aker Environmental, Inc. Airport Office Park, Building 3 420 Rouser Road Coraopolis, Pennsylvania 15108

( 412) ;s9-6000 FAX (412) 269-2002 October 29, 1998 ;}Lj I

Mr. Wen C. Huang, P.E. 1-+ W/ Minnesota/Wisconsin Section t:m/Rt=A-~ RCRA Permitting Branch HRP-8J RegionS 77 West Jackson Boulevard Chicago, Illinois 60604-3590

Subject: Technical Scope ofWork and Proposed Project Schedule Tank Farm Area Closure PPG Industries, Inc. Oak Creek, Wisconsin WID 059 972 935

Dear Mr. Huang:

As per your correspondence to Mr. Tom Yurick ofPPG dated October 8, 1998 attached please find a copy of the Teclmical Scope of Work (including an attached addendum) for the Tank Farm Area Closure (i.e., UST closure and soil and groundwater remediation) at PPG's Oak Creek Wisconsin facility. The proposed project schedule is presented below:

Activity/Description

Bids for Tank Fann Area Closure Received by PPG 1119/98 Contract Award 11/25/98 USTs Removed from Service 12/22/98 Field Mobilization of Tank Farm Area Closure Contractor 1/4/99* Submission of CMS Workplan to EPA 2/1/99 Tank Cleaning, Removal, and In-Place Closure Complete 3/1/99* Soil and Groundwater Remediation Start-up 4/1/99* Soil and Groundwater Remediation Complete 12/1/99*

Activity dates assigned an asterisk are target dates which will be confinned upon the acceptance of the schedule proposed by the successful bidder. PPG will submit a revised schedule to EPA subsequent to a contract being awarded.

PPG will submit a progress and monitoring report bi-monthly to EPA and with copies to Wisconsin DNR for the duration of Tank Farm Area Clos~re activities.

e A Total Quality Corporation Mr. Wen C. Huang, P.E. October 29, 1998 Page 2

Should you have any questions regarding this correspondence, please feel free to contact me at (412) 269- 2063.

Sincerely,

BAKER ENVIRONMENTAL, INC.

Daniel L. Bonk, P .E.

DLB/rw Attachments cc: Mark Gordon- WDNR (w/ attaclunents) Walt Ebersohl- WDNR..(w/ attaclm1ents) Tom Yurick- PPG (w/ attaclunents) Pat Kacsuta- PPG (w/ attaclunents) Tom Ebbert- PPG (w/o attaclunents) Ann Foulkes- PPG (w/o attaclunents) MEMORANDUM OCTOBER 28, 1998

TO: FRANK KIENINGER

FROM: DAN BONK

SUBJECT: ADDENDUM TO BID PACKAGE TANK FARM AREA CLOSURE PPG INDUSTRIES, INC. OAK CREEK, WISCONSIN

The following information and attachments are provided in response to the discussions from the pre-bid meeting for the above referenced project which occurred on Thursday, October 22, 1998.

• Other Contractors Working at the Site: The successful bidder shall be aware of the work being performed by other contractors at the site. Tank cleaning and in-place closure work is being provided by Superior Special Services, Inc. ofFon duLac, Wisconsin [contact: Jed Hoffman (920) 924-5547].

Excavation of the roadway area south of the tank farm will be performed by CG Schmidt Inc. of Racine, Wisconsin [contact: Niels P. Anderson, VP/General Manager (414) 886- 1112].

• Tank Scrap Metal Issue: Upon the completion of tank cleaning activities, Superior Special Services will certify that the UST has been cleaned for demolition and scrap purposes, but not for reuse.

• Underdrain Sump Issues: The average daily production rate for the underdrain sump is anticipated to be approximately 8,000 gallons per day (gpd) during the period from January through March.

According to available drawings the portion of the underdrain system buried beneath the Tank Farm Area is comprised of clay tile. The composition of the above-grade portion of the underdrain sump conduit was not determined prior to the issuance of this addendum. The Contractor shall specify the materials to be used if it is the Contractor's intention to replace any portion of this underdrain sump conduit. • Site Utilities: PPG will provide reasonable volumes of potable water to the Contractor at no charge. The Contractor shall specify its anticipated water requirements in the bid.

Telephone service is available in the contractor trailer and equipment laydown area. The Contractor shall be responsible for the cost of bringing the service from the nearest pole to the Contractor's office trailer and for monthly usage.

Electric service is also available in the contractor trailer and equipment laydown area. The Contractor shall be responsible for the cost of bringing the service from the nearest pole to the Contractor's office trailer. There will be no cost to the Contractor for reasonable normal monthly service to the trailer. PPG will bear the cost of delivering electric service to the Tank Farm Area to support the operation of a remediation system. The Contractor shall specify in the bid the electric service requirements of its remediation system. The Contractor shall be responsible for delivering the service to the remediation system, metering the service, and the monthly usage costs.

• Revised Bid Form: Attachment A contains a revised bid form. The bid form has been revised for the Contracotr to include unit rates for free product collection and odor suppresswn.

• UST and Trestle Column Foundation Details: Attachment B contains three drawings including a plan of the UST foundations (dwg no. CR-7201-S150) and details for both the UST foundations (dwg no. CR-7201-S151) and the trestle column footings (dwg no. CR- 7201-S152). According to the notes provided in the details the majority of the trestle column footings extend 4' 6" below finished grade.

• UST Dimensions: A revised UST data table containing tank dimensions is provided in Attachment C. Tank identification numbers are provided in the table and on a plan of the Tank Farm Area also provided in Attachment C.

• Fire Monitor Platform Foundation Plan and Section: Attachment D contains two figures which depict in plan and section the fire monitor foundations which are located within the paved road area located south of the Tank Farm. The figures indicate that the tower foundations are 14 feet deep and should not be disrupted by tank removal activities.

• Plan of South Roadway Excavation: Attachment E contains a plan of the anticipated extent of roadway excavation in the area south of the Tank Farm. Approximate limits of both contaminated and uncontaminated materials are depicted in the plan. Contaminated materials (i.e., concrete and soil) are to be consolidated into the Tank Farm Area as per the scope of work.

• PPG-Approved Laboratories: Attachment F contains a list of PPG-approved laboratories. The following are responses to questions received by PPG since the pre-bid meeting.

1) What is the expiration date of the facility's RCRA permit?

The RCRA permit for the Oak Creek facility will expire in May 2002.

2) Does PPG have a target date for the completion of the site clean-up?

PPG' s preference is for the site clean-up to be completed in 1999. Contractors shall specify in their bid the target date for the completion of site clean-up using each contractor's particular approach. ATTACHMENT A

Revised Bid Form 1.0 GENimAL PROVISIONS Scope of Work Section 2.0) llcalth and Safety 1'10g1 css and final Reports Waste Management

TANK REMOVAL AND CLOSURE Scope of Work Section 2.1) Mobilization Tank Removal and Disposal Temporary Fireline and Sump Conduit Provisions Pennitting (If Applicable) Demobilization and Site Cleanup

SOIL AND GROUNDWATER REMEDIATION Scope of Work Sections 2.2 and 2.3)

Soil Remediation Via Soil Vapor Extraction 0 Design & Pennitting (including pilot if required) Provide and Install Equipment LS System Start-Up LS 3.2.3 Monthly Operations and Maintenance 3.3 Groundwater Remediation Via Air Sparging 3.3.0 Design & Permitting (including pilot if required) LS 3.3.1 Provide and Install Equipment LS 3.3.2 System Start-Up LS 3.3.3 Monthly Operations and Maintenance 3.4 Site Grading LS 3.5 Concrete and Soil Segregation, Sampling and Analysis (Option) LS Progress Monitoring and Post-Remediation Sampling LS Demobilization and Site Cleanup Subtotal ~j::~~:~!!~:~:~!;::!:l~:::~::·@I ALTERNATIVE SOIL AND GROUNDWATER REMEDIA Scope of Work Sections 2.2 and 2.3)

Soil Remediation Via Soil Vapor Extraction Design & Permitting (including pilot if required) Provide and Install Equipment System Start-Up Monthly Operations and Maintenance Groundwater Remediation Design & Permitting (including pilot if required) LS Provide and Install Equipment LS .2 System Start-Up LS .3 Monthly Operations and Maintenance Site Grading Concrete and Soil Segregation, Sampling and Analysis (Option) LS Permitting LS Progress Monitoring and Post-Remediation Sampling LS 4.8 Demobilization and Site Cleanup

Items Requiring PPG's Pre-Approval Schedule Free Product Collection $ day Draft Conceptual Design Odor Control $ /sq-ft covered Tank Removal Complete Soil/Groundwater Remd. start-up Note each line item to include all costs for total completion of project Soil/Groundwater Remd. complete

Company: ______Authorized Representative: ------­ Date· Note Please type or pnnt In "Authorized Representaltve" By signature bidder clearly states your willingness and ability to comply with all of the contract terms and condttions

10/28/98 ATTACHMENTB

Drawing No. CR-7201-8150: Tank Mats and Trestle Foundation Plans

Drawing No. CR-7201-8151: Tank Mat Details Drawing No. CR-7201-8152: Tank Mat Details ~t rr

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Table- Underground Storage Tank Data with Tank Dimensions

Plan of Tank Farm Area with UST Numbers Correlated to UST Data Table UST.XLS,Tank_data

UNDERGROUND STORAGE TANK DATA

Tank Capacity Diam. Length Remove Close In ID (gal) (ft) (ft) Matl. Name CAS No. Tank Place

101 10,000 10 17 Oxo-hexyl acetate 66230-35-7 Yes 102 10,000 10 17 Ethanol 64-17-5 Yes

103 10,000 10 17 Propylene Glycol Monomethyl Ether 107-96-2 Yes 104 10,000 10 17 Methyl Ethyl ketone 76-93-3 Yes 105 10,000 10 17 Tolusolve Yes

106 10,000 10 17 Aromatic Hydrocarbon mixture 64742-94-5 Yes 107 10,000 10 17 Toluene 106-88-3 Yes 108 10,000 10 17 Dimethyl ethanolamine 108-01-0 Yes

109 10,000 10 17 Methyl amyl ketone (2-Heptanone) 110-43-0 Yes 110 10,000 10 17 Butyl Carbitol 112-34-5 Yes 111 15,000 10 26 n-Propyl alcohol 71-23-8 Yes

112 10,000 10 17 VM&P Blend of SLS-273+SLM-549 64742-46-9 Yes 116 10,000 10 17 Soya oil, non brk 8001-22-7 Yes 117 10,000 10 17 2-Ethyl hexyl acrylate 103-11-5 Yes 118 15,000 10 26 Methyl methracrylate 80-62-6 Yes 125 30,000 12 36 CCS Clean Paint solvent Pending* 126 15,000 10 26 Empty ··Yes 127 15,000 10 26 CCS Clean Resin Solvent Yes 128 15,000 10 26 2-Ethyl hexyl acetate 103-09-3 Pending•

129 15,000 10 26 Diethylene glycol 111-46-6 Yes 130 15,000 10 26 Linseed Oil, alkali refined 8001-26-1 Yes 131 15,000 10 26 Empty 8001-79-4 Yes

133 15,000 10 26 Aromatic solvent (Solvesso 100) 64742-95-6 Pending* 134 15,000 10 26 Isobutyl alcohol 78-63-1 Pending• Propylene glycol methyl ether 135 30,000 12 36 acetate 108-65-6 Yes 136 30,000 12 36 Isobutyl acetate 110-19-0 Pending* 137 30,000 12 36 Xylene 1330-20-7 Yes 138 30,000 12 36 n-Butyl alcohol 71-36-3 Yes 139 30,000 12 36 EMPTY Yes 140 30,000 12 36 Methyl Isobutyl ketone 108-10-1 Yes 141 30,000 12 36 Water Yes 142 30,000 12 36 Butyl cellosolve 111-76-2 Yes 143 15,000 10 26 n-Butyl acrylate 141-32-2 Yes 144 15,000 10 26 Ethyl acrylate 140-88-5 Yes Light VM&P aliphatic petroleum 145 15,000 10 26 fraction 64742-69-6 Yes 146 15,000 10 26 n-Bu\oxymothytaetylamida wlbu\anol 1852-16-0 Yes UST.XLS,Tank_data

UNDERGROUND STORAGE TANK DATA

Tank Capacity Oiam. Length Remove Close in 10 (gal) (ft) (ft) Matl. Name CAS No. Tank Place

147 30,000 12 36 Styrene 100-42-5 Yes 153 10,000 10 17 Diethylene triamine 111-40-0 Yes 154 10,000 10 17 CCS - Clean cleaning solvent Yes 155 10,000 10 17 CCS - Clean cleaning solvent Yes

TOTALS: Number of tanks to be removed= 24 Number of tanks to be closed in place= 16 (5 of these pending WOOC approval)

*Closure in place for these tanks is pending WDOC approval. Tank 128 is located near the control building foundation. Other pending tanks are located near pipe rack structure. ;·. . . ..r . . .· :. I .... ··:. ·._. : . :- :· ~1 ·:. ·.·· ... ·:11 ·."··

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Plan of South Roadway Excavation C.9. ji'! c ),, '· I 'r <,1 J. ~ •: •+ ~ I S: ' FOO A\JOVE CROONO • cuRoto com A!NMnHTNH<~ARM AREA rOUNO.A,llO« !'LAN (XIST PIP(RW< ~ 1,1,';([/>.D:\1. / Sl( owe OC~9SOG-S-\01 1( 1J5217 ( ,h I [XI$1 SUM!" - 1:/ I

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PPG-Approved Laboratories List LABORATORIES

LABORATORY CONTACT(S) KEMRON Environmental Services Debra D. Elliott (Technical Sales Representative) Ohio Valley Sales Office Phone: (614) 374-2741

Patricia D. Lane (Technical Service Representative) KEMRON Environmental Services, Inc. 109 Starlite Park Marietta, Ohio 45750 Phone (614) 373-4071 Quanterra Environmental Services Debora A. Hula (Director of Project Management) (North Canton, OH) Quanterra Inc. 4101 Shuffel Drive NW, North Canton, Ohio 44720 Phone direct: 330-966-9786 Phone office: 330-497-9396

Christopher R. Oprandi (Laboratory Director) Same address as above Phone office: 330-497-9396

Cemic Peg Marple (Technical Service Representative) Pittsburgh, Pennsylvania 412-788-4404

Laboratory 100 Dean Knauss Drive Narragansett, Rhode Island 02882 401-782-8900 Core

Centre Analytical Laboratories, Inc. 3048 Research Drive State College, PA 16801 814-231-8032 Contact: Steven Roach

Trimatrix Michael Movinski (Technical Service Representative) 7430 Summit Ridge Brighton, Michigan 48116 810-220-2075

Laboratory 5555 Glenwood Hills Parkway SE Grand Rapids, Michigan 49588-8692 616-975-4500 October 1998

2344 7-000-0000-00000

SCOPE OF WORK FOR TANK FARM AREA CLOSURE

Prepared for PPG INDUSTRIES, INC. OAK CREEK, WISCONSIN

Prepared by

Baker Environmental, Inc. Coraopolis, Pennsylvania TABLE OF CONTENTS

Section

1.0 INTRODUCTION ...... •...... •...... 1-1 1.1 Background ...... 1-1 1.2 Tank Farm Area Description ...... 1-2 1.3 Project Objectives and General Description of Activities ...... 1-3

2.0 SCOPE OF WORK ...•.....•...... •.•...... 2-1 2.1 Tank Removal ...... 2-2 2.2 Accommodation of Demolished Concrete and Soil ...... 2-3 2.3 Soil and Groundwater Remediation ...... 2-4

3.0 SCHEDULE ••...•....•...... •..• 3-1

4.0 INVOICING ...... •...... 4-1

5.0 PROPOSAL REQUIREMENTS AND FORMAT ...... 5-1

LIST OF ATTACHMENTS

Attachment 1 Miscellaneous Technical Background Data UST Summary Table Montgomery Watson Technical Memorandum

Attachment 2 RFI Excerpts Sample locations Cross Sections Analytical Summary Table Boring Logs

Attachment 3 Approved Plans Excerpts H&S Plan QAPP

H:\23441\000Phase\WORKDOCS\REPORnPpgtank.wpd 1.0 INTRODUCTION

PPG Industries, Oak Creek Wisconsin Facility (PPG) is requesting proposals to close a Tank Farm Area consisting of 40 Underground Storage Tanks (USTs) and associated soil and groundwater contamination. While closure ofthe USTs are regulated by the Wisconsin Department ofCommerce (WDOC), associated soil and groundwater contamination within the Tank Farm Area are regulated under a RCRA Corrective Action Permit issued by USEP A Region V.

As a result, the tank systems must be closed in accordance with WDOC requirements. In addition, PPG is interested in having soil and groundwater remediation performed and documented within the framework of the RCRA permit and USEPA Region V requirements, which include following approved quality assurance and health and safety plans.

1.1 Background

A RCRA operating permit was issued to PPG on March 31, 1992. As part of the permit, PPG was required to evaluate potential releases from 41 SWMUs identified in the permit. Based on an EPA­ approved assessment of the 41 SWMUs, it was determined that 10 of the SWMUs required investigation as part of a formal RCRA Facility Investigation (RFI) in accordance with requirements outlined in the RCRA permit. Of the ten SWMUs investigated, several are located within the Tank Farm Area. These SWMUs consist of the following:

Tank Farm Sump (SWMU #18)

This SWMU serVes as a collection sump for draining precipitation infiltration and potential leak detection within the Tank Farm Area prior to discharging to a POTW.

H:\23447\000Phase\WORKDOCS\REPORl\Ppgtank.wpd l-1 Used Solvent Tanks (SWMUs #8)

These three above-ground storage tanks are used to store waste paint solvents.

An EPA-approved RFI Work Plan, dated May 23, 1995, was implemented to investigate the 10 SWMUs, including the Tank Farm Area. Results ofthis investigation were presented in a RFI Report dated July 31, 1997.

The RFI Report was approved by EPA on August 5, 1998. It concludes that soil in the Tank Farm Area has been impacted with seven volatile organic constituents above approved risk-based screening criteria (i.e. toluene, ethyl benzene, xylene, styrene, methylene chloride, 1,1 ,2,2- tetrachloroethane, and tetrachloroethylene). As demonstrated by the results ofthe RFI investigation, localized groundwater contamination is controlled by an existing groundwater collection system within the Tank Farm Area, which is described in the following section. The RFI investigation did not evaluate groundwater within the Tank Farm Area.

1.2 Tank Farm Area Description

The Tank Farm Area, shown on Figures 1-1 and 1-2, consists of 40 USTs and 15 aboveground storage tanks covering an area of approximately 42,500 feet. Tank-specific data is presented in a summary table and figure contained in Appendix A. The USTs are single-wall tanks ranging in capacity from 10,000 to 30,000 gallons that are required to be taken out of service by December 1998. Aboveground storage tanks (SWMUs #8) have been upgraded with secondary containment and will remain in service. The Tank Farm Area also includes an in-ground 3,000-gallon concrete sump (SWMU#1S) for collecting primarily precipitation infiltration from a UST area drainage system.

The Tank Farm Area was constructed by excavating approximately 10 to 15 feet into native soils predominately consisting of fine-grain glacial tills with discontinuous sand lenses. Individual concrete tie-down mats were constructed for each UST near the base of the excavation. Since the base of the excavation was below the natural water table, approximately 4,000 feet of tile drainage pipe was used to construct a drainage system that gravity drains groundwater and potential leaks to the concrete sump located at the east end of the Tank Farm Area.

H:\23441\000Phase\WORKDOCS\REPORl\Ppgtank.wpd 1-2 Along with the 40 USTs, having a cumulative capacity of 670,000 gallons, approximately 25,000 cubic yards of course-grain sand and gravel was placed as backfill around the tanks. As constructed and operated, groundwater seeping into the backfill, precipitation infiltrating the Tank Farm Area, and potential tank leaks are collected and conveyed to the collection sump. RFI results have revealed radial groundwater flow toward the tank farm drainage system effectively preventing the migration of groundwater releases. Appendix A provides a technical memorandum from Montgomery Watson to PPG that presents cross sections and approximate elevations. This memorandum reveals that, in some areas, the excavation and course grain backfill extend up to seven feet below the drainage system. This suggests that contamination may exist within the saturated zone of the backfill (e.g., smear zone, LNAPL, etc.).

Data obtained by Baker Environmental, Inc. in October 1998, indicates that approximately 0.2 feet of LNAPL product is present in observation well TF2, one of four such wells situated within the Tank Farm Area. TF2 is located in the northeast comer of the Tank Farm Area. In the other three wells (TF1, TF3, and TF4) an LNAPL sheen of nominal thickness was detected.

Structures within the Tank Farm Area associated with the tank systems include the following:

• Aboveground piping, pipe racks and concrete pipe rack foundations; • Aboveground pumps and concrete pump mats; A conservation vapor venting system; • A control building; A contiguous tank truck loading and unloading area at the south end of the Tank Farm Area.

All existing pipe racks that traverse the work area are critical to current operations and must remain in service.

