (see Figure 1). The levee

system includes two water transfer structures, each consisting of two 12-inch diameter

transfer pipes with valves that run through the levees which can be manually opened

and closed to allow water transfer from the marsh into the sinkhole to assist in

maintaining the sinkhole water level. There is also a levee overflow structure that

provides an armored section of levee to channel high water overflows should extremely

high water conditions be encountered.

Initial containment of the sinkhole surface waters was achieved in February 2013, with thecompletion of the levees occurring in September 2013. Daily measurements of the water levelswithin the containment area and in the marsh just outside of the containment systemconsistently demonstrate that the water levels within the containment system drop below thoseof the marsh. If left unadjusted, the water levels within the containment area would continue todrop over time, resulting in a differential of water surface elevations on either side of thecontainment levees. As mentioned above, this is due to the hydraulic connection between thesinkhole waters and the MRAA which has a typical static water level 5 10 feet below thesurrounding marsh water level.


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To maintain the water level differential between the marsh and the containment area atcontrolled levels, water is periodically transferred from the marsh into the containment area,either through transfer pipes that were installed through the containment system levees, or bypumping. The intention is to manage the water surface elevation differential in the 6 to 18inches range.

Since the sinkhole formed, and since the containment levee system was installed, the followinghave been observed:

The concentrations of dissolved constituents, such as TDS and chlorides, are lower atthe surface, and increase as depth increases in the sinkhole waters.

The amount of floating petroleum hydrocarbons that are appearing on the surface of thesinkhole water has declined significantly over time, and that at the time of thepreparation of this Contingency Plan the amount of those hydrocarbons was veryminimal. The TBC team responsible for hydrocarbon management at the sinkhole hasreported that there has been no new release of hydrocarbons observed since lateAugust 2013. Oil sheens have been seen since that time has been attributed to trappedoil in the floating vegetation.

Water levels in the sinkhole continuously drop versus the levels in the marsh just outsidethe containment levees unless water is allowed to transfer from the marsh into thecontainment system.

The observations listed above indicate the following:

1. A downward vertical gradient exists between the sinkhole and the marsh that reflects a

draining condition wherein the sinkhole, even without an artificial containment levee,

receives marsh water and conveys it deeper, rather than discharging water up and into

the marsh. The dissolved phase constituents in the sinkhole, such as dissolved solids,

hydrocarbons and chlorides, will tend to move along with the flow of water downward

into the sinkhole rather than upward toward the surface and out towards the marsh. Thisaccounts for the lower concentrations of TDS near the surface of the sinkhole and higher

concentrations of TDS at depth. The flow gradient towards the sinkhole therefore

provides the primary containment method for the dissolved constituents in water. Over

time, it is possible that the hydraulic connection between the sinkhole and the MRAA will

cease as the portions of the MRAA that are exposed in the sinkhole become sealed off

by deposited sediments from the surface.

2. The potential non-aqueous phase constituents in the sinkhole (e.g. free-phase

hydrocarbons) will tend to overcome the downward advection of water and move to the

upper surface of a water column because they are lighter than water. Non-aqueous

liquid petroleum hydrocarbons will tend to collect (and float) on the surface of the water

in the form of sheens or globules. Multiple rows of floating booms have been placed in

various locations at the surface of the sinkhole water to trap the hydrocarbons. The

trapped hydrocarbons are then removed from the sinkhole waters and sent off site. The

booms therefore provide the primary containment method for the floating hydrocarbons.

The rate at which the floating hydrocarbons are observed to be present on the sinkhole

surface waters has reduced substantially from late 2012 through the time that this

Contingency Plan was prepared. This observation could be an indication that most of


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the petroleum hydrocarbons that were present in the subsurface strata that were

disturbed by the sinkhole have already made their way to the surface, where they were

subsequently captured and removed from the top of the sinkhole water.

3. The earthen levee portion of the containment system creates an additional level of

containment for both the dissolved constituents and the floating hydrocarbons. With thelevees in place, water flow from the marsh towards the sinkhole is hampered, and if no

water is allowed to transfer (through pipes under the levees or by pumping), the

differential in the water levels between the marsh and the area enclosed by the

containment levees, quickly grows, with the water level within the containment area

being lower than that in the marsh. Therefore the levee system provides a secondary

level of containment that allows the primary methods (hydraulic gradient and floating

booms) to work more effectively.

This Maintenance and Contingency Plan describes actions that will be taken to monitor the

condition of the containment system, the surface waters in the containment area and

surrounding marsh, the growth of the sinkhole and the impacts from subsiding areas on the

condition and effectiveness of the containment system. The plan also describes

maintenance and repair activities to be performed to keep the containment system in good

operating condition. In addition, this plan provides trigger points in the event that sinkhole

growth and/or subsidence threatens to cause sections of the containment system levees to

become ineffective or breached to the degree that repair of those sections becomes unsafe

to workers, impossible or impracticable. If those trigger points are experienced, this plan

provides contingency measures to be followed for expanding the levee system to new areas

beyond the subsidence-impacted areas. This plan also addresses contingency plans for the

relocation of a portion of Bayou Corne in the event that the sinkhole expands towards, and

threatens to intercept, the bayou.


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2.0 INTRODUCTION

This Contingency Plan describes the following relative to the sinkhole containment system:

Responsibility matrix for monitoring, inspection, maintenance, repair and emergencyresponse;

Surface water quality monitoring;

Water quality depth profile monitoring;

Sinkhole growth monitoring;

Inspection activities and schedule;

Routine maintenance activities;

Corrective measures for damaged containment system components;

Emergency response actions; and

Addressing potential sinkhole impacts to Bayou Corne.

Each of these items is addressed in greater detail in the sections that follow in this ContingencyPlan.


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3.0 RESPONSIBILITY MATRIX

This section addresses the responsibilities for monitoring, inspection, maintenance, repair andemergency response actions associated with the sinkhole containment system. Thoseresponsibilities are as follows:

Overall decision-makers with the authority to initiate actions designated by the applicableplans as needed:

TBC Vice President of Operations, Bruce MartinPhone Number: (281) 808-5200Email address: [email protected]

or

United Brine Services Company LLC (UBC) President, Mark CartwrightPhone Number: (281) 744-4806Email address: [email protected]

Overall management and direction of containment system integrity operations, includinginspection of containment system conditions, repair of damaged areas and emergencyresponse management; and monitoring sinkhole growth trends and assessing potentialimpact of sinkhole to Bayou Corne:

TBC Response Manager, Charlie Burton and Neal StricklandPhone Number: 423-802-8426 (C. Burton); 404-538-2529 (N. Strickland)Email address: [email protected]; [email protected]

Management and direction of containment system routine maintenance activities:

TBC Response Operations Monitors, Maurice Valentine and Stella WilliamsPhone Number: 913-948-024(Maurice Valentine); 404-583-1230 (S Williams)Email address: [email protected]; [email protected]

Management and direction of surface water quality sampling and water quality depthprofile sampling, analysis and reporting:

Dave Angle of Michael Pisani & AssociatesPhone number: 281-242-5700Email address: [email protected]


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4.0 SURFACE WATER QUALITY MONITORING

Directive 5 requires regular monitoring of surface water both inside and outside the containmentsystem for the following constituents:

Total Petroleum Hydrocarbons (TPH);

Chlorides; and

Total Dissolved Solids (TDS).

A Surface Water Monitoring Plan has been prepared in response to the Directive 5requirements. That plan describes the surface water sampling activities that are conducted bothinside and outside of the containment system levees to monitor the performance of thecontainment system in accordance with the requirements of Directive 5. A copy of the plan isprovided in Appendix A of this Contingency Plan.

