Contingency PlanTexas Brine Contingency Plan For Containing Pollution at The Collapsed Salt Dome in Napoleonville, Louisiana

DRAFT FINAL
Bayou Corne Sinkhole Containment System

Maintenance and Contingency Plan
Submitted by:
Texas Brine Company L.L.C.
December 13, 2013
Investig
Bayou Corne Sinkhole Containment
System Maintenance and Contingency
Plan
Submitted by:
Texas Brine Company L.L.C.
4800 San Felipe
Houston, Texas 77056
Prepared by:
4900 Pearl East Circle, Suite 300W
Boulder CO 80301
(303) 447-1823
Fax (303) 447-1836
Tetra Tech Project No. 114-010647
December 13, 2013
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 ...................................................................................................................4
3.0 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 Repair
Table 2 Consultants and Contractors Available to Assist with Repairs
LIST OF FIGURES
Figure 1 Sinkhole Containment System Plan View
Figure 2a Containment Berm and Sinkhole Plan
Figure 2b Containment Berm and Sinkhole Profiles
Figure 3 Inclinometer, Tiltmeter and Water Level Instrument Locations
Figure 4 Proposed Southern Berm Relocation Option
LIST OF APPENDICES
Appendix A Surface Water Monitoring Plan
Appendix 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 Plan
Appendix E Evaluation of the Bayou Corne Maximum Sinkhole Extent in Lateral Directions;
and Comments on Maximum Bayou Corne Sinkhole Extents
Tetra Tech December 13, 2013 1
1.0 BACKGROUND
Directive 5 of the Fourth Amendment to the Declaration of Emergency and Directive issued by
the 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 system
around the Bayou Corne sinkhole. Directive 5 further requires the sinkhole containment system
to prevent to the greatest extent practicable any dissolved concentrations of total petroleum
hydrocarbons (TPH), elevated chlorides, 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.
In response to Directive 5, an integrated containment system was developed and implemented
by TBC. Since completion of the containment system, it has become apparent that natural
conditions also play a role in preventing the hydrocarbons and chlorides from escaping the
sinkhole. 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 the
completion of the levees occurring in September 2013. Daily measurements of the water levels
within the containment area and in the marsh just outside of the containment system
consistently demonstrate that the water levels within the containment system drop below those
of the marsh. If left unadjusted, the water levels within the containment area would continue to
drop over time, resulting in a differential of water surface elevations on either side of the
containment levees. As mentioned above, this is due to the hydraulic connection between the
sinkhole waters and the MRAA which has a typical static water level 5 10 feet below the
surrounding marsh water level.
To maintain the water level differential between the marsh and the containment area at
controlled 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 by
pumping. The intention is to manage the water surface elevation differential in the 6 to 18
inches range.
Since the sinkhole formed, and since the containment levee system was installed, the following
have been observed:
The concentrations of dissolved constituents, such as TDS and chlorides, are lower at
the surface, and increase as depth increases in the sinkhole waters.
The amount of floating petroleum hydrocarbons that are appearing on the surface of the
sinkhole water has declined significantly over time, and that at the time of the
preparation of this Contingency Plan the amount of those hydrocarbons was very
minimal. The TBC team responsible for hydrocarbon management at the sinkhole has
reported that there has been no new release of hydrocarbons observed since late
August 2013. Oil sheens have been seen since that time has been attributed to trapped
oil in the floating vegetation.
Water levels in the sinkhole continuously drop versus the levels in the marsh just outside
the containment levees unless water is allowed to transfer from the marsh into the
containment 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. This
accounts 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
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 the
levees 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.
2.0 INTRODUCTION
This Contingency Plan describes the following relative to the sinkhole containment system:
Responsibility matrix for monitoring, inspection, maintenance, repair and emergency
response;
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 Contingency
Plan.
3.0 RESPONSIBILITY MATRIX
This section addresses the responsibilities for monitoring, inspection, maintenance, repair and
emergency response actions associated with the sinkhole containment system. Those
responsibilities are as follows:
Overall decision-makers with the authority to initiate actions designated by the applicable
plans as needed:
TBC Vice President of Operations, Bruce Martin
Phone Number: (281) 808-5200
Email address: BMartin@texasbrine.com
or
United Brine Services Company LLC (UBC) President, Mark Cartwright
Phone Number: (281) 744-4806
Email address: MCartwright@unitedbrine.com
Overall management and direction of containment system integrity operations, including
inspection of containment system conditions, repair of damaged areas and emergency
response management; and monitoring sinkhole growth trends and assessing potential
impact of sinkhole to Bayou Corne:
TBC Response Manager, Charlie Burton and Neal Strickland
Phone Number: 423-802-8426 (C. Burton); 404-538-2529 (N. Strickland)
Email address: CBurton@texasbrine.com; nstrickland@texasbrine.com
Management and direction of containment system routine maintenance activities:
TBC Response Operations Monitors, Maurice Valentine and Stella Williams
Phone Number: 913-948-024 (Maurice Valentine); 404-583-1230 (S Williams)
Email address: MValentine@texasbrine.com; SWilliams@texasbrine.com
Management and direction of surface water quality sampling and water quality depth
profile sampling, analysis and reporting:
Dave Angle of Michael Pisani & Associates
Phone number: 281-242-5700
Email address: dangle@mpisani.com
4.0 SURFACE WATER QUALITY MONITORING
Directive 5 requires regular monitoring of surface water both inside and outside the containment
system 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 5
requirements. That plan describes the surface water sampling activities that are conducted both
inside and outside of the containment system levees to monitor the performance of the
containment system in accordance with the requirements of Directive 5. A copy of the plan is
provided in Appendix A of this Contingency Plan.
TBC also conducts water quality monitoring as specified in the Recommended Requirements
Document 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 to
quantify and monitor the inorganic and organic chemical constituents and concentrations in the
sinkhole for the entire water column from the water surface to the bottom of the sinkhole. For
the purpose of monitoring the effectiveness of the containment system, the water quality in the
top 10 feet of sinkhole depth is of particular interest. If trends are observed that show significant
increases in the levels of chlorides, TDS or dissolved TPH in the top 10 feet of the water
column, it may be an indication that the hydraulic gradient has changed, and that water could be
coming up out of the sinkhole towards the surface. If this condition continued, it could result in
increased concentrations for those constituents of interest further from the sinkhole and out
towards the containment levees. The sampling and analysis conducted under the Surface
Water Monitoring Plan (see above) would be carefully reviewed to determine if the water quality
at the sampling locations both inside and outside of the containment levees has been impacted
by 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 Monitoring
Plan identify an upward trend in chloride, TDS or TPH fractions detected at the current sampling
points located on the outside the containment levee, the following actions will be initiated:
Immediately conduct another round of water quality sampling per the Surface Water
Monitoring Plan and conduct sinkhole water quality depth profile sampling for TDS,
chlorides and TPH fractions (sinkhole conditions permitting) and increase the sampling
frequency to once per week.
Notify the Louisiana Department of Natural Resources (LDNR) and Louisiana
Department of Environmental Quality (LDEQ) if the sample results showing the upward
trend of TDS, chlorides and/or TPH fractions outside of the containment system levees
are confirmed by an additional sampling round.
Conduct an investigation as to the cause of the upward trend in the concentrations of the
constituents of concern outside of the containment levees. At a minimum, conduct
inspections of the containment system levees and water transfer pipes and valves to
determine 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 the
direction of flow has occurred and what has caused it. Determine if the changed flow
condition is a temporary effect (such as a change caused by sinkhole
turbulence/activity), or if it is a more permanent change.
The water quality sampling will continue at the increased frequency until the quality of the
surface water at the sampling stations on the outside of the containment system levees has
returned to acceptable levels or if mutually agreed upon with LDNR and LDEQ.
5.0 MONITORING SINKHOLE GROWTH AND LEVEE SUBSIDENCE
Subsidence of the ground below the containment system levees and other areas surrounding
the sinkhole has been observed. This has been especially prevalent along portions of the south
levee. When subsidence occurs in the areas where the containment levees are located, it
results in the elevation of the top of the levee dropping. If the subsidence continues
unaddressed, the elevation of the top of the levee could drop to a level that is below the
elevation of the top of the marsh water. In that event, since the elevation of the top of the marsh
water is higher than the elevation of the top of the containment area water, marsh water would
flow 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 the
downward flow gradient into the sinkhole and the presence of the floating hydrocarbon
containment booms remaining in place above the sinkhole. However, since the levee system
provides secondary containment, backing up those primary containment conditions/measures, it
would be desirable to address the levee subsidence to maintain a separation between the
marsh 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 be
implemented if the levee elevations drop too low. Those monitoring measures include the
following:
Settlement Plate Surveys During the construction of the containment system levees,
settlement plates were installed at various locations around the perimeter of the
containment system (see Figure 1). The purpose of the settlement plates is to provide
established points where elevations can be measured on a regular schedule. The
elevations taken over time are compared to identify levee settlement trends. Currently
the 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 sinkhole
and surrounding areas, approximately monthly, by a licensed professional surveyor,
assuming the sinkhole alert levels allow such work. This frequency may be reduced in
the future if overall stability and reduced sinkhole growth and/or subsidence of the area
around the sinkhole is observed. A plan view topographic contour map is prepared that
shows the current and past locations of specific contour lines such that the growth of the
sinkhole and the subsidence of surrounding areas can be monitored over time. In
addition, cross-section profiles are prepared along established axes that cut through the
sinkhole. These profiles show the location of specific elevation contours as measured
on different dates. The profiles allow for the identification of sinkhole and subsidence
growth trends over time. Review of the chronological plan and profile plot drawings
allows 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 that
have been prepared for areas adjacent to, and running through, the south levee showing
the trends of the bottom slope elevations in these areas over the past year.
Inclinometers, Tiltmeters and Water-Level Transducers Ground movement related to
the 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 failures
may be sudden, they are usually preceded by more gradual movement that can be
detected by monitoring equipment. The current monitoring system that is in use in the
vicinity of the sinkhole includes a network of inclinometers, tiltmeters and water-level
transducers (see Figure 3). That instrumentation provides real-time early-warning of
ground movement in the area by monitoring the rate and acceleration of subsurface
tilting or subsidence that are indicative of impending instability. Since the monitoring
results are available in real-time, these systems can be used to identify potential unsafe
conditions and allows for people and equipment to be quickly relocated away from areas
deemed unstable. Instrumentation located further away from the sinkhole and beyond
the areas where influence from the sinkhole has been recorded helps to delineate the
size of the area where ground movement is occurring due to the sinkhole.
In addition to the currently-installed instruments, it is planned that two additional
inclinometer arrays will be installed between the south levee and Bayou Corne, as
indicated on Figure 3. The inclinometer closest to the south levee will be installed prior
to conducting the remaining work to repair the south levee so that it can be used to
monitor conditions at the levee to protect workers and equipment during the levee
repairs. In addition to the inclinometer, line-of-sight reflectors will be installed by Miller
Engineers & Associates, Inc. and used to monitor the south levee conditions during the
installation and construction activities to protect workers performing that work.
Once the new inclinometers have been installed, they will provide data that will be useful
in monitoring the long-term stability of the existing south berm and any potential impact
on Bayou Corne.
The settlement plate surveys, sinkhole and surrounding areas elevation profile monitoring and
inclinometer/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 the
sinkhole, the containment system levees and Bayou Corne. In addition, at the location
of the proposed deep inclinometer arrays, the approximate depth of any shear failure
planes will be able to be detected.
If the above data indicates that the following trigger points have occurred, contingency actions
will 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 30
days or less, a new alignment route through a more stable area will be selected for that
levee section.
2. If the bottom slope in the area immediately adjacent to a levee section is determined
through 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 levee
section. A geotechnical engineering stability evaluation of the south levee is currently
being conducted and will be completed by December 27, 2013. The report that is
prepared to present the findings of that evaluation will be added as Appendix C to this
plan when completed. Those findings will be used to determine the feasibility of
repairing the south levee and if it is safe for workers to conduct the repair operations on
the levee.
3. If a section of the levee becomes damaged due to seismic activity and cannot be
repaired, or if seismic activity creates a situation where the levee is considered unstable,
a new alignment route through a more stable area would be selected for that levee
section.
4. If the any of the conditions described in items 1 through 3 above occurs for the south
levee, or a portion of the south levee, a new south levee will be constructed. The new
levee alignment will be selected just to the north of Bayou Corne, thus maintaining
containment 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 Corne
will be further developed in the event that the sinkhole growth continues and the new
levee becomes threatened.
5. If a new south levee is constructed as stated above, and at some point in time the levee
elevation, sinkhole profile and/or inclinometer data indicate that the new levee is also in
jeopardy of failing, the plans will move forward for relocation of both Bayou Corne and
the south levee. This is further discussed in Section 10 of this Maintenance and
Contingency Plan.
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 side
include geosynthetic clay liner (GCL) layer between the sand and clay, and the side slopes on
the marsh side contains a geotextile layer between the top of the clay and the bottom of the
limestone 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 the
levee materials that may occur. Early detection and correction of such damaged areas helps
prevent expansion of the problem.
In addition to the levees, the containment system also relies on floating booms to trap and