1.3 Project Objectives and General Description of Activities

Key objectives of Project activities consist of the following:

• Closure of the UST system in accordance with WDOC requirements

H:\23441\000Phase\WORKDOCSIREPORTIPpgtank.wpd 1-3 • Remediation of contaminated soils and groundwater within the Tank Farm Area backfill to specified preliminary remediation goals Implementation of activities consistent with requirements of the RCRA Corrective Action Permit and in a manner that will serve as a final remedy for the Tank Farm Area SWMUs Shut-down of the Tank Farm Area underground drainage system

PPG's approach to implementing the project involves the following:

1. By December 1998, the UST portion of the Tank Farm Area will be out of service, with product storage operations and tank contents transferred to existing and new aboveground tank systems or disposed offsite.

2. In accordance with WDOC requirements, USTs, piping, pumps, and unnecessary metal pipe­ support structures will be excavated and removed from site. Sixteen of the tanks will be closed in place, as approved by WDOC, to prevent undermining the foundation of adjacent aboveground storage tanks. Soils disturbed during UST system removals will be managed within the "Area of Contamination" consistent with US EPA policy to avoid triggering Land Disposal Restrictions. Note: Area ofContamination policy refers to a number ofEPA policy letters and memoranda including MShapiro to N.Nosenchuck, March 25, 1996 and MShapiro to RCRA Branch Chiefs, March 13, 1996).

3. Contiguous soils and debris (e.g., pavement materials, gravel subbase materials, and subgrade soil) beneath the truck loading and unloading area will be consolidated into the Tank Farm Area as backfill and to clear the southern boundary area for ongoing plant expansions. The volume of soils to be consolidated is expected to exceed the volume vacated by the 24 USTs removed from the Tank Farm Area. PPG intends to place all or a portion of the excavated soil in the Tank Farm Area. A determination will be made during the course of the work as to the final grade of the Tank Farm Area.

4. PPG will implement performance-based, in-situ treatment of soils and debris and groundwater within the Tank Farm Area with EPA's presumptive remedy (SVE) for VOCs in soils, and/or an appropriate technologies such as bioventing, air sparging, in-situ

H:\23447\000Phase\WORKDOCS\REPORl\Ppgtank.wpd 1-4 oxidation, or other applicable means. PPG is establishing treatment endpoints consisting of conservative Preliminary Remediation Goals (PRGs).

5. PPG will test the success of soil remediation efforts by allowing the groundwater level to rise within the Tank Farm Area while monitoring drainage collection sump influent.

6. PPG will develop a site-specific, post-remediation risk assessment to evaluate whether interim measures results are sufficient to serve as a final remedy, allowing shutdown of the Tank Farm Area drainage system.

H:\23447\000Phase\WORKDOCS\REPORl\Ppgtank.wpd 1-5 --· :... ~-----·t J TW-s

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LEGEND:

MW-9 .•. RFI GROUNDWATER SAMPLE LOCATION (ICF Kaiser, 1996)

TF-1 0 EXISTING MONITORING WELL LOCATION

[- Fig~re--l-1- GRAPHIC SCALE ---~----- ... ·- . ------~ ------· --· ------1" 200' PPG INDUSTRIES INC. RFI GROUNDWATER MONITORING = WELL SAMPLE LOCATION MAP OAK CREEK, WISCONSIN RCRA FACILITY INVESTIGATION 11..~~--~---~---~~~~;.;~;;;;~ ______, ------··- -- ... ------200 0 200 400 JCF KAISER ENGINEERS¥ INC. 7/31~7 T. BLAIR PITTSBURGH, PA 1" =200' FIG5_4.WOR 'I ...... , . '-::-:..::.,.:s.:.:--r:-..:.....,:·~..,~;~ __;,·~· l· . .· .'

...... r-~.-:-· __:_··-·:...-·· ·.-:-0 j . . ... Tanks to be Closed ln Place 1j .: .... FlGURE 1-2 ------. .• 2.0 SCOPE OF WORK

This project involves the removal and disposal of USTs and the in-situ remediation of soil and groundwater in the Tank Farm Area. This work is part of the implementation oflnterim Measures being conducted under RCRA. As such, the general Tank Farm Area is defined as an Area of Contamination (AOC) within which impacted materials (i.e., soil and concrete) can be picked up and moved without triggering Land Ban Restrictions (LBRs). However, all efforts to remediate impacted materials must be conducted in-situ. General requirements under this scope of work are as follows:

All work shall be performed in accordance with applicable federal, state, and local regulations.

The Contractor shall prepare a project-specific Health and Safety Plan for all work that incorporates health and safety requirements of the approved RCRA Corrective Action program Health and Safety Plan and the facilities operational health and safety requirements (see Attachment 3). The Contractor's Health and Safety Plan shall be subject to review and comment by PPG prior to the commencement of any field activities.

• The Contractor shall attend a mandatory pre-bid meeting to confirm the site layout and become knowledgeable of site conditions including any plant restrictions on work, laydown and equipment areas, or access.

• The Contractor shall provide progress reports to PPG every two weeks throughout the duration of the project. The progress reports shall include: information regarding work completed during the reporting period; a description of activity to be accomplished in the upcoming period; a report on problems encountered/resolved; and a summary of any schedule or cost variances. The progress reports shall also include time-trend plots ofin-situ soil and groundwater remediation progress data (e.g., analysis ofvapor stream samples from the SVE/Air Sparging system) as appropriate.

Provide a Final Report documenting the work accomplished. This report shall include, but not be limited to the following: a description of the major activities performed; disposal

H:\23447\000Phase\WORKDOCS\REPORnl'pgtank.wpd 2-1 facility receipts and documentation; all field and laboratory analytical data obtained throughout the project; boring and well construction logs for any monitoring point installed during the project; drawings to scale depicting the location of all permanent and temporary monitoring points, and data plots and graphs needed to document the success of the in-situ treatment process.

• Project wastes including spent Personal Protective Equipment (PPE), decontamination fluids, vapor phase carbon, and extracted groundwater shall be managed by the Contractor. Waste management in this instance involves placing the wastes in appropriate containers (e.g., drums, tank wagons, etc.). PPG will be responsible for the offsite transportation and disposal of these wastes. Tank wagons will be provided by a PPG contractor under separate contract. The Contractor shall be responsible for placing the wastes in appropriate containers for off-site transport and disposal and for coordinating these activities with PPG. The Contractor's bid shall include an identification of each waste stream the Contractor anticipates generating and an estimate of the volume of each.

A description of the remaining scope of work is included in the following sections.

2.1 Tank Removal

• Remove 24 USTs, clean the exterior and dispose offsite. Tank interiors will have been emptied and cleaned by others. Pipe cleaning and removal will have been be performed by others. Closure of 16 tanks in place will be performed by others.

• Manage and remove solid and hazardous wastes generated during tank closure. Metal debris are to be recycled as scrap at a location approved by PPG.

• Obtain all state permits and prepare plans necessary to complete tank closure in accordance with state requirements including an E&S control plan, if required.

Perform all shoring necessary to support pipe racks during and after tank removal. This may require temporary shoring and replacement of shallow pipe rack foundations and/or the provision of temporary flexible tubing to replace the stiff fireline and sump conduit

H:\23447\000Phase\WORKDOCSIREPORl\Ppgtank.wpd 2-2 currently located above ground in the eastern portion of the Tank Farm Area. Any temporary or permanent modifications to the fire line and sump conduit are subject to PPG review and approval.

• Provide all necessary personnel and equipment to collect free product encountered in the open tank trenches to the satisfaction ofPPG.

• Return excavated soils to the tank trench.

• Control odors to the satisfaction of PPG during project activities.

• Control work area stormwater runoff during project activities.

• Mobilize and demobilize all equipment necessary to complete proposed work, control erosion and sediment migration, and leave the site clean and free of debris.

2.2 Accommodation of Demolished Concrete and Soil

As part of this project, approximately 300 cubic yards of demolished concrete and approximately 2,000 cubic yards of soil will be excavated from the adjoining area south of the Tank Farm. The excavation work will be performed under a separate PPG contract. The material will be made available to the Contractor by the contractor performing the adjoining area excavation. The Contractor shall be responsible for coordinating this activity with the excavation contractor. The Contractor shall make provisions to consolidate this material into the Tank Farm Area in such manner as to minimize volume of space consumed and to include this material (particularly the soil) in the in situ treatment process. Final grading shall be to the satisfaction of PPG. At PPG's discretion, a portion ofthe demolished soil and concrete may be designated for off-site disposal. The Contractor, in this case, shall be responsible for loading this material onto trucks provided by PPG. As an option, PPG may request that the Contractor segregate a portion ofthe excavated concrete and soil and obtain samples to determine if the material can classify as non-hazardous. For bid costing purposes the Contractor shall assume that all of the concrete and one third of the soil will be segregated, sampled and analyzed. The Contractor shall be responsible for managing the segregated

H:\23447\000Phase\WORKDOCS\REPORT\Ppgtank.wpd 2-3 concrete and soil on-site. In the case management includes moving the material to locations at the plant designated by PPG or for loading onto trucks provided by PPG for off-site transport.

The following items are to be performed by others, but are provided for informational purposes and to assure compatible with the bidders anticipated soil/groundwater remediation plans.

• Remove and demolish pavement within area specified on attached drawings and place within the tank farm area as backfill.

• Excavate subbase and soils beneath removed pavement to the elevations identified and place excavated material within the tank farm area.

• Deliver excavated materials to Tank Farm area for placement by closure contractor.

• Backfill excavated areas with WDOT # l crushed limestone to the elevations shown on the drawings.

Mobilize and demobilize all equipment necessary to complete proposed work, control erosion and sediment migration, and leave the site clean and free of debris.

Provide independent surveyor to stake limits of excavation and verify conformance with project requirements.

2.3 Soil and Groundwater Remediation

• Prepare a submit a conceptual design suitable for submission to the EPA. This should include a narrative description of the technologies, conceptual drawings, process flow diagrams, stormwater management plans, schedule, anticipated permits, and details of progress monitoring. This conceptual design is to be revised per PPG comments prior to submission. [Note: EPA approval is not required to continue with project implementation.]

It is anticipated that EPA's presumptive remedy of Soil Vapor Extraction/ Air Sparging will be used for these soils. However, bidders are encouraged to submit alternate bids (e.g., SVE alone with tank area water drawdown, chemical oxidation, etc.). This conceptual design

H:\23447\000Phase\WORKDOCS\REPORT\Ppgtank.wpd 2-4 effort also will include a review and team-oriented suggestions for soils consolidations effort to be performed by others (PPG's facility upgrade contractor).

• Perform field installation, monitoring, operations, maintenance, and decommissioning of the proposed remediation system. This includes supplying all materials, chemicals, emission control devices, and additional design efforts that are required to complete the remediation effort. Uncontrolled air emissions of VOCs as part of the remediation system will not be permitted by PPG.

• Remediate soils and groundwater to meet the Preliminary Remediation Goals provided in Table 2-1 and 2-2.

Control tank area stormwater during project activities and convey to collection sump at a controlled rate. Currently, Tank Farm Area precipitation primarily infiltrates the coarse grain soils. Remediation activities that promote increased peak runoff(e.g., SVE cover) or sediment migration must include stormwater management.

• Perform all progress monitoring including vapor streams, soil sampling, and drainage system effluent, as appropriate. This will include the replacement of four existing monitoring wells within the Tank Farm Area backfill.

• Perform all post remediation sampling, analysis, and data validation in accordance with the approved QAPP. Bidders should assume a minimum of30 soil samples.

Facilitate. and incorporate into the remediation activities, temporary shut-down of the drainage system to test the performance of the soil remediation effort and restart of efforts, if necessary.

• Mobilize and demobilize all equipment necessary to complete proposed work, control erosion and sediment migration, and leave the site clean and free of debris.

11:\23447\000P~\WORKDOCSIREPO!l,l\Ppgtank.wpd 2-5 TABLE 2-1

Soil Preliminary Remediation Goals Tank Farm Area Remediation

I Constituent I Soil PRG mg/kg I Xylene 9.0

Toluene 0.6

Ethylbenzene 0.7

Styrene 0.2

Methylene Chloride 0.001

1,1 ,2,2-Tetrachloroethane 0.0002

Tetrachloroethylene 0.003

Methyl ethyl ketone 1.9

4-Methyl-2-pentanone 1.8

Note: The Soil PRGs for methylene chloride, I, 1,2,2-tetrachloroethane, and tetrachlorethylene are effectively the detection limit.

H:\23447\000Phase\WORKDOCS\REPORTIPpgtank.wpd 2-6 TABLE2-2

Groundwater Preliminary Remediation Goals Tank Farm Area Remediation

I Constituent I Groundwater PRG mg!L I Benzene 0.005

Ethyl benzene 0.7

Toluene 1.0

Xylene 10.0

Styrene 0.1

Methylene chloride 0.005

I, I ,2,2-tetrachloroethane 0.0005

Tetrachloroethylene 0.005

Methyl ethyl ketone 2.5

4-Methyi-2-Pentanone 1.8

H:\23447\000Prn..,;\\'IORKDOCS\REPOR1\Ppgtank. wpd 2-7 3.0 SCHEDULE

At a minimum, the following schedule milestones must be followed:

• The conceptual remediation design (draft) must be provided within two weeks ofthe notice to proceed, with the final conceptual design within a week of receiving comments. • Weather permitting, all tanks should be removed by March 1, 1998. • Pavement and subbase excavation and backfill, and Tank Farm Area grading should be completed by May 1, 1998.

H:\23447\000Phase\WORKDOCS\REPORl\Ppgtank.wpd 3-l 4.0 INVOICING

Invoices shall be submitted on a monthly basis.

H:\23447\000Phase\WORKDOCS\REPOR1\Ppgtank. wpd 4-1 5.0 PROPOSAL REQUIREMENTS AND FORMAT

The successful bidder will include the following information to allow PPG to evaluate the bid:

1. A technical description of the proposed approach to implementing tank closure and remediation activities at the site considering supplied documents and the required contractor site visit. This will include a description of the requested and/or alternate technical approach, progress monitoring, site cleanup, storm water management, anticipated permits, anticipated wastes to be generated and final disposition, and anticipated equipment, supplies, and materials to be utilized.

2. A proposed schedule for critical project activities considering weather, all necessary permits, and plant operational constraints.

3. Proposed project costs including all costing assumptions and markup on subcontractors. Cost estimates must include a proposed payment schedule. Bidders are requested to use the provided bid form, but may provide additional alternate bid formats for clarity. Bids should be fixed costs. Unit costs may be provided for contingencies (e.g., operation of remedial system beyond maximum bidded operational period).

4. Proposed key project personnel, project responsibilities, and relevant qualifications.

5. Identification of all subcontractors, responsibilities, qualifications.

6. A description ofhow project progress and results will be reported to PPG in a timely manner and documented in a final report.

7. Plant support requirements such as power, water, and work space.

H:\23447\000Phase\WORKDOCS\REPOR1\Ppgtank. wpd 5-1 1.0 GENERAL PROVISIONS Scope of Work Section 2.0) I. I Health and Safety I .2 Progress and Final Reports Waste Management

TANK REMOVAL AND CLOSURE Scope of Work Section 2.I) Mobilization Tank Removal and Disposal TANK Temporary Fireline and Sump Conduit Provisions LS Permitting (If Applicable) LS Free Product Collection (Option) LS Demobilization and Site Cleanup

SOIL AND GROUNDWATER REMEDIATION Scope of Work Sections 2.2 and 2.3)

Soil Remediation Via Soil Vapor Extraction .2.0 Design & Permitting (including pilot if required) .2. I Provide and Install Equipment 3.2.2 System Start-Up 3.2.3 Monthly Operations and Maintenance .3 Groundwater Remediation Via Air Sparging .3.0 Design & Permitting (including pilot if required) .3.1 Provide and Install Equipment LS .3.2 System Start-Up LS .3 Monthly Operations and Maintenance .4 Site Grading LS .5 Concrete and Soil Segregation, Sampling and Analysis (Option) LS .7 Progress Monitoring and Post-Remediation Sampling LS .8 Demobilization and Site Cleanup Sub tota IJ~~~~~!~~~~]!~!~~!:~~~~~~~~~t~~~:~:~l 4.0 ALTERNATIVE SOIL AND GROUNDWATER REMEDIA Scope of Work Sections 2.2 and 2.3) Mobilization Soil Remediation Via Soil Vapor Extraction Design & Permitting (including pilot if required) Provide and Install Equipment System Start-Up Monthly Operations and Maintenance Groundwater Remediation .0 Design & Permitting (including pilot if required) .I Provide and Install Equipment System Start-Up .3 Monthly Operations and Maintenance Site Grading Concrete and Soil Segregation, Sampling and Analysis (Option) LS Permitting LS Progress Monitoring and Post-Remediation Sampling LS Demobilization and Site Cleanup

10/14/98 BID FORM TANK FARM AREA CLOSURE PPG, OAK CREEK, WISCONSIN

COST CATEGORY UNIT QUANTITY UNIT COST SUBTOTAL COST COST

1.0 GENERAL PROVISIONS (See Scope of Work Section 2.0) 1.1 Health and Safety LS I $0 1.2 Progress and Final Reports LS I $0 1.3 Waste Management LS I $0 Subtotal $0

2.0 TANK REMOVAL AND CLOSURE (See Scope of Work Section 2.1) 2. I Mobilization LS I $0 2.2 Tank Removal and Disposal TANK 24 $0 2.3 Temporary Fireline and Sump Conduit Provisions LS I $0 2.4 Permitting (If Applicable) LS I $0 2.5 Free Product Collection (Option) LS I $0 2.6 Demobilization and Site Cleanup LS I $0 Subtotal $0

3.0 SOIL AND GROUNDWATER REMEDIATION (See Scope of Work Sections 2.2 and 2.3) 3.1 Mobilization LS I $0 3.2 Soil Remediation Via Soil Vapor Extraction 3.2.1 Provide and Install Equipment LS I $0 3.2.2 System Start-Up LS I $0 3.2.3 Monthly Operations and Maintenance MONTH 6 $0 3.3 Groundwater Remediation Via Air Sparging 3.3.1 Provide and Install Equipment LS I $0 3.3.2 System Start-Up LS I $0 3.3.3 Monthly Operations and Maintenance MONTH 6 $0 3.4 Site Grading LS I $0 3.5 Concrete and Soil Segregation, Sampling and Analysis (Option) LS I $0 3.6 Permitting LS I $0 3.7 Progress Monitoring and Post-Remediation Sampling LS I $0 3.8 Demobilization and Site Cleanup LS 1 $0 Subtotal $0

4.0 ALTERNATIVE SOIL AND GROUNDWATER REMEDIATION (OPTIONAL) (See Scope of Work Sections 2.2 and 2.3) 4.1 Mobilization LS 1 $0 4.2 S.oil Remediation Via Soil Vapor Extraction 4.2. I Provide and Install Equipment LS I $0 4.2.2 System Start-Up LS I $0 4.2.3 Monthly Operations and Maintenance MONTH 6 $0 4.3 Groundwater Remediation 4.3.1 Provide and Install Equipment LS I $0 4.3.2 System Start-Up LS I $0 4.3.3 Monthly Operations and Maintenance MONTH 6 $0 4.4 Site Grading LS I $0 4.5 Concrete and Soil Segregation, Sampling and Analysis (Option) LS I $0 4.6 Permitting LS I $0 4.7 Progress Monitoring and Post-Remediation Sampling LS I $0 4.8 Demobilization and Site Cleanup LS I $0 Subtotal $0

BIDTAB3.xls10/13/9810:35 AM Page 1 of 1 Micltael Baker Corporation ATTACHMENT 1 Miscellaneous Technical Background Data ::::: .~.::: ~ :: ~ e-~ ~ a ~ 1.., 1::::: ~ ..:.:: ~ l:::l ::: ~ ~ ~ ::::: -l:::l ..::::: ~ .<:.J ~ ~ ~

II UNDERGROUNDSTORAGETANKCONTENTS UST.XLS,tank_contents

Tank Size TankiD (gal) Matl. Name CAS No.

101 10,000 Oxo-hexyl acetate 88230-35-7 102 10,000 Ethanol 64-17-5 103 10,000 Propylene Glycol Monomethyl Ether 107-98-2 104 10,000 Methyl Ethyl ketone 78-93-3

105 10,000 Tolusolve

106 10,000 Aromatic Hydrocarbon mixture 64742-94-5 107 10,000 Toluene 108-88-3 108 10,000 Dimethyl ethanolamine 108-01-0 109 10,000 Methyl amyl ketone (2-Heptanone) 110-43-0 110 10,000 Butyl Carbitol 112-34-5

111 15,000 n-Propyl alcohol 71-23-8

112 10,000 VM&P naphtha blend 64742-48-9 116 10,000 Soya oil, non brk 8001-22-7 117 10,000 2-Ethyl hexyl acrylate 103-11-5 118 15,000 Methyl methracrylate 80-62-6 125 30,000 CCS Clean Paint solvent 126 15,000 Empty

127 15,000 CCS Clean Resin Solvent 128 15,000 2-Ethyl hexyl acetate 103-09-3 129 15,000 Diethylene glycol 111-46-6 130 15,000 Linseed Oil, alkali refined 8001-26-1 131 15,000 Non-regulated malls- Temporarily empty 8001-79-4

133 15,000 Aromatic solvent (Solves so 1 00) 64742-95-6 134 15,000 Isobutyl alcohol 78-83-1

135 30,000 Propylene glycol methyl ether acetate 108-65-6 136 30,000 Isobutyl acetate 110-19-0 137 30,000 Xylene 1330-20-7

138 30,000 n-Butyl alcohol 71-36-3 139 30,000 EMPTY 140 30,000 Methyl Isobutyl ketone 108-10-1 141 30,000 Water 142 30,000 Butyl cellosolve 111-76-2

143 15,000 n-Butyl acrylate 141-32-2 144 15,000 Ethyl acrylate 140-88-5

145 15,000 Light VM&P aliphatic petroleum fraction 64742-89-8

146 15,000 n-Butoxymethylacrylamide w/butanol 1852-16-0

147 30,000 Styrene 100-42-5 153 10,000 Diethylene triamine 111-40-0 154 10,000 CCS - Clean cleaning solvent

155 10,000 CCS - Clean cleaning solvent ... ..::::-~ ~ ~ ~ ~ ;:. ~ a ~ -.. ~ ~ ~ ~ 1:::1 :::: ~

~ -1:::1 ~ ..:::: ...... ~ ~ ~ .....~ ...:::~ ~ ~ ~ ~ ~ ~ Co ~ ~ ~ ~ ~ ~ ({I})- MONTGOMERY WATSON

l\rtEMORANDUM

January 12, 1995

To: Rae Mindock Project Manager

From: ·Martin Hamper Technical Manager

Re: Preliminary Technical Memorandum PPG Tank Fann Evaluation Oak Creek, WI

As requested by PPG, I have prepared a preliminary technical memorandum summarizing some important findings regarding the tank fann. Additional field work is expected to be conducted next week, and PPG will be providing some additional data which will be utilized in the final report.