TBC also conducts water quality monitoring as specified in the Recommended RequirementsDocument RRD-Gas-02 Sinkhole Water Quality Depth Profile Sampling. A copy of RRD-Gas-02 is provided in Appendix B of this Contingency Plan. The objective of RRD-Gas-02 is toquantify and monitor the inorganic and organic chemical constituents and concentrations in thesinkhole for the entire water column from the water surface to the bottom of the sinkhole. Forthe purpose of monitoring the effectiveness of the containment system, the water quality in thetop 10 feet of sinkhole depth is of particular interest. If trends are observed that show significantincreases in the levels of chlorides, TDS or dissolved TPH in the top 10 feet of the watercolumn, it may be an indication that the hydraulic gradient has changed, and that water could becoming up out of the sinkhole towards the surface. If this condition continued, it could result inincreased concentrations for those constituents of interest further from the sinkhole and outtowards the containment levees. The sampling and analysis conducted under the SurfaceWater Monitoring Plan (see above) would be carefully reviewed to determine if the water qualityat the sampling locations both inside and outside of the containment levees has been impactedby the change in the water quality in the upper portion of the sinkhole profile.

If the sampling activities conducted under the Sinkhole Containment Surface Water MonitoringPlan identify an upward trend in chloride, TDS or TPH fractions detected at the current samplingpoints located on the outside the containment levee, the following actions will be initiated:

Immediately conduct another round of water quality sampling per the Surface WaterMonitoring Plan and conduct sinkhole water quality depth profile sampling for TDS,chlorides and TPH fractions (sinkhole conditions permitting) and increase the samplingfrequency to once per week.

Notify the Louisiana Department of Natural Resources (LDNR) and LouisianaDepartment of Environmental Quality (LDEQ) if the sample results showing the upwardtrend of TDS, chlorides and/or TPH fractions outside of the containment system leveesare confirmed by an additional sampling round.

Conduct an investigation as to the cause of the upward trend in the concentrations of theconstituents of concern outside of the containment levees. At a minimum, conductinspections of the containment system levees and water transfer pipes and valves todetermine if there are any apparent breaches in the system. If any breaches are found,refer to Section 8 of this Contingency Plan for response actions to be undertaken.

Evaluate the sinkhole/containment system waters to determine if a change in thedirection of flow has occurred and what has caused it. Determine if the changed flow


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condition is a temporary effect (such as a change caused by sinkholeturbulence/activity), or if it is a more permanent change.

The water quality sampling will continue at the increased frequency until the quality of thesurface water at the sampling stations on the outside of the containment system levees hasreturned to acceptable levels or if mutually agreed upon with LDNR and LDEQ.


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5.0 MONITORING SINKHOLE GROWTH AND LEVEE SUBSIDENCE

Subsidence of the ground below the containment system levees and other areas surroundingthe sinkhole has been observed. This has been especially prevalent along portions of the southlevee. When subsidence occurs in the areas where the containment levees are located, itresults in the elevation of the top of the levee dropping. If the subsidence continuesunaddressed, the elevation of the top of the levee could drop to a level that is below theelevation of the top of the marsh water. In that event, since the elevation of the top of the marshwater is higher than the elevation of the top of the containment area water, marsh water wouldflow over the top of the portion of the levee that has subsided and into the containment area.Primary containment of the sinkhole waters would still be in place at that time, due to thedownward flow gradient into the sinkhole and the presence of the floating hydrocarboncontainment booms remaining in place above the sinkhole. However, since the levee systemprovides secondary containment, backing up those primary containment conditions/measures, itwould be desirable to address the levee subsidence to maintain a separation between themarsh and the sinkhole surface water.

TBC has instituted monitoring measures to track the elevations of the containment system

levees and other areas surrounding the sinkhole so that corrective measures can beimplemented if the levee elevations drop too low. Those monitoring measures include thefollowing:

Settlement Plate Surveys During the construction of the containment system levees,settlement plates were installed at various locations around the perimeter of thecontainment system (see Figure 1). The purpose of the settlement plates is to provideestablished points where elevations can be measured on a regular schedule. Theelevations taken over time are compared to identify levee settlement trends. Currentlythe settlement plate elevation measurements are conducted several times per month.

Sinkhole and Surrounding Areas Bottom Elevation Profile Monitoring Currently,

comprehensive topographic and bathymetric measurements are made of the sinkholeand surrounding areas, approximately monthly, by a licensed professional surveyor,assuming the sinkhole alert levels allow such work. This frequency may be reduced inthe future if overall stability and reduced sinkhole growth and/or subsidence of the areaaround the sinkhole is observed. A plan view topographic contour map is prepared thatshows the current and past locations of specific contour lines such that the growth of thesinkhole and the subsidence of surrounding areas can be monitored over time. Inaddition, cross-section profiles are prepared along established axes that cut through thesinkhole. These profiles show the location of specific elevation contours as measuredon different dates. The profiles allow for the identification of sinkhole and subsidencegrowth trends over time. Review of the chronological plan and profile plot drawingsallows sinkhole growth patterns to be tracked and estimates for future sinkhole growth to

be projected. Figures 2a and 2b show a plan view and two cross section profiles thathave been prepared for areas adjacent to, and running through, the south levee showingthe trends of the bottom slope elevations in these areas over the past year.

Inclinometers, Tiltmeters and Water-Level Transducers Ground movement related tothe sinkhole may occur both in the form of sudden slope failures or gradual subsidence.Slope failures in particular present a risk to people and property. While slope failuresmay be sudden, they are usually preceded by more gradual movement that can bedetected by monitoring equipment. The current monitoring system that is in use in the


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vicinity of the sinkhole includes a network of inclinometers, tiltmeters and water-leveltransducers (see Figure 3). That instrumentation provides real-time early-warning ofground movement in the area by monitoring the rate and acceleration of subsurfacetilting or subsidence that are indicative of impending instability. Since the monitoringresults are available in real-time, these systems can be used to identify potential unsafeconditions and allows for people and equipment to be quickly relocated away from areas

deemed unstable. Instrumentation located further away from the sinkhole and beyondthe areas where influence from the sinkhole has been recorded helps to delineate thesize of the area where ground movement is occurring due to the sinkhole.

In addition to the currently-installed instruments, it is planned that two additionalinclinometer arrays will be installed between the south levee and Bayou Corne, asindicated on Figure 3. The inclinometer closest to the south levee will be installed priorto conducting the remaining work to repair the south levee so that it can be used tomonitor conditions at the levee to protect workers and equipment during the leveerepairs. In addition to the inclinometer, line-of-sight reflectors will be installed by MillerEngineers & Associates, Inc. and used to monitor the south levee conditions during theinstallation and construction activities to protect workers performing that work.

Once the new inclinometers have been installed, they will provide data that will be usefulin monitoring the long-term stability of the existing south berm and any potential impacton Bayou Corne.

The settlement plate surveys, sinkhole and surrounding areas elevation profile monitoring andinclinometer/tiltmeter/water level instrument readings will provide data on:

The elevation of the top surface of the levees;

The slope of the ground in the areas adjacent to the levees; and

The presence, rate and acceleration of ground movement in areas adjacent to thesinkhole, the containment system levees and Bayou Corne. In addition, at the location

of the proposed deep inclinometer arrays, the approximate depth of any shear failureplanes will be able to be detected.

If the above data indicates that the following trigger points have occurred, contingency actionswill be initiated, as described below:

1. If, after the currently planned repairs and restoration of the elevation of the south levee,a section of the containment levees has dropped 4 feet or more during a period of 30days or less, a new alignment route through a more stable area will be selected for thatlevee section.

2. If the bottom slope in the area immediately adjacent to a levee section is determinedthrough geotechnical analysis to create a condition where that levee section is unstable,

a new alignment route through a more stable area would be selected for that leveesection. A geotechnical engineering stability evaluation of the south levee is currentlybeing conducted and will be completed by December 27, 2013. The report that isprepared to present the findings of that evaluation will be added as Appendix C to thisplan when completed. Those findings will be used to determine the feasibility ofrepairing the south levee and if it is safe for workers to conduct the repair operations onthe levee.