contain floating hydrocarbons that may be released from the sinkhole. The booms are
interconnected and periodically moved around to be best positioned to effectively control the
movement 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 maintain
effective hydrocarbon control.
The following are actions that could potentially result in damage to the containment system
components:
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 blowing
debris onto the levees and damaging the hydrocarbon containment booms;
Sinkhole sloughing events that may cause damage/interruption of the oil containment
booms;
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 fully
blocking the pipes and valves making them difficult to operate.
Visual inspections of the levees are conducted at least once per week to observe the levee
conditions. Any damage is documented and reported to the TBC Response Manager so that
corrective measures can be initiated to repair the damage. Damage that threatens to cause
imminent loss of containment, or which has already caused loss of containment, will be
addressed immediately on an emergency response basis. Corrective and emergency response
measures are addressed later in this Contingency Plan.
The floating booms are inspected at least once per week, if conditions allow. The observed
conditions of the booms are reported to the TBC Response Manager, who decides if
adjustments in dimension or location of the booms are necessary. Damaged or worn sections
of 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 this
information to determine when to transfer water from the marsh to the sinkhole to keep the
differential in the target range of 6 to 18 inches.
TBC has implemented a Storm Water Pollution Prevention Plan (SWPPP) for the sinkhole
containment system and related access roads, equipment pads, etc. (see Appendix D). That
plan describes best management practices (BMPs) for control of storm water during
construction activities at the site and specifies that inspection and maintenance procedures will
be implemented to maintain adequate sediment and erosion controls. Specifically, BMPs will be
inspected 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. Inspections
will be conducted by field personnel trained in the standards of performance and maintenance
requirements for individual BMPs. Inspectors will determine whether BMPs are in place, as
required, properly maintained, and properly operating. Inspections will be documented using the
Inspection Report form provided to field personnel. In particular, inspectors will note areas
where sediment transport may be occurring, as well as needed BMP maintenance or
replacement. Such maintenance or replacement normally will be initiated within 24 hours of the
inspection findings. Inspectors will note specific indicators of storm water runoff, such as floating
solids, settled solids, suspended solids, foam, or oil sheen.
7.0 ROUTINE MAINTENANCE ACTIVITIES
The following routine maintenance activities are conducted when indicated as being necessary
based 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 transfer
pipes;
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.
8.0 CORRECTIVE MEASURES FOR SYSTEM DAMAGE
Damaged areas on the levee system will require repairs before the damage grows and the
levees become weakened or compromised. The nature and extent of the damage will dictate
how quickly the repair work needs to be initiated. For example, small bare patches in
vegetation or other small erosion-damaged areas require repair, but that work can be scheduled
to occur in coordination with other activities at the site. Minor settlement of the levees can be
monitored to ensure that the levees are still functioning correctly. If the settlement continues to
occur, work to raise the levee heights can be scheduled. Examples of repairs that should be
addressed immediately include erosion damage that exposes or undercuts the geotextile or the
GCL portions of the levees, large erosion cuts across the top of the levee, sections of the levee
damaged 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 containment
system is paramount to TBC. Bruce Martin, Vice President of Operations, TBC or, in his
absence, Mark Cartwright, President of UBS, will be responsible for determining when such
work may be conducted. In making such determination they will consider data supplied by
passive seismic monitoring equipment, inclinometers and sinkhole survey information. All
applicable OSHA regulations and any other applicable federal and state statutes shall be
followed in making such determinations.
The following actions would be taken in the event that damage to the containment system
components occurs such that the ability of the levees to keep the marsh waters from flowing
uncontrolled into the containment system is compromised:
Ensure that at least two rows of oil containment booms are deployed along the damaged
or impacted levee.
Closely review the water quality monitoring data to see if the change in flow patterns is
adversely impacting the water quality near the breached portion of the levee.
Monitor settlement and movement of the impacted sections of levee and repair/rebuild
the damaged sections as soon as its safe to do so.
If deemed necessary, increase the frequency of the sinkhole depth surveys to track the
changes to the sinkhole and slope of the slides.
If it becomes unfeasible or completely unsafe to repair or rebuild a damaged or subsided
levee section that is allowing water to flow uncontrolled from the marsh into the
containment area and if the water quality monitoring data show increasing trends in the
concentrations of TDS, chlorides and/or detectable levels of TPH fractions in surface
water samples collected directly outside a sinkhole containment levee, then TBC would
commence actions to construct a new levee in a more stable location further away from
the 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 are
allowing water to pass through them, TBC will provide regular updates to LDNR and LDEQ and
participate in review meetings as warranted to communicate the status of the sinkhole
containment system monitoring and repair activities and what additional action, if any, is
warranted. The construction of a new levee segment located further from the sinkhole will
require the clearing of a corridor through the marsh, resulting in the loss of additional trees and
other disturbance of the marsh environment. Therefore, such levee relocation should not be
done prematurely if other measures can be identified to satisfy the containment requirements of
Directive 5.
To be prepared to expeditiously repair major damage to the containment system, TBC will have
the 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 a
damaged levee section. Since the length of a damaged section can vary quite a bit
depending 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, and
additional quantities readily available at nearby off site sources that could be brought to
the site prior to the onsite stockpile quantities being depleted.
Oil booms, absorbent pads, silt fencing and turbidity curtain in quantities that would be
needed to support levee repair work and emergency containment measures such as
might be required during levee system failure.
Construction equipment, tools, support vehicles and water craft to be used to repair the
levees, deploy the oil boom and turbidity curtain.
Adequate trained labor to safely manage, direct and perform the repair activities. This
can 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 of
consultants and contractors that TBC may utilize, as necessary, to assist with containment
system repairs.
9.0 EMERGENCY RESPONSE ACTIONS
If sections of the containment levee system subside or become damaged such that they
become breached and allow water to flow uncontrolled from the marsh into the containment
system, response measures will be implemented. The timing of that implementation is
dependent on conditions at the sinkhole at the time. Such measures could include actions such
as 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 TBC
Response Manager of nature and extent of containment system damage.
The TBC Response Manager will assess the source/cause of the subsidence or damage
to 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 the
following 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 the
best method of addressing and repairing the damage.
The TBC Response Manager will contact a qualified contractor, provide them with the
repair 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-site
stockpiles can be utilized for the repair work, with additional material being brought to
the 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 and
document the work being performed.
Once containment has been restored and the repair work completed, documentation of
the activities completed will be prepared.
A review of the cause of the damage or containment loss will be conducted. A report
summarizing the identification of the damage, the emergency response actions, and
identified cause of the damage will be prepared.
If levee repairs are not possible, or cannot be conducted safely, and the conditions specified in
Section 8 regarding the decision to relocate sections of the levee system further away from the
sinkhole apply, TBC will work with LDNR to select a new levee alignment route, and design
plans and specifications will be prepared and used to direct the construction of the new levee
section.
10.0 ADDRESSING POTENTIAL IMPACTS TO BAYOU CORNE
The following trigger points will be used to determine actions to be taken with regard to possible
relocation of a section of Bayou Corne:
1. If any of the trigger points described in Section 5 of this Maintenance and Contingency
Plan 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 figure
indicates, the new south levee would go from Oxy Taft 10 well pad (located at the
southern end of the TBC plant access road) and continue to the west staying to the north
and west of Bayou Corne, roughly paralleling the Bayou, and continuing on to the north
to connect with the containment systems west levee. Selecting this route will help
ensure that containment of the sinkhole surface waters is maintained prior to those
waters reaching Bayou Corne. Note that, should this new south levee be required, the
final alignment would be selected based on available information at that time.
2. The decision to construct a new south levee would initiate further development of
contingency plans for re-routing Bayou Corne. A final decision to relocate Bayou Corne
will occur if Item 3 below occurs.
3. If any of the trigger points listed in Section 5 of this Maintenance and Contingency Plan
result in the determination that the new south levee shown in Figure 4 is threatened by
continued subsidence, actions will be initiated to determine what, if any, interim
measures 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 guidance
for 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, including
identification of an initially preferred alternative based on available information;
Development of a list of recommended studies and information required for selection of
preferred alternative and final design; and
Development of order-of-magnitude cost estimate for design and construction of the
initially preferred reroute alignment.
The current size and shape of the sinkhole, and the growth it has exhibited since it formed in
August 2012 through the time that this Contingency Plan was prepared (November 2013) do not
indicate an impact to the Bayou Corne waterway in terms of TPH, chlorides and/or TDS. Both
LDNRs consultants and those retained by TBC have reviewed the current conditions of the
sinkhole and the brine cavern that has been the receptor of the sediments that created the
sinkhole, and have concluded that Bayou Corne would not be encroached upon even using
exceedingly conservative assumptions.
1
1
See Brandshaug, T., 2013. Evaluation of the Bayou Corne Maximum Sinkhole Extent in
Lateral Directions and Van Sambeek, 2013, Comments on Maximum Bayou Corne Sinkhole Extents
attached hereto as Appendix E.
Therefore, at this time further evaluation or engineering for a Bayou Corne reroute option does
not appear warranted.
If the current south levee needs to be relocated, TBC will further develop plans for possible
relocation 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, channel
velocities 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 in
Section 5 of this Maintenance and Contingency Plan result in the determination that this new
south levee is threatened by continuing subsidence, the plans for the relocation of Bayou Corne
will be made final, requests will be made to the appropriate agencies to conduct the relocation
activities, and the work will commence.
TABLES
Table 1. Materials and Supplies for Containment Repair
ITEM STORAGE LOCATION APPROXIMATE QUANTITY
STORED
Sand 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
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 greg.farrell@tetratech.com
Renes Trucking Supply trucks, sand, clay and
limestone
Rene Esneault
Phone 225-474-3500
Email rene@renestrucking.com
Rocks Trucking General Contractor Rock Scioneaux
Phone 985-513-2711
Email dellcno@charter.com
Action
Environmental
Deployment of booms; Oil and
Debris Removal
Chas Leblanc
Phone 225-385-0850
Email chase.leblanc@actionindinc.com
Miller Engineers &
Associates, Inc.
Surveying Joel Miller
Phone - (337) 828-1950
Email - joel.miller@cox-internet.com
FIGURES
PLAN VIEW
1
INITIAL CONTAINMENT SYSTEMLEVEE/ROADCENTER LINE
INITIAL CONTAINMENT SYSTEMLEVEE/ROADCROWN
INITIAL CONTAINMENT SYSTEMLEVEE/ROADBOTTOMOF SLOPE
EDGE OF TEXAS BRINE ROADS ANDPADS USEDAS PART OF CONTAINMENT SYSTEM
APPROXIMATE LOCATION OF EXISTING PIPELINE
APPROXIMATE SETTLEMENT PLATE LOCATION (SEE DTL 2 ON SHT 4)
LEGEND
0
SCALE:
### #### 240'
#########
N
8911 North Capital of Texas Highway
Building 2, Suite 2310
Austin, TX 78759
(512) 338-1667 (512) 338-1331 fax
BY REFERENCE REVISIONS NO. DATE
PROJ ECT NO.:
FIGURE
REVISION
ENGINEER'S SEAL
DATE:
ISSUEDBY
APPROVEDBY:
CHECKEDBY:
DRAWN BY:
DESIGNEDBY:
FILE NAME:
TETRA TECH
ISSUEDFOR SCALE:
OF 1
AS SHOWN
GTF
SHD
GTF
GTF
114-010647
-
- - - -
TEXAS BRINE COMPANY, LLC.
SINKHOLE CONTAINMENT SYSTEM
114-010647 10/31/2013
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B-XX
ALTERNATIVE CONTAINMENT SYSTEMLEVEE/ROADCENTERLINE
FINAL LEVEE ELEVATIONS
NORTH
EAST
SOUTH
WEST (ORIGINAL SECTION)
SECTION APPROXIMATE STATION/LOCATION TOP OF CLAY ELEVATION
STA 0+00 - 15+00 +5.0'
TEXAS BRINE ACCESS ROAD EXISTING ELEVATION
STA 18+00 - START OF NEWWEST LEVEE
WEST (NEWSECTION) STA 60+00 - 81+00 +6.0'
+6.0'
STA 33+25 - 46+00 +6.0'
SOUTH STA 46+00 - 48+00 TRANSITION FROM+6.0' TO +5.0'
SOUTH STA 48+00 - 52+00 +5.0'
WEST (ORIGINAL SECTION) STA 30+00 - 33+25 +6.0'
NORTH/WEST CORNER STA 15+00 - STA 16+00 +5.0'
APPROXIMATE BORING LOCATION
STA 16+00 - STA 18+00 TRANSITION FROM+5.0' TO +6.0' WEST (ORIGINAL SECTION)
SP-XX
S
T
A
. 1
+
0
0
S
T
A
. 2
+
0
0
S
T
A
. 3
+
0
0
S
T
A
. 4
+
0
0
S
T
A
. 5
+
0
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S
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A
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+
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0
S
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A
. 7
+
0
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S
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. 1
0
+
0
0
S
T
A
. 1
1
+
0
0
S
T
A
. 1
2
+
0
0
S
T
A
. 1
3
+
0
0
S
T
A
. 1
4
+
0
0
S
T
A
. 1
5
+
0
0
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
S
T
A
. 4
2
+
0
0
S
T
A
. 4
3
+
0
0
S
T
A
. 4
4
+
0
0
S
T
A
. 4
5
+
0
0
S
T
A
. 4
7
+
0
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S
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. 4
8
+
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9
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S
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A
. 5
0
+
0
0
S
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. 5
2
+
0
0
STA. 33+00
STA. 31+00
STA. 32+00
S
T
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. 3
4
+
0
0
S
T
A
. 3
5
+
0
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S
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. 3
6
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S
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. 3
7
+
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S
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8
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9
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1
+
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F
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ID
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IA
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F
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ID
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P
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A
C
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B
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A
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S