Tank Farm Cross-Sections Cross-sections through the tank farm were prepared to depict the relationships between the tank fann backfill, the estimated bottom of the tanks, the estimated elevations of the underdrain piping, and the surrounding geology composed of clay with a few sand lenses. The locations of the cross-sections are shown on Figure 1. Figures 2 and 3 indicate that the underdrain is located at elevations below the bottom of the tanks, and that there is up to 7 feet of back fill below the underdrain elevation. Another important feature is the clay berm between the east and west sides of the tank farm, which is expected to provide some hydraulic separation between the two sides. The east and west tank farms are connected on the north side where the drain piping from the west side traverses the east side to connect to the sump. The draft cross-sections will be revised to include the new TF series wells.

\Vater Levels 5 Since the installation of the observation wells within the tank farm (i.e, TF1, TF2, TF3, and TF4), comparisons between the surrounding monitoring well water levels can be made to determine if there is an inward gradient to the tank farm and sump system. Based upon water level data for 10/18/94, 11/11/94, and 12/29/94, it appears that an inward gradient is sometimes present at the tank farm. The 10/18/94 water levels for LW4 and TF4 indicate that there is the potential for an outward gradient in this portion of the tank fann. This would occur in situations where the tank farm water levels increase faster than for the surrounding soils, such

~] 2100 Corporate Drive Te I: 708 691 5000 Serving the World's Environmental Needs L:--- Addison, Illinois Fax: 708 691 5133 - 60101 1] ,,

as during a precipitation evenL It is assumed that the tank farm backfill will allow more precipitation infiltration than the surrounding soils due to their more permeable nature. The 12/29/94 water levels for LW4 and TF4 indicate that an inward gradient is present (0.5 ft head difference). The other shallow wells (LWl, LW2, and LW3) indicate the presence of an inward gradient during each of the measurement events.

The available water level measurements for LPl vs TFl and TF2 indicate that there is an ., upward/inward gradient towards the tank farm from this well. The water level measurements for LP3 vs TF3 and TF4 indicate that for 10118/94 and 11/11/94 there is an upward/inward gradient towards the tank farm. But for 12/29/94 water level measurements, there appears to be a slightly downward/outward gradient from the tank farm near LP3. ~I Comparison of Groundwater Data to Sump Data Recent analytical results (i.e, August 1994 to October 1994) for the water samples collected from the sump and well LW4 indicate that similar compounds are present. The list of detected compounds is provided below.

Sump LW4 l Ethylbenzene Ethylbenzene ,J VM&PExempt 4 VM&PExempt MIBK > MIBK Solvesso 100 < Solvesso 100 J Xylenes - Xylenes VM&P Acetate < VM&P Acetate MEK J Toluene

j The concentrations for xylenes were overlapping between LW4 and the sump samples. Concentrations of ethylbenzene, VM&P Exempt, Solvesso 100, and VM&P Acetate tend to be higher in the LW4 samples as compared to the sump concentrations. L W 4 sample j concentrations of MIBK tend to be lower than in the sump samples, except for the Sept. 94 results. The September 1994 sump sample concentrations ofVM&P Exempt, Solvesso 100, j andVM&P Acetate spiked above the LW 4 concentrations. Target compounds (exclusive of TON) are generally not detected in samples from the other groundwater monitoring wells surrounding the tank farm quring this period except for the J September 1994 results for well L\V3. VM&P acetate was detected in the September 1994 sample from well LW3, which was the same sampling round where high concentration spikes J were also detected in the samples from L\V4 and the sump. J J J ..... / ... Storage Tank Locations for Detected Constituents Ethylbenzene Cleaning Solvent Tanks .,' 125 127 154 155 VM&PExempt 145 MIBK 139 (also see cleaning solvent tanks) 140 Solvesso 100 133 -·i -..1: Xylenes 137(also see cleaning solvent tanks) VM&P Acetate 112 MEK 104(also see cleaning solvent tanks) Toluene 107(also see cleaning solvent tanks)

Solvesso 100, and cleaning solvent (ethylbenzene, MIBK, and xylenes) are stored in the west half of the tank farm, which is monitored by LW3 and LW4. The presence of these constituents in LW3 -LW4 groundwater monitoring samples indicates the potential for these detections (if out of control) to be related to current tank storage. "Out of control" is one possible result of a statistical method used by PPG to evaluate the monitoring data, indicating the need to conduct further evaluation. The cleaning solvent storage tank and the Solvesso 100 tank have been tested in 1994 and found to be sound, indicating that these tanks may not be a current source of these compounds. J VM&P Exempt and VM&P acetate are stored in east side of the tank farm, indicating that detections of these constituents in LW3 or LW 4 located on the west side of the tank farm would not likely be related to current raw material tank storage. The detections in LW3 and J LW4 would more likely be related to past storage and spills, or potentially the cleaning solvent storage in the west side of the tank farm. The cleaning solvent storage tank was tested in 1994 and found to be sound. The VM&P acetate tank was tested in 1994 and found to be sound. J This testing indicates that these tanks may not be a current source of these compounds.

MEK and toluene, which are stored in the west side of the tank farm, were detected in the sump J samples but not in samples from LW 4. This suggests that the MEK and toluene tanks are not the source of the detections in the sump water samples. The detections of constituents in the J sump could be related to current or past management practices at either the east or west sides of the tank farm as dictated by past practices.

J The raw materials MlBK and xylenes are stored on the east side of the tank fann, and their presence (if out of control) in the sump water samples could potentially indicate impacts from J the storage of these raw materials. The xylene tank was tested in 1994 and found to be sound, indicating that the xylene tank may not be a current source of xylene.

Non-Aqueous Phase Liquids Light non-aqueous phase liquids (LNAPL) were observed in LW 4 and TF2 in the past. LNAPL was not observed in TF2 in December 1994, which was the most recent observation event. LNAPL (0.02 ft) was observed in well LW4 during the December sampling round. The non-aqueous phase liquids have been analyzed to determine the type of VOCs present and concentrations. The sample from LW 4 (Sept 93) indicated the presence of ethylbenzene and toluene. The sample from TF2 (Oct 94) indicated that toluene, ethylbenzene, xylenes, naphthalene, 1,2,4-trimethlybenzene, and cumene were present. Ethylbenzene and toluene are routinely detected in the sump water samples. Naphthalene, 1,2,4-trimethylbenzene, and cumene are not routinely analyzed for in the sump.

Information to be supplied bv PPG • Volume of liquids removed from Tank Farm sump from September 1993 to present. • Location(s) of water main breaks, and date and duration of break(s) • Location of spills, and materials and volume spilled in tank farm • MSDS for materials stored in the Tank Farm

Discussion The tank farm is surrounded by clay with a few sand lenses. Groundwater monitoring data indicates that contaminated water within the tank farm are generally controlled by the sump system as groundwater contamination is typically only found in samples from well L\V 4. The water level data indicates the potential for outward migration from the tank farm near LW 4.

LW4 has been observed to contain an LNAPL layer on the surface of the water. LNAPL has been observed in TF2 in the recent past but not in the most recent measurement. The target VOCs present in the LNAPL from TF2 are also detected in the LW 4 and sump water samples. Six of the eight constituents detected in the sump water samples are detected in the samples from LW4. The concentrations of constituents in LW4 are similar or sometimes greater than the concentrations detected in the sump samples. In some cases, the constituents detected in the groundwater and sump samples are not the materials stored in the tanks, indicating that some of the contaminants found in the groundwater and sump samples are due to past spills or releases. LEGEND FACILITY BOUNDARY

RAILROAD TRACK

X .... ~.·.·... u.·.·.-,·,.,·,·,·,v.. ·.-...· •• ·,·.-.v, FENCE LINE

APPROXIMATE LOCATION OF GEOTECHNICAL BORING CONDUCTED BY LAYNE-WESTERN COMPANY, INC. IN 1973

APPROXIMATE LOCATION OF MONITORING WELL INSTALLED BY GERAGHTY & MILLER IN 1987

APPROXIMATE. LOCATION OF WATERTABLE WELL (LW) OR PIEZOMETER WELL (LP) INSTALLED BY _WARZYN INC. IN 1992

APPROXIMATE LOCATION OF SOIL BORING CONDUCTED BY O.H. MATERIALS CORP. IN 1987 0 ~ (/) APPROXIMATE LOCATION OF MONITORING WELL INSTALLED BY WARZYN ENGINEERING INC. IN 198.1 ~ Ji' .., ..0 .. "'Q... 0 c c APPROXIMATE LOCATION OF ENVIRONMENTAL SOIL BORING (B) ~ .Q 0 e ...... ~······················ ...... -...... ~." ~ - I Q. OR GEOTECHNICAL SOIL BORING (GTB) CONDUCTED BY ~ ~ ·i '""- WARlYN INC. IN 1991 .. 0 ~ a:: a:: ' \ ' APPROXIMATE LOCATION OF SOIL BORING CONDUCTED BY I WARlYN INC. AUGUST 1991 l 0 #30/#18 APPROXIMATE LOCATION OF SUMP/SOLID WASTE MANAGEMENT UNIT #30/#18 8 A' I A n LINE OF GEOLOGIC CROSS-·SECTION !

NOTES 1. BASE MAP DEVELOPED FROM A DRAWING PROVIDED BY PPG INDUSTRIES, INC. COATINGS AND RESINS GROUP TITLED N MONITOR WELL & SOLID WASTE MANAGEMENT UNIT LOCATIONS N I DATED JULY 13, 1992. '

2. LOCATIONS OF BORINGS/WELLS USED FOR CROSS-SECTIONS I ARE PROJECTED PERPENDICULAR TO CROSS-SECTION LINE •

• .. ~ - "l.. fit !.. 1i~ z lsi 0 ~ ' 8 :a 1H• r;-'l; I .,E _ § _l!I ~ ]~J". i ~g•O.t I nort~~ ] 0 100 : 200 ~·., Drawing Number SCALE IN FEET 20023101 81 ] . ~-MONTGOMERYWATSOIY

J 1::1 n• n:u:: o4 (IJD Ll::ut:NU

• ASPHALT

GRAVELLY CLAY A WEST TANK EAST TANK EAST TANK A ~ FARM BASIN FARM BASIN FARM BASIN SOUTHWEST NORTHEAST ~~ FILL. ELEVATION ELEVATION IIIIIID sILT .,It 700 ~------~------~-L------~---L---.------~~------~------.-----L--~--~----~L-----~ 700 't ~ CLAY 0<: 810 85 86 84 A7 87 LW2 c:., EJ SAND I .,E gD>s..; .. rfa SILTY SAND !i5 SUMP - T- APPROXIMATE EU I 695 695 OF TANK DEPTH FILL ... "'' --. D- APPROXIMATE Ell SLOPING DRAIN l J I r ./1 UST BACKFILL Ml I I 690 690 .,It I 't NOTES 0<: It 1. STRATUM LINES ARE BASE: g·!! I ·- t REPRESENT ACTUAL SUBSl I ~a<: I ¥::~: t-O.. 2. TANK FARM BASIN BOUND/ 685 I 685 ON FIGURE 1.

1 ,...... 3. DEPTH OF UST FILL MATE! .p SKETCHES PROVIDED BY F CLAY __... --- 4- ..·-" '\J / / ~3.11) 4. APPROXIMATE ELEvATIONS I c / .0 BY PPG. / 0 .D .p 680 / 680 5. APPROXIMATE SLOPE OF D d CLAY I .. _ .> ,-.....-..... // PPG INDUSTRIES -cHICAGO 0 1? QJ ___... .-- PLANS, TANK FARM AREA". I ?'> -.....-..... _/' I ~ .~ / c .. w .,../ .1".,.,.. - / .a ll LL---L...-..;;:____J 6. ELEVATIONS ARE SHOWN I~ < ? // l ~£ -..> / .&:; Q.'O -c:....:_ ,/ 7. QUESTION MARKS AND 0~ I e o ?.,;:::::- Clj 675 675 ~ 8. HORIZONTAL DISTANCES BE -. PROJECTED DISTANCES ON ~~ -"- ...... SILT I o8 -- 9. GROUNDWATER ELEVATIONS -- INC. ON DECEMBER. _13; 1! CLAY - -- 1 0. FOR THE PURPOSE OF ILL .------? --- SOME OF THE BORING LOC I t! 670 670 OF SUBSURFACE CONDITIO! :j- . PRESENTED IN THE RCRA lji! 11. THE DASHED AREA BETWE£ WEST TANK BASINS, INDICA 11:1 THE TWO LITHOLOGIES. Jfo 665 665 Jl} CROSS I :ti 5

I 0 40 80 120 160 200 240 280 320 Distance Along Profile (ft) 0 I 0 SCA I VER I:ASI LEGEND TANK WEST TANK EAST TANK FARM II FARM BASIN FARM BASIN BASIN • r------.-----L---,------.------~.------.-----~--.------.------.------J_~--_J----~--~--~~----~ 700 8 8 700 •810 •85 89 811 SOUTHEAST •IIIIIrn ! NORTHWEST ~ ELEVATION t ELEVATION LW3 WJ LP3 LW1 B1 EJ 1 •SUMP }. 695 ----- 695 rra f -T- t~· 'f "} ~~ --D-- ,< ,.//1 690 690

(687.59) 685 685 15 NOTES ·; 1. STRATUI . REP RES c~ CLAY ~ ! 2. TANK f, .ON FIGl i '" ~ 680 680 3. DEPTH 1 ~ .._...'"""'.... ~ :sKETCH! £ c J 0 =+:; 4. APPROX i -o > BY PPG. ~ Ill jj] 5. APPROX 1 ~· SILT PPG INC ~ 675 f. 675 PLANS, ~~ 6. ELEVATIC .-._-----~---­ ------? 7. QUESTIO ,8. HORIZOf\ 670 PROJECl 670 7 !" CLAY 9. GROtJND 'NC. ON r '·· 10. FOR THE ~----- SOME 01 --·------.....-. -..:._ ?.______OF SUB~ ..._ 665 PRESENl 665 ------'-- ---SILT-- ~-----.;,._ --- ? --~-- (683.65) -- -. ·-:------35.0 ------.I - --- CLAY ---(686-:2"4) 36.0 660 li'ill· 660 I

655 L------~------J~------~------L------L------L------L~------L------L------_J-----~----L------~ 655 I 200 240 280 320 360 400 0 40 80 120 160 J Distance Nong Profile (ft)

-1..,..--...... _ ,.-- --. --- r-- -- ~. -~- .. r--asTT? .___i.._____;.t____j------.J------.Ja___j---.jL-...J----.JL...J.____,;-.

Water Level Well TOC TOC 10/18/94 10/31/94 11/3/94 11/11/94 12/29/94 TF1 118.35 698.91 683.51 683.95 683.29 684.27 683.01 TF2 117.3 697.86 683.82 684 683.3 684.41 683.04 TF3 118.52 699.08 683.54 683.8 683.14 . 684.14 682.7 TF4 118.09 698.65 683.53 683.81 683.14 684.07 683.77 Water Level Trends in TF1, TF2, TF3, TF4, and the Sump ~·

684.6 I IVS I fJ~ /ANt. f=A?e:.f..-1 UJeU,S

684.4

684.2

684

-+-TF1 683.8 "'-"';;;;, _._TF2 ~ -.r _,._TF3 ~ '.11 -l:-TF4 683.6 .. -X-SUMP .-.r- ~.::; --""" 683.4

683.2

683

682.8

682.6 12/2/94 12/12/94 12/22/94 111/95 10/13194 10/23/94 11/2/94 11/12/94 11/22/94 Date of Measurement Micftael Baker Corporation ATTACHMENT 2 RFI Excerpts ::: "-:) .s:.... ::::: ~ ~ ~ ~ ~ e. '-J a ~ ;,. ..:.::~ 1::: ~ ~ 1::: ..:::: .~ ::§ 818 6

GB22 ' 0 SE

GB28 _;-MW-15 0 ~® MW-14 MW-16 ® 181 B(9 TW-4 817 B1(0HM) ~ ; Q LEGEND:

MW-15 @) Monitoring Well (Active) ®'LW-3 LP-3® TW-2 !8l Monitoring Well (abandoned) GB23 ~ 0 83 B2 83(0HM) 0 (fl Soli Boring Location (Warzyn, 1992) B2(0HM) A4 @ Soli Boring Location (OHM, 1987)

84(0HM) MW-11 I 0 Soil Boring Location (OHM, 1987) ® CiP-40 ~~ Geoprobe Location (Montgomery Watson, 1995)

<:iTB1 0 Geotechnical Boring (Warzyn, 1992) GB17 0 Geotechnical Boring (Layne-Western, 1973) 81

( L . GRAPHIC SCALE 1" =60'

'l_ 50 0 60 120 r.

MW-9® >< FIGURE8-1 FORMER IMPOUNDMENT BASIN PPG INDUSTRIES INC. RFI AND HISTORICAL SOIL BORING ~ LOCATIONS· TANK FARM AREA ICF Kaiser, 1996- LW-5, LW-6 Installed; LP-2, LP-4 and MW-9 replaced OAK CREE~ WISCONSIN RCRA FACIUTY INVESTIGATION Wa.rzyn, 1994- TF-1 thru TF-41nstalled Warzyn, 1992- LW-1, LW-2 and LW-4; LP-2 thru LP-41nstalled 7/31/97 T. BLAIR LW =water table wells LP =deep wells ICF KAISER ENGINEERS, INC. Geraghty & Miller, 1987- MW-14 thru MW-16 Installed Warzyn, 1981 - TW-2, TW-3, TW-4 and TW-8 Installed (abandoned, 1992) PITTSBURGH, PA 1" =60' FIG8-1.WOR

%-9 I I HA07 Ethylbenzene 19

JI

1,1,2,2 PCA 0.007 J 490 0-2 ,...------; Ethylbenzene 200 D Toluene 120 D 0-2 l Xylene 580 D 0-2 Ethylbenzene 34 0-2 Toluene 69 0-2 LEGEND: Xylene 280 0-2 Ethylbenzene 11 0-2 OG Toluene 14 0-2 Sample Number --- Gp-35 GS-12 luene 110 0-2 PCE 0.020J 0-2 § DD ~----l1,1,2,2PCA 0.011J ---~ Depth Interval (ft-bgs) D D 0 0-2 Xylene 140 D 0-2 ~--Constituent

DDDDDDD -Area of Excavated Soils

8-9 Toluene D D G TANK FARM AREA 1,1,2,2 PCA 0.009 J 0-2 Notes: Ethylbenzene 8.7 14-16 1. J - estimated value

2. D - dilution

GS-23 3. mglkg- milligrams per kilogram Ethylbenzene 17 0 0-2 D D D D PCE O.Q15 J 0-2 D D 12 D 0-2 4. ft-bg!;- feet below ground surface 12 D 0-2 5. · GS-38 - Samples collected by Warzyn, 1992 not included in risk assessment due to inadequate QAIQC. GP-25 Ethylbenzene 15 Ethyl benzene 1o

GRAPHIC SCALE 1" =30'

30 0 30 GO

FIGURE 8~2 r------PPG INDUSTRIES INC. CONSTITUENTS IN SOIL EXCEEDING --l USEPA SSLs OR REGION V DQLs I OAK CREEK, WISCONSIN RCRA FACILITY INVESTIGATION 7/31/97 T. BlAIR I /CF KAISER ENGINEERS1 INC. I PIITSBURGH, PA _____j ___ _ 1" = 30' FIG8-2.WOR '---·-··-·-··-·-----·------·------··------····-··· --·------·------