3. If a section of the levee becomes damaged due to seismic activity and cannot berepaired, or if seismic activity creates a situation where the levee is considered unstable,


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a new alignment route through a more stable area would be selected for that leveesection.

4. If the any of the conditions described in items 1 through 3 above occurs for the southlevee, or a portion of the south levee, a new south levee will be constructed. The newlevee alignment will be selected just to the north of Bayou Corne, thus maintainingcontainment between the sinkhole and Bayou Corne (see Figure 4). If the new south

levee needs to be constructed, at that time contingency plans for re-routing Bayou Cornewill be further developed in the event that the sinkhole growth continues and the newlevee becomes threatened.

5. If a new south levee is constructed as stated above, and at some point in time the leveeelevation, sinkhole profile and/or inclinometer data indicate that the new levee is also injeopardy of failing, the plans will move forward for relocation of both Bayou Corne andthe south levee. This is further discussed in Section 10 of this Maintenance andContingency Plan.


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6.0 CONTAINMENT SYSTEM INSPECTION ACTIVITIES

The containment system primarily consists of earthen levees with sand cores covered by clay,limestone top surfaces, and vegetated side slopes. The side slopes on the sinkhole sideinclude geosynthetic clay liner (GCL) layer between the sand and clay, and the side slopes onthe marsh side contains a geotextile layer between the top of the clay and the bottom of thelimestone layers. While such construction is durable and stands up well under most conditions,periodic inspections are appropriate to help identify any erosion damage or other wear of thelevee materials that may occur. Early detection and correction of such damaged areas helpsprevent expansion of the problem.

In addition to the levees, the containment system also relies on floating booms to trap andcontain floating hydrocarbons that may be released from the sinkhole. The booms areinterconnected and periodically moved around to be best positioned to effectively control themovement of the floating hydrocarbons. Over time the booms can become worn and damaged,lessening their effectiveness. Periodic replacement of the booms may be necessary to maintaineffective hydrocarbon control.

The following are actions that could potentially result in damage to the containment systemcomponents:

Vehicular traffic causing ruts on the levees;

Storm water runoff causing erosion;

Wave action causing erosion or damaging the hydrocarbon containment booms;

Heavy winds, especially during tropical storm events, knocking trees down or blowingdebris onto the levees and damaging the hydrocarbon containment booms;

Sinkhole sloughing events that may cause damage/interruption of the oil containmentbooms;

Differential settlement or sudden subsidence of areas below sections of the levees; and

Sediment and debris buildup at the ends of the water transfer pipes partially or fullyblocking the pipes and valves making them difficult to operate.

Visual inspections of the levees are conducted at least once per week to observe the leveeconditions. Any damage is documented and reported to the TBC Response Manager so thatcorrective measures can be initiated to repair the damage. Damage that threatens to causeimminent loss of containment, or which has already caused loss of containment, will beaddressed immediately on an emergency response basis. Corrective and emergency responsemeasures are addressed later in this Contingency Plan.

The floating booms are inspected at least once per week, if conditions allow. The observedconditions of the booms are reported to the TBC Response Manager, who decides ifadjustments in dimension or location of the booms are necessary. Damaged or worn sectionsof boom are also documented and reported such that repairs can be planned and initiated.Repair measures are addressed later in this Contingency Plan.

The water levels for both the containment system and the adjacent marsh are recorded daily,and from those readings the differential of the water levels is calculated. TBC uses thisinformation to determine when to transfer water from the marsh to the sinkhole to keep thedifferential in the target range of 6 to 18 inches.


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TBC has implemented a Storm Water Pollution Prevention Plan (SWPPP) for the sinkholecontainment system and related access roads, equipment pads, etc. (see Appendix D). Thatplan describes best management practices (BMPs) for control of storm water duringconstruction activities at the site and specifies that inspection and maintenance procedures willbe implemented to maintain adequate sediment and erosion controls. Specifically, BMPs will beinspected at least once per week for a minimum of four inspections per month. BMPs also will

be inspected within 24 hours of the end of a storm event of 0.5 inches or greater. Inspectionswill be conducted by field personnel trained in the standards of performance and maintenancerequirements for individual BMPs. Inspectors will determine whether BMPs are in place, asrequired, properly maintained, and properly operating. Inspections will be documented using theInspection Report form provided to field personnel. In particular, inspectors will note areaswhere sediment transport may be occurring, as well as needed BMP maintenance orreplacement. Such maintenance or replacement normally will be initiated within 24 hours of theinspection findings. Inspectors will note specific indicators of storm water runoff, such as floatingsolids, settled solids, suspended solids, foam, or oil sheen.


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7.0 ROUTINE MAINTENANCE ACTIVITIES

The following routine maintenance activities are conducted when indicated as being necessarybased on the inspection observations:

Mow vegetation on levee side slopes, as required;

Restore vegetation in bare patches;

Regrade surface soils on levee slopes to repair small erosion rills;

Regrade and/or place additional limestone on top of the levees to repair ruts;

Clear debris and sediment away from the valves and ends of pipe at the water transferpipes;

Remove floating hydrocarbons that have been trapped by floating booms; and

Add new and/or replace worn sections of floating boom.

The above activities may be performed by either TBC personnel or contractors retained by TBC.


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8.0 CORRECTIVE MEASURES FOR SYSTEM DAMAGE

Damaged areas on the levee system will require repairs before the damage grows and thelevees become weakened or compromised. The nature and extent of the damage will dictatehow quickly the repair work needs to be initiated. For example, small bare patches invegetation or other small erosion-damaged areas require repair, but that work can be scheduledto occur in coordination with other activities at the site. Minor settlement of the levees can bemonitored to ensure that the levees are still functioning correctly. If the settlement continues tooccur, work to raise the levee heights can be scheduled. Examples of repairs that should beaddressed immediately include erosion damage that exposes or undercuts the geotextile or theGCL portions of the levees, large erosion cuts across the top of the levee, sections of the leveedamaged by trees or tree limbs that fall onto it during storms, and other such major damage.

Ensuring the safety of workers involved in inspecting, monitoring and repairing the containmentsystem is paramount to TBC. Bruce Martin, Vice President of Operations, TBC or, in hisabsence, Mark Cartwright, President of UBS, will be responsible for determining when suchwork may be conducted. In making such determination they will consider data supplied bypassive seismic monitoring equipment, inclinometers and sinkhole survey information. All

applicable OSHA regulations and any other applicable federal and state statutes shall befollowed in making such determinations.

The following actions would be taken in the event that damage to the containment systemcomponents occurs such that the ability of the levees to keep the marsh waters from flowinguncontrolled into the containment system is compromised:

Ensure that at least two rows of oil containment booms are deployed along the damagedor impacted levee.

Closely review the water quality monitoring data to see if the change in flow patterns isadversely impacting the water quality near the breached portion of the levee.

Monitor settlement and movement of the impacted sections of levee and repair/rebuildthe damaged sections as soon as its safe to do so.

If deemed necessary, increase the frequency of the sinkhole depth surveys to track thechanges to the sinkhole and slope of the slides.

If it becomes unfeasible or completely unsafe to repair or rebuild a damaged or subsidedlevee section that is allowing water to flow uncontrolled from the marsh into thecontainment area and if the water quality monitoring data show increasing trends in theconcentrations of TDS, chlorides and/or detectable levels of TPH fractions in surfacewater samples collected directly outside a sinkhole containment levee, then TBC wouldcommence actions to construct a new levee in a more stable location further away fromthe sinkhole and determine if a mitigation plan for the affected area is merited.