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A
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FLORIDA GAS PIPELINE
MARSH
MARSH
C
O
N
T
A
IN
M
E
N
T
A
R
E
A
G-03 PAD
MARSH
GCL ANGLE INSTALLATION
GCL ANGLE INSTALLATION
EXISTING SHEET PILE WALL
(PROTECT IN PLACE)
AREA OF PONDEDWATER
OG PAD 3
EXISTING ACCESS
ROADANDPAD
S
T
A
. 9
+
0
0
S
T
A
. 8
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1
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2
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. 6
3
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S
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A
. 6
4
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S
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. 6
5
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S
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A
. 6
6
+
0
0
S
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A
. 6
7
+
0
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STA. 69+00
STA. 70+00
STA. 71+00
STA. 72+00
STA. 73+00
STA. 74+00
STA. 75+00
STA. 76+00
STA. 77+00
STA. 78+00
STA. 79+00
STA. 29+00
S
T
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. 6
8
+
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ORW-9 PAD
ORW-9 WELL
STA. 30+00
ORW-5 PAD
ORW-5 WELL
FLARE PAD5
M
A
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R
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C
E

R
O
A
D
CONTAINMENT AREA
TEXAS
BRINE
PLANT
STA. 80+00
S
T
A
. 8
1
+
0
0
S
T
A
. 6
0
+
0
0
INTERIMWATER
TRANSFER STRUCTURE #2
INTERIMWATER TRANSFER STRUCTURE #1
LEVEE OVERFLOWSTRUCTURE F
LO
R
ID
A
G
A
S
P
IP
E
LIN
E
G-01 GEOPHONE WELL
G-01 GEOPHONE PAD
OG-2 WELL PAD
OG PAD9
LEVEE ROADBETWEEN G-01
GEOPHONE PADANDOG PAD9
MARSH
MARSH
B-01
B-02
B-03
B-04
B-05
B-06
B-07
B-08
B-09
STA. 51+00
B-10
B-11
B-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-N
SP-2-N
SP-1-N
SP-11
SP-13
SP-14
SP-15
SP-16
SP-6-N
SP-5A-N
SP-5-N
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. 4
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. 5
+
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. 6
+
0
0
S
T
A
. 7
+
0
0
S
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. 1
0
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0
0
S
T
A
. 1
1
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S
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. 1
2
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3
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S
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. 1
4
+
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. 1
5
+
0
0
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
S
T
A
. 4
2
+
0
0
S
T
A
. 4
3
+
0
0
S
T
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. 4
4
+
0
0
S
T
A
. 4
5
+
0
0
S
T
A
. 4
7
+
0
0
S
T
A
. 4
8
+
0
0
S
T
A
. 4
9
+
0
0
S
T
A
. 5
0
+
0
0
S
T
A
. 5
2
+
0
0
STA. 33+00
STA. 31+00
STA. 32+00
S
T
A
. 3
4
+
0
0
S
T
A
. 3
5
+
0
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S
T
A
. 3
6
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A
. 3
7
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S
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. 3
8
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. 3
9
+
0
0
S
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A
. 4
0
+
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0
S
T
A
. 4
1
+
0
0
S
T
A
. 9
+
0
0
S
T
A
. 8
+
0
0
S
T
A
. 0
+
0
0
S
T
A
. 4
6
+
0
0
S
T
A
. 6
1
+
0
0
S
T
A
. 6
2
+
0
0
S
T
A
. 6
3
+
0
0
S
T
A
. 6
4
+
0
0
S
T
A
. 6
5
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0
0
S
T
A
. 6
6
+
0
0
S
T
A
. 6
7
+
0
0
STA. 69+00
STA. 70+00
STA. 71+00
STA. 72+00
STA. 73+00
STA. 74+00
STA. 75+00
STA. 76+00
STA. 77+00
STA. 78+00
STA. 79+00
STA. 29+00
S
T
A
. 6
8
+
0
0
STA. 30+00
STA. 80+00
S
T
A
. 8
1
+
0
0
S
T
A
. 6
0
+
0
0
STA. 51+00
AREA &VOLUME CALCULATIONS:
Unable to calculate quantities due to Code 1 access restrictions.
AERIAL IMAGE TAKEN ON 11/02/13.
NOTE: CONTAINMENT ROADNOT USEDIN CONTOURS ANDVOLUME CALCULATIONS.
1) Bubble activity observed on north side of sinkhole.
2) Bottomelevation by fathometer was approximately -190'.
3) Bottomelevation by wireline was approximately -207'.
11-11-13 SURVEY NOTES:
4) Eastern side of sinkhole off-limits due to Code 1 safety requirements.
Austin, TX 78759
(512) 338-1667 (512) 338-1331 fax
PROJ ECT NO.:
FIGURE
REVISION
DATE:
ISSUEDBY
APPROVEDBY:
CHECKEDBY:
DRAWN BY:
DESIGNEDBY:
FILE NAME:
TETRA TECH
ISSUEDFOR SCALE: AS SHOWN
GTF
SHD
GTF
GTF
114-010647
114-010647 12/11/2013
-
N
0
SCALE:
50' 100' 200'
1" =100'
CONTAINMENT BERM AND
SINKHOLE PLAN
2A
PROFILE:
CONTAINMENT BERM AND
SINKHOLE PROFILES
2B
Austin, TX 78759
(512) 338-1667 (512) 338-1331 fax
PROJ ECT NO.:
FIGURE
REVISION
DATE:
ISSUEDBY
APPROVEDBY:
CHECKEDBY:
DRAWN BY:
DESIGNEDBY:
FILE NAME:
TETRA TECH
GTF
SHD
GTF
GTF
114-010647
114-010647 12/11/2013
-
CROSS SECTION S-N
SCALE: H 1" =60', V 1" =60'
CROSS SECTION SSW-NNE
SCALE: H 1" =60', V 1" =60'
BAYOU CORNE
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F
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ID
A
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P
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CONTAINMENT AREA
MARSH
TEXAS
BRINE
PLANT
W
E
S
T
C
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N
T
A
IN
M
E
N
T
(A
B
A
N
D
O
N
E
D
)
MARSH
EXISTING ACCESS
ROADANDPAD
OG PAD3
MARSH
G-01
GEOPHONE
WELL PAD
ORW-5 PAD
OG-2 WELL PAD
OG PAD 9
A
C
A
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IA
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P
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C
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P
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WEST CONTAINMENT BERM
NORTH CONTAINMENT BERM
W
E
S
T
C
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N
T
A
IN
M
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N
T
B
E
R
M
SOUTH CONTAINMENT BERM
T
E
X
A
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B
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IN
E
A
C
C
E
S
S
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A
D
(E
A
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T
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T
A
IN
M
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B
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R
M
)
A
C
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S
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CONTRACTOR
STAGING AREA
A
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W
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B
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R
M
W
E
S
T
C
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T
A
IN
M
E
N
T
B
E
R
M
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, TILTMETER
AND WATER LEVEL
INSTRUMENT LOCATIONS 3
0
SCALE:
100' 200' 400'
1" =200'
N
Austin, TX 78759
(512) 338-1667 (512) 338-1331 fax
PROJ ECT NO.:
FIGURE
REVISION
DATE:
ISSUEDBY
APPROVEDBY:
CHECKEDBY:
DRAWN BY:
DESIGNEDBY:
FILE NAME:
TETRA TECH
GTF
SHD
GTF
GTF
114-010647
114-010647 12/11/2013
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LEGEND:
I INCLINOMETER
P PRECIPITATION
T TILTMETER
WL WATER LEVEL
EQUIPMENT LOCATION
ANDDESIGNATION
PROPOSEDINCLINOMETER
LOCATION
36 (T, WL)
PROP (I)
BAYOU CORNE
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PROPOSEDSOUTHERN
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MAXIMUMOVAL SHAPE SINKHOLE SHAPE
PER ITASCA CONSULTING GROUP
MEMORANDUMDATEDAUGUST 5, 2013
OG-2 WELL PAD
CONTAINMENT AREA
PROPOSED SOUTHERN BERM
RELOCATION OPTION
4
0
SCALE:
80' 160' 320'
1" =160'
N
Austin, TX 78759
(512) 338-1667 (512) 338-1331 fax
PROJ ECT NO.:
FIGURE
REVISION
DATE:
ISSUEDBY
APPROVEDBY:
CHECKEDBY:
DRAWN BY:
DESIGNEDBY:
FILE NAME:
TETRA TECH
GTF
SHD
GTF
GTF
114-010647
114-010647 12/11/2013
-
APPENDIX A
SURFACE WATER MONITORING PLAN
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
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
Page 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 of
Emergency 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.
Page 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.
Page 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 the
use 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.
Page 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 the
sinkhole 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 monitoring
along 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
Monthly
Laboratory Analysis
Page 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 the
containment system along
Bayou Corne.
Field Parameters
Monthly
Laboratory 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.
Page 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 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. 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.
Page 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 of
monitoring 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:
1
st
quarter sample in the month of January
2
nd
quarter sample in the month of April
3
rd
quarter sample in the month of July
4
th
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 Parameters
Quarterly
Laboratory Analysis
SHSW 02
Vertical profiling of the northern
end of the sinkhole
Field Parameters
Quarterly
Laboratory Analysis
SHSW 03
Vertical profiling of the western
edge of the sinkhole
Field Parameters
Quarterly
Laboratory Analysis
SHSW 04
Vertical profiling of the eastern
Field Parameters
Quarterly
Laboratory Analysis
SHSW 05
Vertical profiling of the southern
Field Parameters
Quarterly
Laboratory Analysis
Page 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 vertical
depths 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 of the Teflon tubing will be connected at the surface to a peristaltic pump.
When the bottom of the tubing reaches the desired depth, the tubing will be purged of approximately
two volumes of water to ensure the sample collected is representative of the desired depth.
The purge water will be monitored using a handheld Ultrameter II or comparable portable water quality
instrument. Measurements will be monitored until all parameters have stabilized.
Due to the nature of the sinkhole and difficulty in obtaining specific depths, alternate intervals may be
obtained and selected by field personnel.
Due to the nature of sampling on an air boat, and to minimize time on the sink hole dedicated tubing will be
used to obtain samples at each location in place of decontamination procedures. At each location, and
before a sample is taken at each interval, three volumes of tubing volume will be evacuated for collection
of a representative sample.
Page 9
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.
Page 10
5 QAQC AND DATA MANAGEMENT
5.1 Field QAQC
The field quality control/quality assurance (QAQC) procedures for the monitoring program include the
following activities
One field blank sample will be collected for each sampling event or for every ten (10) samples
collected.
o The field blank will be analyzed for all laboratory analyses outlined in the monitoring
program. This sample will consist of filling sample bottles with de-ionized water in the
field. The preparation of the field blank will be at an existing sample location and will be
noted on the field form.
o Field blanks will be concealed from the laboratory by using the CSSW or SHSW sample
prefix system (i.e. CSSW-50).
Temperature blanks will be requested from the laboratory for each sampling event. The laboratory
will look for an arrival temperature of 42C. If the arrival temperature is outside this range, the
sampling team will be contacted to discuss an appropriate course of action; resample or analyze
the sample, with the disclaimer stating that the analyzed sample was not appropriately preserved
with respect to temperature.
At each sample location, field QAQC sample collection data will be recorded on the surface water sampling
field form in Appendix A of this plan.
5.2 Laboratory QAQC
Laboratory QC should include method blanks, analytical duplicates, matrix spikes, matrix spike duplicates
(MS/MSD), calibration checks and laboratory control standards, as required by the analytical methods. The
laboratory QAQC procedures for this monitoring program include the following activities:
One Trip blank will be requested from the laboratory for each sampling event. The trip blank is
prepared by the lab to determine whether anything associated with the preparation of the sample
containers by the laboratory, shipment of the empty containers to the field, traveling in the field
with the sampling team during the event, and return shipment to the laboratory could have any
impact on sample integrity.
One duplicate sample will be collected for each sampling event or for every ten (10) samples
collected. Duplicate samples will be concealed from the laboratory by using the CSSW or SHSW
sample prefix system.
One MS/MSD sample will be collected for every twenty project samples. This equates to one
MS/MSD sample every other event.
At each sample location, laboratory QAQC sample collection data will be recorded on the surface water
sampling field form in Appendix A of this plan.
Page 11
The quality of the analytical results of both the field and laboratory QA/QC programs will be assessed. A
QA/QC review of the laboratory analytical results will be performed to evaluate the level of accuracy,
precision and completeness of laboratory data following each event. Accuracy is a measure of the system
bias. The level of accuracy is evaluated by examination of blank results, MS/MSD recoveries, laboratory
calibration verification sample recoveries and surrogate recoveries (organic analyses). Precision is a
measure of agreement among replicate measurements of a sample under similar conditions. Precision is
monitored by the examination of field and laboratory duplicate results. Completeness is a measure of the
amount of data actually collected, analyzed, and considered usable compared to the amount specified in
the monitoring plan.
Where a suspect value is identified, the internal QA/QC data relevant to the projects sample set (method
blanks, matrix and method spikes, spike duplicates, and charge balances) will be requested from the
laboratory, if not already provided. Tetra Tech may also request that the laboratory check calculations
performed in completing analyses and/or check for data transcription errors. These data will be reviewed
to evaluate the precision and accuracy of the analytical results. In particular, the data will be compared to
laboratory control limits for blank, spike, and duplicate samples, where applicable. Where lab error is
apparent, corrective action will be taken. Corrective action may include reanalysis of the sample,
qualification of the sample result, and/or rejection of the erroneous data.
5.3 Data Management
Copies of field sheets, chains of custody and laboratory data will be sent to Tetra Tech directly and will be
maintained on the project SharePoint site which serves as the location to exchange documentation among
internal team members. In addition to the SharePoint site, a SQL database is maintained to allow efficient
access to groundwater analytical data.
FIGURES
October, 2013
Figure 1
Napoleonville Salt Dome Project
Surface Water Monitoring
Sampling Locations
0 250 500
Feet
Texas Brine Company, LLC
R
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Note: * Samples to be analyzed for TPH, Chlorides, and TDS.
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Legend
Approximate TBC Leased Property
Approximate OCC Owned Property
Boundary of Containment
Existing Roads and Pads
Existing Barrier
!>
Background Locations
!> Containment System Sampling Locations
!> Sinkhole Sampling Locations
")
Water Transfer Structure
APPENDICES
APPENDIX A
Surface Water Sampling Field Form
SURFACE WATER SAMPLING RECORD
Project Number: Project Name: Date:
Sampled By:
Weather (at sampling): Weather (past 48 hours):
Water Body (describe type, flow): Cooridinates (GPS, site specific):
Surface Water Sampling Location :
METHODS (vertical profiling, composite surface water, etc.):
Cleaning Equipment (frequency and equipment):
Sampling (dups, trip blanks, MS/MSD/equipment blanks):
INSTRUMENTS (Indicate make, model, I.d.) Field Calibration Verifications:
Multi Meter(s): __________________________________ Date: Standard
__________________________________ pH 4: _______ Conductivity:
Parameters: __________________________________ pH 7:________ TDS:
pH 10:_______ Other:
FIELD MEASUREMENTS FOR STABILIZATION
Time
Temp.
(
o
C)
pH
Specific
Conductance
ORP TDS
Visual Oil
and Grease
Flow at Sampling Point (units): Total Depth at Sampling Point (ft.):
SAMPLE INVENTORY
Time Vol. Qty.
X X
X X
X X
X
X
X X
X
X
X
X
DATE:
QUALITY ASSURANCE
Sampling
Depth (ft.)
Br,Cl, SO
4
- SW-846 9056A
hydrogen sulfide - SM4500 H;
sulfide - SM4500S S
Sinkhole
Vertical
Profiling
Bottles Collected
Analysis
Ca, Fe, Mg, Mn, K, Na - SW846
6010B
BTEX - Method 8260B
Containment
System
Monitoring
SIGNATURE OF FIELD REPRESENTATIVE:
DUP/Blank/
Sample
Sample ID
Alakalinity (bicarb, carb) - SM
2320B
pH - SM 4500S; Spec. Cond.-
SM2510B; TDS - SM2540C
Verification Reading
All VOCs - 8260B
TPH fractions -
TX1006/LA1006
PAH SVOCs - 8270C
Dissolved Gases - RSK175
Comments
PAGE _____ of _____
Tetra Tech, Inc.
4900 Pearl East Circle Suite 300
Boulder, CO. 80301
Phone: 303-447-1823 Fax: 303-447-1836
________________ _______________
________________ _______________
________________ _______________
APPENDIX B
SINKHOLE WATER QUALITY DEPTH PROFILE SAMPLING
RECOMMENDED REQUIREMENTS DOCUMENT (RRD-GAS-02)
RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Date of Revision 6/27/2013

This Recommended Requirements Document (RRD) is intended to define the minimum technical requirements for conducting the subject
work tasks. This is not a work plan for conducting the work.
RRD-GAS-02
SINKHOLE WATER QUALITY DEPTH PROFILE SAMPLING

RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Page 1 of 3

RECOMMENDED REQUIREMENTS DOCUMENT
Subject: Sinkhole Water Quality Depth Profile Sampling
1.0 Background
The Blue Ribbon Commission (BRC) Gas Group recommends that reducing and maintaining methane gas
formation pressures in the Mississippi River Alluvial Aquifer (MRAA) to equal to hydrostatic pressure
across the Bayou Corne gas area as one metric necessary in order to lift the mandatory evacuation
order. This Recommended Requirements Document (RRD) defines the technical requirements for
obtaining sinkhole depth profile water quality data needed to address this overall objective. The intent
of this RRD is to provide recommended requirements for use by the appropriate state agencies when
directing the development of a comprehensive work plan for addressing the RRD objective.
This RRD for collecting sinkhole water quality depth profile data has been prepared with consideration
of the following site conditions and data requirements:
Since the formation of the sinkhole, natural gas and crude oil have been percolating up from
depth and into the sinkhole waters. During periodic sinkhole burps where the amount of gas
migration to the surface appears to increase, trees and other debris float to the surface for a
short period of time, and the amount of crude oil on the surface of the sinkhole also typically
increases.
The available water quality data from the sinkhole illustrate that there is a substantial
degradation of water quality from the surface to the 100-foot water depth in the sinkhole with
total dissolved solids concentration increasing from approximately 5,000 mg/L at the surface to
over 50,000 mg/L at a depth of 100 feet (Hecox and Saxton, 2013).
Establishing a more complete chemical profile of the sinkhole water quality including dissolved
gas concentration will provide a more defined picture of the water column in the sinkhole and
will help to determine if the water column contains distinct layers or if there is a chemical
gradient throughout the water column.
The potential exists that reducing conditions in the bottom of the sinkhole are conducive to
microbial degradation of sulfate in the presence of methane is producing hydrogen sulfide in the
deeper portions of the sinkhole. This sampling will determine if this is occurring and quantify
hydrogen sulfide concentrations, if any.
Data collected from monthly sampling will be used to monitor changes in the sinkhole water
quality and how sinkhole events, such as the periodic burps or subsidence events, affect the
chemical composition of the sinkhole waters.
This RRD has been prepared as part of the overall GAS-04 BRC task. This BRC task addresses the need
for chemical constituent concentration data in the sinkhole water for use in quantitative evaluations of
RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Page 2 of 3

gas migration and mitigation. The quantitative evaluation requirements are addressed in other RRDs.
This RRD establishes the procedures and equipment required to collect these data.
2.0 Objective and Requirements
The objective of this RRD is to quantify and monitor the inorganic and organic chemical constituents and
concentrations in the sinkhole for the entire water column from the water surface to the bottom of the
sinkhole. The specific laboratory and testing programs shall be specified in the work plan addressing
this RRD.
3.0 Requirements
The requirements of this RRD for sinkhole water quality depth profile data are:
1. Conduct monthly sinkhole depth-profile water and dissolved gas sampling of the water column
from the surface to the bottom of the sinkhole. Due to ongoing changes in the sinkhole
configuration, the location of the deepest portion may change over time. As such, the location
of the deepest portion for a given sampling event will be determined by the results of the most
current bottom survey conducted prior to each sampling event.
2. Field water quality parameters shall be measured and include pressure, specific conductance,
temperature, pH, dissolved oxygen (DO), turbidity, and oxidation-reduction potential (ORP).
3. Water samples shall be collected at the water surface and at 25-foot depth intervals down to
the bottom of the sinkhole.
4. Water and dissolved gas samples should be analyzed for parameters in Table 1. As data are
obtained, this parameter list can be adjusted. Both total and dissolved (0.45 filter) metals shall
be analyzed.

RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Page 3 of 3

Table 1. Sinkhole Water Quality Laboratory Analyte List
Gas Analysis Trace Metals
Major Ions and
General Parameters

Organic
Compounds
Argon Aluminum
Total Alkalinity (as
CaCO3)
Total Petroleum
Hydrocarbons, GRO
Butane Antimony
Alkalinity, Bicarbonate
(as CaCO3)
Total Petroleum
Hydrocarbons, DRO
Carbon Dioxide Arsenic
Alkalinity, Carbonate
(as CaCO3)
Aliphatic C6-C8
del 13C1 Barium Calcium Aliphatic >C8-C10
del 13C2 Beryllium Chloride Aliphatic >C10-C12
del 13C3 Boron Magnesium Aliphatic >C12-C16
del 13IC4 Bromide Potassium Aliphatic >C16-C35
del 13NC4 Cadmium Sodium Aromatic >C8-C10
del Dc1 Chromium, Total Sulfate (as SO4) Aromatic >C10-C12
Ethane Cobalt
Total Dissolved Solids
(Residue, Filterable)
Aromatic >C12-C16
Ethene Copper Total Suspended Solids Aromatic >C16-C21
Helium Iron Water Density Aromatic >C21-C35
Hexanes + heavier Lead Benzene
Hydrogen Lithium

Ethylbenzene
hydrogen Sulfide Manganese

Toluene
Isobutane Mercury

Xylene, total
Isopentane Nickel

Methane Selenium

Nitrogen Silver

Oxygen Strontium

Pentane Thallium

Propane Vanadium

Propene Zinc

Specific Gravity

Appendix 1 presents suggested procedures for data collection to meet the above objective and
requirements. These procedures can be modified or replaced as appropriate to meet the objectives and
requirements.

RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1

APPENDIX 1
SUGGESTED PROCEDURES

RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Page 1 of 7

1.0 Introduction
This appendix is intended for use as a procedural reference for obtaining the data required in the RRD.
The procedures in this section have been used by one or more Blue Ribbon Commissioners to obtain or
generate the data specified in Section 3.0 of the RRD. In preparing the work plan to address this RRD,
other procedures can be used provided the objectives and data requirements in Sections 2 and 3 are
met.
2.0 Contract Services
2.1 Isotech Laboratories, Inc.
Water samples submitted for compositional gas analysis and isotopes should be submitted to Isotech
Laboratories, Inc. in Champaign, Illinois or an equivalent laboratory specializing in analysis of dissolved
gases.
2.2 Louisiana Accredited Analytical Laboratory
With the exception of samples submitted for compositional gas analysis and isotopes, all other samples
submitted for laboratory analysis should be analyzed by a laboratory accredited under the Louisiana
Department of Environmental Qualitys (LDEQ) Louisiana Environmental Laboratory Accreditation
Program (LELAP).
3.0 Specialized Field Equipment
3.1 Boat Equipped with a Sample Winch/Depth Meter
The sampling boat shall be equipped with a manual or electric sample winch with the cable marked in
feet or an attached depth counter. The winch should have a minimum of 300 feet of cable. A second
supply boat is recommended for handling decontamination activities and storage of sample coolers,
sample containers, and sampling supplies.
3.2 Tag Line
A tag line, with a minimum of 500 feet of line weighted at the end and marked in feet and tenths of feet
or equivalent, should be provided for depth measurements.
3.3 In-Situ Troll
9500 and Rugged Reader

The In-Situ Troll 9500 with cable-coupled RDO dissolved oxygen sensor (http://www.in-
situ.com/products/water-quality/troll-9500-sensors/rdo-sensors-for-the-troll-9500) and 9500 magnetic
stirrer, is a water quality instrument that can measure up to nine (9) water quality parameters which can
be recorded and saved on the Rugged Reader. At a minimum the following water quality parameters
should be measured in the sinkhole: pressure, pH, temperature, conductance, DO, ORP, and turbidity.
The Troll is programmed and data recorded with a Rugged Reader or smarTROLL iPhone app.
RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Page 2 of 7

3.4 Van Dorn Samplers
Van Dorn-style samplers are recommended to collect samples at various depths of the water column to
maintain integrity of the dissolved gases in the water sample. The sampler should have a minimum of
4.2 liter capacity although the 6.2 liter sampler may reduce field time if a properly configured winch is
used. A vertical Van Dorn sampler is recommended as this allows for easier dissolved gas sample
retrieval. Two Van Dorn samplers are recommended to allow for one to be decontaminated while the
other one is being used to collect a sample.
3.5 Sample Filtering Equipment
Peristaltic pump and 0.45 micron high-capacity filters and tubing should be provided in sufficient
quantity for the number of anticipated samples.
3.6 Sampling Supplies
Appropriate sample containers (sufficient quantity for the number of anticipated samples), coolers,
labels, chain-of-custody forms, nitrile or latex gloves, and miscellaneous sampling supplies should be
provided.
3.7 Decontamination Supplies
Appropriate tubs, brushes, decon fluids (distilled or deionized water, Alconox soap or equivalent),
brushes, paper towels, and foil should be provided. It is recommended that a decon station be set up on
a second boat for this sampling.
3.8 GPS Unit
A portable global positioning system (GPS) unit with sub-meter accuracy and real-time tracking
capability is recommended.
RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Page 3 of 7

4.0 Definitions
The following definitions are applicable to this appendix:
Van Dorn Samplerspecialized sampling device capable of collecting dissolved gas and water
samples at a specific depth.