&-10

JOB NO.: 6693000701 PLOT SCALE: 1= 1 A STARTED ON: 4/18/96 REVISED: 7/23/97 A' n ~ . 1 I WEST r··-, Fill: Lean clay, sand EAST L1 & gravel .I 120 n 810 85 87 LW-6 120 } Fill: Fine to ...... __ Clay: Brown ...... ____ ...... 110 medium sand MW-11 D & gravel silty, some ...... _.... ___ J .1 gravel, trace 110 sand Fill: grass, -­roots, [] clay, gravel :::j 13' Thin gravel seam -- - 100 Fill: Fine -to ~;; -1~~/~£- ~------;:~~o:_- medium ------rounded gravel very fme 100 r sand & 16 • WATER TABLE sand & clay gravel Clay: Gray silty, trace Well Screen r ' 103.6-93.6 ft Fill: Fine to sand and I( .'. (plant datum) ___ medium sand shale 15' 90 & gravel 90 ! ;

,~- --. I . ' 80 !" .. · 80

i '-. ..i

50 100 150 200 250 300 350 400 450 500 1/~ ~ LEGEND r~J m FILL SAND WELL SCREEN ...... ~ D CONCRETE [J] SILT GROUND SURFACE - -. ~ CLAY THIN SAND, CLAY, GRAVEL, OR SILT SEAMS WATER TABLE

. FIGURE 8-5 '. NOTES ~ GEOLOGIC CROSS SECTION A-A' HORIZONTAL SCALE 1" : 40' PPG OAK CREEK . OAK CREEK, WISCONSIN RCRA FACILITY INVESTIGATION REPORT - VERTICAL SCALE 1 " : 10' .. ~ ICF KAISER ENGINEERS DATE: 7/31/97 DR.: T. BLAIR R PITTSBURGH, PA SCALE: AS NOTED DWG. NO. 10157001 u.J 8-13 rl JOB NO.: 6693000701 PLOT SCALE: 1=1 r7:1 STARTED ON: 4/25/96 REVISED: 7/23/97 1';1 I n B B' 'Ll ~ .J NORTH SOUTH F":! GP25 LATERAL LIMITS 120 86 &----OF THE FUTURE 9 82 MW-9 120 LJ_I -~""--AB:GROUND TANK FARM GT84 n 1. ---- ! coarse Clay: Brown/Gray 110 sand stiff, trace 110 sand & gravel

...... Clay:-- Brown/Gray little gravel ...... , Fill: Fine to -----Clay: Brown/Gray Well Screen voce fine sand --._ ---- _ medium sand, - stiff, trace 108.9-98.9 ft some gravel - sand & gravel (plant datum) 100 Clay: EirO'wn/Gray - --- 100 15.5'-Sand & gravel seam stiff, trace gravel Sand & silt seam (0.5' thick) WATER TABLE Silt: Brown/Gray little fine sand 90 90

80 80

I \. L.. :

50 100 150 200 250 300 350 400

LEGEND

;.l ._.; ~ FILL SAND WELL SCREEN Li,;.~ j CJ CONCRETE SILT GROUND SURFACE CLAY THIN SAND, GRAVEL, ~ OR SILT SEAMS WATER TABLE FIGURE 8-6 NOTES PPG OAK CREEK GEOLOGIC CROSS SECTION 8-8' HORIZONTAL SCALE 1" : 30' OAK CREEK, WISCONSIN RCRA FACILITY INVESTIGATION REPORT CROSS SECTION VERTICAL SCALE 1" : 1o· ICF KAISER ENGINEERS DATE: 7/31/97 OR.: T. Blair PITTSBURGH, PA SCALE: AS NOTED DWG. NO. 10157002

8-14 i

~-· JOB NO.: 6693000701 PLOT SCALE: 1= 1 RI STARTED ON: 6/26/97 REVISED: 7/23/97 I c n c' lJ SOUTHWEST J NORTHEAST

120 LP-4 TF-4 TF-1 TF-2 Fill: Clay GTB3 120 trace sand LP-2 ~ MW-14 & gravel _...... --- -...... __,~ Fill: Coarse ...... nI gravel & Fill:--- Gravel ------...._, _ some sand 110 Clay: Brown dense, trace 110 Clay: Brown MW-12 fine gravel 0.J silty with trace sand some fine & gravel to coarse gravel fj] ---- ...... Clay: Gray with gravel some fine to 51 Clay: Brown --- 100 coarse gravel r-· ~ Clay: Gray ------silty with 100 Clay: Gray i .: trace sand 18.5' rounded gravel ' Clay: Gray lean, stiff Sand: Brown, very ' & gravel 19.5' lean, stiff fine, some silt . • 9 5 Well Screen 22' 90.7-85.7 WATER TABLE Well Screen Clay: Brown (plant datum) 99.9-89.4 ft silty with 90 Silt: Gray (plant datum) little gravel trace sand 15.5' 90 & gravel Silt: Sandy trace gravel 28' -. 30' Well Screen 87.5-82.5 ft Clay: Gray Clay: Gray (plant datum) with gravel trace sand 80 & sand & gravel 35' 80

60 120 180 240 300 360 410 470 630 690 750 810 870

LEGEND NOTES . LJ. ~ FILL SAND WELL SCREEN _j E;:::J CONCRETE SILT HORIZONTAL SCALE 1" : 60' ~ []] ------GROUND SURFACE LJ VERTICAL SCALE 1 " : 10 I _J ~ CLAY THIN SAND, CLAY, GRAVEL, OR SILT SEAMS ------WATER TABLE FIGURE 8-7 ------PPG OAK CREEK GEOLOGIC CROSS SECTION C-C' OAK CREEK, WISCONSIN RCRA FACIUlY INVESTIGATION REPORT CROSS SECTION LOCATION ICF KAISER ENGINEERS DATE: 7/31/97 OR.: T. BLAIR [] PITTSBURGH, PA SCALE: AS NOTED DWG. NO. XSECTDD j 8-1 'i ... .-~ ~ .:::: ~ ~ e.~ ~ a ~ ~ ~ .::c~ 1::: ~ ~ ~ ~ -1::: ~ ..:::: ~ .~ ...... ~ 1:::: ...... ~ ~ .0 1:::: :::: ~ I

l...... •.:. ~ ..

APPENDIXC HISTORICAL SAMPLE RESULTS- TANK FARM AREA PPG - OAK CREEK

SAMPLE LOCATION B1 B10 B10 B11 B11 B2 B2 B2 SAMPLE DEPTH(ft) 13.50-15.5 6.00-8.0 13.50-15.5 11.00-13.0 3.50-5.5 1.00-3.0 33.00-35.0 21.00-23.0 SAMPLE DATE Region V 8/8/91 8/6/91 8/14/91 8/14/91 8/16/91 8/8/91 8/9/91 8/10/91 PARAMETER DQLs VOLATILES (ug/kg) 1,1 ,2,2-Tetrachloroethane 900 ND ND ND ND ND ND ND ND 2-Butanone (MEK) 8,700,000 100 u 9400 100 u 100 u 45 100 u 100 u 100 u 2-Hexanone - ND ND ND ND ND ND ND ND 4-Methyl-2-pentanone (MIBK) 5,200,000 100 u 100 u 100 u 100 u 120 72000 D 100 u 100 u Acetone 2,000,000 66 J ND ND ND ND ND 70 8 ND Benzene 1,400 5 u 5 u 5 u 5 u 5 u 5 u 5 u 5 u Crotonaldehyde -- ND ND ND ND ND ND ND ND Chlorobenzene 160,000 ND ND ND ND ND 14 ND ND Chloroform 530 ND ND ND ND ND ND ND ND Ethylmethacrylate 340,000 ND ND ND ND ND ND ND ND Ethyl benzene 2,900,000 5 u 11000 170000 4000 190 1100 DJ 5 u 5 u Methylene chloride 2,000 ND ND ND ND ND ND 46 8 ND Styrene 2,200,000 ND ND ND ND ND ND ND ND Trans-1 ,4-Dichloro-2-8utene 7.6 ND ND ND ND ND ND ND ND Tetrachloroethene 7,000 ND ND ND ND ND 2 J ND ND Toluene 1,900,000 5 u 1200 7400 5 u 12 36 5 u 5 u Trlchloroethene 7,100 ND ND ND ND ND ND ND ND Trichlorofluoromethane 710,000 ND ND ND ND ND ND ND ND Xylenes (total) 980,000 su 14000 18000 7000 1100 6600 D 5 u 5 u

U- Not detected. NA- Not analyzed. NO • Not detected,detectlon limit not available. J • Estimated B - blank contamination. 0- onutton. Page 1 ' ' '•

APPENDIXC HISTORICAL SAMPLE RESULTS- TANK FARM AREA PPG - OAK CREEK

SAMPLE LOCATION 82 83 84 85 86 86 87 87 SAMPLE DEPTH(ft) 13.50-15.5 13.50-15.5 13.50-15.5 8.50-10.5 6.00-7.0 18.50-20.5 8.50-10.5 18.50-20.5 SAMPLE DATE Region V 8/13/91 8/9/91 8/9/91 8/14/91 8/12/91 8/14/91 8/13/91 8/23/91 PARAMETER DQLs VOLATILES (ug/kg) 1,1 ,2,2-Tetrachloroethane 900 NO NO NO NO NO NO NO NO 2-8utanone (MEK) 8,700,000 100 u 100 u 100 u 100 u 100 u 100 u 100 u 100 u 2-Hexanone --- NO NO NO NO NO NO NO NO 4-Methyl-2-pentanone (MIBK) 5,200,000 100 u 100 u 100 u 100 u 100 u 100 u 100 u 100 u Acetone 2,000,000 NO NO NO NO NO NO NO NO Benzene 1,400 5 u 5 u 5 u 5 u 5 u 5 u 5 u 5 u Crotonaldehyde -- NO NO NO NO NO NO NO NO Chlorobenzene 160,000 NO NO NO NO NO NO NO NO Chloroform 530 NO NO NO NO NO NO NO NO Ethylmethacrylate 340,000 NO NO NO NO NO NO NO NO Ethylbenzene 2,900,000 6500 5 u 5 u 5 u 15000 5 u 640 J 10 Methylene chloride 2,000 NO NO 47 8 NO NO NO NO NO Styrene 2,200,000 NO NO NO NO NO NO NO NO Trans-1 ,4-0ichloro-2-Butene 7.6 NO NO NO NO NO NO NO NO Tetrachloroethene 7,000 NO NO NO NO NO NO NO NO Toluene 1,900,000 5 u 5 u 5 u 5 u 4500 J 5 u 330 J 5 u Trichloroethene 7,100 NO NO NO NO NO NO NO NO Trichlorofluoromethane 710,000 NO NO NO NO NO NO NO NO Xylenes (total) 980,000 15000 5 u 5 u 5 u 110000 5 u 530 J 7

U - Not detected. NA- Not analyzed. NO- Not detected,detectlon limit not available. J - Estimated B - blank contamination. D- Dilution. Page 2 APPENDIXC HISTORICAL SAMPLE RESULTS- TANK FARM AREA PPG - OAK CREEK

SAMPLE LOCATION 88 88 89 89 GS-1 GS-10 GS-11 GS-12 SAMPLE DEPTH(ft) 18.50-20.5 1.00-3.0 1.00-3.0 13.50-15.5 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 SAMPLE DATE Region V 8/14/91 8/15/91 8/15/91 8/16/91 8/2/91 8/2/91 8/2/91 8/6/91 PARAMETER DQLs VOLATILES (ug/kg) 1,1 ,2,2-Tetrachloroethane 900 NO NO 9 J NO NO NO NO 11 J 2-Butanone (MEK) 8,700,000 100 u 100 u 100 u 100 u 100 u 100 u 100 u 360 2-Hexanone -- NO NO NO NO NO NO NO NO 4-Methyl-2-pentanone (MIBK) 5,200,000 100 u 100 u 100 u 100 u 100 u 100 u 100 u 9500 DJ Acetone 2,000,000 ND ND ND ND ND ND ND ND Benzene 1,400 5 u 5 u 5 u 5 u 5 u 5 u 5 u 5 u Crotonaldehyde --- NO ND ND ND ND ND NO ND Chlorobenzene 160,000 ND ND NO ND ND ND ND ND Chloroform 530 ND ND ND ND ND ND ND ND Ethylmethacrylate 340,000 ND ND ND ND ND ND ND ND Ethylbenzene 2,900,000 5 u 3900 D 5 u 8700 5 u 5 u 5 u 4300 DJ Methylene chloride 2,000 ND ND ND NO NO ND ND NO Styrene 2,200,000 NO ND ND ND ND ND ND 400 Trans-1 ,4-0ichloro-2-Butene 7.6 ND ND ND ND ND ND ND ND Tetrachloroethene 7,000 ND ND ND ND ND ND ND 20 J Toluene 1,900,000 5 u 5 u 5 u 820 J 5 u 5 u 5 u 3300 DJ Trichloroethene 7,100 NO NO NO NO NO NO NO ND Trichlorofluoromethane 710,000 NO ND ND ND ND ND ND ND Xylenes (total) 980,000 5 u 51000 D 5 u 27000 340 5 u 5 u 140000 D

U - Not detected. NA - Not analyzed. NO - Not detected,detectlon limit not available. J - Estimated B - blank contamination. D- Dllutton. Page 3 APPENDIX C HISTORICAL SAMPLE RESULTS- TANK FARM AREA PPG - OAK CREEK

SAMPLE LOCATION GS-13 GS-14 GS-15 GS-16 GS-17 GS-18 GS-19 GS-2 GS-20 SAMPLE DEPTH(ft) 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 SAMPLE DATE Region V 8/2/91 8/5/91 8/2/91 8/7/91 8/2/91 8/6/91 8/2/91 8/2/91 8/2/91 PARAMETER DQLs VOLATILES (ug/kg) 1,1,2,2-Tetrachloroethane 900 ND ND 7 J ND ND ND ND ND ND 100 100 2-Butanone (MEK) 8,700,000 100 u 100 u 80 100 u 100 u 100 u 100 u u u ND ND ND 2-Hexanone --- ND ND 130 ND ND ND 4-Methyl-2-pentanone (MIBK) 5,200,000 100 u 100 u 120000 D 390000 100 u 100 u 100 u 100 u 100 u ND ND Acetone 2,000,000 ND ND ND ND ND ND ND 5 5 5 Benzene 1,400 5 u 5 u 10 5 u 5 u 5 u u u u Crotonaldehyde --- ND ND ND ND ND ND ND ND ND Chi oro benzene 160,000 ND ND 7 ND ND ND ND ND ND Chlorofonn 530 ND ND ND ND ND ND ND ND ND Ethylmethacrylate 340,000 ND ND 8 J ND ND ND ND ND ND Ethylbenzene 2,900,000 5 u 11000 200000 D 810000 5 u 5 u 5 u 5 u 5 u Methylene chloride 2,000 ND ND ND ND ND ND ND ND ND Styrene 2,200,000 ND ND 89 ND ND ND ND ND ND Trans-1 ,4-Dichloro-2-Butene 7.6 ND ND 9 J ND ND ND ND ND ND Tetrachloroethane 7,000 ND ND 2 J ND ND ND ND ND ND Toluene 1,900,000 5 u 14000 120000 D 570000 5 u 5 u 5 u 5 u 5 u Trichloroethane 7,100 ND ND 2 J ND ND ND ND ND ND Trtchlorofluoromethane 710,000 ND ND ND ND ND ND ND ND ND Xylenes (total) 980,000 5 u 28000 580000 D 2100000 5 u 5 u 5 u 76 5 u

U- Not detected. NA - Not analyzed. NO • Not detected,detectlon limit not available. J - Estimated B - blank contamination. Page 4 APPENDIX C HISTORICAL SAMPLE RESULTS· TANK FARM AREA PPG • OAK CREEK

SAMPLE LOCATION GS-21 GS-22 GS-23 GS-24 GS-25 GS-26 GS-27 GS-28 GS-29 SAMPLE DEPTH(ft) 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 SAMPLE DATE Region V 8/2/91 8/2/91 8/5/91 8/5/91 8/2/91 8/2/91 8/7/91 8/6/91 8/8/91 PARAMETER DQLs VOLATILES (ug/kg) 1,1,2,2-Tetrachloroethane 900 NO NO NO NO NO NO NO NO NO 2-Butanone (MEK) 8,700,000 100 u 100 u 100 u 100 u 34 100 u 100 u 100 u 100 u 2-Hexanone -- NO NO NO NO 180 NO NO NO NO 4-Methyl-2-pentanone (MIBK) 5,200,000 100 u 100 u 100 u 100 u 100 u 100 u 100 u 100 u 100 u Acetone 2,000,000 NO NO NO ND 71 B ND ND ND ND 5 5 Benzene 1,400 5 u 5 u 7 J 5 u 5 u 5 u 5 u u u Crotonaldehyde --- NO NO ND ND NO ND ND NO NO Chtorobenzene 160,000 ND ND ND ND ND ND ND ND ND Chlorofonn 530 ND ND ND ND ND ND ND ND ND Ethylmethacrylate 340,000 ND ND ND ND ND ND ND ND ND Ethylbenzene 2,900,000 5 u 5 u 17000 0 5500 26 5 u 5 u 27 5 u Methylene chloride 2,000 NO ND ND ND NO NO NO ND NO Styrene 2,200,000 ND ND ND ND ND ND ND ND ND Trans-1,4-Dichloro-2-Butene 7.6 ND ND ND ND ND ND ND ND ND Tetrachloroethene 7,000 ND ND 15 J ND ND ND ND ND ND Toluene 1,900,000 5 u 5 u 12000 0 2300 16 5 u 5 u 3 J 5 u Trichloroethene 7,100 NO NO NO NO ND NO NO ND NO Trichlorofluoromethane 710,000 NO ND ND ND ND ND ND NO NO Xvtenes (total) 980,000 5 u 5 u 140000 D 26000 81 5 u 5 u 15 5 u

U • Not detected. NA • Not analyZed. NO • Not deteeted,detecttori ltmtt not avattable. J- Estimated B - blank contamination. l"l. nnutto11. Page 5 r r· ~: ..,,.,,

APPENDIX C HISTORICAL SAMPLE RESULTS· TANK FARM AREA PPG - OAK CREEK

SAMPLE LOCATION GS-3 GS-30 GS-31 GS-32 GS-33 GS-34 GS-35 GS-36 GS-37 SAMPLE DEPTH(ft) 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 SAMPLE DATE Region V 8/2/91 8/3/91 8/5/91 8/10/91 8/6/91 8/6/91 8/4/91 8/8/91 8/4/91 PARAMETER DQLs VOLATILES (ug/kg) 1,1 ,2,2-Tetrachloroethane 900 NO NO NO NO NO NO NO NO NO 2-Butanone (MEK) 8,700,000 100 u 100 u 8700 100 u 100 u 100 u 6 J 100 u 100 u 2-Hexanone - NO NO NO NO NO NO NO NO NO 4-Methyl-2-pentanone (MIBK) 5,200,000 100 u 100 u 100 u 100 u 100 u 100 u 22 100 u 1 J Acetone 2,000,000 NO NO NO NO NO 64 B 94 B NO NO Benzene 1,400 5 u 5 u 5 u 5 u 5 u 5 u 5 u 5 u 5 u Crotonatdehyde --- NO NO NO NO NO NO NO NO NO Chlorobenzene 160,000 NO NO NO NO NO NO 1 J NO NO Chloroform 530 NO 1 NO NO NO NO NO NO NO Ethyl methacrylate 340,000 NO NO NO NO NO NO NO NO NO Ethyl benzene 2,900,000 5 u 5 u 5 u 5 u 5 u 5 u 5 u 5 u 5 u Methylene chloride 2,000 63 B NO NO NO NO NO NO NO NO Styrene 2,200,000 NO NO NO NO NO NO NO NO NO Trans-1 ,4-0ichloro-2-Butene 7.6 NO NO NO NO NO NO NO NO NO Tetrachloroethene 7,000 NO NO NO NO NO NO NO NO NO Toluene 1,900,000 5 u 5 u 5 u 5 u 5 u 5 u 8 5 u 5 u Trichloroethene 7,100 NO NO NO NO NO NO NO NO NO Trichlorofluoromethane 710,000 NO NO NO NO NO NO NO NO 1 J Xylenes (total) 980,000 31 5 u 9 J 5 u 5 u 5 u 24 1700 4 J

U - Not detected. NA- Not analyzed. NO • Not detected,detectlon limit not available. J • Estimated B • blank contamination. D· onution. Page 6 APPENDIX C HISTORICAL SAMPLE RESULTS· TANK FARM AREA PPG - OAK CREEK

SAMPLE LOCATION GS-38 GS-39 GS-4 GS-40 GS-41 GS-42 GS-43 GS-44 GS-45 SAMPLE DEPTH{ft) 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 SAMPLE DATE Region V 8/5/91 8/6/91 8/5/91 8/7/91 8/4/91 8/4/91 8/9/91 8/16/91 8/16/91 PARAMETER DQLs VOLATILES (ug/kg) 1,1 ,2,2-Tetrachloroethane 900 ND ND ND ND ND ND ND ND ND 2-Butanone (MEK) 8,700,000 100 u 100 u 100 u 100 u 100 u 100 u 100 u 100 u 100 u 2-Hexanone --- ND ND ND ND ND ND ND ND ND 4-Methyl-2-pentanone (MIBK) 5,200,000 100 u 100 u 100 u 9900 J 100 u 100 u 100 u 100 u 100 u Acetone 2,000,000 ND NO NO NO NO NO NO NO NO Benzene 1,400 5 u 5 u 5 u 5 u 5 u 5 u 5 u 5 u 5 u Croton aldehyde --- ND NO ND ND NO ND ND ND ND Chlorobenzene 160,000 ND ND NO NO NO NO NO NO NO Chloroform 530 NO NO NO NO NO NO NO NO NO Ethyl methacrylate 340,000 NO NO NO NO NO NO NO NO ND Ethylbenzene 2,900,000 .34000 100000 5 u 5 u 5 u 15 5 u 5 u 1 Methylene chloride 2,000 ND ND ND ND ND ND ND ND ND Styrene 2,200,000 ND ND ND ND NO ND NO ND ND Trans-1,4-Dichloro-2-Butene 7.6 ND NO NO NO NO NO NO NO NO Tetrachloroethane 7,000 ND ND NO ND NO NO NO NO ND Toluene 1,900,000 69000 630000 5 u 5 u 5 u 5 u 5 u 5 u 5 u Trichloroethene 7,100 ND ND ND ND ND ND ND ND ND Trichlorofluoromethane 710,000 ND ND ND NO ND ND NO NO ND Xylenes (total) 980,000 280000 490000 2100 390000 5 u 29 5 u 5 u 5 u