In the event that portions of the levee system experience damage to the extent that they areallowing water to pass through them, TBC will provide regular updates to LDNR and LDEQ andparticipate in review meetings as warranted to communicate the status of the sinkholecontainment system monitoring and repair activities and what additional action, if any, iswarranted. The construction of a new levee segment located further from the sinkhole willrequire the clearing of a corridor through the marsh, resulting in the loss of additional trees andother disturbance of the marsh environment. Therefore, such levee relocation should not bedone prematurely if other measures can be identified to satisfy the containment requirements ofDirective 5.


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To be prepared to expeditiously repair major damage to the containment system, TBC will havethe following readily available, either on site or at locations close to the site:

Sand, clay, limestone and geotextile fabric in quantities capable of being used to repair adamaged levee section. Since the length of a damaged section can vary quite a bitdepending on the cause of the damage, there should be a sufficient quantity of these

materials available in on site stockpiles to support up to two days of repair work, andadditional quantities readily available at nearby off site sources that could be brought tothe site prior to the onsite stockpile quantities being depleted.

Oil booms, absorbent pads, silt fencing and turbidity curtain in quantities that would beneeded to support levee repair work and emergency containment measures such asmight be required during levee system failure.

Construction equipment, tools, support vehicles and water craft to be used to repair thelevees, deploy the oil boom and turbidity curtain.

Adequate trained labor to safely manage, direct and perform the repair activities. Thiscan include TBC employees, consultants and contractors.

Table 1 provides a listing and the approximate quantities of materials and supplies that are to be

kept readily available for repair and emergency response activities. Table 2 provides a listing ofconsultants and contractors that TBC may utilize, as necessary, to assist with containmentsystem repairs.


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9.0 EMERGENCY RESPONSE ACTIONS

If sections of the containment levee system subside or become damaged such that theybecome breached and allow water to flow uncontrolled from the marsh into the containmentsystem, response measures will be implemented. The timing of that implementation isdependent on conditions at the sinkhole at the time. Such measures could include actions suchas deployment of additional oil booms, turbidity curtains, continuing to monitor water levels,and/or repair or replacement of sections of levees.

If levee repairs are considered, the following will occur:

The inspector or other person that discovers the damaged area notifies the TBCResponse Manager of nature and extent of containment system damage.

The TBC Response Manager will assess the source/cause of the subsidence or damageto ensure that it is safe for workers and equipment to mobilize to repair the levee.

After confirming the damage assessment, the TBC Response Manager will contact thefollowing regulatory agencies to notify them of the incident:

- LDNR- Louisiana Department of Environmental Quality (LDEQ)- Assumption Parish Office of Emergency Planning

The TBC Response Manager will contract a qualified engineering firm to determine thebest method of addressing and repairing the damage.

The TBC Response Manager will contact a qualified contractor, provide them with therepair information and authorize them to mobilize to the site with the equipment,manpower and supplies necessary to implement the repair work.

As soon as it is safe to do so, repair activities will commence. Initially the on-sitestockpiles can be utilized for the repair work, with additional material being brought tothe site to replenish the material used and to continue to supply the repair work.

As the repair work progresses, the retained engineering firm will conduct inspections anddocument the work being performed.

Once containment has been restored and the repair work completed, documentation ofthe activities completed will be prepared.

A review of the cause of the damage or containment loss will be conducted. A reportsummarizing the identification of the damage, the emergency response actions, andidentified cause of the damage will be prepared.

If levee repairs are not possible, or cannot be conducted safely, and the conditions specified inSection 8 regarding the decision to relocate sections of the levee system further away from thesinkhole apply, TBC will work with LDNR to select a new levee alignment route, and designplans and specifications will be prepared and used to direct the construction of the new levee

section.


20/113



10.0 ADDRESSING POTENTIAL IMPACTS TO BAYOU CORNE

The following trigger points will be used to determine actions to be taken with regard to possiblerelocation of a section of Bayou Corne:

1. If any of the trigger points described in Section 5 of this Maintenance and ContingencyPlan occur for the south levee and result in a decision to construct a new south levee,the new levee would be located approximately as shown in Figure 4. As that figureindicates, the new south levee would go from Oxy Taft 10 well pad (located at thesouthern end of the TBC plant access road) and continue to the west staying to the northand west of Bayou Corne, roughly paralleling the Bayou, and continuing on to the northto connect with the containment systems west levee. Selecting this route will helpensure that containment of the sinkhole surface waters is maintained prior to thosewaters reaching Bayou Corne. Note that, should this new south levee be required, thefinal alignment would be selected based on available information at that time.

2. The decision to construct a new south levee would initiate further development ofcontingency plans for re-routing Bayou Corne. A final decision to relocate Bayou Cornewill occur if Item 3 below occurs.

3. If any of the trigger points listed in Section 5 of this Maintenance and Contingency Planresult in the determination that the new south levee shown in Figure 4 is threatened bycontinued subsidence, actions will be initiated to determine what, if any, interimmeasures are needed to ensure containment and for the relocation of Bayou Corne.

As a contingency measure in the event that Bayou Corne does eventually need to be relocated,TBC has already contracted Tetra Tech to evaluate options and provide conceptual guidancefor re-routing of a portion of Bayou Corne. That evaluation included:

A field inspection of project site;

A cursory review of available information;

Identification of preliminary alternatives for reroute of Bayou Corne, includingidentification of an initially preferred alternative based on available information;

Development of a list of recommended studies and information required for selection ofpreferred alternative and final design; and

Development of order-of-magnitude cost estimate for design and construction of theinitially preferred reroute alignment.

The current size and shape of the sinkhole, and the growth it has exhibited since it formed inAugust 2012 through the time that this Contingency Plan was prepared (November 2013) do notindicate an impact to the Bayou Corne waterway in terms of TPH, chlorides and/or TDS. BothLDNRs consultants and those retained by TBC have reviewed the current conditions of thesinkhole and the brine cavern that has been the receptor of the sediments that created thesinkhole, and have concluded that Bayou Corne would not be encroached upon even usingexceedingly conservative assumptions.1

1See Brandshaug, T., 2013.Evaluation of the Bayou Corne Maximum Sinkhole Extent in

Lateral Directionsand Van Sambeek, 2013, Comments on Maximum Bayou Corne Sinkhole Extentsattached hereto as Appendix E.


21/113



Therefore, at this time further evaluation or engineering for a Bayou Corne reroute option doesnot appear warranted.

If the current south levee needs to be relocated, TBC will further develop plans for possiblerelocation of the bayou. The actions that would be taken at that time include:

1. Conduct survey of channel bed profile and representative cross sections.2. Investigate and apply design criteria for existing pipelines such as minimum burial depth

and other protection requirements,3. Refine channel re-reroute design for selected re-alignment route, as necessary. This

would include a review of existing and proposed bed elevations, substrate material,existing pipeline depths, and to the extent possible with the available data, channelvelocities and potential scour depths.

4. Develop final design recommendations for channel alignment and dimensions.5. Develop plans and specifications, and determine excavation quantities and construction

timelines.6. Initiate the permitting process with Office of Coastal Management (OCM) and US Army

Corp of Engineers (USACOE) for the relocation of Bayou Corne.

If the new south levee shown in Figure 4 is constructed, and if any of the trigger points listed inSection 5 of this Maintenance and Contingency Plan result in the determination that this newsouth levee is threatened by continuing subsidence, the plans for the relocation of Bayou Cornewill be made final, requests will be made to the appropriate agencies to conduct the relocationactivities, and the work will commence.