Figure 1. Vertical Van Dorn sampler
LELAP Louisiana Environmental Laboratory Accreditation Program. Laboratory data generated
by commercial environmental laboratories that are not accredited under these regulations will
not be accepted by the department in accordance with LAC 33:I.4501.A.2. Whenever samples
are subcontracted to another environmental testing laboratory, the original laboratory shall
maintain a verifiable copy the results with a chain of custody. The procedure may not be used to
circumvent proper accreditation or any state requirements. The original laboratory is
responsible for ensuring that the secondary laboratory used is properly accredited for the scope
of testing performed in accordance with LAC 33:I.5307.D.
5.0 Procedure
The following procedures are recommended for the collection of depth-profile water quality samples
from the sinkhole. These procedures are based on previous experience with sampling surface water and
water at depth along the Louisiana Gulf Coast. The sampling should be conducted using a primary
sample boat with a second supply boat for handling decontamination, sample coolers, ice, and bottles.
5.1 Sinkhole Access/Seismic Clearance
Before launching the boats, meet with the site seismic monitoring authority to obtain the current
Seismic Activity Level Code which will indicate if personnel can enter and perform work on the sinkhole.
The depth-profile sampling can only be conducted during periods when the Seismic Activity Level Code
is at Level 1/Green. A competent and knowledgeable person should monitor the seismic helicorders
when personnel are working on the sinkhole. Cell-phone or OEP radio communications will be used
during the sampling.
RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Page 4 of 7

5.2 Route and Sample Location Tracking
Upon leaving the boat launch, turn on the GPS unit in tracking mode and allow it to record the track of
the entire sample event. Place the unit in the location where it has a clear signal from the sky, away
from any other electronic or magnetic equipment that could cause interference, but is out of the way
for sampling. Turn the unit off only after sampling is complete and the boats are back at the dock.
5.3 Boat Positioning/Sample Location
Position the sampling boat over the deepest depth location in the sinkhole, based on the most recent
depth profiles. Since it may not possible to anchor the boats, procedures for maintaining proper location
over the deepest part of the sinkhole should be coordinated with the boat operators.
5.4 Depth Gauging
Once the boat has been positioned over the deepest part of the sinkhole, sound the bottom of the
sinkhole using the tag line. Record the depth of the sinkhole at this location.
5.5 Water Quality Measurements
With the In-Situ, Inc. Troll 9500, measure pressure, pH, specific conductance, temperature, DO,
turbidity, and ORP at 10-foot depth intervals from the water surface down to just above the bottom of
the sinkhole. Attach the tag line to the Troll sensor for measuring the depthit is not possible to use
pressure to determine depth because of the variable density water in the sinkhole. Use the Troll
logging function (In-Situ, Inc. Rugged Reader required) to continuously record the data and write down
the final values at each 10-foot depth interval on the sample collection log. It may take several minutes
for the DO and ORP readings to stabilize at a given depth; the magnetic stirrer facilitates stabilization.
5.6 Surface Water Sample Collection
Using a peristaltic pump and new, clean Teflon tubing, collect water and dissolved gas samples at
approximately 1-foot below the water surface. Place the proper aliquots in the labeled sample bottles.
Filter the sample that will be submitted for dissolved metals analysis. Use the Isobag and peristaltic
pump for collecting the dissolved gas samples.
5.7 Depth Profile Water Sample Collection
Using the Van Dorn sampler (Lane et al., 2003), collect depth profile water samples at depths of 10 feet,
25 feet, 50 feet, and every 25 feet thereafter to the bottom of the sinkhole. The last sample should be
approximately 5 feet above the bottom of the sinkhole. As a guide for the final sample, if the bottom of
the sinkhole is at 160 feet, it is not necessary to collect a sample at 155 feet and the 150-foot sample will
be the bottom sample. If the bottom of the sinkhole is at 165 feet, then the bottom sample will be
collected at the 160-foot depth.
RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Page 5 of 7

It is important that the boat location be maintained close to the deepest portion of the sinkhole during
all sampling. It is recommended that the GPS unit be operated in tracking mode to document any
changes in boat location during the sampling events.
A water sample at the selected depths should be collected as follows using a Van Dorn sampler which
has been properly decontaminated. Any sampling personnel that will come into contact with the
sampling device and/or sampling containers shall wear a new, clean pair of nitrile or latex gloves during
all sampling activities. The gloves should all be changed in between each sample. Below are the general
sampling procedures that are recommended:
1. Confirm that the winch cable is securely attached to the sampling device. Check that the
sample valves (located on the sampler end caps) on the Van Dorn sampler are both closed. Set
the end cap trigger mechanism as per manufacturer instructions.
2. Using the winch with depth meter on the boat, lower the Van Dorn sampler to the target
depth. Make sure that the rope attached to the sampler is free of knots and kinks so that the
messenger (weighted cylinder) can reach the sampling device.
3. Upon reaching the desired depth, release the messenger (weighted cylinder) to trigger the
closing of the sampler end caps.
4. Retrieve the Van Dorn sampler into the boat using the winch.
5. Hold the sampling device in the vertical position then open the top sample port. The sampler
will be under pressure and so caution must be used when opening the valves.
6. Open the bottom valve and using the attached sample port and Teflon tubing, fill the
dissolved gas Isobag first followed by the VOC vials. As pressure is relieved in the Van Dorn
sampler, open the top sample port to allow for water flow out of the bottom port.
7. New Teflon tubing will be used for each new sample depth.
8. After these samples are collected, fill the appropriate bottles including the filtered dissolved
metals container. For dissolved metals, it is preferable to connect tubing to the bottom
sample port and pump directly from that port, through the filter into the sample bottle.
9. Properly label each sample at the time of collection. At a minimum, the label should contain
the following information: Sample I.D., Depth, Date and Time collected, Samplers name,
requested analysis.
10. Except for the Isobags, samples will be placed on ice in coolers immediately following sample
collection.
11. The sampler will hold approximately 4 or 6 liters of water. Make repeated trips to the sample
depth as necessary to fill all sample bottles.
12. Decontaminate the sampler on the decon boat using the proper materials and procedures.
Because there will likely be oil film on the sampler, a mild (phosphate-free) detergent may be
necessary for thorough decontamination. Two samplers are recommended so one can be
decontaminated while the second on is being used for sampling.
RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Page 6 of 7

5.8 Sample Handling and Shipment
Upon returning to the dock, pack the samples for shipping to the appropriate laboratory. Add ice if
necessary/required. Complete the Chain-of-Custody forms. Transport the samples to the laboratory,
laboratory courier, or shipper (i.e. Fed-Ex or UPS).
5.9 Sample Analysis
The water samples from each sample depth will be submitted to the appropriate laboratories, following
proper chain-of-custody procedures, for analyses. The following analyses will be requested:
5.9.1 Isotech Laboratories
The Isobags should be submitted to Isotech Laboratories in Champaign, Illinois or equivalent dissolved
gas laboratory for analysis of:
Compositional Gas (see Table 1 for list of components)
Compound-specific isotope Ratios (see Table 1 for list of isotopes)
5.9.2 LELAP Laboratory
The remaining samples from each depth should be submitted to the selected LELAP laboratory for the
following analyses:
Alkalinity by Method 2320 or equivalent
Benzene, Toluene, Ethylbenzene, Xylene (BTEX) by U.S. Environmental Protection Agency (EPA)
Method 8260 or equivalent
Chloride by Method SM4500 or Method 9056 or equivalent
Inorganic Anions by Method 9056 or equivalent
Metals (dissolved and total) EPA Method 6010 or equivalent (see Table 1 for metals list)
Specific Conductance by Method SM2510 or equivalent
Total Dissolved Solids by Method SM2540 or equivalent
Total Petroleum Hydrocarbons Gasoline Range Organics/Diesel Range Organics/Oil Range
Organics by EPA Method 8015 or equivalent
Total Petroleum Hydrocarbon fractions (aliphatics >C6C35, and aromatics >C8C35) by
Massachusetts TPH Method
Total suspended solids by Method 160.2 or equivalent
Water density by hydrometer or equivalent
5.10 Equipment Decontamination
At the conclusion of the sampling event, all sampling equipment should be thoroughly decontaminated
and placed in proper storage pending future sampling. All disposable equipment shall be properly
disposed.
RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1
Page 7 of 7

5.11 Submittal of Data
All field activities should be documented and reported to LDNR in an electronic format and reasonable
time frame. Upon receipt, analytical results shall also be submitted to LDNR in PDF and Excel or similar
electronic data transfer format.
6.0 Attachments
Attachment 1Isobag fill procedures
7.0 Forms
Daily Field Activity Log
Chain-of-Custody Document
Sample Collection Log
8.0 References
Hecox, G. R., and Saxton, D. C., 2013, Bayou Corne Sinkhole Status Report to Blue Ribbon Commission,
Baton Rouge, LA, CB&I, 121 plus appendices p.:
Lane, S. L., Flanagan, S., and Wilde, F. D., 2003, Chapter A2, Book 9, Selection of Equipment For Water
Sampling, Handbooks for Water-Resources Investigations, National Field Manual for the
Collection of Water-Quality Data, Reston, VA, U.S. Geological Survey, v. A2, 123 p.:

RRD No. RRD-GAS-02
BRC Task ID GAS-04
Version Draft 1

ATTACHMENT 1
ISOBAG FILL PROCEDURES

1. Sampling source: Water samples should either be collected from a pressurized water system or by using a suitable water
pump. When sampling from a pressurized water system, it is recommended to use an outdoor spigot or other source which
bypasses any water treatment systems (i.e. water softeners, etc.). When using a pump, it should be capable of maintaining a
constant pressure at or above that which exists within the aquifer. This is to ensure that gases dissolved in the water within the
aquifer remain dissolved until the water is transferred into an IsoBag. If using a pulsating pump such as a bladder pump, please
contact Isotech for additional recommendations.
2. Sampling Mechanism: After purging the well, a mechanism consisting of a pressure
gauge in line with two valves should be attached to the spigot or pump output (see
figure). The purge valve (see figure) allows water to be pumped through the
system to purge both the well and the tubing. The sampling valve (which should
point downward), provides a point whereby a sample split can be slowly bled off
from that water which is being continuously purged out of the system via the purge
valve. Sampling in this manner allows for collection of a sample over a longer period
of time, and as such should provide a sample that is more representative of the water
source, in essence creating an averaging effect during collection.
3. IsoBags: The gas bags provided have been evacuated in advance. A capsule lled
with bactericide has also been inserted.
4. Collection of samples: Slowly open the purge valve to purge any gas or air from the tubing. The ow rate should be controlled
so as to allow a reasonable ow, while also maintaining a pressure close to the maximum pressure of the water system or pump.
When the line has been adequately purged and a steady state situation is achieved, open the sampling valve slightly to purge
the air from it. Then, with the water still running at a low rate, connect the tting to the valve on the IsoBag and proceed to ll
the bag (note: the slower the lling rate, the greater the averaging effect). The bag should be lled with approximately 500 cc
of water (i.e. to a thickness of about 1 inch). When sufcient sample has been collected, close the sampling valve and quickly
disconnect the tting from the IsoBag. The water ow can now be turned off and the hose disconnected. Reattach the cap to
the valve of the IsoBag.
5. Submission of samples. After recording the sample identification on the attached label, the bag should be placed in its
protective box and packed laying at. Complete a Chain-of-Custody/Analysis Request form and include it with the sample(s).
If possible, samples should be shipped the same day collected, via an overnight delivery service. Client MUST inform
Isotech of shipment prior to arrival. Please note Isotechs receiving hours of Monday thru Friday 8:00 am to 4:30 p.m.

Ship samples to:
Isotech Laboratories, Inc.
1308 Parkland Court
Champaign, IL 61821
These instructions have been provided to simplify the collection of samples for dissolved gas analysis. Although we try to foresee and avoid problems in
the field, it is never possible to predict every situation. If you encounter any difficulties, or if any additions or changes in these instructions would
be benecial, please let us know.
Isotech Laboratories, Inc. makes no warranty as to the applicability and/or safety of the procedures described herein.
I SOTECH LABORATORI ES
R
1308 Parkland Court Champaign, IL 61821 (877) 362-4190 www.isotechlabs.com
Collection of Ground Water Samples
from Domestic and Municipal Water Wells
for Dissolved Gas Analysis
1
APPENDIX C
GEOTECHNICAL ENGINEERING STABILITY REPORT
(To be inserted when the report is completed in late December 2013)
APPENDIX D
STORM WATER POLLUTION PREVENTION PLAN

Storm Water Pollution Prevention Plan
(SWPPP)
Permit No. LAR10J367
Grand Bayou Incident Response Project

Development Location:
Napoleonville Salt Dome
Assumption Parish, LA

Submitted by:
4800 San Felipe
Houston, TX 77056
(901) 482-2500
Fax (985) 369-7873

Prepared by:
Tetra Tech, Inc.
Boulder, CO 80301
(303) 447-1823
Fax (303) 447-1836

April 2013
SWPPP Texas Brine Company, LLC
Tetra Tech April 2013 i
CERTIFICATIONS

To Be Completed by Construction Site Operator with Operational Control

I certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is,
to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for attesting to false information, including the possibility of fine and imprisonment for knowing
violations.

To Be Completed by Construction Site Operator with Day-to-Day Operational Control

I certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to ensure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, to the best of my knowledge
and belief, the information submitted is true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment for knowing
violations.

Mike Taylor, Response Manager

(901) 482-2500
Name and Title Telephone Number

Signature

Date

Operators Name and Title Operators Telephone Number

Operators Signature Date
Tetra Tech April 2013 ii
TABLE OF CONTENTS
1.0 CONTACT INFORMATION ............................................................................................. 1
2.0 INTRODUCTION ............................................................................................................. 2
3.0 SITE DESCRIPTION ....................................................................................................... 3
3.1 Site Location ........................................................................................................ 3
3.2 Nature of the Project ............................................................................................ 3
3.3 Construction Activities .......................................................................................... 4
3.3.1 Pads ....................................................................................................................... 4
3.3.2 Containment System Dikes .................................................................................... 4
3.3.3 Access Roads ........................................................................................................ 4
3.3.4 Material Stockpiles ................................................................................................. 4
3.4 Sequence of Major Activities ................................................................................ 5
3.5 Estimated Area of Disturbance............................................................................. 5
3.6 Soils ..................................................................................................................... 5
3.7 Estimated Runoff Coefficient ................................................................................ 7
3.8 Waters of the U.S. within 1 Mile of the Site .......................................................... 7
3.9 Drainage Patterns ................................................................................................ 7
3.10 Non-Storm Water Discharges .............................................................................. 7
3.11 Listed Species or Critical Habitat ......................................................................... 7
3.12 Historic Properties ................................................................................................ 8
3.13 Total Maximum Daily Load ................................................................................... 8
4.0 CONTROLS .................................................................................................................... 9
4.1 Structural Controls ............................................................................................... 9
4.1.1 Silt Fence ............................................................................................................... 9
4.1.2 Wattles ................................................................................................................. 10
4.1.3 Turbidity Curtains ................................................................................................. 10
4.1.4 Construction Exist Pads ....................................................................................... 10
4.2 Stabilization Practices ........................................................................................ 11
4.2.1 Slopes .................................................................................................................. 11
4.2.2 Turf Reinforcement Mat ....................................................................................... 11
4.2.3 Revegetation ........................................................................................................ 11
4.3 Storm Water Management Practices.................................................................. 11
4.3.1 Off-site Equipment Maintenance.......................................................................... 11
4.3.2 Off-site Fertilizer Storage ..................................................................................... 11
4.3.3 Trash Removal ..................................................................................................... 11
4.3.4 Portable Sanitary Facilities .................................................................................. 12
4.3.5 Engineering and Construction Practices .............................................................. 12
5.0 INSPECTIONS AND RECORDKEEPING ..................................................................... 13
5.1 Inspections......................................................................................................... 13
5.2 Maintenance ...................................................................................................... 14
5.3 Emergency Notification ...................................................................................... 15
5.4 Recordkeeping ................................................................................................... 15
Tetra Tech April 2013 iii
6.0 SWPPP AMENDMENTS ............................................................................................... 16
7.0 TERMINATION ............................................................................................................. 17
8.0 REFERENCES .............................................................................................................. 18
LIST OF TABLES
Table 1-1. Contact Information .................................................................................................... 1
Table 3-1. Sequence of Construction Activities and Potential Pollutants ..................................... 5
Table 3-2. Areas of Disturbance .................................................................................................. 5
Table 3-3. Runoff Coefficients ..................................................................................................... 7
Table 4-1. List of BMPs ............................................................................................................... 9
Table 4-2. Engineering Design for Silt Fences .......................................................................... 10
LIST OF APPENDICES
Appendix A Figures
Appendix B Cultural Resources
Class I Letter Report