U - Not detected. NA - Not analyzed. NO - Not detected, detection limit not avallable. J- Estimated · B - blank contamination. 0- Dilution. Page 7 .,_ :.:: ...... ··

APPENDIX C HISTORICAL SAMPLE RESULTS- TANK FARM AREA PPG - OAK CREEK

SAMPLE LOCATION GS-46 GS-47 GS-48 GS-49 GS-5 GS-50 GS-53 GS-53 GS-5 SAMPLE DEPTH(ft) 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 0.00-2.0 1.00-2.0 3.00-4.0 1.00-2 SAMPLE DATE Region V 8/16/91 8/14/91 8/16/91 8/16/91 8/2/91 8/16/91 1/30/92 1/30/92 8/16/9 PARAMETER DQLs VOLATILES (ug/kg) 1,1,2,2-Tetrachloroethane 900 ND ND ND ND ND ND NA NA ND 2-Butanone (MEK) 8,700,000 100 u 100 u 100 u 100 u 100 u 100 u 100 u 100 u 2-Hexanone --- ND ND ND ND ND ND NA NA ND 4-Methyl-2-pentanone (MIBK) 5,200,000 100 u 100 u 100 u 100 u ND 100 u 100 u 100 u Acetone 2,000,000 ND ND ND ND ND ND ND ND Benzene 1,400 5 u 5 u 5 u 5 u 2 J 5 u 5 u 5 u Crotonaldehyde --- ND ND ND ND ND ND NA NA ND Chlorobenzene 160,000 ND ND ND ND 2 J ND NA NA ND Chloroform 530 ND ND ND ND ND ND NA NA ND Ethyl methacrylate 340,000 ND ND ND ND ND ND NA NA ND Ethylbenzene 2,900,000 5 u 5 u 5 u 5 u 5 u 5 u 15300 9.1 UJ Methylene chloride 2,000 ND ND ND ND ND ND NA NA ND Styrene 2,200,000 ND ND ND ND ND ND NA NA ND Trans-1 ,4-0ichloro-2-Butene 7.6 ND NO NO NO ND NO NA NA ND Tetrachloroethene 7,000 ND ND NO NO ND ND NA NA ND Toluene 1,900,000 5 u 5 u 5 u 5 u ND 5 u 740 UJ 7.6 UJ Trichloroethene 7,100 ND ND NO NO ND ND NA NA ND Trichtorofluoromethane 710,000 ND ND ND NO ND ND NA NA ND Xylenes (total) 980,000 5 u 5 u 5 u 5 u 200 5 u 31600 13.6

U- Not detected. NA- Not analyzed. ND - Not detected,detection limit not available. J- Estimated B - blank contamination. D- Dilution. Page 8 .·· :. ~ ,.

APPENDIX C HISTORICAL SAMPLE RESULTS· TANK FARM AREA PPG • OAK CREEK

SAMPLE LOCATION GS-53 GS-54 GS-54 GS-54 GS-54 GS-6 GS-7 GS-8 SAMPLE DEPTH(ft) 0 3.00-4.0 1.00-2.0 2.00-3.0 1.00-2.0 2.00-3.0 0.00-2.0 0.00-2.0 0.00-2.0 SAMPLE DATE Region V 8/16/91 1/30/92 1/30/92 8/16/91 8/16/91 8/7/91 8/2/91 8/2/91 PARAMETER DQLs VOLATILES (ug/kg) 1,1,2,2-Tetrachloroethane 900 NO NA NA NO NO NO NO NO 2-Butanone (MEK) 8,700,000 NA NA 100 u 100 u NA NA 9800 100 u 100 u 2-Hexanone --- NO NA NA NO NO NO NO NO 4-Methyl-2-pentanone (MIBK) 5,200,000 NA NA 5380 5890 NA NA 100U 100 u 100 u Acetone 2,000,000 NA NA NO NO NA NA NO NO NO Benzene 1,400 NA NA 5 u 5 u NA NA 5 u 5 u 5 u Crotonaldehyde --- NO NA NA NO NO NO NO NO Chlorobenzene 160,000 NO NA NA NO NO NO NO NO Chloroform 530 NO NA NA NO NO NO NO NO Ethylrnethacrylate 340,000 NO NA NA NO NO NO NO NO Ethylbenzene 2,900,000 NA NA 373000 43900 NA NA 5 u 37 1 J Methylene chloride 2,000 NO NA NA NO NO NO NO NO Styrene 2,200,000 NO NA NA NO NO 52000 17 1 J Trans-1 ,4-0ichloro-2-Butene 7.6 NO NA NA NO NO NO NO NO Tetraehloroethene 7,000 NO NA NA NO NO NO NO NO Toluene 1,900,000 NA NA 376000 49400 NA NA 5 u NO 5 u Trichloroethane 7,100 NO NA NA NO NO NO NO NO Trichlorofluorornethane 710,000 NO NA NA NO NO NO NO NO Xylenes (total) 980,000 NA NA 1083000 136200 NA NA 5 u 8 5 u

U - Not detected. NA - Not analyzed. NO - Not detected,detectlon limit not available. J - Estimated B - blank contamination. 0- Dilution. Page 9 '•, . .. ): :.:-~ . '· :·,. ....:::.. .. "' .. ;.;;·.~ .

APPENDIX C. HISTORICAL SAMPLE RESULTS· TANK FARM AREA PPG - OAK CREEK

SAMPLE LOCATION GS-9 SAMPLE DEPTH(ft) 0.00-2.0 SAMPLE DATE Region V 8/2/91 PARAMETER DQLs VOLATILES (ug/kg) 1,1 ,2,2-Tetrachloroethane 900 ND 2-Butanone (MEK) 8,700,000 100 u 2-Hexanone --- NO 4-Methyt-2-pentanone (MIBK) 5,200,000 100 u Acetone 2,000,000 ND Benzene 1,400 5 u Crotonatdehyde --- ND Chtorobenzene 160,000 ND Chloroform 530 NO Ethyl methacrylate 340,000 ND Ethytbenzene 2,900,000 5 u Methylene chloride 2,000 48 8 Styrene 2,200,000 ND Trans-1 ,4-0ichtoro-2-Butene 7.6 ND Tetrachtoroethene 7,000 ND Toluene 1,900,000 5 u Trichloroethane 7,100 ND Trichtorofluoromethane 710,000 ND Xvtenes (total) 980,000 5 u

U - Not detected. NA - Not analyzed. NO- Not detected,detectlon limit not available. J - Estimated · B - blank contamination. D- Dttutton. Page 10 ::: ;§ ~ ~ ~ e.~ ~ a ~ .....;.., ~ ..::.::""' ~ l:::l ~ ~

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. :.• ·.: :. 'This Conn is aut.h~ril.c:d b)' Ch;ptctS 1~.147 :and 162. W"~t. St.:.c.s. Clmpkcion oC thts repott i$ m~cocy. Penalties: Porlclt not I~ t.'l~n s•O nor mote t1 . ~-·~"..C.. : :· .. : .~.000 fot' e.:~ch ~~~tion. F"mc:H GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 1 of 25 Effective Date: March 5, 1997 Revision Number: 2

Purpose:

Contractor personnel are routinely used to provide a wide variety of on-site and/or in­ plant services. In general, contractor personnel are not familiar with PPG processes, material hazards, plant safety rules & procedures, or plant emergency procedures. This procedure establishes minimum safety, health, fire protection, and security requirements for contractor personnel.

Scope:

This procedure applies to any contractor performing work on-site at the PPG OakCreek, WI facility.

References:

29 CFR Part 1910- Occ~pationaf Safety andHealth Standards

29 CFR Part 1926- Safety and Health Regulations For Construction

Definitions:

OSHA Occupational Safety and Health Administration

RCIR Recordable C~~ Incidence Rate. A recordable case is simply defined as· an.y·work-related injury or illness which:

1. Requires treatment other than first aid, 2. Results in days lost due to restricted activity (individual cannot perform all job functions due to injury or illness), 3. Results in days lost away-from-work (individual cannot report to work due to injury or illness), 4. Results in unconsciousness or death.

The recordable case incidence rate is calculated by multiplying the number of recordable cases by 200,000 - then dividing the factor by the number of hours worked:

# Recordable Cases x 200,000 # Hours Worked CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett .. Page: 2 of 25 Effective Date: March 5, 1997 Revision Number: 2

The recordable case incidence rate represents the number of recordable cases experienced per 100 employees.

EMR Experience Modifier Rate. A numeric rate used by insurance carriers to adjust worker's compensation insurance rates based on an employers worker's compensation experience and assoCiated costs.

Contractor Any individual 'Yho is self employed or employed by an employer.other than PPG and who performs work or provides a service at the-Oak Creek facility. Examples of work/services provided by contractors include but are not limited to calibration, construction, demolition, health care, inspection, installation, maintenance, paint4Ig_, repair, replacement, etc. Delivery personnel, over the road carrier service truck drivers, visitors, and individuals who are continuously escorted while reviewing conditions on-site to submit bids for work are not considered contractors for the Pl;l;llJOSe of this procedure.

Procedure: ;~;r..-

Responsibility: Activity_:

A. Bid Pro~'Css · ··

··:-:.. PPG Associate 1. Inform contractor of the Contractor Safety Requirements Soliciting Bid For appli~able to the type of work to be performed before or Contract Work while· obtaining bids.

a. Inform contractor that all employees arriving to perform work on-site must receive Contractor Safety Requirements . orientation prior to starting work. b. Inform contractor of applicable General Plant Safety Standard Operating Procedures and/or OSHA standards listed msection II of the Contractor Safety Requii~ments.

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 3 of 25 Effective Date: March 5, 1997 Revision Number: 2

2. Notifies Regional Purchasing if contractor will perform work directly on equipment, utilities, or facilities for processes covered by the OSHA Process Safety Management Of Highly Hazardous Chemicals standard. Notification is made using the "ATTACHMENTS" function provided on the Oracle Applications requisitioning system.

Note

The intent of items 1 and 2 above are to ensure contractors are notified of special PPG Oak Creek safety requirements and applicable OSHA health and safety standards before bids are solicited, andto ensure compliance with contractor selection requirements outlined in the OSHA Process Safety Management Of Highly Hazardous Chemicals standard.

Regional Purchasing 1. Requests Contractor Safety Pre-Qualification Questionnaire from any contractor performing work directly on equipment, utilities, or facilities for processes covered by the OSHA Process SafetY Management.OfHighly Hazardous Chemicals standard. Request is made at time of initial contract award and upon req.ewal or extension of affected blanket contracts.

2. Ins~~ts·~~tractors to submit completed Contractor Safety Pre-QuaFffr~t~on Questionnaires directly to Oak Creek Safety with ~py to Regional Purchasing.

3. Forwards listing of contractors with current insurance certificates to Safety on monthly basis.

Note

All contractors performing work on-site must have current liability insurance .

.,• . :tv' i' 1•

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 4of 25 Effective Date: March 5, 1997 Revision Number: 2

Manager, Safety & 1. Reviews Contractor Safety Pre-Qualification Questionnaire Loss Prevention for all contractors· performing work directly on equipment, utilities, or facilities for processes covered by the OSHA Process Safety Management Of Highly Hazardous Chemicals standard.

a. Evaluates safety performance and compares recordable case incidence rate (RCIR) to industry average for contractor's specific Standard Industrial Classification (SIC) code. A Meets Requirements (MR) rating is assigned to any contractor with a RCIR less than or equal to 120% of the industry average. A Needs Improvement (NI) rating is assigned to any contractor with a RCIR greater than 120% of the industry average. b. Evaluates the worker's compensation insurance experience modifier rate (EMR) and compares to an EMR of 1. A Meets Requirements (MR) rating is assigned to any contractor with an EMR less than or equal to 1. A Needs Improvement (NI) rating is assigned to any contractor with an EMR greater than 1.

2. Contractors receiving NI ratings for both the RCIR and EMR will n:ot be p~imitted to perform work on-site.

3. Notifies Regional Purchasing and appropriate requisitioner of contractot~ l·eteiving ratings ofNI.

Regiopal Purchasing 1. If notified by. Oak Creek Safety that a contractor has received aNI rating:

a. Informs individual soliciting bids for contractor work that contractor i~·notpermitted to perform work on-site, b. lnforrils contractor that work may not be performed on-site.

PPG Associate 1. If notified by ,Qak Creek Safety that a contractor is not Soliciting Bid For peiniitted to p:erform work on-site: Contract Work a. Selects. another contractor, b. Begins bid process. CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF020l6.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: .. ID: SAF02016 Written By: Ted Huyett ..... Page: 5 of 25 Effective Date: March 5, 1997 Revision Number: 2

·'J B. Before Contract9r Begins Work On-Site

PPG Associate 1. Reviews applicable sections of Contractor Safety Coordinating On-Site Requirements with all contractor employees arriving to Contractor Work perform wor~ on site .

. a. Section I of the Contractor Safety Requirements must be reviewed with all contractor employees prior to performing work on-~it~. b. Sections.JI and III of the Contractor Safety Requirements must be reviewed with appropriate contractor employees prior top~if.orming work on-site - as dictated by the nature and extent of the work to be performed.

Note

Sections I, II, and III must be reviewed with all contractor personnel who will perform work on a process covered by the OSHA Pro¢ess Safety Management standard.

2. Administers Contractor Safety Orientation Quiz to all contractoq~~ployees arriving on-site to perform work. Cont.ractoi ..Safety.Qrientation Quizzes are "open book"- the Contract<;>r, ~~fety Requirements document may be used while the quiiis completed.

a. Contractor SafetY Orientation Quiz - Section I will be administered to all contractor personnel who receive only the Section I - General orientation. b. Contractor.Safely Orientation Quiz- Sections I-III will be .administer~d to ·~n other contractor personnel.

Reviews correct quiz answers with contractor personnel and forwards c~~pleted quizzes to Security . • • " • ! .• ~· . • . 3. Ha8 each':eonttactor employee complete a Confidentiality Agreement:.- Forwards completed Confidentiality Agreements to Security.·

CONTROLLED DOCUMENT If. PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 6 of 25

Effective Date: March 5, 1997 : Revision Number: 2

4. Completes applicable sections of the Contractor Safety Requirements Verification Checklist with contractor employees and forwards to Security.

5. Periodically monitors contractor on-site work activities to assure compliance with applicable Contractor Safety Requirements. Addresses non-conformance's as needed.

Safety Secretary 1. Maintains listing of contractor employees who have received Contractor Safety Requirements orientation. Listing is maintained alphabetically by contractor firm. Copies of the listing are available in Security and Safety.

Security Attendant 1. Reviews listing of contractor employees who have received Contractor Safety Requirements orientation to verify that ~ contractor employees entering the plant have received orientation.

2. If Contractor Safety Requirements orientation has been received, Security will:

a. Verify contractor has current liability insurance, b. Notify appropriate PPG associate contractor is on-site, c. Have each contractor employee sign in on the Contractor Log she6('· d. Issue each contractor employee a Contractor Badge, e. Issue a parking:permit (if approved by PPG associate responsible for on-site contractor activities), f. Instruct contractor employees to wait for PPG associate responsible for, on-site contractor activities in lunch room, or direct contractor employees to location specified by PPG associate.

3. If Contractor Safety Requirements orientation has not been received, Security will: . . '

a. Verify contractor has current liability insurance, .b. Notify appropriate PPG associate contractor is on-site,

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 7 of 25 Effective Date: March 5, 1997 Revision Number: 2

c. Have each contractor employee sign in on the Contractor Log sheet, d. Issue each contractor employee a Contractor Badge, e. Instruct contractor employees to wait for PPG associate responsible for. on-site contractor activities in lunch room.

C. After Contractor Completes Work On-Site

PPG Associate 1. Requires contractor to complete the Contractor's Daily Coordinating On-Site Timesheef(see attachment 2) for any work performed in a Contractor Work laboratory~ warehouse, or production area.

Contractor 1. Completes Contractor's Daily Timesheet.

2. Lists any adhesives, lubricants, aerosols, degreasers, cleaners, ~ sealants, pipe compounds, etc. used while performing work. Materials to be listed by day and location used as shown on Contractor's Daily Timesheet.

PPG Associate 1. Forwards one (1) copy of Cop.tractor' s Daily Timesheet to Coordinating On-Site Safety. · ·~·,.· Contractor Work ol· '\"( 'L~~· < •' •, :, ...

Safety Secretary I. Files Contt;actor Daily Timesheets chronologically. Copies maintained1for one (1) year.

D. Miscellaneous

PPG Associate 1. Informs Security - in writing - of any contractor work which Coordinating On-Site will b~ perforroe~ pn weekends or holidays. Written Contractor Work notification must include:

a. Contractor name, b. Number of contractor employees expected, c. Tirlle(s) and date(s) contractors will arrive on-site, d. Name of PPG associate overseeing on-site contractor work

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements '. Approved By: ,,·. ID: SAF02016 Written By: Ted Huyett Page: 8 of 25 Effective Date: March 5, 1997 Revision Number: 2

Note

Contractor work performed on-site on weekends or holidays must be coordinated on-site by a PPG associate familiar with the · ·· work being pet(ormed and the area where work will be performed.

2. Grants contractors permission to drive vehicles into plant grounds .ofily for legitimate business needs'(e.g. tool box or crib mounted to vehicle, equipment mounted to vehicle, parts required for work stored on vehicle, etc.). Convenience is not an acceptable business need. Vehicles making equipment or supply deliveries to a contractor work site ~ill be permitted to enter the south truck gate without a parking permit.

Security Attendant 1. Does not ·pewit contractor to enter facility in the event of the folltiwiiig~ ·.,

a. Contractor 'arrives on-site to perform work during normal bus~ness ·~o~s and PPG associate responsible for .. -~. :. ~ ... ~' .· ·-:( "\.· ' . ov~rseefug work is not on-site, b. Contractor arrives on-site to perform work on a weekend or . ·f\1'!:::''·i .C· holiday and prior notification has not been given and PPG assoCiate respo~ible for overseeing work is not on-site.

2. Informs PPG associate responsible for overseeing contractor work and Safety if contractor does not have current liability insurance. 4·:.·: ... '\: .,, PPG Associate 1. Obtains current insurance certificate from vendor prior to Coordinating On-Site start of work,- if liability insurance is not listed or expired.

·~: Contractor Work ...... ~_ .. 2. Forwards .friscirance certificate to Security or Safety . . ·: ·.. ~ . . . .

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.D.OC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

·•' ·'• ' Approved By: ID: SAF02016 Written By: Ted Huyett Page: 9 of 25 Effective Date: March 5, 1997 Revision Number: 2

Manager, Safety & 1. The insurance requirement may be waived by the Manager, Loss Prevention Safety & Loss Prevention; Plant Engineer; or Plant Manager if an emergency situation exists (e.g. utility or fire Plant Engineer protection impairment, environmental release, major production disruption) and liability insurance is not Plant Manager listed or expired. Regional Purchasing must be notified of the excepti9n as soon as possible - even if work has started or is complete.

• ~ I • ' • ' • ., Records:

Completed Contractor Safety Pre-Qualification Questionnaires are maintained in the Safety Office for at least 3 years.

Listings of contractor employees who have received Contractor Safety Requirements orientation are maintain,e.a in the Safety and Security Offices. . • • .•• 'tl

Completed Contractor's Daily Tii:nesheets are maintained by safety for one (1) year.

Attachments: ... ~ ~ ' ~ . .. . -~ .!' Attachment # 1 Contractor Safety Requirements Attachment #2 Contractor's Daily;.Timesheet Attachment #3 Confidentiality Agreement . . ~ .

Revision History:

Revision Number Change .. 1 Add SectioirC- After Contractor Completes Work On-Site. Add items E & F:to Se.cJioiiTofContractor Safety Requirements list. 2 Add requirements for Contractor Safety Orientation Quiz to Section B, item2. Add th.e following to Attachment 1 - Contractor Safety · Requirements: (1) 'introduction paragraph, (2) section I A, item 6, • : ;_,. ,.! (3) section I B; item· 5, ( 4) intro paragraph to section I D, (5) change refer.enc.e to safety belts to harnesses in section II G 2, • J ·.: • ~ ';. I • I • ( 6) add g, h, and i to section II M 1, (7) add reference to process hazards to· section liN ·1 ~ (8) add section II 0 1 - Lineffank!Vessel Opening. Add definition - Contractor.