22/113

TABLES


23/113

Table 1. Materials and Supplies for Containment Repair

ITEM STORAGE LOCATION APPROXIMATE QUANTITY

STOREDSand Geophone Pad # 3 2,500 Tons

Clay Geophone Pad # 3 2,500 Tons

Limestone Geophone Pad # 3 & Pad 2

Near Geophone 1 Pad

1,500 Tons

Geosynthetic Clay Liner Geophone Pad # 3 2100 Linear Feet x 15 Feet

Wide

Geotextile Geophone Pad # 3 525 Linear Feet x 15 Feet

Wide

Oil Boom (soft) Maintenance Shop 1,000 Linear Feet

Oil Boom (hard) Maintenance Shop 1,700 Linear Feet

Absorbent Pads Maintenance Shop 5 Bags, 100 Pads Per Bag

Turbidity Curtain Maintenance Shop 1,000 Linear Feet


24/113

Table 2. Consultants and Contractors Available to Assist with Repairs

NAME Role Contact Information

Tetra Tech, Inc. Design, Construction Oversight Gregory Farrell, P.E.Phone 610-908-2596

Email [email protected]

Renes Trucking Supply trucks, sand, clay and

limestone

Rene Esneault

Phone 225-474-3500


Rocks Trucking General Contractor Rock Scioneaux

Phone 985-513-2711


Action

Environmental

Deployment of booms; Oil and

Debris Removal

Chas Leblanc

Phone 225-385-0850


Miller Engineers &

Associates, Inc.

Surveying Joel Miller

Phone - (337) 828-1950

Email - [email protected]


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FIGURES


26/113

PLAN VIEW

INITIAL CONTAINMENT SYSTEM LEVEE/ROADCENTERLINE

INITIAL CONTAINMENT SYSTEM LEVEE/ROADCROWN

INITIAL CONTAINMENT SYSTEM LEVEE/ROADBOTTOM OF SLOPE

EDGEOF TEXASBRINEROADS ANDPADSUSEDAS PART OF CONTAINMENT SYSTEM

APPROXIMATELOCATIONOF EXISTING PIPELINE

APPROXIMATESETTLEMENT PLATELOCATION(SEEDTL 2 ON SHT 4)

LEGEND

0

SCALE:

### #### 240'

#########

N

8911 North Capital of Texas HighwayBuilding 2, Suite 2310

Austin, TX 78759(512) 338-1667 (512) 338-1331 fax

BYREFERENCE REVISIONSNO. DATE

PROJECT NO.:

ENGINEER'S SEAL

DATE:

ISSUED BY

APPROVED BY:

CHECKED BY:

DRAWN BY:

DESIGNED BY:

FILE NAME:

TETRA TECH

ISSUED FOR SCALE: AS SHOWN

GTF

SHD

GTF

GTF

114-010647

-

- - - -

TEXAS BRINE COMPANY, LLC.SINKHOLE CONTAINMENT SYSTEM

114-010647 10

-

-

-

-

-

-

-

-

-

-

-

-

- - -

- -

- -

- -

- -

- -

- -

B-XX

ALTERNATIVECONTAINMENT SYSTEM LEVEE/ROADCENTERLINE

FINAL LEVEE ELEVATIONS

NORTH

EAST

SOUTH

WEST (ORIGINAL SECTION)

S ECTI ON A PP ROXI MA TE S TA TI ON/LOCATION TOP OF CLAY E LE VA TI ON

+5.0'

T EX AS B RI NE A CC ES S R OA D E XI ST IN G E LE VA TI ON

STA 18+00 - START OF NEW WEST LEVEE

WEST (NEW SECTION) +6.0'

+6.0'

+6.0'

SOUTH STA 46+00 - 48+00 TRANSITION FROM +6.0' TO +5.0'

SOUTH +5.0'

WEST (ORIGINAL SECTION) +6.0'

NORTH/WEST CORNER STA 15+00 - STA 16+00 +5.0'

APPROXIMATEBORING LOCATION

STA 16+00 - STA 18+00 TRANSITION FROM +5.0 ' TO +6 .0 'WEST (ORIGINAL SECTION)

SP-XX

STA.

1+00

STA.2+00

STA.3+00

STA.4+00

STA.

5+00

STA.6+00

STA.

7+00

STA.10+00

STA.11+00

STA.12+00

STA.13+00

STA.14+00

STA.

15+00

STA.28+00

STA.27+00

STA.26+00

STA.25+00

STA.24+00

STA.23+00

STA.22+00

STA.21+00

STA.20+00

STA.19+00

STA.18+00

STA.17+00

STA.16+00

STA.

42+00

STA.43+00

STA.

44+00

STA.

45+00

STA.

47+00

STA.48+00

STA.49+00

STA.50+00

S T A . 5 2 + 0 0

STA.33

+00

STA.

31+0

0

STA.

32+0

0

STA.34+00

STA.35+00

STA.36+00

STA.37+00

STA.

38+00

STA.39+00

STA.

40+00

STA.41+00

FLORIDAGASPIPELINE

FLORIDAGAS

PIPELIN

E

ACADIAN

GA

SPIPELINE

FLORIDA

GASPIPELINE

ACCESSROAD

T E X A S B R

CROSSTEXPIPELINE

ACADIAN

GAS

PIPELINE

FLORIDAGASPIPELINE

MARSH

MARSH

CONTAIN

MENT

AREA

G-03 PAD

GCL ANGLE INSTALLATION

GCL ANGLE INSTALLATION

EXISTING SHEET PILE WALL(PROTECT IN PLACE)

AREA OF PONDED WATER

OGPAD3

EXISTING ACCESS

ROAD AND PAD

STA.

9+00

STA.

8+00

STA.0+00

STA.

46+00

STA.61

+00

STA.62+00

STA.63+

00

ST

A.64+00

STA.65+0

0

STA

.66+00

STA.67+0

0

STA.69

+00

STA.7

0+00

STA.71

+00

STA.72+0

0

STA.73

+00

STA.74

+00

STA.75

+00

STA.76

+00

STA.77

+00

STA.7

8+00

STA.79

+00

STA.29+00

STA

.68+00

ORW-9 PAD

ORW-9 WELL

STA.30+0

0

ORW-5 PAD

ORW-5 WELL

FLARE PAD 5

MAURICEROAD

CONTAINMENT AREA

TEXAS

BRINE

PLANT

STA.8

0+00

STA

.81

+00

STA.60+00

INTERIM WATERTRANSFER STRUCTURE #2

INTERIM WATER TRANSFER STRUCTURE #1

LEVEE OVERFLOW STRUCTURE FLORID

AGASPIP

ELIN

E

G-01 GEOPHONE WELL

G-01 GEOPHONE PAD

OG-2 WELL PAD

OG PAD 9

LEVEE ROAD BETWEEN G-01

GEOPHONE PAD AND OG PAD 9

MARSH

MARSH

B-01

B-02B-03

B-04

B-05

B-06

B-07

B-09STA.5

1+00B-10

B-11B-12

B-13

B-14

B-15

B-16

B-17

B-18

B-19

SP-01

SP-04

SP-05

SP-06

SP-4-N

SP-3-NSP-2-N

SP-1-N

S

SP-13

SP-14

SP-16

SP-6-N

SP-5A-N

SP-5-N

STA.

1+00

STA.2+00

STA.3+00

STA.4+00

STA.

5+00

STA.6+00

STA.

7+00

STA.10+00

STA.11+00

STA.12+00

STA.13+00

STA.14+00

STA.

15+00

STA.28+00

STA.27+00

STA.26+00

STA.25+00

STA.24+00

STA.23+00

STA.22+00

STA.21+00

STA.20+00

STA.19+00

STA.18+00

STA.17+00

STA.16+00

STA.

42+00

STA.43+00

STA.

44+00

STA.

45+00

STA.

47+00

STA.48+00

STA.49+00

STA.50+00

S T A . 5 2 + 0 0

STA.33

+00

STA.

31+0

0

STA.

32+0

0

STA.34+00

STA.35+00

STA.36+00

STA.37+00

STA.

38+00

STA.39+00

STA.

40+00

STA.41+00

STA.

9+00

STA.

8+00

STA.0+00

STA.