Tetra Tech April 2013 1
1.0 CONTACT INFORMATION
Table 1-1 summarizes company and contractor contact information for the Storm Water
Pollution Prevention Plan (SWPPP).
Table 1-1. Contact Information
Name Phone/Fax/Mobile Address
Property Owner
(901) 482-2500
(985) 369-7873
4800 San Felipe
Houston, TX 77056
Project Contractor
Tetra Tech, Inc.
(303) 447-1823
(303) 447-1836
Boulder, CO 80301
Project Erosion Lead/24-hour Contact
Tetra Tech, Inc. (985) 252-8832
1491 Highway 70 South
Belle Rose, LA 70341
2.0 INTRODUCTION
Texas Brine Company, LLC (TBC) is preparing this SWPPP to comply with requirements set
forth in the General Permit for Discharges of Storm Water from Construction Activities 5 Acres
or More (LAR100000), issued by the Louisiana Department of Environmental Quality (DEQ) on
September 30, 2009. TBC submitted a Notice of Intent for permit coverage to DEQ on April 5,
2013 and received authorization to discharge storm water associated with construction activity
on April 19, 2013 (LAR10J367). The SWPPP describes the Grand Bayou Incident Response
Project (Project), associated response activities, and construction storm water controls.
The SWPPP will be maintained on site, in accordance with Part IV(B)(1) of the General Permit.
TBC will post a notice near the main entrance of the construction site with the information listed
below, in accordance with Part IV(B)(2) of the General Permit.
The permit number for the Project
The name and phone number of a local contact person
A brief description of the Project

3.0 SITE DESCRIPTION
A sinkhole formed in August 2012 on property near Grand Bayou, Louisiana, which is owned by
Occidental Chemical Corporation and leased and operated by TBC. TBC mines brine from the
Napoleonville Salt Dome cavern which supplies the chlor-alkali industry. The sinkhole is related
to TBCs Oxy No. 3 cavern in the Napoleonville Salt Dome. The area of the sinkhole was
approximately 13 acres in size in April 2013.
3.1 Site Location
The sinkhole is located southeast of the Bayou Corne community, and south of State Highway
70, in Assumption Parish. It is centered at the following coordinates: Lat. 30
o
00 31.2; Lon. 91
o

08 22.7 (Figure 1). The legal description for the area is Township 12 South, Range 13 East,
Section 40. The area surrounding the sinkhole is a cypress-tupelo swamp associated with
Bayou Corne, a tributary of Grand Bayou. The sinkhole is approximately 0.22 miles from Bayou
Corne and 0.52 miles from the confluence of Bayou Corne and Grand Bayou.
3.2 Nature of the Project
TBC proposed construction of the facilities listed below to support corrective action for the
sinkhole in response to emergency directives issued by the Louisiana Department of Natural
Resources (LDNR).
Pads to support well facilities and other activities, as described below

o Observation and relief wells to determine the presence and pressure of natural
gas occurring in the Mississippi River Alluvial Aquifer (MRAA) and safe treatment
of the natural gas by combustion at portable flare locations

o Pressure monitoring wells to determine the presence and pressure of natural gas
in the MRAA with optional flaring

o Groundwater monitoring wells to monitor water levels and groundwater quality

o Geoprobes to monitor water quality and the pressure of the natural gas in the
aquitard overlying the MRAA

o Portable flares for safe treatment of the vented natural gas by combustion

A containment system consisting of a perimeter of dikes to prevent the migration of
constituents from the sinkhole

Access roads to support the well facilities and containment system
Details regarding the facilities, their areas of disturbance, and construction activities are
described in Section 3.3.
3.3 Construction Activities
3.3.1 Pads
Pads for ORWs, pressure monitoring wells, and groundwater monitoring wells will be completed
to a finished size of approximately 50 feet by 100 feet. Finished pads for geoprobes will be
approximately 20 feet by 20 feet. Finished pads for portable flares will be approximately 100 feet
by 100 feet. Vegetation removal needed for pad installation requires an additional 15 feet of
clearance in both length and width for each pad (Figure 2).
Pad construction will consist of, from bottom to top, an optional geotextile liner, approximately 4
feet of sand fill, a second geotextile liner, approximately 2 feet of compacted clay, a third
geotextile liner, and an approximately 12-inch limestone cap.
3.3.2 Containment System Dikes
The containment system for the sinkhole will be provided by a continuous low permeability
perimeter of dikes with top elevations several feet above the surface water water elevation in
the sinkhole during normal, non-storm event conditions. There will be approximately 5,127 linear
feet of 40-foot-wide newly constructed dikes or raised dikes over existing road beds. An
additional approximately 15 feet will be needed along dikes for tree laydown (Figure 3). The
system will incorporate, to the extent practicable, existing roads and well pads to minimize new
construction.
Dike design will consist of, from bottom to top, an optional geotextile liner, a base layer of sand
fill (dependent on water depth), a liner to cap the material which will be secured in anchor
trenches [the liner will be a geotextile liner on the bayou side of the dike overlapping with a
geosynthetic clay liner (GCL) on the sinkhole side of the dike], additional fill over the anchor
trenches, at least 18 to 24 inches of compacted clay, a third geotextile liner, and an
approximately 12-inch limestone cap (Figure 4). Wood matting may be added, if necessary.
Access roads used to form the eastern and western dikes will have a similar design but will not
require the initial geotextile base layer.
3.3.3 Access Roads
Access roads are shown on Figure 1. Approximately 5,534 linear feet of access roads are
proposed to support the well pads, containment dikes, and other facilities. Access roads will
consist of, from bottom to top, an optional geotextile liner, a base layer of sand fill (dependent
on water depth), a liner to cap the material which will be secured in anchor trenches, additional
fill over the anchor trenches, at least 18 to 24 inches of compacted clay, a third geotextile liner,
and an approximately 12-inch limestone cap. Wood matting may be added to the top, if
necessary. Access road design is illustrated on Figures 3 and 5.
3.3.4 Material Stockpiles
Material required for construction consists of sand, limestone, compacted clay, geotextile liners,
and wood mats. Sand and limestone will be used for construction at the time it is delivered to
the Project site. These materials will not be stockpiled on the Project site. Clay will be stockpiled
at well pad 3, adjacent to the TBC facility, and on existing pads along the dikes. Geotextile liners
and wood mats will be stockpiled at the TBC facility. At the point of construction for containment
system dikes and access roads, soils excavated for anchor trenches will not be stockpiled. It will
be transferred onto dike and road beds as fill, and then fresh fill will be added to the anchor
trenches.
3.4 Sequence of Major Activities
Sites proposed for construction activity require vegetation clearing using an excavator. In areas
where water depth does not exceed approximately 2 feet, a track hoe with a chipper attachment
will be used to chip cleared trees and other vegetation. Trees and other vegetation otherwise
will be placed alongside the cleared area without chipping. The activities will be followed by
excavation work for anchor trenches to support access roads and dikes. Fill then will be placed
using dump trucks and bulldozers. Fill will be obtained from an off-site borrow location. Sites will
be finished using a grader. The sequence of construction activities and potential pollutants are
summarized in Table 3-1. Work currently is scheduled to be complete in January 2014.
Table 3-1. Sequence of Construction Activities and Potential Pollutants
Construction Activity Potential Pollutants
Vegetation clearing
Sediment, total suspended solids,
turbidity, hydrocarbons
Vegetation chipping
Excavation
Fill work
Grading

3.5 Estimated Area of Disturbance
The total estimated area of disturbance for the construction activities described in Section 3.3 is
20.90 acres. This value is inclusive of the disturbed footprint for well pads, dikes, access roads,
excavated anchor areas for dikes and access roads, and material and equipment storage. The
Project area (a polygon encompassing the facilities shown on Figure 1) is approximately 570
acres. Table 3-2 shows the breakdown of areas of disturbance.
Table 3-2. Areas of Disturbance
Activity Area of Disturbance (acres)
Well pads 6.58
Containment system dikes 6.44
Access roads 7.88

3.6 Soils
Soils in the area are Fausse association according to the Natural Resources Conservation
Service Web Soil Survey (NRCS 2012). Fausse soils consist of deep, poorly drained, slowly
permeable soils that formed in clayey alluvium. These soils are located in low, ponded swamp
areas of the lower Mississippi River alluvial plain. Slopes in the area are less than 1 percent.
3.7 Estimated Runoff Coefficient
The Project site is swamp with saturated soils. Post-construction runoff coefficients were
developed based on two stages of post-construction conditions. Stage 1 represents the state of
the pads, containment system dikes, and access roads after construction but prior to
establishment of vegetation on the side slopes of the facilities. The Stage 1 runoff coefficient is
estimated to be 0.76. Stage 2 represents the state of the pads, containment system dikes, and
access roads after construction and establishment of vegetation on the side slopes of the
facilities. The Stage 2 runoff coefficient is estimated to be 0.73. The variables considered in
calculating the runoff coefficients are shown in Table 3-3.
Table 3-3. Runoff Coefficients

Flat
Surface
Ratio of
Flat Areas
Flat Runoff
Coefficient
Sloped
Surface
Ratio of
Sloped
Areas
Slope
Runoff
Coefficient
Total
Runoff
Coefficient
Stage 1
Limestone
Cover
0.71 0.75
Not
vegetated
0.29 0.79 0.76
Stage 2
Limestone
Cover
0.71 0.75 Vegetated 0.29 0.69 0.73

3.8 Waters of the U.S. within 1 Mile of the Site
Figure 1 shows Bayou Corne to the west and Grand Bayou to the east relative to the Project
site. The Project site is located within a cypress-tupelo swamp.
3.9 Drainage Patterns
Surface water in the area drains southwest toward Bayou Corne, a tributary of Grand Bayou.
Slopes in the area, however, are less than 1 percent. Water levels in the swamp surrounding
the Project site vary by season from approximately 1 to 3 feet above mean sea level.
3.10 Non-Storm Water Discharges
The containment system is designed with 5-foot-tall dikes. A discharge from the containment
system is anticipated only in the event of a major storm event requiring a controlled release to
maintain the integrity of the dikes. In that event, pumping storm water outside of the dike is not
planned. Instead, a gravity head on the storm water volume inside the containment area would
force excess storm water to flow to a transfer structure. The transfer structure consists of twin
30-inch-diameter pipes within the containment system to act as a manually-operated spillway.
There also will be a single 6-inch-diameter pipe at an elevation of 4.5 feet to supplement the
manual spillway. Absorbent booms will prevent the release of hydrocarbons in storm water.
3.11 Listed Species or Critical Habitat
There are no threatened or endangered species, or critical habitat, in Assumption Parish. The
information was determined using the U.S. Fish and Wildlife Services (USFSs) Information,
Planning, and Conservation System (IPaC).
3.12 Historic Properties
There are no historic properties listed or eligible for listing on the National Register of Historic
Places located on or near the Project site. The information was determined by a Class I cultural
resources literature review of the Louisiana Office of Cultural Development, Division of
Archaeology, Cultural Records online database. Documentation of the Class 1 literature review
is provided in Appendix B.
3.13 Total Maximum Daily Load
There are no total maximum daily load limits for pollutants in the swamp where the Project site
is located or in Bayou Corne downstream of the Project site. TBC is not anticipated to contribute
to pollutant loadings because storm water controls are designed to prevent pollutants
associated with construction activities from reaching Bayou Corne.
4.0 CONTROLS
This section describes best management practices (BMPs) for control of storm water during
construction activities at the Project site. The BMPs are organized as structural controls,
stabilization practices, and storm water management practices. The BMPs are listed in Table 4-
1, illustrated in Figure 6, and discussed below.
Table 4-1. List of BMPs
Type BMP
Structural controls Silt fence
Wattles
Turbidity curtains
Construction exit pads
Stabilization practices Slopes
Revegetation
Turf reinforcement mat
Storm water management practices Off-site equipment
maintenance
Off-site fertilizer storage
Trash removal from the site
Portable sanitary facilities
Engineering and
construction practices

4.1 Structural Controls
Structural controls are equipment or materials that will be installed to prevent movement of
sediment-laden storm water runoff from the Project site. Temporary structural controls will be
used to reduce the velocity of storm water flows and to intercept suspended sediments
conveyed by overland flow, while allowing runoff to continue down gradient. Structural control
measures were selected and will be installed and maintained in accordance with the
manufacturers specifications and standard engineering practices. The controls are designed to
retain sediment within the affected area and to avoid, to the greatest extent possible, sediments
from entering nearby surface water. Structural controls for the Project are described below.
4.1.1 Silt Fence
Silt fences will be used on downgradient slopes of well pads, dikes, access roads, and material
storage areas to capture sediment conveyed by sheet flow. The silt fences provide a temporary
barrier which reduces runoff velocities and allows sediment to collect behind the silt fence. Silt
fences consist of filter fabric stretched between support posts in increments no greater than 6 to
8 feet apart. The posts will be anchored in 4-inch by 4-inch trenches. Wire fencing then will be
stapled to the posts, and filter fabric will be attached to the wire fencing. Silt fence will be
attached on the up-slope side of the posts, and the bottom will be buried in the anchor trenches.
The trenches will be backfilled with excavated soil and compacted.
Silt fences normally are not used to mitigate sedimentation in a waterbody. In this case,
however, silt fences are used because there is no measurable flow rate in this portion of the
swamp in contrast to the typical threshold of 1 cubic foot per second (cfs). In addition, overland
sheet flow on the Project site will drain construction areas measuring, at most, approximately
100 feet by 100 feet which is less than the 0.25-acre threshold per 100 feet of silt fence normally
specified for silt fencing. Slopes behind the silt fence will be 1:1 and approximately 5 to 6 feet
high in contrast to the 100-foot-high slope threshold normally specified. The engineering design
for silt fences at the Project site is summarized in Table 4-2 and contrasted with common
thresholds established for use of silt fences.
Table 4-2. Engineering Design for Silt Fences
Design Element TBC Design Common Thresholds
Flow rate De minimis 1 cfs
Drainage area < 0.25 acres per 100 feet of silt fence 0.25 acres per 100 feet of silt fence
Slope 1:1 2:1

4.1.2 Wattles
A wattle is an erosion and sediment control barrier constructed of straw wrapped in a tube of
biodegradable plastic or other casing. Carefully placed wattles reduce storm water velocity and
capture sediment. A typical wattle is 8 to 10 inches in diameter and can be 25 feet long.
Wattles on the Project site will be installed perpendicular to slopes in shallow trenches,
approximately 2 to 3 inches deep and 9 inches wide. Wattles will be secured using wooden
stakes measuring 1x2x36 inches driven into the slope, leaving approximately 2 to 3 inches of
the stake exposed. Adjacent wattles will tightly abut one another to prevent pathways for storm
water runoff.
4.1.3 Turbidity Curtains
A turbidity curtain is a floating geotextile material used to prevent or minimize sediment
transport within a waterbody. It consists of a sleeved, buoyant upper portion and a lower portion
with a weighted hem that acts as a curtain when held by anchor points in the vertical position in
a column of water. Turbidity curtains will be used in areas with greater than 1 foot of standing
water.
4.1.4 Construction Exist Pads
Construction exit pads will be used to knock sediments from construction vehicles to minimize
the transfer of sediments onto public roadways. They will consist of a coarse aggregate base at
the exit areas of the construction site (i.e., the point of transfer from access roads onto public
roadways). Aggregate will be approximately 6 inches deep and will cover an area at least 50
feet long.
4.2 Stabilization Practices
Stabilization practices are used to minimize movement of sediments during storm events and
are described below.
4.2.1 Slopes
Side slopes on pads, dikes, and access roads will be 1:1 which will be mitigated with turf
reinforcement mat and revegetation.
4.2.2 Turf Reinforcement Mat
Turf reinforcement mat (TRM) will be used to prevent soil erosion and promote revegetation of
disturbed slopes. The TRM will be unrolled along slopes to cover the slopes. It will be anchored
with stakes in trenches approximately 6 inches deep and 6 inches wide. Trenches will be
backfilled and compacted. The TRM seams will be stapled to provide overlap. The TRM also will
be staked and anchored at the water line in trenches approximately 12 inches deep and 6
inches wide which will be backfilled and compacted. Once in place, revegetation growth will
occur through the TRM.
4.2.3 Revegetation
Constructed slopes will be revegetated using Natural Resource Conservation Service
recommendations for seed mix consisting of 400 pounds/acre of triple 13 fertilizer; 40
pounds/acre of brown top millet; and 30 pounds per acre of common Bermuda grass.
4.3 Storm Water Management Practices
Storm water management practices are other methods used to avoid or minimize pollutants
from entering the swamp. Storm water management practices for the Project are described
below.
4.3.1 Off-site Equipment Maintenance
Vehicles and equipment will be maintained and repaired off site to prevent fuels or other
pollutants from entering storm water runoff.
4.3.2 Off-site Fertilizer Storage
Fertilizer used for revegetation will be stored off site, if necessary, and used in appropriate
quantities as it arrives on site.
4.3.3 Trash Removal
Litter and construction debris will be removed as soon as is practicable following construction
activities in a specific work area.
4.3.4 Portable Sanitary Facilities
Portable sanitary facilities will be provided for all workers on site.
4.3.5 Engineering and Construction Practices
In addition to the storm water management practices above, TBC will use good engineering and
construction practices which include, at a minimum, the following:
Limit vegetation clearing to the minimum needed for construction activities
Limit soil disturbance to the minimum needed for construction activities
Select and install BMPs according to manufacturer or designer specifications
Maintain natural buffers around surface water
Provide spill kits and absorbent materials for control of hydrocarbons or other
contaminants

5.0 INSPECTIONS AND RECORDKEEPING
5.1 Inspections
Inspection and maintenance procedures will be implemented to maintain adequate sediment
and erosion controls. Specifically, BMPs will be inspected 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.
Inspections will be conducted by field personnel trained in the standards of performance and
maintenance requirements for individual BMPs. Inspectors will determine whether BMPs are in
place, as required, properly maintained, and properly operating. Inspections will be documented
using the Inspection Report form provided to field personnel. In particular, inspectors will note
areas where sediment transport may be occurring, as well as needed BMP maintenance or
replacement. Such maintenance or replacement normally will be initiated within 24 hours of the
inspection findings. Inspectors will note specific indicators of storm water runoff, such as floating
solids, settled solids, suspended solids, foam, or oil sheen. A sample Inspection Report form is
shown below.
INSPECTION REPORT

Locations: ____________________________________________

Date: ____________________________________________

Inspector/Title: ____________________________________________

BMP
Satisfactory
Yes/No Corrective Action

1.