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 10 of 25 Effective Date: March 5, 1997 Revision Number: 2

Attachment 1

CONTRACTOR SAFETY REQUIREMENTS PPG Industries, Inc. is a manufacturer of paint and coatings for the automotive and industrial markets. Our manufacturing processes involve-the handling and processing of over one thousand various liquid and solid raw materials to produce thousands of finished paint and coatings products. Our manufacturing processes are unique to the paint and coatings industry and can pose unique hazards to those who ar'e unfamiliar with them. The following Contractor Safety Requirements have been es~blished ,to ensure the safety and health of contractor and PPG employees, and to ensure uniform compliance with PPG safety policies and rules.

All contractor employees performing work for PPG Industries must adhere to the Contractor Safety Requirements outlined below. Failure to comply with these requirements may expose contractor and/or PPG employee~ to injury/illness. Blatant disregard for the Contractor Safety Requirements will result in the discharge of individual contractor employees and the termination of existing contracts.

I. GENERAL

A. Facility Access

. t~H· . 1. All contractoremployee~.mustsign in and <.)ut at Security each time the plant is entered or exited. (N~te::·:The word "plant" refers to the physical PPG Oak Creek facility). 2. All contractor employees-must wear a contractor identification badge while on plant grounds ... Th~ ba.dg~_f11yst.be visibly displayed on an outer garment. 3. Contractor vehicles will park in the north parking lot. 4. Contractor vehicles Will be'peritlitted to enter the south truck gate on an as needed basis only (i.e. tool box or crib mounted to vehicle, equipment/parts required for work stored on vehicle). Convenience is not an acceptable business need. A Parking Permit must be displayed on the driver side dashboard. 5. Vehicle operators must obey th~ .. posted speed limit, traffic signs, and remain alert for forktruck, pedestrian and vehicular traffic at all times. 6. Parking is not permitted in the following areas: a. Within 20 feet of~fire hydrants, fire hose houses, or red fire protection control valyes .. :: b. On roadway'sior In intersections. c. In front of doorw~ys, exits, or building access ramps. 7. Vehicles which park oil"iiiCI'ines (such as the dock area at the east end of the Office/Administrative Building} must place at least one wheel chock behind a front or rear wheel to preve9-t the vehicle from moving after being parked.

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requir_ernents

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 11 of 25 Effective Date: March 5, 1997 · Revision Number: 2

B. Prohibited Activities

1. Alcoholic beverages, intoxicating drugs and/or weapons are not permitted on PPG premises under any circumstances. - ~- -. 2. Solicitation of any type is prohibited. 3. Cameras are not permitted on PPG premises without prior approval of the Plant Manager or Manger, Safety & Loss Prevention. 4. Smoking is permitted only~n the concrete patio or wooden gazebo located outside and adjacent to the main lunchroom. 5. Matches and lighters af~ not.permitted in paint or resin manufacturing, maintenance, warehouse;·orlaboratory areas. Matches and lighters must be kept in personnel '\;'ehicles or wi!h the receptionist or guard.

C. Personal Protective Equipment

1. Safety glasses with side shields, hard hats and substantial leather work shoes (preferably-steel toe) are required in all production, maintenance, warehouse, and all outSide yard or roofareas .. 2. Safety glasses with side shields and substantial leather work shoes (preferably steel toe) are required in all laboratory areas. 3. Contractor employees·ai

D. Emergency Procedures

The manufacture of paint and.~ati~gs illvolves the handling and processing of flammable, combustible, cdrtosiv~,.reactive, and potentially toxic materials. These materials pose the potential fdfnipialy spreading fires, explosion, adverse health effects, and the release of potentially harmfu.l materials to the environment. The following . • .. ·'j!· contractor emergency p~:o~qpre!) fiave been established to assure contractor personnel are familiar with PPG' s fire; spi(f~ and medical emergency procedures . ..•.. ._.,:.JJ. ..• . .

I. The PPG Oak Creek faciH_ty is divided into seven (7) fire zones as follows:

a. Zone 1 - Administration & Technical Lab Building b. Zone 2- Shipping Warehouse c. Zone 3 - Paint Production & APA Lab Building CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: " ID: SAF02016 Written By: Ted Huyett Page: 12 of 25 Effective Date: March 5, 1997 Revision Number: 2

D. Emergency Procedures (cont'd)

d. Zone 4- Receiving Warehouse & Maintenance e. Zone 5 - Resin Production f. Zone 6 - Utility Center & Waste Treatment g. Zone 7 - Tank Farm

2. The plant fire alarm consistS of a series of coded electronic tones - followed by a voice message. The electronic tones identify the general Zone the fire alarm signal originates from:"''11ie.voice message identifies the general Zone and area the fire alarm originates from. Flashing white strobe lights (indoors) and rotating red beacons (outside) also operate to provide visual indication of a fire alarm. In the event of any fire alarm tone, voice message, or flashing fire alarm strobe light or red rotating beacon - shutdown operating equipment, exit any building via the nearest exit doorway and report to the area designated "VCD" in the main parking lot. APPG associate will report to the "VCD" to perform a head count-of contraCtor personnel vs. the Contractor Log sheet. Remain in the area designated "VCD'' until the ALL CLEAR is given - the ALL CLEAR is indicated by the activation of flashing blue beacon lights located above the security entrance & lab wing. 3. In the event offire,:activate the nearest manual fire alarm pull station. Fire alarm pull stations ate·io'cated at each exit. ...Follow instructions printed on the fire alarm pull station,,_,~;,_~., . 4. One time first aid treatnient is available in the Health Services Department between the hours ·cif6:30 AM and 6:30 PM. Emergency medical assistance can be obtained by dialing extension. 400. 5. Spills of any size or material must be reported to the PPG representative or plant Security immediately by dialing extension 400. 6. In the event of severe weather, various voice messages will be activated by Security. Severe weather ~amirig'and tornado watch messages do not require any special response· from C~ilttactor personnel. In the event of a tornado warning, a warble torie followed by a voice message will be activated by Security. The voice message will state "A tornado warning is now in effect. All personnel are to n~port'ib designated shelter areas." Contractor personnel are to shutdo:Wi{ operations and report to the nearest tornado shelter area. Tornado shelter hreas are designated by Tornado Shelter signs.

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 13 of 25 Effective Date: March 5, 1997 Revision Number: 2

E. Material Registration

1. Materials such as adhesives, lubricants, aerosols, degreasers, cleaners, sealants, pipe compounds, etc. must be approved for use in laboratory, warehouse, or production areas. A list of any such materials which will be used to perform work must be presented to the PPG assbciate overseeing work before work is started. 2. The use of silicone and silicone containing materials is prohibited.

F. Contractor's Daily Timesheet,

1. A Contractor's Daily Timesheet must be completed for all contractors performing work against a blanket purchaSe order. In addition, a Contractor's Daily Timesheet must be completed for any work performed in a laboratory, warehouse, or production area. 2. Any materials capable of causing finished products to crater (e.g. adhesives, lubricants, aerosols, degreasers, ci"eam;rs, sealants, pipe compounds, etc.) must be listed on the Contractor'S Daily Timesheet by day and location used- if the material is used in a laboratory, warehouse, or production area.

G. Miscellaneous

1. Food and beverage items are not to be consl}med in plant, laboratory, warehouse, maintenance and outside yard and roof areas. Lunch boxes/bags are to be stored inside vehicles or in designated break or lunch areas. 2. The main lunchroom, breakrooms and washrooms are available to contractor employees tinles's·otheiwise indicated by the PPG representative. 3. The contractor is responsible for housekeeping in the immediate work area. Questions regarding disposal of ~ash, scrap metal, wood, etc., should be directed to the PPG n~presentativ.e .. 4. PPG is responsible to p~otectit's.employees from all forms of harassment­ verbal, physical, and yistial.:. d~e to sex, race, color, creed, religion, national origin, citizenship status, age, disability, or veteran status. Derogatory comments; sexual jokes; slurs; threats; unwelcome sexual advances; repeated requests for dates; unwanted physical contact; blocking or impeding .,:··· . movement; derogatory"cartoons, drawings, postcards, or pictures; or anything which creates an intim~dating, hostile or offensive work environment may be considered forms ofliaralsnient. Harassment will not be tolerated in any form. Any individual who-feels he or she is a victim of harassment can obtain prompt, appropriate action by notizying the PPG representative or any member of PPG management.

CONTROLLED DOCBMENT IFP,RINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC

,•!_' GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 14 of 25 Effective Date: March 5, 1997 Revision Number: 2

G. Miscellaneous (cont'd)

·'

5. Beepers, cellular phones, or other electrical devices are not permitted inside ·.-{ production areas unless they are UL or FM listed as intrinsically safe for Class I, Division 1, Groups ;C and--D hazardous locations. 6. Riding on vehicle tailgates (e.g. pick-up truck) is prohibited.

II. SPECIFIC PROCEDURES

A. Electrical Equipment

1. Electrical equipment shall be installed, maintained and used as outlined in applicable sections of the National Electrical Code, the Wisconsin Administrative ~bde;·and the Code of Federal Regulations (29CFR 1910.301- 399 and 1926.400-499). · · · · 2. Many areas of the PPG facility are electrically classified by the NEC as Class I, :Division 1 or 2 hazardous locations. Electrical equipment operated in these areas must,be\Jll.d'ehvriters Laboratories (UL) or Factory Mutual (FM) approved for hazardou~ T~cation ·use. Operation of electrical equipment which is not approved for hazardous location use and/or the opening of energized electrical equipment such as exple>sion proof enclosures or purged cabinets in these areas must be ~pproved by the PPG representative prior to -::: the start of work. AnElectric Tool/Equipment Use Permit will be required in accordance with plant SOP SAF02021. The following areas of the PPG facility are considered Class I, Division 1 or 2 hazardous locations:

a. Paint Manufacturing Areas b. Cationic, Can·Coat;:aildResin Manufacturing Areas. c. Tank Wagon Loading Stations d. Resin Storage Cells e. Waste Treatment Cente~: (excluding north east desk area) f. Catalyst Bunker Storage Rooms g. Receiving Wareliouse1 APA Mini-Bulk Area h. Tank Farm: Within Spill Containment Dikes, Trenches & Sumps; and Within 5' Of Unloading M~i'nifblds, Unloading Pumps, Transfer Pumps & Tank Vents

3. Ground fault interruption ((jFI) protection must be used when portable electrical equipment will be operated in wet or damp areas.

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC '' GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 15 of 25 Effective Date: March 5, 1997 Revision Number: 2

B. Welding, Cutting, Burning, Grinding, Soldering, Use of Open Flame

1. A Hot Work Permit must be issued by the PPG representative prior to the start of any operation involving welding, cutting, burning, grinding, soldering, or the use of open flame producing equipment. In addition, the applicable requiremehts of plant SOP SAF02025- Hot Work- must be followed. 2. The contractor will be responsible for providing a fire watch during welding, cutting, burning and grinding operations. 3. Grounds for all welding operations shall be through the work place.

C. Confined Space Entry

1. A Confined Space Entry Permit must be issued by the PPG representative prior to the entry ofany tarik; process vessel, manhole, sewer, pit, boiler, etc. In addition, the applicable requirements of plant SOP SAF02026 - Confined Space Entry - must be followed. 2. DO NOT PLACE YOUR HEAD INSIDE A CONFINED SPACE- EVEN FOR AN INSTANT:. TIIE .ATMOSPHERE INSIDE THE SPACE MAY BE OXYGEN DEFICIENt.TOXIC, OR EXPLOSIVE/FLAMMABLE. 2. Contractors are responsible for providing required respiratory protection and must complete the PPG c~iifined Space Entry Training Course prior to entry. 3. The contractor will be responsible for providing a standby watch during all confined space entries:

D. Lockoutffa:gout

1. Equipment whi~~ m.~Y expd~e <;ontractor employees to the sudden release of electrical, gasecius,>fluid~' or mechanical energy must be locked out and tagged in accordance·with.the Code ofFederal Regulations 29CFR 1910.147 and plant SOP SAF02023. . 2. Contractors are respon.si~_le~forsupplying lock out locks as required. ~,. ,.·. ' . E. Utilities - Electricity, Wate·r~Compressed Air, Nitrogen, Inert Gas, Steam, Natural Gas, Fire Protection. ···

1. Contractor personnel shall not connect to, adjust or otherwise tamper with PPG equipment or utilities without prior approval of the PPG representative. 2. Utility outages must be authorized by the PPG representative and the area affected by the outage. 3. Compressed air, nitrogen, inert gas and/or steam fittings and hose must be compatible with those maintained by PPG in the maintenance store room. CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 16 of 25 Effective Date: March 5, 1997 Revision Number: 2

E. Utilities - Electricity, Water, ~ompressed Air, Nitrogen, Inert Gas, Steam, Natural Gas, Fire Protection (cont'd)

4. When connecting to electrical outlets, the PPG representative must be consulted to assure compatibility of the circuit and equipment current/voltage capacities.

F. Excavation, Drilling, Trenching, Floor and Wall Openings

1. All work involving excavation and/or trenching must be performed in compliance with the Code of Federal Regulations 29 CFR 1926.650-653. 2. The PPG representative must be consulted prior to any excavation, drilling or trenching to assure buried utility lines, piping, fire mains, storm and sanitary sewer lines, ·etc., 'have been identified. 3. Barricades shall-be provided around all sides of an excavation, trench, or floor or wall opening whenever work is temporarily suspended. Lighted barricades.are required when vehicle or pedestrian traffic is permitted in the work area at night. < ; ''·.: ... i.·.- .. G. Elevated Work/Roof Work

1. Ladders and scaffolding must be designed, _maintained and used in compliance with the Code

H. Cranes, Rigging, Overhe~d Lifting

1. Rigging equipment shall be inspected, maintained and used in compliance with the Code ofFederal Regulations 29 CFR 1910.184 and 1926.251. Defective equipme1;1t shall be removed from service immediately.

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 17 of 25 Effective Date: March 5, 1997 Revision Number: 2

H. Cranes, Rigging, Overhead Lifting (cont'd)

2. The operation, maintenance and inspection of cranes shall be in compliance with the Code ofFederal Regulations 29 CFR I9I0.179 and 1926.550. 3. Work shall not be performed under or immediately adjacent to loads being hoisted. Personnel must,be·,evacuated from the immediate lift area. "Safety personnel" or barricade tape should be used to alert personnel that a lift is in progress.

I. Powered Equipment

1. Contractor personnel will not be permitted to operate PPG powered equipment (fork trucks, manlifts,.etc.) unless authorized by the PPG representative. V erifica~ion of training or competence is required. 2. All fuel-driven equipment must be shut down prior to refueling. 3. The use of internal combustion engine powered equipment inside any building must be approv~d-by the PPG representative. - ... . \ .• ~- . i ' . ,1"'":' J. Compressed Gas Cylinders . ~-~~ ,.:.i:'t~ ~/{' I. The use of compressed gas cylinders must be approved by the PPG representative. -· 2. Compressed gas cylinders must be secured in an upright position by rope, chain or the equivalent. 3. Compressed gas cylinders are to be transported by an approved cylinder truck or rack. '"" 4. Cylinder valve'eovefsjncl'st\be threaded in place whenever cylinders are transported or not in service: 5. Storage locations for flammable gas cylinders must be approved in advance by the PPG representiitiv~;~··· . ·- • ';\. ·!' : -~~...... ~ . v ... ~~-r K. Flammable/Combustible Liqfi.ids - Bonding/Grounding

' ,.•{~:-i'f-;.';T I. Flammable liquids must be stored inside an approval (UL or FM) metal safety can. The cai1inustbe clearly labeled to identify the contents. 2. Storage locations for flammable/combustible liquids must be reviewed with and approved by the PPG representative. 3. Bonding and/or grounding is required whenever flammable or combustible liquids are transferred p~tw~en two containers, from a pipe outlet into a container, or during liquid. agitation. Specific instructions and procedures will be reviewed by the: PPG''represeiltative, in accordance with plant SOP SAF02022. ,., .

CONTROLLED DOCUMENT IF PRINTED ON BLUE Q-IMPRINTED PAPER File: SAF02016.DOC , .. ,. GENERAL PROCEDURE

TITLE: Contractor Safety Requirements

Approved By: ID: SAF02016 Written By: Ted Huyett Page: 18 of 25 Effective Date: March 5, 1997 Revision Number: 2

L. Lead

1. Demolition or sand blasting activities which may disturb lead containing coatings must be performed in accordance with the Code of Federal Regulations 29 CFR 1926'.62. The PPG representative will notify contractor personnel of the presence of any lead containing coatings which may be disturbed by the work:being-performed.

M. Asbestos

1. Construction, demolition, maintenance, repair, or renovation activities which may disturb asbestos containing materials must be performed in accordance with the Code of Federal Regulations 29 CFR 1926.1101. Asbestos containing materials may be found in the following plant areas: ~=-

a. Plant Original Roof Flashing b. Plant Original Flaiige' & Man way Gaskets c. Fire Wall Pipe Sleeve.I;ire Stop Materials d. Resin Plant Pipe Chas~ Cement e. Cooling TowerTransiteBaffle Plates & Resin QS Lab Hood Transite Liners f. Wiring Labeled As ROCKBESTOS® g. Vinyl floor tile or linoleum floor coverings. Floor tile, linoleum, vinyl base, and carpet mastics. h. Make-up air unit vibration isolation materials. i. North tank farm aboveground-tank top coatings...... ' ·- ... ' . ~ . The PPG representati'v~ will notify contractor personnel of the presence of any asbestos containing materi~\s which may be disturbed by the work being performed. A complete inventory of asbestos containing building materials is maintained in the Safety'Department. ASBESTOS CONTAINING - MATERIALS ARE NCif'TO BE DISTURBED BY CONTRACTOR PERSONNEL. - ,,. .,,::;.-.;,.

N. Process Safety Management __ ., 1. The PPG Oa.k Creek facility is covered by the Code ofFederal Regulations 29 CFR 1910.119- Process Safety Management ofHighly Hazardous Chemicals (commonly referred_!o as the PSr-J standard). Processes covered by the PSM standard include: ·

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a. Resin Plant b. Paint Plant

i. Reactor Systems ·I-:-6 i. AP A Paint Process ii. Batch Tanks ii. Industrial Paint Process iii. 2nd Floor Meter Stations iii. Solvent Cleaning Booths iv. Cationic Stripper v. Solvent Recovery vi. Resin Storage Tanks & Cells

c. Materials d. Miscellaneous

i. Tank Farm· i Thermal Oxidizer Unit ii. Initiator Storage .. ii. Therminol Heat Transfer System (Catalyst Bunker) iii. Waste Treatment Organic Receivers

2. Process Hazards:

a. The processes listed abc,we contain flammable, combustible, corrosive, reactive, and potenti~Hy tbxic materials. These materials pose the potential for rapidly spreading fires, explosion, adverse health effects, and the release of potentially harmful materials to the environment. b. Most process tanks and vessels are blanketed with nitrogen or inert gas (a blend of oxygen free gases - primarily nitrogen, carbon dioxide, and carbon monoxide) to prevent fire/explosion. The oxygen deficient atmospheres inside these tanks/vessels 'pose a significant asphyxiation risk to anyone who places their head inside or near an open tank/vessel hatch. c. Resin processes involve the chemical change of raw materials into new chemical compounds called resin or polymers. ·The production of resin requires the use of tempe'ted water, steam, or a heat transfer fluid which is heated to 600°F.:~· ·contact with released tempered water, steam, or heat transfer fluid; or contact with exposed heating jackets or distribution piping poses the po~entialfor serious thermal bum injury . •. ,.,J' •

3. Any change to eqliipinent or utilities affecting a covered process must be managed according to plant' SOP' SAF02020 - Management of Change and Pre-Startup Safety Reviews. It is the responsibility of the contractor to notify the PPG representative before any installation change or "work in process" change is made to a covered process (installation change and "work in proces~" c~imge·a.re intellded to refer to any change to previously agreed upon installation dni\Vings, instructions, or specifications; equipment or instrumentation mO'del numbers; materials of construction; voltages; etc.).

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0. Lineffank/Vessel Opening . "c.···.'

1. The opening of any process or utility line, tank, or vessel must be coordinated with the PPG representative and must be performed in accordance with General Plant Safety SOP SAF02024 - Line/Tank/Vessel Opening.

III. Hazardous Substances

A. Hazard Communication Conipliaiice Program

1. The Occupational Safety and Health Administration (OSHA) requires that manufacturers, importers and users of hazardous chemicals inform contractors of the hazardous chemicals contractor employees may be exposed to while perforrtiing contract work. In accordance with the requirements of the OSHA Hazard Communication Standard, PPG maintains a written ·Hazard Communication Compliance Program. This document~ontains information regarding raw material and finished product labeling, hazard ass~ssment, a . ·copy of the OSHA standard, etc. The Compliance Program and a listing ofhazardous materials used at PPG is available for contractor review.

_,· B. Material Labeling ·"'• .. 1. Raw materials utilized throughout the PPG facility are labeled utilizing a hazard warning system referred to as the PPG Safety and Health Index System (SHIS). The _systefu. uses a numerical rating from 0-4 to convey relative degree_s ofhazar~fpresented by a given material in terms of health, flammability and reai:ltivl'cy .. The numerical ratings identify relative degrees of hazard ranging froill:'(>'(no hazard) to 4 (severe hazard). Specific personal protective equipment reedtnmendations are identified by a letter designation. A 20 minute video ftipe regarding the PPG Safety and Health Index System is available for contractor employee review. Contact the PPG representative for specific requests~ ,.