46+00

STA.61

+00

STA.62+00

STA.63+

00

ST

A.64+00

STA.65+0

0

STA

.66+00

STA.67+0

0

STA.69

+00

STA.7

0+00

STA.71

+00

STA.72+0

0

STA.73

+00

STA.74

+00

STA.75

+00

STA.76

+00

STA.77

+00

STA.7

8+00

STA.79

+00

STA.29+00

STA

.68+00

STA.30+0

0

STA.8

0+00

STA

.81

+00

STA.60+00

STA.51+00


27/113

AREA & VOLUME CALCULATIONS:

Unable to calculate quantities due to Code 1 access restrictions.

AERIAL IMAGE TAKEN ON 11/02/13.

NOTE: CONTAINMENT ROAD NOT USED IN CONTOURS AND VOLUME CALCULATIONS.

1) Bubble activity observed on north side of sinkhole.2) Bottom elevation by fathometer was approximately -190'.3) Bottom elevation by wireline was approximately -207'.

11-11-13 SURVEY NOTES:

4) Eastern side of sinkhole off-limits due to Code 1 safety requirements.

8911 North Capital of Texas Highway

Building 2, Suite 2310Austin, TX 78759

(512) 338-1667 (512) 338-1331 fax

PROJECT NO.:

FIGURE

REVISION

DATE:

ISSUED BY

APPROVED BY:

CHECKED BY:

DRAWN BY:

DESIGNED BY:

FILE NAME:

TETRA TECH


GTF

SHD

GTF

GTF

114-010647


114-010647 12/11/2013

-

N

0

SCALE:

50' 100' 200'

1" = 100'

CONTAINMENT BERM AND

SINKHOLE PLAN2A


28/113

CONTAINMENT BERM AND

SINKHOLE PROFILES8911 North Capital of Texas HighwayBuilding 2, Suite 2310Austin, TX 78759

(512) 338-1667 (512) 338-1331 fax

PROJECT NO.: DATE:

ISSUED BY

APPROVED BY:

CHECKED BY:

DRAWN BY:

DESIGNED BY:

FILE NAME:

TETRA TECH


GTF

SHD

GTF

GTF

114-010647


114-010647 12

CROSS SECTION S-NSCALE: H 1" = 60', V 1" = 60'

CROSS SECTION SSW-NNESCALE: H 1" = 60', V 1" = 60'


29/113

BAYOU CORNE

FLORIDAGASPIPELINE

ACADIAN

GAS

PIPELINE

ACADIANGASPIPELINE

CROSSTEXPIPELINE

FLORIDAGASPIPELINE

CONTAINMENT AREA

MARSH

TEXASBRINEPLANT

WESTCONTA

INMENT(ABANDONED)

MARSH

EXISTING ACCESSROAD AND PAD

OG PAD 3

MARSH

G-01

GEOPHONEWELL PAD

ORW-5 PAD

OG-2 WELL PAD

OG PAD 9

ACADIAN

GAS

PIPELINE

ACADIANGASPIPELINE

CROSSTE

XPIPELINE

WESTCONTAINMENT BERM

NORTH CONTAINMENT BERM

WESTCONTAINMENTBERM

SOUTH CONTAINMENT BERM

TE

XAS

BRIN

EA

CCE

SSR

OAD

( EAST

CO

NTA

INM

ENT

BER

M)

ACCESSROAD

CONTRACTOR

STAGING AREA

ACCESSROAD

WESTCONTAINMENT

BERM

WESTC

ONTAINMENT

BERM

CONTAINMENT AREA

60 (T, WL)

35 (WL)

53 (WL)

52 (WL)

55 (WL)

21 (T, WL)

22 (T, WL)

36 (WL) 34 (WL)

37 (WL)

54 (WL)

32 (WL)

59 (T, WL)

31 (WL)

29 (WL)

89 (WL)

33 (T, WL)1 (I, WL)

11 (I, WL)40 (WL)

50 (WL)

39 (WL)

2 (T)

48 (WL)

44 (WL)77 (T)

99 (P)

88 (T)

26 (T, WL)

18 (WL)

25 (WL)

30 (WL)

PROP (I)

PROP (I)

INCLINOMETER, TILTMETE

AND WATER LEVEL

INSTRUMENT LOCATIONS

0

SCALE:

100' 20

1" = 20

N


Austin, TX 78759(512) 338-1667 (512) 338-1331 fax

PROJECT NO.: DATE:

ISSUED BY

APPROVED BY:

CHECKED BY:

DRAWN BY:

DESIGNED BY:

FILE NAME:

TETRA TECH


GTF

SHD

GTF

GTF

114-010647


114-010647 12

LEGEND: I INCLINOMETER

P PRECIPITATION

T TILTMETER

WL WATER LEVEL

EQUIPMENT LOCATION

AND DESIGNATION

PROPOSED INCLINOMETE

LOCATION

36 (T, WL)

PROP (I)


30/113

BAYOU CORNE

FLORIDAGASPIPELINE

ACADIANGASPIPELINE

ACADIANGASPIPELINE

CROSSTEXPIPELINE

FLORIDAGASPIPELINE

CONTAINMENT AREA

MARSH

TEXAS

BRINE

PLANT

WESTC

ONTA

INMENT(ABAN

DONED)

MARSH

EXISTING ACCESSROAD AND PAD

OG PAD 3

MARSH

G-01 GEOPHONEWELL PAD

ORW-5 PAD

OG PAD 9

ACADIAN

GAS

PIPELINE

ACADIANGASPIPELINE

CROSSTEXPIPELINE

PROPOSED SOUTHERN

BERM RELOCATION OPTION

WEST CONTAINMENTBERM

NORTH CONTAINMENT BERM

WESTCONTAINMENTBERM

SOUTHCONTAINMENT BERM

TEXASBRI N

EACCESS

ROAD

( EAST

CONTAINM

ENTBERM)

ACCESS

ROAD

CONTRACTOR

STAGING AREA

ACCESSROAD

WEST

CONTA

INMENT

BERM

WESTCONTAINMENT

BERM

MAXIMUM OVAL SHAPE SINKHOLE SHAPE

PER ITASCA CONSULTING GROUP

MEMORANDUM DATED AUGUST 5, 2013

OG-2 WELL PAD

CONTAINMENT AREA

PROPOSED SOUTHERN BER

RELOCATION OPTION

0

SCALE:

80' 16

1" = 16

N


Austin, TX 78759(512) 338-1667 (512) 338-1331 fax

PROJECT NO.: DATE:

ISSUED BY

APPROVED BY:

CHECKED BY:

DRAWN BY:

DESIGNED BY:

FILE NAME:

TETRA TECH


GTF

SHD

GTF

GTF

114-010647


114-010647 12


31/113

APPENDIX A

SURFACE WATER MONITORING PLAN


32/113

SURFACE WATER MONITORING PLAN

IN RESPONSE TO:

LOUISIANA DEPARTMENT OF NATURAL RESOURCES

DECLARATION OF EMERGENCY FOR BAYOU CORNE

FOURTH AMENDMENT, DIRECTIVE N0 5:

For

TEXAS BRINE COMPANY, L.L.C.

Provided By:Tetra Tech, Inc.

June 25, 2013


33/113

TABLE OF CONTENTS

1 INTRODUCTION.................................................................................................................................... 1

2 BACKGROUND...................................................................................................................................... 2

2.1 Pre-Containment Surface Water Monitoring Program .................................................................. 2

2.2 Containment System .................................................................................................................... 2

3 CONTAINMENT SYSTEM PERFORMANCE MONITORING PROGRAM ...................................................... 4

3.1 Field Parameters........................................................................................................................... 5

3.2 Laboratory Analyses ..................................................................................................................... 6

3.3 Surface Water Sample Collection Methods ................................................................................... 6

4 SINKHOLE MONITORING PROGRAM ..................................................................................................... 7

4.1 Sinkhole Vertical Profiling Sample Collection Methods.................................................................. 8

5 QAQC AND DATA MANAGEMENT....................................................................................................... 10

5.1 Field QAQC................................................................................................................................. 10

5.2 Laboratory QAQC........................................................................................................................ 10

5.3 Data Management...................................................................................................................... 11

TABLES

Table 1 Containment System Monitoring Summary

Table 2 Sinkhole Monitoring Summary

FIGURES

Figure 1 Surface Water Monitoring Locations

APPENDICES

Surface Water Sampling Field Form


34/113Page 1

1 INTRODUCTION

This Work Plan has been prepared for Texas Brine Company, L.L.C. (TBC) by Tetra Tech, Inc. (Tetra Tech) in

response to the issuance, by the Louisiana Department of Natural Resources (LDNR), pursuant to the

authority granted under Louisiana Revised Statute 30:1, eq seq., and more particularly Louisiana Revised

Statute, 30:6.1, of a Declaration of Emergency. The Declaration of Emergency is related to subsidence that

has occurred immediately adjacent to the TBC Oxy Geismar No.3 well site and associated salt cavern.