2.

3.

4.

5.

6.

7.

8.

Other Findings:

Summary of Findings:

I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.

5.2 Maintenance
BMPs will be maintained in effective operating condition, as follows:
Silt fences, wattles, and turbidity curtains will be inspected for tears and repaired or
replaced, as appropriate.

Sediment build-up will be removed from sediment barriers when it has reach one-half of
the height of the barrier. Sediment will be placed in a stabilized site to prevent re-entry
into the same site or another entrapment area.

Seeding will be inspected for bare spots, washouts, and healthy growth until new growth
has reached 1 inch in height and the planted area has achieved 70 percent, or more,
ground cover.

BMPs which have been disabled, run over, removed, or otherwise rendered ineffective
will be replaced or corrected upon discovery.

Name and Title

Telephone Number

Signature

Date
5.3 Emergency Notification
In the event of an unauthorized discharge that causes an emergency condition, TBC or a
representative will promptly notify the Louisiana Emergency Hazardous Materials Hotline by
telephone (225-925-6595). Written notification will be provided 7 days following telephone
notification in accordance with the General Permit requirements. Written notification will include,
to the extent possible, the date and time of the incident, weather conditions, cause,
environmental problems, response procedures, parties notified, recommended revisions to the
SWPPP and operating procedures, and equipment or materials needed to prevent recurrence.
5.4 Recordkeeping
Copies of the SWPPP, General Permit requirements, and inspection reports will be retained on
site until termination of construction activity and final stabilization of the Project site. The
SWPPP will be made available to the DEQ at the time of an agency on-site inspection.

6.0 SWPPP AMENDMENTS
The SWPPP will be amended when the following conditions occur, in accordance with Part
IV(C) of the General Permit.
A change in design, construction, operation, or maintenance which has a significant
effect on the discharge of pollutants not otherwise addressed in the SWPPP

Site inspections indicate that the SWPPP provisions are ineffective in controlling
pollutants in storm water associated with construction activity

Identification of a new contractor or subcontractor who will implement measures in the
SWPPP

7.0 TERMINATION
To terminate coverage under the General Permit, TBC will submit a Notice of Termination
(NOT) in accordance with Part VIII of the General Permit which will include the following:
1. The name, location, and latitude and longitude of the Project
2. The name, address, and phone number of the permittee submitting the NOT
3. The permit authorization number for the storm water discharge identified in the NOT
4. Whether storm water discharges associated with construction activity have been
eliminated
5. Certification that storm water discharges associated with construction activity have been
eliminated
6. Confirmation that regulated activity authorized by the General Permit has been
completed
7. Confirmation that final stabilization has been achieved on all portions of the site for
which the permittee is responsible

8.0 REFERENCES
Caltrans. 2003. SWPPP/WPCP Preparation Manual. February 1, 2003.

LDNR. 2008. Best Management Practices (BMPs) for Coastal Louisiana Nonpoint Source
Pollution. 2008.

Mississippi Department of Environmental Quality. 2005. Field Manual for Erosion and Sediment
Control on Construction Sites in Mississippi. 2005.

Natural Resources Conservation Service. 2012. Web Soil Survey. 2012.

Office of Cultural Development. 2013. Archaeological Databases. Website address:
http://www.crt.state.la.us/archaeology/databases. Accessed March 13, 2013.
USFWS. 2013. IPaC. Website address: http://ecos.fws.gov/ipac. Accessed March 13, 2013.

APPENDIX A
FIGURES
R
ig
R
o
a
d
T
e
x
a
s

B
r
i
n
e
A
c
c
e
s
s

R
o
a
d
Jambalaya St.
Sauce Piquante Ln.
C
r
a
w
f
is
h

S
t
e
w
S
t
G
u
m
b
o

S
t
Hwy 70
TBC Portable Flare 3
NSDMW015
NSDMW016
NSDMW017
OG
1
OG 2
OG 3
unknown1
Geo-Gulf
No.3
Geo-Gulf
No.4
Geo-Gulf
No.5
Geo-Gulf
No.6
OG 3A
SGP-1
SGP-4
SGP-5
SGP-6
SGP-2
SGP-3
SGP-7
SGP-8
SGP-10
SGP-11
NSDMW013
NSDMW014
NSDMW007
NSDMW008
NSDMW009
NSDMW010
NSDMW001
NSDMW002
NSDMW003
NSDMW004
NSDMW005
NSDMW006
ORW-3
ORW-2
ORW-1
ORW-4
RW-1
RW-2/OCH
Oxy-Taft
Well #9
Well 10
WW2
W2
WW1
W1
WW3
W3
Seismic
Observation
Well
Abandoned
Water Well
LA-13
LA-12
LA-10
LA-14
LA-11
LA-15
LA-16
ORW-23 ORW-24
ORW-26
ORW-8
ORW-11
ORW-22
ORW-14
ORW-15
ORW-16
ORW-13
3
4
2
1
6
5
ORW-7
ORW-5
ORW-6
ORW-9
ORW-18
ORW-27
ORW-10
ORW-32
ORW-28
ORW-29
ORW-19
ORW-31 ORW-30
ORW-17
ORW-12
TBC-2
MW-1
MW-2
MRAA-02
MRAA-03R
D
MRAA-01
BC-2
G-03
TBC-1
TBC-3
MRAA-03D
MRAA-03M
DMW-1
Geophone-02
Geophone-01
BC-1
ORW-21
ORW-25
ORW-20
ORW-35
ORW-34
ORW-33
ORW-37
ORW-36
B-2 B-3 B-4
B-5
B-6
B-8
B-10 B-11
B-12
B-15
April 15 2013
Figure 1
Napoleonville Salt Dome Project
Existing and Proposed Wells
P
a
th
:
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:\a
r
c
p
r
j2
\0
1
0
6
4
7
\m
x
d
\E
x
is
tin
g
_
P
r
o
p
o
s
e
d
_
W
e
lls
_
B
o
r
in
g
s
_
C
o
n
ta
in
m
e
n
t2
.m
x
d
0 400
SCALE IN FEET
Legend
Proposed Wells
Geophone
Observation/Relief Well
ORW Flare
Deep Groundwater Monitoring Well
Phase 1 ORW 250-foot buffer
Well Access Road (26 feet)
Boundary of Containment (40 feet)
Existing Barrier
Existing Wells
Abandoned Water Well
Seismic Geophone
Geophone
Seismic Observation Well
Cavern Well
Shallow Groundwater Monitoring Well
ORW Installed
ORW Flare
Geoprobe/Monitoring Well
Monitoring Well Pair
Pressure Monitoring Well
TBC Operational Well
Geotechnical Borings
Subdivision Boundary
Magnolia Ridge
Militus Babin
Sportsman's Paradise
Approximate TBC Leased Property Line
Aerial Imagery: March 13, 2013
EDGE OF CLEARING
DGE OF PAD SLOPE
EDGE OF CLEARING

ac
Texas Brine
Company, LLC
Issued for
TYPICAL PROPOSED WELL PADS
Scale: As Shown
Designed by: RB
Drawn by: BS
Checked by: TB
Approved by: OF
TETRA TECH
4900 Pearl East Circle, Ste 300W
Boulder, CO 80301
(303) 447-1823 (303) 447-1836 fax
Projecb
TEXAS BRINE
Location:
LOU ISIANA
Issued by:
FIGU RE 2
WELL PAD
PLAN VIEW
Project no.:
114-010647
Date:
3/12/13 2
sH
o
r
4
TREE LAYDOWN (
,
- -
,
15')
1
ANCHOR TRENCH/EDGE OF CLEARING ('5')
ROAD BASE (
,
- .6')
1.5(H): 1(V)
I
1
7
TRAVEL LANE
,
- .14' .- - .1 7- 31'
,
- .41'
,
- .56'
Z
ROAD BASE (,- .6')
1.5(H): 1(V)
I
ANCHOR TRENCH/EDGE OF CLEARING (r- 5')
I
TYPICAL PROPOSED ROADS
TREE LAYDOWN (
,
-
,
15')
1
ANCHOR TRENCH AND BANK COVER FILL/EDGE OF CLEARING (r.-
,
5')
ROAD BASE (
,
- .6')
1.5(H): 1(V)
I
1
7
TRAVEL LANE X14' "19- 30'
,
- .41'
,
- .56'
Z
ROAD BASE (,..6')
1.5(H): 1(V)
I
ANCHOR TRENCH AND BANK COVER FILL/EDGE OF CLEARING (
,
- -
,
5')
TYPICAL CONTAINMENT DIKE
Designed by: RB
Drawn by: BS
Checked by: TB
Approved by: CF
Scale: As Shown Issued for
Texas Brine
Company, LLC
ac
TETRA TECH
Boulder, CO 80301
(303) 447- 1823(303) 447- 1836 fax
Issued by:
FIGURE 3
ACCESS ROAD AND CONTAINMENT DIKE
PLAN VIEW
Projecb
11DCAS BRINE
Project no.:
114-010647
Location:
LOUISIANA
Date:
3/12/13 1
sH
o
r
4

CONTAINMENT
AREA SIDE
LADOTD 610
LIMESTONE
(OR WOOD MATTING
IF NECESSARY)
L- . L- . - L- 1 - A I L- 1- _ .
14'
z
- r- EL. +5. 0
EL. +4.0
TOP OF SAND
1
L
MIN 2'
BOTTOM OF ANCHOR TRENCH
GCL DETAIL
*BASED ON ROLL WIDTH 15. 5'
2'
H
SWAMP SIDE
W I -
r- 15'
TREE LAYD
3' I
7
,
7
2ND GEOTEXTILE FABRIC (FOR DRILLING
/ ACCESS ROADS OR PADS) OR G C L
/ (FOR CONTAINMENT SYSTEM DIKES)
/ (CASES I & II)
EL +0. 3 TO - 2. 0
1ST GEOTEXTILE FABRIC (OPTIONAL)
(CASE I ONLY)
REBAR SEGMENTS TO SINK
FABRIC TO BOTTOM (OPTIONAL)
r
//
A
ADDITIONAL FILL ONLY
REQUIRED FOR CONTAINMENT DIKES,
NOT GENERAL ROADS AND PAD
(IT IS REQUIRED TO COVER
MUDLINE
3'
L. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
3'
3RD GEOTEXTILE-
FABRIC
EDGE OF CLEARING
r- 41'
PERMANENTLY BACKFILLED
ANCHOR TRENCH
SEE DETAIL A
1
EL +0. 5 TO +2. 0
GEOTEXTILE
1
PERMANENTLY BACKILLED
ANCHOR TRENCH
SEE DETAIL A
CONTAINMENT
AREA SIDE
1
GCL le/
TREE t. 4
9
c2 a:
V
1
9(0
ANCHOR TRENCH
EDGE OF CLEARING
SEE DETAIL A
r- 41'
COMPACTED CLAY
EL:,+1.0 (SEE NOTE 1)
GCL
(SEE NOTE 1) SAND FILL
/
- GEOTEXTILE FOR
SEPARATION (OPTIONAL) FILL
19' TO 30'
SWAMP SIDE
r- EL +5. 0
EL. +4. 0
3RD GEOTEXTILE
FABRIC
V
LADOTD 610
LIMESTONE
(OR WOOD MATTING
IF NECESSARY)
L~l . L- l. 111 I
14'
COMPACTED CLAY
EL +1. 0
EXISTING
ROADWAY EMBANKMENT
19' TO 30'
2'
GEOTEXT LE /
0.2' TO 4'
EL . +0. 3
TO - 2. 0
FILL
L +0

0
EL - 2. 7
TO - 5. 0
ANCHOR TRENCH
SEE DETAIL A
CASE I (NO EXISTING ROAD) CASE II (EXISTING ROADS)
NORTHERN & SOUTHERN BOUNDARIES EASTERN & WESTERN BOUNDARIES LEGEND
PROPOSED CONTAINMENT DIKES
=XX
TREE LAYDOWN AREA

EXCAVATION & BACKFILL
GEOTEXTILE 1
GCL
GEOTEXTLE 2
GEOTEXTILE 3
NOTES:
1. WATER ELEVATION AT TIME OF ROAD CONSTRUCTION MAY DIFFER FROM ELEVATION SHOWN HERE. THE
CONSTRUCTED ELEVATION OF THE TOP OF THE SAND FILL LAYER MAY THEREFORE ALSO VARY. THE TOP OF THE
SAND LAYER WILL NEED TO BE CONSTRUCTED TO AN ELEVATION THAT IS 6 INCHES ABOVE THE WATER ELEVATION.

Scale: As Shown
Designed by: RB
Drawn by: BS
Checked by: TB
Approved by: CF
a c
Issued for
Texas Brine
Company, LLC
Issued by:
Project TEXAS BRINE
Project no.:
114-010647
TETRA TECH
Boulder, CO 80301
(303) 447-1823 (303) 447-1836 fax
FIGURE 4
CONTAINMENT DIKE
SECTION VIEW
Location:
LO U ISIANA
Date:
3/12/13 L I-
sH
o
r
4
PAD
,
--200' OR 50'
+5.0
3RD GEOTEXTILE
TEMPORARY
FABRIC
SECONDARY EL. +4.0
CONTAINMENT
LADOTD 610 BERM AND LINER
LIMESTONE
1
EL +0.5 SEE NOTE 1
WL
EXISTING MUDLINE
COMPACTED CLAY FILL
EL +1.0 (SEE NOTE 1
T T
GEOTEXTILE
SAND FILL
FABRIC
EDGE OF CLEARING
EL +0.3 TO 2.0
PROPOSED WELL PAD
SWAMP SIDE
14'
v
/ EL. +5.0
EL +4.0
14'
7
,,
EL +5.0
EL +4.0
COMPACTED CLAY
SWAMP SIDE
LADOTD 610
LIMESTONE
(OR WOOD MATTING
IF NECESSARY)
3RD GEOTEXTILE
FABRIC
SWAMP SIDE SWAMP SIDE
LADOTD 610
LIMESTONE
(OR WOOD MATTING
IF NECESSARY)
3RD GEOTEXTILE
FABRIC
COMPACTED CLAY
EL +1.0
1r
STROBE LIGHT
TYP
1
WI-
,EL. +1.0_(SFF NOTE 1)
TREE LAYDOWN _
2ND GEOTEXTILE
SAND FILL
'
1 #--1ST GEOTEXTILE FOR SEPARATION (OPTIONAL) 11
TO 2.0
TO 31'
I
1
EL +0.3
V WI-
TYP. TREE LAYDOWN /4>
Y
.
1//
16'
EXISTING
ROADWAY EMBANKMENT
f
/GEOTEXTILE
FABRIC
-f
t
\
1'
1
0.2' TO 5.0'
1"
--
""
5$
H i EL +0.3
TO 2.0
EL +0.5 TO +3.0
17' TO 31'
PERMANENTLY BACKFILLED PERMANENTLY BACKFILLED
ANCHOR TRENCH ANCHOR TRENCH
(SEE DETAIL A (SEE DETAIL A
ON SHEET 4)
EDGE OF CLEARING
ON SHEET 4)
,
--41'
CASE I
NO EXISTING ROAD
NOTES:
1. WATER ELEVATION AT TIME OF ROAD CONSTRUCTION MAY DIFFER FROM ELEVATION SHOWN HERE. THE
CONSTRUCTED ELEVATION OF THE TOP OF THE SAND FILL LAYER MAY ALSO VARY. THE TOP OF THE SAND LAYER
WILL NEED TO BE CONSTRUCTED TO AN ELEVATION THAT IS 6 INCHES ABOVE THE WATER ELEVATION.
ANCHOR TRENCH
(SEE DETAIL A
EDGE OF CLEARING
ON SHEET 4)
41'
LEGEND
EXISTING ROAD
CASE II
00<><><
TREE LAYDOWN AREA
EXCAVATION & BACKFILL
GEOTEXTILE 1
GCL
GEOTEXTILE 2
GEOTEXTILE 3
\EL 2.7
TO 5.0
PROPOSED ROADS
ANCHOR TRENCH
(SEE DETAIL A
ON SHEET 4)
Scale: As Shown Issued for
Location:
LOU ISIANA
Date:
3/12/13
3 SHOITT 4

ac
Texas Brine
Company, LLC
Issued by:
TETRA TECH
Boulder, CO 80301
(303) 447-1823 (303) 447-1836 fax
Designed by: RB
Drawn by: BS
Checked by: TB
Approved by: OF
Projecb
TEXAS BRINE
FIGU RE 5
WELL PAD, STROBE LIGHT, ACCESS ROAD
SECTION VIEW
Project no.:
114-010647
COMPLETED CONTAINMENT LEVEE/ACCESS ROAD