C. Material Safety Data Sheets (MSDS)

1. PPG maintains a complete file of material safety data sheets for all raw materials, intermediat~s and finished products. Contractor employees may review MSDS information prior to the onset of work. Contact the PPG representative for specific requests . . . . . •.• ( ·i

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TITLE: Contractor Safety Requirements

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2. Specific materials to which contractor employees may be directly exposed while performing work on-site include:

:.;- 3. The contractor must supply the PPG representative copies ofMSDS's for any hazardous material which may be.brought on-site before work is performed using the material.

Revised 9/14/98

.' .-'·*-·

..... · ··::·.·.

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Safety & Health Index

HAZARD INDEX (Chemical Identifier) 4 Severe hazard HEALTH 3 Serious hazard 2 Moderate hazard FLAMMABILITY 1 Slight hazard 0 Minimal hazard REACTIVITY * Chronic hazard PERSONAL PROTECTION (The health hazard rating for ~ this material Is based on chronic, or long-term, health hazard(s). The material may also present acute, or short­ term, health hazards.)

PERSONAL PROTECTION INDEX

A ~' F ·e +'7jS Eye hazard +~ +~ Eye/skin/lung vapor/liquid hazard

8 ~+ ~ G ·e +'7jS .. +~ +~ Eye/hand hazard ' - Eye/skin/lung dusUvapor hazard

c ~ +'7jS ·e+ H ~ +~ ~ +'t Eye/skin hazard Hazardous material with poor warning properties

X . Refer to written procedures or consult Eye/skin corrosive hazard supervisor.

Eye/skin/lung dust hazard I PPE SELECTION DEPENDS UPON CON~!!IONS ~F USE AND EXPOSURE POTENTIAL

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TITLE: Contractor Safety Requirements

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Contractor Safety Requirements Verification Checklist

Complete each section applicable to the work being performed. Detach verification checklist and forward to Security or the Safety department. Contractor to retain hard copy of Contractor Safety Requirements for reference purposes.

CHECK EACH SECTION REVIEWED

I. General

II. Specific Procedures

A. Electrical Equipment ····-·-- ... B. Welding, Cutting, Burning; Grinding, Use of Open Flame Equipment C. Confined Space Entry D. Lockout/Tagout,. E. Utilities F. Excavation, Drilling, Trenching, Floor & Wall Openings G. Elevated Work/Roof Work H. Cranes, Rigging, Overhead Lifting I. Powered Equipmen~. ·. J. Compressed Gas Cylinders ~- K. Flammable/Combustible Liquids - Bonding/Grounding L. Lead M. Asbestos N. Process Safety ~ .. ... :. ·"· · 0. Line/Tank/Vessel Opening··

III. Hazardous Materials

IV. Confidentiality Agreement

Contractor ------PPG Representative------­ Worktobeperrormed ------

I understand the Contractor Safety requirements outlined above and agree to comply with those that apply to the nature of my work.

Contractor employee name(s) ------Date ______

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Attachment 2

Coatings Oak Creek Plant

CONTRACTOR'S DAILY TIMESHEET

Job Description------­ Contractor Name------­ Blanket Release#------­ Date Work Started--::------Date Work Completed ______:_ ___

HOURS WORKED

*Materials Used:. ______

* List any adhesives, lubricants, aerosols, degreasers, cleaners, sealants, pipe compounds, etc. used while performing work.

Total Labor Hours ------'-"--...;.:_- Material Cost$------­ Contractor Name ______:. __ NTE Cost$------(PLEASE PRINT CLEARLY) Contractor Signature------

PPG Representative------(PLEASE PRINT CLEARLY)

Fonn 6665 Rev. 11/97 Original Submitted With Invoice

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TITLE: Contractor Safety Requirements

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Attachment 3 CONFIDENTIALITY AGREEMENT

As an employee of ("Supplier"), I recognize that pursuant to the relationship between Supplier and PPG Industries, Inc. ("PPG") that hires Supplier to provide services for PPG, that I will upon approval by PPG be assigned temporarily to one or more PPG facility and will gain knowledge of, or develop on behalf of PPG, information relating to products, operations and plans of PPG. In consideration of my being approved by PPG for assignment to such PPG facility and gaining access to such facility,

1. I agree (i) to use PPG Confidential Information only for the purposes of providing services to PPG; (ii) not to disclose PP~ Confidential Information without PPG's prior written consent' to any third party; and (iii) not tp allow any third party access to PPG Confidential Information. 2. The obligations of Paragraph (1) shall continue with respect to any PPG Confidential Information for a period of ten (10) years from the date of gaining access to the PPG facility. -· · '''· 3. I agree to return t6 PPG Lall PPG Confidential Information which is in my possession upon request by PPG:' · ,. ·· 4. "PPG Confidential Information" means information, both oral and written,· including documents and the inforrria~Jon· co_ntained therein, including drawings, designs, plans, specifications, requisitions, instructions, data, manuals, electronic media such as computer disks, computer progra-ms and data stored electronically, security code numbers, dial in access numbers, and tlie like, provided or disclosed to me by PPG or otherwise learned or ascertained by me. 5. PPG Confidential lriformatiori· and any rights therein shall be and remain the property of PPG. · ·· -.· .·· · ··· ·

signature

print Date:------

THE THEFT OR UNAUTHORIZED USE OF CONF-IDENTIAL INFORMATION MAY CONSTITUTE A VIOLATION OF THE ECONOMIC ESPIONAGE ACT AND/OR OTHER LAWS WITH FINES UP TO $500,000 AND IMPRISONMENT UP TO 15 YEARS. · ;<: .

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RCRA FACILITY INVESTIGATION

PPG INDUSTRIES, INC. 10800 SOUTH 13TII S1REET OAK CREEK, WISCONSIN

NOVEMBER 1992

PREPARED FOR: PPG INDUSTRIES, INC. OAK CREEK, WISCONSIN • • • PREPARED BY: WARZYNINC. MILWAUKEE, WISCONSIN

Environmental Contractor Environmental Contractor Site Safety Officer Project Manager

Environmental Contractor Corporate Health and Safety Manager PPG Industries, Inc. Health and Safety Plan Revision:O Date: November 2, 1992 Table of Contents Page 1 of 4 TABLE OF CONTENTS

1

INTRODUCTION...... :...... l-1 1.1 Key Personnel, Responsibilities, and Training ...... 1-1 1.1.1 Genera1 ...... 1-1 1.2 Personnel Roles ...... 1-2 1.2.1 Project Manager (PM) ...... 1-2 1.2.2 Health and Safety Coordinator (HSC) ...... 1-2 1.2.3 Site Safety Officer (SS0) ...... ~ ...... 1-2 1.2.4 Corporate Health and Safety Manager (HSM) ...... 1-3 1.3 J;mployee Education and Training ...... 1-3 1.3.1 Health and Safety Plan Training ...... :...... 1-4 1.3.2 Response Training ...... 1-4 1.3.3 PPG Required Training ...... 1-4 1.4 Site Description ...... 1-4 2

HAZARD EVALUATION ...... 2-1 2.1 Site Chemical Hazards ...... 2-1 2.1.1 Oxygen Deficiency ...... 2-1 2.1.2 Combustible Gas (Explos~ve Environment) ...... 2-1 2.1.3 Volatile Organic Compounds ...... 2-1 2.1.4 Hydrogen Sulfide ...... ~ ...... 2-1 2.1.5 Hydrogen Cyanide ...... ~ ...... 2-1 2.1.6 Heavy Metals ...... 2-1 2.2 Site Physical Hazru:ds ...... 2-2 2.2.1 Severe Weather ...... :...... 2-2 2.2.2 Other Weather Considerations ...... 2-2 2.2.3 Use of Heavy Equipment ...... ;2-2 3

HAZARD RISK ANALYSIS ...... 3-1 3.1 Hand-Auger Sampling ...... ;...... ~ .. 3-1 · 3.2 Sediment Sampling ...... ~ ...... 3-1 3.3 Hydraulic Probe Sampling ...... ;...... 3-2 3.4 Soil Borings and Monitoring Well Installation ...... 3-2 3.5 Monitoring Well Development, Sampling, and Aquifer Testing ...... 3-3 3.6 Concrete Coring ...... ;...... 3-3 PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: Novembec2,1992 Table of Contents 4 Page2of4

PERSONNE~ PROTECTION EQUIPMENT REQUIREMENTS ...... A-1 4.1 Personal Protective Equipment (PPE) ...... A-1 4.1.1 Level D ...... 4-1 4 .1.2 Level D Modified ...... 4-1 4.1.3 Level C ...... A-2 4.1.4 Level B ...... 4-2 5

TASK SPECIFIC HAZARD EVALUATION...... ; ...... S-1 6

AIR MONITORING AND OTiffiR FIELD EQUIPMENT ...... 6-1 6.1 PID Action Levels ...... 6-1 6.2 Explosive Atmosphere Action Levels ...... :6-2 7

TASK SPECIFIC AIR MONITORING REQUIREMENTS ...... -...... 7-1 8

DECONTAMINATIONPR.OCEDURES ...... 8-1 ·8.1 Equipment ...... ~ ...... 8-1 82 Personnel...... :.. ~ ...... 8-2 9

GENERAL HEALTH AND SAFETY PRACTICES ...... 9-1 10

MEDICAL SURVEILLANCE PROGRAM ...... 10-1 PPG Industries, Inc. Heaith and Safety Plan Revision:O Date: November2, 1992 Table of Contents 11 Page3 of 4

SI'fE CONTROL AND SECURffY...... -...... 11-1 11.1 Exclusibn Zone ...... 11-1 11.2 Decontamination Zone ...... 11-2 11.3 SupportZone...... _ ...... 11-2 11.4 Control and Securlty ...... 11-2 12

EMERGENCY RESPONSE AND CONTINGENCY PROCEDURES ...... 12-1 12.1 On-Site Communication Systern ...... •...... 12-1 12.2 Work Site Emergency Procedures ...... •...... 12-1 12.3 EmergencyEquipment ...... •....•...... 12-2 12.4 Emergency Action- Standard Operation Procedures ...... •...... 12-2 12.5 Medical Emergencies .....•...... -...... 12-2 12.6 Explosive Atmosphere ...... 12-3 12.7 General On-Site First Aid ...... •...... 12-3 13

EMERGENCY INFORMATION ...... 13-1 13.1 Emergency Routes ...... :...... •...... •...... 13-1 13.2 Driving Directions ...... ;...... •...... 13-2 14

EQUIPMENT MAINTENANCE AND CALffiRATION...... 14-1 1s··

PPG CONTRACTOR SAFETY REQUIREMENTS ...... lS-1 16

NAMES AND SIGNATURES ...... 16-1 PPCJ.Industries, Inc. Health and Safety Plan Revision: 0 Date: Novembec 2. 1992 Table of Contents Page4 of 4 LIST OF APPENDICES

Appendix A VOC Physical and Chemical Infonnation AppendixB Metals Physical and Chemical Characteristics AppendixC Severe Weather SOP Appeil.dixD Temperature Stress SOP AppendixE Decontamination and Emergency Decontamination SOP AppendixF General Site Health and Safety Rules AppendixG Emergency Response SOP AppendixH First Aid Appendix I Equipment Maintenance and Calibration AppendixJ PPG Safety and Security Standard Project Manager: To Be Determined

Health and Safety Coordinator: To Be Determined

Site Safety Officer: To Be Determined Alternate: To Be Determined

Site Manager: To Be Determined Alternate: To Be Determined

Proposed Project Start Date: To Be Determined

Personnel working at this site must meet the training and medical monitoring requirements of 29 CFR 1910.120: Hazardous Waste Operations and Emergency Response. Documentation of this training and medical surveillance should be available upon written request to the environmental contractor.

'. ~ ;·.·, PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: November 2, 1992 Section 2 Page 1 of2

2

HAZARD EvALUATION

2.1 SITE CHEMICAL HAZARDS

2.1.1 Oxygen Deficiency Based on prior iiwestigation, oxygen deficiency is not anticipated to occur during field activities. · ·

2.1.2 Combustible Gas (Explosive Environment) Due to .the volatile nature of some of the raw materials used at the site, potentially explosive atmospheres is a concern. An atmosphere of greater than 20% of the lower explosive limit (LEL) should be considered sufficient to immediately stop work.

2.1.3 Volatile Organic Compounds Volatile organic compounds (VOCs) previously identified in site soils al).d groundwater may require respiratory protection. A significant amount of past soil and groundwater analytical data is available. Appendix A, Table 1 gives physical ~- and chemical data for key site VOC contaminants previously identified during past investigations and Table 2 gives health and safety data for these compounds.

2.1.4 Hydrogen Sulfide Based on prior investigation, hydrogen sulfide is not anticipated to be present during field acti_vities.

2.1.5 Hydrogen Cyanide Based on prior investigation, hydrogen cyanide is not anticipated to be present during field activities.

2.1 .•6 Heavy Metals Heavy metals potentially present at the site pose threats to health if site personnel come in contact with them. Table 3 (Appendix B) gives chemical and health data for key heavy metals to be analyzed. PPG Industries, Inc. Health and Safety Plan Revision:O Date: November 2, 1992 Section 2 Page 2 of2

2.2 SITE PHYSICAL HAZARDS

2.2.1 Severe Weather Weather conditions on-site cannot be controlled. Site personnel are to be aware of the warnings of impending severe weather and the precautions that are to be taken when severe weather threatens. Refer to Appendix C of this Site Health and Safety Plan for Severe Weather Standard Operating Procedures (SOP).

2.2.2 Other Weather Considerations Working in hot or cold weather requires special health and safety considerations .. Appendix D to this plan, Temperature Stress SOP, describes symptoms of temperature stress and responses to emergencies due to heat or cold exposure.

2.2.3 Use of Heavy Equipment Activity around, and use of, heavy equipment presents hazards to site personnel. Personnel must engage in standard safe operating procedures in the operation of heavy equipment.. Only personnel actively involved in associated operations should be in th~ immediate vicinity of the hydraulic probe system or drill rig. Use caution when working around heavy equipment; a hard hat, safety glasses with side shields, and steel-.toed boots should be worn within a 50-foot radius of heavy equipment. Hearing protection should be worn as necessary around operating heavy equipment. Generally, if you cannot be heard by a person three feet from you when you are speaking in a normal conversation level, hearing protection is .to be worn. PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: Novembec2, 1992 Section 3 Page 1 of3

3

HAZARD RISK ANALYSIS

3.1 HAND-AUGER SAMPLING

Hazard Precautions

Contaminated soil/air Inhalation, skin Gloves, protective clothing, emissions from VOCs contact decon, real-time monitoring, and heavy metals respirators available

Utility contact ExplosioQ, fire, Pre-sampling utility location electrocution

3.2 SEDIMENT SAMPLING

Hazard Precautions

.Contaminated soil/$' Inhalation, skin Gloves, protective clothing, emissions from VOCs contact decon, real-time monitoring, and heavy metals respirators available

Utility contact Explosion, frre, · Pre-:-sampling utility electrocution location PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: November 2, 1992 Sedion3 Page2of3

3.3 HYDRAULIC PROBE SAMPLING

Hazard Risk Precautions

Contaminated soil/air Inhalation, skin Gloves, protective clothing, emissions from VOCs contact decon, real-time monitoring, and heavy metals respirators available, containment of samples and waste

Hazard Precautions ' Noise Hearing loss, Hearing protection communication interference

Operation of heavy Physical injury Hard hat, safety glasses, equipment steel-to~ boots, first-aid kit available, only qualified personnel in immediate vicinity of work area

Utility contact Explosion, fire, Pre-drilling utility electrocution location

3.4 SOIL BORINGS AND MONITORING WELL INSTALLATION

Hazard Precautions

Operation of Physical injury Hard hat, safety glasses, drilling/support steel-toed boots, first-aid equipment kit available, only qualified personnel in immediate vicinity of work area

Con-taminated soil, Inhalation, skin Gloves, protective clothing, and water/emissions contact decon, real-time monitoring, respirators available

Noise Hearing loss, Hearing protection communication interference PPG Industries, Inc. Health and Safety Plan Revision:O Date: November 2, 1992 Section 3 Page3 of3

Utility contact Explosion, fire, Pre-drilling utility electrocution location

3.5 MONITORING WELL DEVELOPMENT, SAMPLING, AND AQUIFER TESTING

Hazard Precautions

Contaminated water, Inhalation, skin Gloves, protective clothing, soil/emissions contact decon, respirator available, containeriZe samples and waste

3.6 CONCRETE CORING

Hazard Risk Precautions Operation of heavy Physical injury Hard hat, safety glasses, steel-toed equipment boots, first aid kit available, only qualified personnel in immediate vicinity of work area PPG Industries, Inc. Health and Safety Plan Revision:O Date: November2, 1992 Section 4 Page 1 of3

4

PERSONNEL PROTECTION EQUIPMENT REQUIREMENTS

Personnel performing active site duties must use the appropriate ensemble of personal protective equipment, unless performing- oversight duties from upwind support areas. Changes in levels of protection may be initiated by the SSO, but downgrades in level of protection must involve consultation with the Health and Safety Coordinator (HSC). ·

4.1 PERSONAL PROTECTIVE EQUIPMENT (PPE)

4.1.1 Level D Level D is to be worn during activities which do not suggest any initial respiratory or dermal he~lth hazards. The following list outlines the personal protective equipment to be utilized for Level D:

Required PPE: • Steel-toe/steel-shank work boots or steel-toe/steel-shank neoprene boots • Work uniform • Eye protection (safety glasses and side shields, with or without face shield) • ·Hard hat

Optional PPE - Use as needed: • Hearing protection

4~1.2 Level D Modified . Level D modified is to be worn during activities which do not suggest any initial respiratory hazards, but where dermal protection is warranted. The following outlines this level of protection:

Required PPE: • Steel-toe/steel-shank work boots with latex overboots or steel-toe/steel­ shank neoprene boots • Polyethylene-coated Tyvek® coveralls PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: November 2, 1992 Section 4 Page2of3

• Neoprene outer gloves • Surgical inner gloves • Hard hat • Eye protection (safety glasses and side shields, with or without faceshield)

Optionai PPE - Use as needed: • Hearing protection

4.1.3 Level C Level C should be worn when the criteria for using air-purifying respirators are '!€ met, and a higher level of skin protection is needed. The following outlines this level of protection:

Required PPE: • Steel-:-toe/steel-shank work boots with latex overboots or steel-toe/steel- shank neoprene boots • Polyethylene-coated Tyvek® coveralls • Neoprene outer gloves • Surgical inner gloves • Full-facepiece air-purifying respirator • Combination organic vapor/acid gas/particulate respirator cartridges • Hard hat

Optional PPE -Use as needed: • Hearing protection

4.1.4 Level B Level B protection is worn when the highest level of respiratory protection is needed and higher level of skin protection is required. Level B is the primary level of choice when encountering unknown environments.

Required PPE: • Steel-toe/steel-shank work boots with latex overboots or steel-toe/steel- shank neoprene boots • Polyethylene-coated Tyvek® coveralls • Silver Shield® outer gloves • Vinyl inner gloves PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: Novembec2, 1992 Section 4 Page 3 of 3

• Positive-pressure/pressure-demand self-contained breathing apparatus (SCBA), or airline respirator • Hard hat

Optional PPE - Use as needed • Hearing protection PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: November2, 1992 SectionS Page I of2

5

TASK SPECIFIC HAZARD EVALUATION

Concrete Coring Entry - Level D modified Upgrade - Level C

Sediment Sampling Entry - Level D modified Upgrade - Level C

Soil Sampling with a Hand-Auger Entry - Level D modified ; Upgrade - Level C, Level B

Soil and Groundwater Sampling with Hydraulic Probe System Entry - Level D Upgrade - Level D modified, Level C, Level B

Soil.Borings and Monitoring Well Installation Entry - Level D modified· Upgrade - Level C, Level B

Monitoring Well Development, Sampling, and Aquifer Testing Entry - Level D modified Upgrade - Level C

The Level of Personal Protective Equipment .(PPE) shall be upgraded or downgraded based upon a change in site conditions or findings of investigations. When a significant change in site conditions occurs, the hazards should be reassessed. Changes in levels of protection may be initiated by the SSO, but downgrades in the level of protection must involve consultation with the HSC. Some indicators of the need for reassessment are: PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: November2, 1992 Section 5 Page2of2

• Commencement of a new work phase, such as the start of a significantly different sampling activity, or work that begins on a different portion of the site

• Change in job tasks during a work phase

• Change of season/weather

• Temperature extremes or individual medical considerations which limit the effectiveness of PPE

• Contaminants other than those previously identified are encountered

• Change in ambient levels of airborne contaminants

• Change in wor~ scope which effects the degree of impacted media PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: November 2, 1992 Section 6 Page 1 of 2

6

AIR MONITORING AND OTHER FIELD EQUIPMENT

Required equipment includes:

• Organic Vapor Detector with a 11.7 eV lamp • Combustible gas indicator (e.g., Exotox, Gastechtor, Industrial Scientific Multi-Gas meter)

6.1 PID ACTION LEVELS

Readings upon which PID action levels are based are those taken in the worker breathing zone; i.e., within a foot of the head of the worker closest to a source of contamination during normal activities. Readings to be considered should be persistent rather than instantaneous maximum values. Initial action levels are based on the hazards posed by compounds identified during past soil and groundwater investigations and are a "worse case" approach. However, this is most likely not the case of the site. As both field-screening and laboratory analytical results are received, the SSO should re-evaluate PID action levels based on this new information.