A containment system consisting of existing and new levees has been constructed around the sinkhole to

meet the requirements of Directive 5 of the Fourth Amendment to the Declaration of Emergency to

prevent to the greatest extent practicable, any dissolved concentrations of total petroleum hydrocarbons

(TPH), elevated chloride, or total dissolved solids (TDS) in the surface water within the sinkhole and

surrounding area from migrating in such a manner that will damage the environment.

This Monitoring Plan is specific only to Directive No.5 of the Fourth Amendment to the Declaration ofEmergency and presents the steps to be taken by TBC, with technical assistance from its consultants, Tetra

Tech and Michael Pisani and Associates, Inc. (MP&A). This Monitoring Plan describes the surface water

sampling activities proposed to monitor the performance of the containment system.

This monitoring plan refines the current sample locations and frequencies of sampling in accordance with

Directive No.5 of the Fourth Amendment to the Declaration of Emergency. The existing sampling

conducted by MP&A and the containment system design are discussed as background in section 2.0. The

containment system monitoring program is discussed in section 3.0, the sinkhole monitoring program is

discussed in section 4.0, and QAQC and data management are discussed in section 5.


35/113Page 2

2 BACKGROUND

2.1 Pre-Containment Surface Water Monitoring Program

The existing surface water monitoring program at the sinkhole is conducted by MP&A. MP&A has collected

field parameters twice per week at up to nineteen (19) sinkhole transect locations and at two (2)

background locations since August 2012 which have included the following:

Conductivity,

TDS,

ORP,

pH, and

Temperature.

MP&A has collected biweekly surface water samples at up to nineteen (19) sinkhole transect locations and

two (2) background locations since August 2012 which have included the following:

pH Method SM 4500H,

Specific conductance (mhoms/cm) Method SM2510B,

TDS Method SM 2540C,

Anions (bromide, chloride, sulfate) Method SW-846 9056A,

Hydrogen sulfide Method SM4500S H,

Sulfide Method SM4500 S,

Benzene, ethylbenzene, toluene, and xylenes (BTEX) Method 8260B, and

Total petroleum hydrocarbon (TPH) fractions Method TX 1006/Massachusetts EPH/VPH.

In addition to the field parameters and laboratory samples taken at the existing sinkhole surface water

sample locations, MP&A also completed vertical profiling of the sinkhole water column on three separate

occasions. The vertical profiling was proposed by MP&A to identify surface water stratification. In addition

to the laboratory analyses at the transect locations, the following additional analyses were completed for

vertical profiling samples:

Dissolved gases (methane, ethane, propane, and butane) - Method RSK175,

Volatile Organic Compounds (VOCs) full suite of Method 8260B,

Semi Volatile Organic Compounds (SVOCs) Polycyclic aromatic hydrocarbon (PAH) suite of

Method 8270C,

Alkalinity (bicarbonate and carbonate) Method SM 2320B, and

Cations (calcium, iron, magnesium, manganese, potassium, and sodium) Method SW-846 6010B.

Tetra Tech proposes to continue vertical profiling on a regular schedule as discussed in section 4.0.

2.2 Containment System

The containment system installation was completed in response to Directive No.5 of the Fourth

Amendment to the Declaration of Emergency.


36/113Page 3

The containment system for the sinkhole provides a continuous low permeability perimeter of structures

designed to contain surface waters surrounding the sinkhole up to an elevation of four (+4) feet during

normal, non-storm event conditions. The containment system incorporates, to the extent practicable,

existing roads and well pads to minimize new construction and additional disturbance of swamp areas. In

the event of a storm event where water reaches a pre-determined high level, the containment system will

allow the controlled water transfer from the containment area to the swamp areas adjacent to the

southwest corner of the containment dike where the released water can mix with the naturally occurring

flow outside of the dike. The main constituents of concern are high chloride concentrations in the sinkhole

at depth and hydrocarbons which float on the surface. The release structure design incorporates controls

to help prevent release of chlorides and floating materials (e.g., hydrocarbons) by its vertical position.

Newly constructed dikes that are part of the containment system utilize a corridor that is approximately 40-

foot-wide. Trees and vegetation were cleared from the construction corridor prior to the placement of

sand bedding material that was used to create a working surface above the water table that served as the

base of the dike and as the platform for continuing the construction of the dike further along the alignment.The upper components of the dikes are constructed on top of the base sand layer. The following describes

the dike design elements from bottom to top.

The base layer of sand fill placed on the swamp floor (height of sand was dependent on water

depth at the time of construction).

A geosynthetic clay liner (GCL) placed over the sand along the entire dike slope that faces the

sinkhole, creating an extremely low permeability surface to the dike.

A layer of geotextile fabric placed over the sand on the dike slope on the side facing the swamp,

which is used to help stabilize the sand fill material there.

Both the geotextile and the GCL are secured in place at the bottom of each side slope through theuse of anchor trenches. Additional fill is placed over the anchor trenches and carried up the slopes

to provide a protective layer for the geotextile fabric and GCL.

The top of the sand component of the dike is capped with approximately 18 to 24 inches of

compacted clay, which anchors the top of the geotextile fabric and GCL, and provides a stable top

surface for the dike.

A layer of geotextile fabric is placed over the top of that clay layer to provide a separation barrier.

A layer of limestone approximately 6 to 12-inches thick covers the geotextile separation layer to

create a surface for supporting vehicular traffic to allow access around the containment area

perimeter.

Existing access roads (Rig Road and the Texas Brine Access Road) have been used to form the eastern and

western perimeters of the containment system. GCL was also added to the side slopes facing the sinkhole

for these roads to continue the low permeability barrier around the entire perimeter of the containment

area. In addition, Rig Road was raised and improved upon in many areas in a manner similar to that

described above for the newly-constructed dikes. The containment system boundary is shown on Figure 1.


37/113Page 4

3 CONTAINMENT SYSTEM PERFORMANCE MONITORING PROGRAM

The objective of the surface water monitoring program is to monitor the surface water in and around the

containment system to document that the containment system is preventing to the greatest extent

practicable any dissolved concentrations of TPH, elevated chloride, and TDS in the surface water within thesinkhole and surrounding area from migrating in such a manner that will damage the environment.

The proposed performance monitoring surface water sample locations were chosen at cardinal locations

around the containment system (see Figure 1). Paired sample locations were chosen to compare the

surface water chemistry at five (5) locations inside and outside of the containment system. The sample

locations were named with the following sample prefix ID:

CSSW - Containment System Surface Water.

The proposed performance monitoring schedule of the containment system will consist of the collection of

field parameters and water samples at ten (10) sample locations around the containment system and four

(4) background locations. The scope, frequency, and type of monitoring for each sample location is

summarized in Table 1.

In addition to performance monitoring, field parameters and water samples will be taken immediately prior

to a water transfer from the containment system to the outside swamp and once daily during the transfer

at sample locations CSSW-01 and CSSW-02.