LOW WATER DEPTH
SAND FILL
COMPACTEDCLAY
MARSH
SIDE
MLWL
TURF REINFORCEMENT
MAT
GEOTEXTILE
MUDLINE
SILT FENCE
CONTAINMENT
AREA SIDE
TURF REINFORCEMENT
MAT
SILT FENCE
COMPLETED CONTAINMENT LEVEE/ACCESS ROAD
HIGH WATER DEPTH
SAND FILL
COMPACTEDCLAY
MARSH
SIDE
GCL/GEOTEXTILE
TURF REINFORCEMENT
MAT
GEOTEXTILE
MUDLINE
TURBIDITY
CURTAINWITH
ANCHOR
CONTAINMENT
AREA SIDE
TURF REINFORCEMENT
MAT
TURBIDITY
CURTAINWITH
ANCHOR
INTERIM CONTAINMENT LEVEE/ACCESS ROAD
LOW WATER DEPTH
MARSH
SIDE
MLWL
MUDLINE
SILT FENCE
CONTAINMENT
AREA SIDE
SILT FENCE
1
VARIES
SAND FILL
INTERIM CONTAINMENT LEVEE/ACCESS ROAD
HIGH WATER DEPTH
MARSH
SIDE
MLWL
MUDLINE
CONTAINMENT
AREA SIDE
1
VARIES
WATTLE (12" DIA.) TO BE
INSTALLED PER DTL 4
SAND FILL
TURBIDITY
CURTAINWITH
ANCHOR
TURBIDITY
CURTAINWITH
ANCHOR 1
VARIES
1
VARIES
WATTLE (12" DIA.)
AS NEEDED
WATTLE (12" DIA.)
AS NEEDED
WATTLE (12" DIA.) TO BE
INSTALLED PER DTL 4
EROSION AND
SETTLEMENT CONTROL
DETAILS
9/9
Austin, Texas 78759
(512) 338-2862 (512) 338-1331fax
BY REFERENCE REVISIONS NO. DATE
PROJ ECT NO.:
SHEET NO.
REVISION
ENGINEER'S SEAL
DATE:
ISSUEDBY
APPROVED BY:
CHECKEDBY:
DRAWN BY:
DESIGNED BY:
FILE NAME:
TETRA TECH
ISSUED FOR SCALE:
114-010647 3/15/2013
AS SHOWN
AK
SM
GF
GF
114-010647
0
- - - -
- - - -
- - - -
- - - -
- - - -
- - - -
- - - -
0 INITIAL SUBMITTAL-FOR TEXAS BRINE REVIEW GF 03/15/2013
GCL/GEOTEXTILE
EROSION AND SETTLEMENT CONTROL DETAILS 1
_
SCALE: NOT TO SCALE
EXTENSION OF FABRIC INTO THE TRENCH 2
_
SCALE: NOT TO SCALE
SHORELINE INSTALLATION 3
_
SCALE: NOT TO SCALE
EXTENSION OF FABRIC INTO THE TRENCH 2
_
SCALE: NOT TO SCALE
WATTLE DETAIL 4
_
SCALE: NOT TO SCALE
CONSTRUCTION OF TEMPORARY SILT FENCING 5
_
SCALE: NOT TO SCALE
PRELIMINARY
NOT FOR CONSTRUCTION
Figure 6

APPENDIX B
CULTURAL RESOURCES
CLASS I LETTER REPORT

Tetra Tech
136 East South Temple, Suite 910, Salt Lake City, UT 84111

Tel 801.364.1064 Fax 801.364.2021 www.tetratech.com

March 14, 2013

Department of Environmental Quality (DEQ): Office of Environmental Services
Post Office Box 4313
Baton Rouge, LA 70821-4313
Attention: Water Permits Division

Subject: Texas Brine Companys Napoleonville Salt Dome Project Cultural Resource Literature Review

To whom it may concern:
The following is the result of Tetra Techs cultural resource literature review for the Texas Brine
Companys Napoleonville Salt Dome project. This letter report presents our methodology, details the
results of the search, and the projects potential impact will be to cultural resources as part of the
Stormwater General Permit Associated with Construction Activity Greater than 5 Acres Notice of Intent
(NOI) CSW-G permit.
Project Overview
Texas Brine Company (Texas Brine) contracted Tetra Tech to install a series of monitoring wells, access
roads, and containment dikes in response to a sink hole affecting a gas storage cavern in Assumption
Parish, Louisiana.
Methodology
Tetra Tech conducted a file search through the Louisiana Office of Cultural Development, Division of
Archaeology Cultural Records online database on March 13, 2013. The database includes records of all
previously completed cultural resource investigations, all documented prehistoric and historic
archaeological sites and standing structures. The Louisiana National Register of Historic Places (NRHP)
online database for Assumption Parish was also checked.
Per the stipulations outlined in the DEQ NOI permit, the literature review encompassed the proposed
wells, access roads, and containment dikes where storm water structures could impact known NRHP
eligible or potentially eligible cultural resources.
Search Results
The literature search indicates that no cultural resource inventories have been previously
completed within the proposed project area. No previously record cultural resource sites, NRHP
eligible or otherwise, have been recorded within proposed project area. No NRHP listed or potentially
eligible structures are present within the proposed project.
The storm water structures associated with the proposed project will have no effect on known NRHP
eligible or potentially eligible cultural resources.
If there are any questions or concerns over our literature review, please call me at 801-364-1064 or email
me at mark.karpinski@tetratech.com.

Sincerely,

Mark Karpinski, M.A., RPA
Cultural Resource Group Lead
APPENDIX E
EVALUATION OF THE BAYOU CORNE MAXIMUM SINKHOLE EXTENT
IN LATERAL DIRECTIONS
COMMENTS ON MAXIMUM BAYOU CORNE SINKHOLE EXTENTS
Evaluation of Bayou Corne Maximum Sinkhole Extent in Lateral Directions 8/30/20138/5/2013
Ref. 13-2775-30TM
Itasca Consulting Group, Inc. Page 1 www.itascacg.com
Minneapolis, Minnesota, USA
Date: August 5, 2013
To: LDNR/BRC Stability sub group
From: Terje Brandshaug, Itasca Consulting Group, Inc.
Re:
Evaluation of Bayou Corne Maximum Sinkhole
Extent in Lateral Directions
Ref: 13-2775-30TM

1.0 INTRODUCTION
Commissioners,
The current document reflects changes based on commissioners comments during the LDNR/BRC
stability sub-group conference call on August 1, 2013, including an expansion of the evaluation that
considers an oval-shaped sinkhole.
This is an informal and simple evaluation of the extent of the sinkhole in the lateral directions. I am
suggesting this may be something that can be agreed upon among the commissioners as being the
maximum lateral extent of the sinkhole based on the current estimate of the maximum volume of the
Oxy-3 cavern. The estimate represents the maximum extent of the sinkhole at a future time when the
cavern is completely filled with debris and local slope failure of the sinkhole banks have achieved a
minimum angle of repose.
To eliminate effects of uncertainty related to the presence of a disturbed rock zone (DRZ) and its
size, as well as the amount of material bulking that may occur I am focusing first on a worst-case
scenario. If we assume that all the mass that is filling up the cavern comes from the sinkhole, and
that there is no bulking of that mass in the process of being transported from the sinkhole to the
cavern, then the existence of a DRZ becomes irrelevant and the conditions define the largest volume
that the sinkhole can develop into (i.e., from simple continuity). Conceptually, this is illustrated in
Figure 1. However, there are two conditions that may affect the sinkhole to become larger; (1) a
negative bulking factor, i.e., a compaction (decreased porosity, increased density) of the transported
material relative to its initial in-situ state, and (2) the dissolution of salt, providing additional void
space for solids to occupy.
While the transport of some finer materials, especially near ground surface, may consolidate into
somewhat denser materials over time than their initial in-situ density, most of the sedimentary
materials in the stratigraphic column are expected to experience some amount of bulking, i.e.,
Ref. 13-2775-30TM
decrease in density and increase in volume relative to their in-situ state. To assume a zero bulking
factor, therefore, is believed to be sufficiently conservative for the current evaluation.
Groundwater that is less than saturated in sodium chloride will have the capacity to dissolve salt over
time. Such groundwater conditions are expected in the sediments at Bayou Corne, and it is assumed
that its effect can result in as much as 15% increase in the volume of the Oxy-3 cavern (i.e., volume
available to store debris).
In a second case, I am providing a perspective of the effects of the presence of a DRZ and the effect
of material bulking. This is shown conceptually in Figure 2.
When evaluating the sinkhole profile (see Figure 3), it is not unreasonable to approximate the
sinkhole into an inverted circular cone of radius r and depth h. We express h = r * tan(alpha);
where alpha is the minimum angle of repose in the sinkhole. Figure 4 shows that the current size of
the sinkhole is significant, with a minimum angle of repose of about 7.5 to 15.
The mass balance equation in the first case can be expressed:

( ) ( )
3
1
tan 1
3
c
V r alpha BF
| |
= -[- - - +
|
\ .
(1)
Where V
c
= total volume of Oxy 3 cavern (23e6 Barrels or 4.8e6 cubic yards or 3.7e6 m
3
,
accounting for 15% salt dissolution over time the total volume becomes 4.2e6 m
3
or 5.5e6 cubic
yards), BF = bulking factor (assumed to be zero), r = cone radius, alpha = minimum angle of repose
in the sinkhole, which is 7.5 to 15 judging from Figure 4. While erosion of the sinkhole banks
from currents and wave actions in the water over a long period of time could result in lower slope
angles, 7.5 is considered a reasonable lower value to use in projections for the next few decades.
Solving for r we get:
( ) ( )
1/3
(3* / ( 1 * * ))
c
r V BF tan alpha = + [ (2)
When using a minimum angle of repose of 7.5, we get a cone diameter of 625 m (2050 ft), a top
surface area of 3.1e5 m
2
(76 acres) and a depth of 40 m (135 ft). These can be considered maximum
values in an average sense when the cavern is completely filled with debris and the sinkhole shape is
taken to be equivalent to an inverted cone. In reality, the sinkhole is butting against the caprock and
the salt dome to the east, and therefore the sinkhole will tend to grow toward the west and in the
north-south directions.
When evaluating Equation 2 for angles of repose from 7.5 to 15, the sinkhole diameter is given by
the blue curve in Figure 5. If we make the same evaluation but allow the material to bulk by 5%
while being transported from the sinkhole to the cavern, then the sinkhole diameter is defined by the
Field Code Changed
Field Code Changed
Ref. 13-2775-30TM
red curve in Figure 5. Hence, 5% bulking of the material will have the effect of slightly reducing the
sinkhole diameter.
When considering the second case of accounting for both a DRZ and bulking factor, the mass
balance equation can be expressed:
( ) ( ) ( )
3
1/ 3 * * * * 1 *
c DRZ
V r tan alpha BF V BF = [ + + (3)

2
* *
DRZ DRZ
V r H = [ (4)
Where V
DRZ
= volume of the DRZ, r
DRZ
= DRZ radius, H = DRZ height (1650 m or 5400 ft).
Solving for r we get
( ) ( ) ( )
1/3
(3* * / ( 1 * * ))
c DRZ
r V V BF BF tan alpha = + [ (5)
When evaluating Equation 5 for a bulking factor of 5%, a DRZ diameter of 100 ft and an angle of
repose ranging from 7.5 to 15, the sinkhole diameter is given by the purple curve in Figure 5.
Repeating the evaluation but using a DRZ diameter of 300 ft, the sinkhole diameter is given by the
green curve in Figure 5. These curves illustrate that when bulking occurs, the sinkhole diameter will
decrease as the DRZ volume increases.
It is emphasized that these evaluations are based on a maximum cavern debris volume of 4.2e6 m
3

(5.5e6 cubic yards), which includes the total cavern volume of 3.7e6 m
3
(4.8e6 cubic yards) plus a
15% increase from potential salt dissolution.
If we evaluate Equation 2 for the estimated debris volume in the cavern sinkhole currently (3.7e6
cubic yards or 2.8e6 m
3
as of 6/28/13), the sinkhole diameter is defined by the light blue curve in
Figure 5.
Current estimates from measurements of the sinkhole lateral dimensions where the water-depth is 10
ft or deeper are approximately 1000 ft east-west and 1500 ft in the northeast-southwest direction.
When including shallower depths (2 ft), the maximum sinkhole dimension is about 1900 ft in the
northeast-southwest direction and 1600 ft in the east-west direction, and the sinkhole covering an
area of approximately 51 acres. When simplifying the oval-shape structure of the sinkhole into the
conceptual model in Figure 6, using the ratio of the maximum to minimum dimensions at 10-ft depth
or deeper (i.e., 1500 ft to 1000 ft), the sinkhole volume can be expressed as:
( ) ( )
3
(( 3) / 24)* * * 1 *
oval drz
V D tan alpha BF V BF = [+ + + (6)
Where D is the width dimension of the sinkhole and the diameter of the half-cones at each end of
the sinkhole. Setting the volume in Equation (6)(6) equal to the maximum cavern volume of 4.2e6
Field Code Changed
Field Code Changed
Field Code Changed
Field Code Changed
Ref. 13-2775-30TM
m
3
and solving for D (see Figure 6), using a minimum angle of repose of 7.5, a zero bulking
factor and a zero DRZ volume the estimated maximum value for D is 500 m (1650 ft). The
sinkhole length dimension then becomes 750 m (approximately 2500 ft). The depth is 30 m (100 ft)
and the top surface area is 321,350 m
2
(80 acres). The longer dimension is expected to develop in the
northeast-southwest direction, while the shorter dimension is expected to develop in the east-west
direction but more toward the west.
Figure 7 and Figure 8 illustrate the maximum dimensions of the oval-shaped sinkhole when the
angle of repose is varied from 7.5 to 15. The effects of adding a 5% bulking factor and a DRZ on
the extent of the sinkhole also are shown in these figures. The effects are similar to that shown for
the inverted cone-shaped sinkhole. When evaluating the sinkhole extent in this case using the
current debris volume in the cavern (2.8e6 m
3
or 3.7e6 cubic yards), the light-blue curves in Figure 7
and Figure 8 show the estimated long and short sinkhole dimensions, respectively. Figure 7 shows
that the current sinkhole measurement of 1900 ft in the northeast-southwest direction falls well
within the maximum estimate (light blue curve) for the oval-shaped sinkhole. However, the
measurement of 1600 ft in the east-west direction falls outside of the maximum predicted value as
shown by the light blue curve in Figure 8. This simply means that the sinkhole extent as defined by
the shallower depth of 2 ft conforms more to a circular shape than an oval shape.
A previous evaluation of the sinkhole size, which made use of Monte Carlo simulations (Pierce et
al., 2012), predicted a likely diameter of 740 ft and a maximum sinkhole diameter of 1400 ft.
However, the previous analysis made use of certain assumptions, which were believed to be
reasonable at the time. It considered the effect of (1) a positive bulking factor ranging between 0.0
and 1.0, (2) a disturbed rock zone (DRZ) in the shape of a cylinder with a diameter ranging from 100
to 300 ft, (3) a friction angle of the sinkhole material ranging between 15 and 45 and (4) a total
cavern volume of 3.1e6 m
3
(4.1e6 cubic yards).
The friction angle can be considered an approximation to the angle of repose, and probably is the
largest contributing factor to the difference in sinkhole diameter estimate between the previous
Monte Carlo analysis and the current simple analysis. A reevaluation of the Monte Carlo simulations
using a range in friction angle between 7.5 and 45 resulted in a likely sinkhole diameter of 760 ft
and a maximum diameter of 1800 ft (i.e., 100 percentile).
In summary, the results illustrate that the sinkhole diameter is sensitive to the angle of repose of the
sinkhole slopes. The current sinkhole profiles suggest that an angle of repose as low as 7.5 is
possible. Over time, after the cavern is filled, failure along the sinkhole banks is expected to continue
resulting in a widening of the sinkhole until an angle of repose near 7.5 is achieved. Eventually, this
would result in a maximum sinkhole diameter of approximately 2050 ft if the sinkhole developed in
the shape of a circular cone and the most conservative evaluation (no bulking factor and no DRZ) is
considered.
Ref. 13-2775-30TM
The tendency has been for the sinkhole to grow in the northeast-southwest direction and in the east-
west direction mostly toward the west. The most conservative evaluation for an oval-shaped sinkhole
suggests is that it will extend approximately 2500 ft in the northeast-southwest direction and about
1650 ft in the east-west direction. If we assume that the sinkhole growth is relatively uniform, then
the edge of the sinkhole to the north will come close to Highway 70 while the edge to the south will
come close to the Bayou Corne waterway, but the sinkhole will not actually breach these locations.
This is illustrated in Figure 9. However, if the sinkhole growth is non-uniform, then there is a
possibility that either the highway or the waterway could be breached by the sinkhole. Figure 9 also
shows the extent of the current sinkhole and the maximum estimated extent for a circular cone-
shaped sinkhole.
We note that both a bulking factor and a DRZ volume have the effect of reducing the sinkhole
dimensions. However, there is much uncertainty with respect to both of these factors, as well as the
relative growth of the sinkhole in the different directions. Therefore, it is suggested to use the
maximum sinkhole dimension of 2500 ft in the northeast-southwest direction estimated from the
most conservative evaluation of the oval-shaped sinkhole, and 2050 ft in the east-west direction
estimated from the most conservative evaluation of the circular cone-shaped sinkhole. Monitoring
the sinkhole growth is imperative and should be part of a remediation plan to minimize the effect of
the sinkhole encroaching on the Bayou Corne waterway to the south, and a plan to eliminate the
potential effects to Highway 70 to the north by considering a re-routing plan.
Respectfully,
Terje Brandshaug

Ref. 13-2775-30TM

Figure 1 Conceptual model of volume balance considering direct transport of
sinkhole mass to fill cavern volume (i.e., no bulking factor and no
DRZ effects).

Figure 2 Conceptual model of volume balance considering the effect of a
bulking factor and a DRZ.
Ref. 13-2775-30TM

Figure 3 Bayou Corne sinkhole depth contours.

Figure 4 Estimated minimum angle of repose from sinkhole profiles.
Ref. 13-2775-30TM

Figure 5 Sinkhole diameter versus angle of repose of sinkhole slope.

Figure 6 Conceptual model of oval-shaped sinkhole.
Ref. 13-2775-30TM

Figure 7 Maximum dimension of oval-shaped sinkhole in northeast-southwest
direction.

Figure 8 Maximum dimension of oval-shaped sinkhole in east-west direction.
Ref. 13-2775-30TM

Figure 9 Current sinkhole extent and estimated maximum extent of the oval-
shaped sinkhole and circular cone shaped sinkhole
2.0 REFERENCES
Pierce, M., T. Brandshaug, B. Damjanac and W. Pettitt. (2012) Results of Baseline Bulking
Model, Itasca Consulting Group, Inc. Report, 12-2775-71TM, to Shaw Group Inc., December.
3824 Jet Drive, PO Box725, RapidCity, SouthDakota57709- 0725 Phone: 605.394.6400 Fax: 605.394.6456 www.respec.com
RSI(RCO)-2153/11-13/8

November 12, 2013

Mr. Mark Cartwri ght
Mr. Bruce Marti n
Texas Bri ne Company, LLC
4800 San Fel i pe
Houston, TX 77056

Dear Mr. Cartwri ght and Mr. Marti n:
RE: Comments on Maximum Bayou Corne Sinkhole Extents
At your request, I revi ewed four documents and am presenti ng my reacti ons and comments.
The four documents i ncl ude the fol l owi ng:
1. Brandshaug, T., 2013. Evaluation of the Bayou Corne Maximum Sinkhole Extent in
Lateral Directions, techni cal memorandum (13-2775-30TM) from T. Brandshaug, I tasca
Consul ti ng Group, Mi nneapol i s, MN, to Loui si ana Department of Natural Resources/Bl ue
Ri bbon Commi ssi on (LDNR/BRC) Stabi l i ty subgroup, August 5.
2. Brandshaug, T., undated. Response to Comments From Commi ssi oners Duncan and
Voi ght Provi ded August 9, 2013, from T. Brandshaug, I tasca Consul ti ng Group,
Mi nneapol i s, MN, undated.
3. Seni, S. J ., undated. Si nkhol e Evol uti on, prepared by S. J. Seni .
4. Brandshaug, T., W. Pettitt, and J . Wang, 2013. Evaluation of Slope Stability for the
East Side of the Bayou Corne Sinkhole, techni cal memorandum (13-2775-36TM) from
T. Brandshaug, I tasca Consul ti ng Group, Mi nneapol i s, MN, to G. Hecox and D. Saxton,
CB&I , August 30.
Based on the three I tasca documents, I tascas posi ti on seems to be that the fi nal (eventual )
si nkhol e vol ume, after accounti ng for any bul ki ng of the di sturbed sedi ments, wi l l match the
precol l apse OXY-3 cavern vol ume. That i s, the OXY-3 cavern wi l l be compl etel y fi l l ed wi th
materi al s (mostl y sedi ments) from outsi de the cavern and beyond the edge of the sal t dome, and
the di spl acement of those sedi ments wi l l cause an equi val ent vol ume of near-surface soi l s to
move downward i n compensati on and create the surface si nkhol e. Hence, after the cavern i s
fi l l ed and al l movement and consol i dati on of sedi ments stop, the l ateral extent of the si nkhol e
wi l l be di ctated by the geometri cal factors of (1) depth of the si nkhol e; (2) the sl ope angl e of the
si nkhol e si des; and (3) the bul ki ng factors of the soi l s, sedi ments, and rocks i nvol ved.
Thus, I see the fol l owi ng cri ti cal questi ons:
1. What vol ume of the OXY-3 cavern wi l l actual l y be fi l l ed compared to the l ast sonar-
measured vol ume?
Mr. Mark Cartwright and Mr. Bruce Martin Page 2 November 12, 2013

2. What are reasonabl e fi nal bul ki ng factors (postconsol i dati on or at stati onary pore
pressure) for the sedi ments and soi l s i nvol ved both i nsi de and outsi de the cavern?
3. What i s a reasonabl e angl e-of-repose for the si nkhol e sl opes?
4. Are there any external factors that wi l l i nfl uence the si nkhol e shape?
The OXY-3 cavern vol ume i s ci ted by I tasca as 23 mi l l i on barrel s (3.7 mi l l i on). The l ast ti me
the sedi ment l evel i n the col l apsed cavern was tagged (Jul y 2013), the i nterpretati on was that
over 90 percent of the cavern was al ready fi l l ed (thus, the remai ni ng cavern vol ume was
approxi matel y 2 mi l l i on barrel s accordi ng to Seni s Fi gure 5, or 0.32 mi l l i on m
3
).
Bul ki ng factors pl ay two di fferent rol es: 1) when deepl y-buri ed sedi ments are moved i nto the
cavern or when near-surface soi l s are moved i nto the space vacated by the sedi ments, the
materi al s l i kel y expand i n vol ume (bul k) and i ncorporate addi ti onal water or bri ne i n thei r pore
space, and (2) as the sedi ments and soi l s consol i date (water or bri ne i s squeezed out), they
reduce i n vol ume, assumi ng that water i s not trapped (an undrai ned condi ti on). These two
bul ki ng-rel ated processes are confl i cti ng and consol i dati on i s ti me dependent; therefore, the
materi al vol umes are sti l l changi ng and we can onl y extrapol ate to l i kel y fi nal states. My
esti mates for the bul ki ng factor are based on porosi ti es of the sedi ments, whi ch wi l l be
expl ai ned i n the fol l owi ng text.
I expect the angl e of repose for the si nkhol e sl opes to be i nfl uenced by soi l composi ti on and
wave acti on i n the si nkhol e; especi al l y because ful l y saturated fi ne si l ts and cl ays can be
agi tated by wave-acti on forces to wash the si nkhol es sl opes even fl atter than they mi ght stand
i f they are i n cal m water. I tasca proposes a fi nal si nkhol e sl ope angl e of 7.5 degrees (a rati o of
approxi matel y 1:8 verti cal to hori zontal ). I cannot di sagree wi th thei r sel ecti on, but woul d
emphasi ze that I tasca al so bel i eves (and I concur) that i t mi ght take a decade or more to
accompl i sh such fl at sl opes.
I tasca al l udes to the sal t dome- (caprock-) restri cti ng expansi on of the si nkhol e to the east. I
can accept thi s as a credi bl e scenari o because the shal l ower and shorter sedi ment col umn over
the sal t dome was not as di sturbed as the much deeper and tal l er sedi ment col umn al ongsi de
the dome. Thus, the overal l angl e of draw toward the di spl aced sedi ment col umn wi l l be steeper
toward and above the sal t dome (defi ni ng the east si de of the si nkhol e) and fl atter away from
the dome (defi ni ng the south, west, and north si des of the si nkhol e). For extrapol ati on purposes,
the exi sti ng eastern ri m of the si nkhol e i s the smal l est maxi mum l ateral extent that can be
recogni zed for predi cti ng the eventual si nkhol e extent.
The assumed bul ki ng factors for the sedi ments seem to be the most cri ti cal or i nfl uenti al
factors i n the anal yses of possi bl e si nkhol e si zes. I vi ew the bul ki ng factor i n terms of a
materi al s i ni ti al porosi ty versus i ts fi nal porosi ty. The rel ati onshi p i s ( ) ( ) bul ki ng
1 1 F n n =
where n i s the i ni ti al porosi ty and n i s the bul ked porosi ty (note, porosi ty n =
Vol ume
voi ds
/Vol ume
total
). A si mi l ar rel ati onshi p exi sts i f the preference i s to work i n terms of the
voi d rati o
1
;
( ) ( ) bul ki ng
F 1 1 e e = + + , where e i s the i ni ti al voi d rati o and e i s the bul ked voi d rati o
(note, voi d rati o e = Vol ume
voi ds
/Vol ume
sol i ds
).

1
Voi d rati o, e, can be cal cul ated from the porosi ty, n, rel ati onshi p of e = n/(1n).

A reasonabl e esti mate of the i ni ti al voi d rati o of these muddy si l tstones and cl aystones i s
25 percent, based on the soi l mechani cs chart reproduced i n Fi gure 1. When these sedi ments
(e = 0.25 and n = 0.2) are mobi l i zed and squeezed i nto the cavern, thei r bul ked porosi ty wi l l
i ncrease, or, perhaps, even doubl e (n = 0.4); hence, an esti mate of the bul ki ng factor
2
i n terms of
porosi ty wi l l be
( ) ( ) bul ki ng
1.33 F 1 0. 1 0.40 2 = = , or, i n terms of voi d rati o (for e = 0.25 and e =
0.67)
( ) ( ) bul ki ng
1.33 F 1 1.6 1 0.25 7 = + = + .
The cavern was apparentl y fi l l ed wi th sedi ments that moved from outsi de the sal t dome i nto
the cavern through a si dewal l breach. I f thi s same cavern breach wi l l al l ow bri ne to drai n from
the cavern, then the cl ay-ri ch sedi ments fi l l i ng the cavern wi l l l ose consol i date as the drai nage
of pore fl ui ds removes excess pore pressures from the entombed sedi ments and compressi on of
the soi l parti cl es i s caused by gravi ty-dri ven l oadi ng and creep cl osure of the cavern.
Consi deri ng the OXY-3 cavern depth and knowi ng that several years wi l l be requi red for
consol i dati on (i .e., the undi sturbed sedi ments were previ ousl y consol i dated i n geol ogi cal ti me),
the fi nal sedi ment voi d rati o (e) after a few years mi ght be dri ven as l ow as 0.5 (equi val ent to
a fi nal porosi ty, n = 0.33). The fi nal state expressed i n terms of the ori gi nal undi sturbed
porosi ty (n = 0.2) to the fi nal bul ki ng factor i s
( ) ( ) ( ) ( ) bul ki ng
. 1 0.2 1 0.33 1.19 F 1 1 n n = = =
The I tasca memorandum di scuss fi nal bul ki ng factors of zero, or even negati ve bul ki ng (i n
my nomencl ature that woul d be bul ki ng factors l ess than or equal to 1). Such l ow bul ki ng i s not
possi bl e wi thi n just a few years; geol ogi cal ti me and si gni fi cant depth wi l l be requi red to
consol i date and compress the sedi ments back to thei r undi sturbed val ues. Thi s i s parti cul arl y
true because of the l ow permeabi l i ty of these si l ts and cl ays, whi ch i mpl i es the drai nage
requi red for consol i dati on.
I tasca proposes that addi ti onal di ssol uti on by the water i n the i nfi l l i ng sedi ments mi ght
i ncrease the vol ume of the cavern by 15 percent. Because no basi s i s provi ded for the 15 percent
i ncrease, I presume thei r postul ated 15 percent vol ume i ncrease i s based on the noti on that
6 vol umes of fresh water wi l l di ssol ve 1 vol ume of sal t (1/6 = 15 percent). However, the vol ume
of water avai l abl e to di ssol ve addi ti onal sal t i s not the enti re cavern vol ume; rather, the vol ume
of water avai l abl e i s merel y the pore water i n the sedi ments and probabl y then onl y the pore
water i n those sedi ments proxi mate to the sal t. The greatest vol ume of avai l abl e water i s the
pore vol ume i n the sedi ments fi l l i ng the cavern (i .e., porosi ty ti mes cavern vol ume or, perhaps,
40 percent of the cavern vol ume). Then, the addi ti onal cavern vol ume created by di ssol uti on i s
at most 1/6 of thi s 40 percent, or a maxi mum of a 6.7 percent i ncrease i n cavern vol ume,
assumi ng total sal t saturati on of all pore water.
The concl usi on from the August 5 memorandum i s that, even though a bul ki ng factor and a
(Di sturbed Rock Zone) DRZ vol ume (i f i ncl uded i n the anal yses) both have the effect of reduci ng
the si nkhol e di mensi ons, thei r uncertai nti es l ead I tasca to recommend usi ng the maxi mum
si nkhol e di mensi ons for pl anni ng. Sti l l , the maxi mum possi bl e oval -shaped si nkhol e di mensi on
of 2,500 feet i n the northeast-southwest di recti on woul d not breach ei ther Hi ghway 70 or the

2
Note: I use the defi ni ti on of bul ki ng factor as bei ng the rati o of the fi nal vol ume to the i ni ti al vol ume. I tasca
uses the term bul ki ng factor to be the i ncrease i n vol ume; so i n use, thei r bul ki ng factor (i n thi s case 0.50)
must al ways be subsequentl y added to 1.0. After thei r addi ti on, both of us obtai n i denti cal rel ati onshi ps
between i ni ti al and fi nal vol ume.

Bayou Corne Waterway. Si mi l arl y, the maxi mum possi bl e ci rcul ar-shaped si nkhol e di mensi on
of 2,050 feet i n the east-west di recti on i s too short to encroach on the Bayou Corne communi ty.
I n these cases, the si nkhol e expansi on i s such that the eastern l i mi t (over the sal t dome) i s fi xed
and expansi on occurs i n the preferred di recti on whi l e mai ntai ni ng the geometri cal shapes of
oval or ci rcl e.
RSI-2153-13-199
Figure 1. Voi d Rati o Expected for Di fferent Soi l Types After Consol i dati on by Overburden
Loadi ng. Reproduced from Lame and Whi tman [1969]
3
.

3
Lame, T. W. and R. V. Whitman, 1969. Soil Mechanics, John Wi l ey & Sons, I nc., New York.

I n a l ater undated memorandum, I tasca broadens thei r possi bi l i ti es for si nkhol e expansi on
by wonderi ng i f the si nkhol e coul d i ndeed expand nonuni forml y and preferenti al l y i n an
unfavorabl e di recti on (expandi ng onl y to the north toward Hi ghway 70 or to the southwest
toward the waterway). These extreme devi ati ons i n si nkhol e shape i n the future do not seem
credi bl e. As I tasca states, because the si nkhol e appeared one year ago, and has been
devel opi ng (i .e., wi deni ng) si nce then, i ts devel opment shape i s consi dered somewhat mature i n
the sense that i t wi l l probabl y conti nue to grow and devel op much i n the same proporti ons.
I n synopsi s, I tascas anal yses of the maxi mum extent of the si nkhol e l ed to thei r concl usi on
that the Hi ghway 70 and Bayou Corne Waterway woul d not be encroached upon even usi ng
exceedi ngl y conservati ve condi ti ons. Moreover, I poi nt out that two of thei r assumed, worst-
case condi ti ons or factors (a 15 percent i ncrease i n cavern vol ume by sal t di ssol uti on and zero
bul ki ng factors for the sedi ments) are i ndeed even worse than possi bl e or unreal i sti c i n short
ti me peri ods of a decade or so. I cannot refute I tascas thi rd conservati ve condi ti on of a
7.5 degree sl ope angl e on the si nkhol e, but thi s angl e i s certai nl y fl at for short ti me peri ods. One
has to consi der that natural sedi mentati on (sedi ment from external source) mi ght be a faster
process for reduci ng the si nkhol e sl ope to i ts angl e of repose than soi l sl umpi ng and the sl ope
fai l ure of the soi l s around the si nkhol e.
Thank you for the opportuni ty to submi t my comments. I f you have any questi ons or need
further i nformati on, pl ease contact me (605.394.6400 or Leo.VanSambeek@respec.com).

Si ncerel y,

Leo L. Van Sambeek, Ph.D., P.E.
Pri nci pal Consul tant

LVS:l l f
cc: Mr. Troy Charpenti er, Kean Mi l l er LLP
Project Central Fi l e 2153 Category A

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