The field parameters and laboratory analyses included as part of the performance monitoring and

immediate release events are discussed in sections 3.1 and 3.2 respectively.

Table 1 Containment System Monitoring Summary

Sample ID Scope Monitoring Frequency

CSSW-01 and

CSSW-02

Performance monitoring at

the south end of the

containment system.

Field Parameters

Monthly

Laboratory Analysis

Characterization of release

water during a water transfer

event.

Field Parameters Immediately prior to

a water transfer and

once daily during

each transfer.Laboratory Analysis

CSSW-03 and

CSSW-04

Performance monitoringalong Rig Road and the west

end of the containment

system.

Field Parameters

Monthly

Laboratory Analysis

CSSW-05 and

CSSW-06


the north end of the

containment system.

Field Parameters

MonthlyLaboratory Analysis


38/113Page 5

CSSW-07 and

CSSW-08


the northern portion of the

access road and the eastern

edge of the containment

system.

Field Parameters

Monthly

Laboratory Analysis

CSSW-09 and

CSSW-10


the eastern portion of the

access road and eastern edge

of the containment system.

Field Parameters

Monthly

Laboratory Analysis

BG-01

Background concentration in

the swamp south of the

containment system.

Field Parameters

Monthly

Laboratory Analysis

BG-02


the swamp south of thecontainment system along

Bayou Corne.

Field Parameters

MonthlyLaboratory Analysis

BG-03


Bayou Corne at the closest

location to the water transfer

area.

Field Parameters

Monthly

Laboratory Analysis

BG-04

Background concentration on

Grand Bayou upstream of

Bayou Corne.

Field Parameters

Monthly

Laboratory Analysis

3.1 Field Parameters

Field parameters will be collected at each monitoring location according to the schedule in Table 1 using a

hand held Ultrameter II or a YSI 556 multi-parameter sonde. Field parameters will include:

visual hydrocarbon sheen,

conductivity,

TDS,

ORP,

pH, and

temperature.

The Ultrameter II and the YSI will be calibrated in accordance with the manufacturers recommended

procedures at the beginning of each sampling day to ensure accuracy of the equipment. Calibration

activities will be recorded on calibration logs and copies will be kept on file. Calibration of the meters will

be conducted at the beginning and end of each sampling day. Additionally, verification of meter accuracy

will be conducted in the middle of each sampling day.


39/113Page 6

3.2 Laboratory Analyses

Samples collected for performance monitoring of the containment system and during a water transfer due

to a major storm event will be collected according to the schedule in Table 1 and analyzed by Gulf Coast

Analytical Laboratories (GCAL) for the following analytes:

pH Method SM 4500HS,

Specific conductance (mhoms/cm) Method SM2510B,

TDS Method SM 2540C,

anions (bromide, chloride, sulfate) Method SW-846 9056A,

hydrogen sulfide unionized Method SM4500 S,

sulfide Method SM4500 S,

benzene, ethylbenzene, toluene, and xylene (BTEX) Method 8260B, and

Total Petroleum Hydrocarbon (TPH) fractions Method TX 1006/ Massachusetts EPH/VPH.

3.3 Surface Water Sample Collection MethodsAt each sample location, equipment calibration data, field parameters and sample collection data will be

recorded on the surface water sampling field form in Appendix A of this plan. Sample forms will be utilized

during performance monitoring events and if practicable, during an immediate transfer.

Field parameters and lab samples will be collected directly from the top two (2) feet or less of the surface

water at each sample location. The temperature will be the only parameter recorded immediately. Once

pH, conductivity, TDS, and ORP have stabilized the values will be recorded on the field forms. Once the

field parameters have been recorded a pre-cleaned plastic bottle will be used to transfer water samples

from the bucket to each sample bottle. The plastic bottle and sample bucket will be rinsed at each site.

Field meters will be rinsed using de-ionized water between sample locations.

Samples will be collected in order location of low concentration to high concentration of hydrocarbons and

chloride to minimize cross contamination. The sampling team will collect samples at the background

locations first, followed by the outer containment system locations, and finally within the containment

levee.

Once samples are collected they will be immediately placed on ice in the lab issued sample cooler. Sample

information will be added to the lab issued chain of custody and on sample bottles. At the end of each

sampling day, fresh bags of ice will be changed out to ensure that the samples are delivered to the

laboratory at the appropriate temperature.


40/113Page 7

4 SINKHOLE MONITORING PROGRAM

MP&As pre-containment surface water monitoring locations were chosen based on a transect system. Six

cardinal directions were established from the center of the sinkhole and sample locations were named with

the subsequent cardinal direction. Due to the recent containment of the sinkhole, the number ofmonitoring locations in the sinkhole will be reduced to a total of five (5) locations in four (4) cardinal

directions (see Figure 1).

The purpose of the sinkhole surface water sample locations will be to continue vertical profiling of the

sinkhole to identify stratification of the water column. The proposed scope, frequency and monitoring

activities are summarized in Table 2. The sinkhole sample locations will be differentiated from the

containment system sample locations by using the following sample identification prefix:

SHSW - Sinkhole Surface Water.

Sinkhole monitoring activities will include the collection of the field parameters discussed in section 3.1,laboratory analyses discussed in section 3.2 and the following additional laboratory analyses:

Dissolved gases (methane, ethane, propane, and butane) - Method RSK175

Volatile Organic Compounds (VOCs) full suite of Method 8260B

Semi Volatile Organic Compounds (SVOCs) Polycyclic aromatic hydrocarbon (PAH) suite of

Method 8270C

Alkalinity (bicarbonate and carbonate) Method SM 2320 B

Cations (calcium, iron, magnesium, manganese, potassium, and sodium) Method SW-846 6010B

Quarterly monitoring dates should adhere to the following schedule:

1st

quarter sample in the month of January

2nd

quarter sample in the month of April

3rd quarter sample in the month of July

4th quarter sample in the month of October

Table 2 Sinkhole Monitoring Summary

Sample ID Scope Monitoring Frequency

SHSW 01 Vertical profiling of the center of

the sinkhole.

Field ParametersQuarterly

Laboratory Analysis

SHSW 02 Vertical profiling of the northernend of the sinkhole

Field Parameters QuarterlyLaboratory Analysis

SHSW 03 Vertical profiling of the western

edge of the sinkhole


Laboratory Analysis

SHSW 04 Vertical profiling of the eastern



Laboratory Analysis

SHSW 05 Vertical profiling of the southern



Laboratory Analysis


41/113Page 8

4.1 Sinkhole Vertical Profiling Sample Collection Methods

At each sample location, equipment calibration data, field parameters and sample collection data will be

recorded on the surface water sampling field form in Appendix A of this plan.

Vertical profiling samples will be collected as discrete grab samples. Samples will be collected at verticaldepths of approximately two (2), ten (10), twenty five (25), fifty (50), and one hundred (100) feet. The

sample depths will vary depending upon the depth of the sinkhole at the time of sampling. The sample

name will indicate the depth at each location by using the following labeling system:

SHSW2-01 Sinkhole sample location 1 taken at a depth of 2 feet





The following procedures have been determined by MP&A to be the most effective method of collecting

samples at depth within the sinkhole:

The discrete samples will be collected through teflon tubing secured to a weighted wire line.

o New tubing will be used for each sample location in the sinkhole to minimize cross

contamination of samples.

The wire line will be advanced by winch (attached to an airboat) to the deepest (100 feet) position.

The approximate airboat position will be maintained with an electric trolling motor, anchor line or

other safe method determined by field personnel.

A poly vinyl chloride (PVC) casing with end cap will be mounted on the bow of the boat.

The PVC casing will extend from the surface of the water through any layer and/or sheen of

hydrocarbon product floating on the water surface to reduce the risk of cross contamination.

The weighted wire line and Teflon tubing will be advanced through the casing and used to knock off the

end cap.

The end cap will be attached to a string with the end inside the boat in order to recover the cap.

The output end

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