PID: Readings at or below background concentration - Level D or Level D modified

Readings greater than background concentration, but less than or equal to 5 i!lstrument units over background - Level C

Readings greater than 5 instrument units over background concentration, but less than 50 instrument units - Level B

Readings greater than 50 instrument units- Depart from the immediate area and contact PM and HSC PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: Novembet-2, 1992 Section 6 Page2of2

6.2 EXPLOSIVE ATMOSPHERE ACTION LEVELS

Readings upon which explosive atmosphere action levels are based are those taken throughout the work zone. Readings to be considered should be any instantaneous maximum value and not a persistent reading. Due to the nature of the PPG production operation, the presence of an explosive atmosphere may be due to a manufacturing-type operation and not from subsurface-disruption of impacted soil. For this reason, there will be no smoking on the PPG property except in designated areas. Care should be taken to minimize or eliminate any activity which could generate a spark.

Combustible gas indicator:

Readings of 0 to 1.0% LEL- Continue working and monitor work zone atmosphere for combustible gases. Inform personnel working in area whenever readings exceed 5% LEL.

Readings of 10 to 20% LEL- Continue working with

Readings >20% LEL - Cease operations and move to safe area. Re-evaluate work plan. Engineering controls such as forced ventilation may need to be implemented. Do not continue working until conditions are consistently below 20% LEL. PPG Industries, Inc. Health and Safety Plan Revision: 0 Date: November 2, I992 Section 7 Page I of I

7

TASK SPECIFIC AIR MONITORING REQUIREMENTS

Concrete Coring

• Organic Vapor Detector • Combustible Gas Indicator

Hand-Auger Sampling ·

• Organic Vapor Detector • Combustible Gas Indicator

Sediment Sampling

• Organic Vapor Detector

Hydraulic Probe· Sampling

• Organic Vapor Detector • Combustible Gas Indicator

Soil Borings and Monitoring Well Installation

• Organic Vapor Detector • Combustible Gas Indicator

":>i: Monitoring Well Development, Sampling and Aquifer Testing

• Organic Vapor Detector • Combustible Gas Indicator for wells where an LEL >0% was identified during installation :::: ·~ ~ ~ e.~ ~ a...... :.:~ !:::! ~

~ !:::! -.::::: .~ ~ WARZYN

PROJECT 20023101

WORK PLAN DOCUMENTS VOLUME II OF ill QUALITY As-suRANCE PROJECT PLAN ·FIELD SAMPLING1>LAN

RCRA FACILITY INVESTIGATION

PPG INDUSTRIES, INC. 10800 SOUTH 13TH STREET OAK CREEK, WISCONSIN

JANUARY 1994

PREPARED FOR: ·­ ppQ INDUSTRIES, INC. OAK CREEK, ~WISCONSIN ••• PREPARED BY: WARZYNINC. CHICAGO, iiJ:iNbiS . No.J_oflJ_ Quality Assurance Project Plan Revision: I Dat~: January 28. !994 Table of Contents Page I of 5 TABLE OF CONTENTS

LIST OF ACRONYMS AND ABBREVIATIONS

1

PROJECT DESCRIPTION...... ~ ...... l-1 1.1 Introduction, ...... 1-1 1.2 Site Description ...... ~ ...... ;...... 1-2 1~2.1 Facility Description ...... 1-2

·1.2.2 Site Topography and Drainag~ ..... n ...... ,...... 1-3 1.2.3 Geology and Hydrogeology ...... ·...... ~ ...... 1-3 1.3 Site Background ...... 1-5 1.3.1 Site History ...... , ...... 1-5 1.3.2 Previous Investigations ...... ;...... 1-6 1.3.3 Permit Conditions ...... :...... 1-6 1.3.4 Target Compounds ...... :.: ..- ..... , ...... 1-6 -1.3.4.a Historical Records ...... ,...... ,... 1-7 1.3.4.b Investigation Results ...... ~ ...... , ...... 1-7 1.3.4.c Target Parameter List Selection ..... , ...... :...... ;.... ;...... 1-11 1.4 Project Objectives and Scope ...... 1•12 1.5 Sample Network Design and Rationale ...... ;...... 1-13 1.6 Parameters to be Tested and Freq~ency .. ;...... ~ ...... :...... 1-13 1.7 Intended Data Usage and Data Quality Objectives ...... 1-13 1.8 Project Schedule ...... :...... ,...... ~ ...... 1-15 ~. 2

. PROJECT ORGANIZATION AND RESPQNSIBILITY...... :...... 2-1 2.1 Overall Responsibility ...... 2-1 '2.2 Specialized Responsib_ilities ...... 2-4 2.2.1 Monitoring and Sampling Operations and QC ...... ;: ...... 2-4 2.2.2 Laboratory Analysis ...... ;...... , ...... 2-4 2.2.3 Laboratory Data and QC...... :...... ;2-6 2.2.4 Performance and Systems Audits ...... 2-6 3

. QUALITY ASSURANCEOBJECTIVES FOR MEASUREMENT DATA...... 3-1 3.1 Level of Quality Control Effort...... ;... ,.... :...... ,...... 3-1 3.2 Accuracy, Precision, and Sensitivity of Analyses ...... ;...... 3-2 Qualny Assurance Project Plan Revision: I Date: January 28, 1994 Table of Contents · Page 2of5

3.3 Completeness, Representativeness, and Comparability ...... 3-3

4

SAMPLING PROCEDURES ...... 4-1 . 4.1 Bottle Requirements ...... _...... 4-1 5

SAMPLE CUSTODY AND DOCUMENTATION...... S-1 .5.1 Field Specific Custody Procedures ...... :...... 5-1 5 .1.1 Initiation of Chain-of-Custody Field Procedures ...... 5-1 5.1.2 Field Logbooks/Documentation ...... S-2 5.1.3 Transfer of Custody and Shipment Procedures ...... 5-3 5.2 Laboratory Chain-of-Custody Procedures ...... :...... ~ ...... S-4 5.3 Final Evidence File Custody Procedure ...... 5-4 6

, CALffiRATION PROCEDURES AND FREQUENCY...... 6-1 6.1 Fiel

7

ANALYTICAL PROCEDURES ...... 7-1 7.1 Field Screening An3lytical Protocols ...... ~ ...... :...... 7-..1 7 2 Laboratory Analysis ...... : ...... ~ ...... _ ...... 7-1 8

INTERNAL QU.ALITY CONTROL CHECKS ...... , ...... S-1 8.1 Field Sample Collection ...... '.8-i 8.2 Field Measurements ...... 8-1 · 8.3 Laboratory Analysis ...... :...... _...... ~.! ... .-:...... 8-1 (Juahty Assurance Project Plan Revision: I Date: January 28, 1994 Table of Contents Page 3 of5 9.

DATA REDUCTION, VALIDATION, AND REPORTING ...... 9-1 9.1 Field Measurements and Sample Collection ...... 9-1 9.2 Laboratory Services ...... 9-1 9.2.1 . ,Data Reduction ...... :...... 9-1 9.2.2 Data Validation ...... ;...... 9-3 9.2.3 Data Reporting ...... 9-4 10

PERFORMANCE AND SYSTEM AUDITS ...... lQ-1, 10.1 Field Audits ...... ~ ...... ,...... 10-1 10.1.1 Internal Audits ...... : ...... 10-1 10.1.2 .External AuditS ...... 10-1 _10.2 Laboratory Audits ...... ,...... 10-1 10.2.1 Internal Audits .... .-...... ·10-1 10.2.2 External Audits ...... 10-2 11

. PREVENTATIVE MAINTENANCE ...... -...... "...... Il-l 11.1 Field lnstnJments/Equipment...... :...... 11-1 11.2 Laboratory Instruments ...... :...... 11-1 12

···- SPECIFIC ROUTINE PROCEDURES USED TO ASSESS . ::---:· ~. DATA PRECISION, ACCURACY, AND COMPLETENESS ...... 12-1 12.1 Field Measurenlents ...... ;...... :...... 12-1 12.2 Laboratory Data ...... :~ ...... :...... 12-1 12.2.1 Precision ...... "...... ;...... 12-1 12.2.2 Ac~cy ...... ~ ...... 12~2 12.2.3 , Completeness ...... :~ ...... 12-2 12.2.4 Sensitivity ... - ...... 12~2 13

CORRECTIVE ACTION ...... ;...... 13-l 13.1 Sample Collection/Field Measurements ...... 13-l 13.2 Laboratory Analysis ...... :...... -...... 13-3 Quain y Assurance Project Plan Revision: I Date: January 28, 1994 Tabk of Contents Page 4 of 5

14

.QUALITY ASSURANCE REPORTS TO MANAGEMENT...... 14-1

LIST OF TABLES

Table 1-1 'Sample Type and Estimated Sample Numbers Table 1-2 Sample Quantities, Containers, Preservatives, and Packaging RequirementS Table 1-3 Summary of Data Generating Activities and Associated Data Quality Objectives Table 1-4 Project Schedule . _ , Table 3-1 Volatile Organic Compound Target List and Practical Quantification Ljmits Table 3-2 Semi-Volatile Organic Compound Target List and Practical Quantification Limits ·Table 3-3 Inorganic Target List and Practical Quantification Limits Table 3-4 Physical Characteristics and Field Measurements Parameter Lists and Required Detection Limits · · · Table 3-5 Summary of Quality Control Requirements Table 7-1 Summary of Analytical Methods Table 11-1 Routine Preventative Maintenance Procedure~) and ScJ:Iedules

LIST OF FIGURES

Figure 1 Site Location Map Figure 2 Plat Map Figure 3 ZQningMap Figure4 Site Features Map Figure 5 RFI Project Organization Chart Figure6 Soil Boring and Monitoring Well Location Map

LIST OF APPENDICES

Appendix A Analytical Services Standard Operating Procedures (SOPs)

Appendix B Field Measurement SOPs B-1 pH. B-2 Conductivity and Temperature

Appendix C Laboratory Custody SOPs c..:1 Wadsworth C)lain-of-Custody C-2 Warzyn Chain-of-Custody · C-3 Internal Field Audit Checklist LIST OF ACRONYMS AND ABBREVIATIONS

AOC Area of Concern , ARAR Applicable or Relevant and Appropriate Req!_Iirements AST Aboveground Storage Tank ASTM American Standards for Testing Materials- COO Central District Office CMS Corrective Measures Study CRDL Contract Required Detection Limits CRQL Contract Required Quantitation Limits CRL Central Regional Laboratory DQO Data Quality Objective FSP Field Sampling Plan GC Gas Chromatography _ HSP Site Specific Health and Safety Plan ITL Inorganic Target List LSSS Laboratory Scientific Suppbrt Section - Reg. V . MS/MSD ·Matrix Spike/Matrix Spike Duplicate OTL Organic Target List PMP Project Man~gement Plan .. : .· . . : PPG PPG Industries, Inc 4il~·:2.~-:~-:- : QA:- Quality-Assurance QAO __ . Quality Assurance Officer QAPP?: Quality Assurance Project Plan ·;_'::_~~~-.i.::·~­ -:.~--=----:..::.: ...... -:.~·~:.: ._ QAS; _ Quality Assurance Section ~------i.l.------_...., __ _ --t~-~~:-~l~~: . :_. ~- ·:~ ~ . · QC :· - Quality Control RFA RCRA Facility Assessment .. RFI RCRA Facility Investigation :::..:...;.....:.:.:::·.... ,...... -... --·· .. ~~·=~;~ · RPD --,. Relative Percent Difference · ~- r i:. i.,. ,,,_ · RPW - Remedial Permit Writer RCRA Resource Conservation and Recovery Act ------~--:. ____ SW-846 Test Methods for Evaluating Solid Waste ·· SWMU Solid Waste Management Unit " SOP Standard Operating Procedure TIC Tentatively Identified Compound , U.S. EPA· United States EnVironmental Protection Agency, Region V UST Underground Storage Tank -VOA Volatile Organic Analysis VOC Volatile Organic Compound W arzyn W arzyn Inc. : WDNR Wisconsin Department •of Natural Resources WPDES Wisconsin Pollutant Discharge Elimination System vuatny Assurance l'rOj('Ct Plan Revision: I Date: January 28. 1994 Section 3 Page I of 4

3

QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT DATA

The overall QA objective is to develop and implement procedures for field sampling, chain-of-custody, laboratory analysis, and .reporting that will provide documentable, reproducabl~ and accurate results. Specific procedures for sampling, chain-of-custody, laboratory instruments calibration, laboratory analysis, reporting of data, internal quality control, audits, preventive maintenance of field equipment, and _corrective action are described in other sections of this QAPP. The purpose of this .section is to address the specific objectives for accuracy, preCision, completeness,. representativeness, and comparability. '- . .

3.1 LEVEL OF QUALITY CONTROL EFFORT

The QA objectives for precision, accuracy, and ·sensitivity are to achieve the QC acceptance ~riteria for -the proposed analytical procedures. For thy organic and inorganic procedures, the precision and accuracy guideline requirements are specified in the SOPs provided in Appendices A. · ·

·' Required field blank, trip .blank, field duplicate, and matrix spike samples will be analyzed to assess the quality of the data resulting from the field sampling program. Field and trip blanks c()nsisting of deionized water.stored in po~yethylene containers, will be submitted along with aqueous samples to the analytical laboratories to provide the means to assess the quality of the data resulting from the field sampling progr_am. Field ~lank samples are analyzed to check for procedural contamin(!.tion at the site which may cause sample contamination. Trip blanks are used to assess the potential for contamination of samples by volatile org~nic compounds due to contaminant migration dtJring sample shipment and storage. Duplicate samples are analyzed to check ·for sampling and analytical reproducibility. Matrix spikes provide information about the effect of the sample matrix on the digestion and measurement methodology. All matrix· spikes are performed in duplicate and are here-in.:after referred to as matrix spike/matrix spike duplicate (MS/MSD) samples. MS/MSD samples are \,('U<.lH\) r\.'l.'IWdll"-C r·IU_t<.:'\.' t l•UI Reva"on: I Oat~: January 2!!. 199-1 S.:claon3 Page 2 of -1

not designated/collected for DQO Level 3 analyses but are assigned by the · laboratory. One MS/MSJ? sample will be assigned for every 20 or fewer investigative samples per sample matrix.

The number of field duplicate and field blank samples to be collected for this site are_listed in Table 1-1. Sampling procedures are specified in the FSP.

The general level of the QC effort will be one field duplicate for every 10 or fewer . . investigative samples. One field blank will be prepared and analyzec!_ for every 10 or fewer investigative aqueous samples. One volatile organic analysis (VOA) trip blank consisting of deionized, ultra pure \Yater, will be included along with each shipment of aqueous VOA samples.

The level of QC effort for soil and groundwater samples sent to one-of the laboratories listed in Section 2.2.2 for analysis is specified in the analytical SOP presented in Appendix A. Parameter lists and· required quantitation levels are summarized in Tables 3-1, 3-2, 3-3, and 3-4. Method references are summarized in.Table 'J-1.

The. level of laboratory QC effort for field measurements ar~ specified in the SOPs presented in Appendix C and summarized in Table 3.-5.

3.2 ACCURACY, PRECISION, AND SENSITIVITY OF ANALYSES

The fundamental QA objective with respect to accuracy, precision, and sensitivity of laboratory analytical data is to 'achieve the QC acceptance criteria of the analytical protocols.

Organics/Inorganics ·Laboratory analysis of volatile and semi-volatile will follow the methods referenced in Table 7-1. The accuracy and precision, requirements are · summarized in Table 3-5. Sensitivity requirements are summarized in Tables 3-1 and 3-2. SOPs are provided in Appendix A.

Laboratory analysis of inorganics will follow the methods referenced in Table 7-.1. The ac.ctiracy and precision, requirements are summarized in Table 3-5. Sensitivity require~ents are summarized in Table 3-3. SOPs are provided in Appendix A. vua1uy ASsuranc~ Project Plan Revision: I Date: January 28. 1994 Section 3 Page 3 of 4

Physical Characteristics Physical characteristics of grain size distribution, moisture content, and percent _ organic carbon will follow the methods referenced in Table 7-1. SOPs for the ·physical characteristics are provided in Appendix B. The accuracy and precision requirements for these analyses are summarized in Table 3-5. Sensitivity requirements are summarized in Table 3-4.

Field Measurements Field measurements of pH, condpctivity, and temperature will follow.the methods referenced in Table 7-1. SOPs for the field equipment are provided in Appendix C. The !lccuracy and precision requirements of these analyses are summarized in Table 3-5. The sensitivity requirements of these analyses are summarized in Table 3-4. ,

3.3 COMPLETENESS, REPRESENTA TIVENE~S, AND COMPARABILITY

Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under normal conditions. It is expected that the participating laboratories will provide data meeting QC acceptance criteria for 90 percent or more for all samples tested using the methods and SOPs referenced in Section 3.2. Following c9mpletion <;>f the analytical testing, the percent completeness will be calculated by the following equation:

Completeness(%)= NB x 100

where, A = number of valid data . B = number of samples anticipated for each parameter

Representativeness expresses the degree to which data _accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental comlition. Representativeness is a.· qualitative parameter which is dependent upon the proper design, of the sampling program and upon proper laboratory protocol. The sampling network was designed to provide data representative of site conditions\ The rationale of the sampling network is discussed in detail in th~ FSP. Representativeness will be satisfied by insuring that the FSP is followed, proper sampling techniques are used, proper analytical procedures are followed, and holding times of the samples vuatny ASSUiancc riUJCI...I f"I.&U Revisaon: I Date: January 28. 1994 Section 3 Page 4 of 4 are not exceeded in the laboratory. Representativeness will be assessed by the analysis of field duplicate samples.

Comparability expresses the confidence with which one d.ata set ~an be compared with another. The extent to wbich existing and planned analytical data will be comparable, depends on the similarity of sampling and analytical methods. The procedures used to obtain the planned analytical data, as documented in the QAPP, are expected to provide· comparable data These new analytical data may not be directly compa~able to all existing data generated outside of this RFI because of differences in procedures and QA objectives. R~vision: I Dat~: January 28. 1994 Section-! Page I of I

4

SAMPLING PROCEDURES

Sampling procedures are described in the FSP which is provided in Volume II of the RFI Work Plan. ·

4.1 BOTTLE REQUIREMENTS

The contaminant-tree sample containers (bottles) used for analyzing organics and in organics will be prepared consistent with the procedures specified, in U.S: EPA's Specifications and Guidance for Obtaining Contaminant-Free Sample Containers, April1990. use of these procedures will aSSUre that the bottles used 'for the sampling activity do not contain contarili.nants exceeding the level specified in the above-mentioned document.

In addition, the data for fieid blanks and trip blanks will be monitored for contamination, ana corrective ac~ions will be taken as soon as practical after a . problem is identified. Problems with contaminated potties generally are not apparent until the analytical data is validated. Corrective action is taken by qualifying the results using the procedures specified for validation (see section 9.2.2) and notifying the Environmental Contractor Project Manager. Quaht y Assurance ProJeCt Plan Revision: I Date: January 28. 1994 Section: 9 Page I of 4

9

I I DATA REDUCTION,

VALIDATION, -AND REPORTING --­·~.

Required deliverables and validation procedures vary depending upon the DQO level. of the sample analysis. Table 1-3 provides a summary of data generating activities, intended data uses, and associated DQOs for the site.

9.1 FIELD MEASUREMENTS AND SAMPLE COLLECTION

Raw data from field measurements and sample collection activities will be appropriately re~orded in the field l

9.2 LABORATORY SERVICES

9.2.1 Data Reduction Each laboratory is responsible for identification, quantification, data reporting, and data deliverables for the analyses performed. Data reduction and deliverables_ of volatile, semi-volatile and inorganic data will follow.the requirements set forth 'in SW-846.

R'equired deliverables are determined by 'the Data QualitY Objective (DQO) Level. The DQO, and-thus the ~equired deliverables for samples, are presented in Table 1-3. Required deliverables are summarized as follows: , ¥

• Level 4- Analytical results, QC ~um~ary Package,_ Raw Data Packages.

• Modified Level4'" Analytical results, QC Summary Package, Raw Data Packages. \,IUallt y Assurance ProJeCt !'I an Revision: I Date: January 28. 1994 Section: 9 Page 2 of 4

Analytical Results - The sample report, which consists of tabulated results ·of ' . appropriate analytical parameters including detection limits, and reported concentrations for all detected parameters.

QC Sum'mary package - A summary of all qu~lity control results related to the analysis, including: /

• Narrative including statement of samples received, description of any deviations from standard procedures, explanation of qualifications regarding data quality, and any other significant problems encountered during analysis

• A QA/QC report including; • surrogate spike results for each sample • matrix spike and matrix spike duplicate results · • method blank results • initial and continuing calibration checks • instrument tuning and performance summaries

' • Field ~nd laboratory chain.:of-custody documentation pertaining to each sample delivery group ana]yzed, including, but not limited to, copies of the chain-of-custody forms

Raw Data Package- The. data package includes printouts (or legible copies) of appropriate data for samples, blanks, initial and continuing calibration standards, _and QC samples. Depending on the analytical method (GC, GCMS, ICP/AA), appropriate data will include, but are not limited to:

• chromatograms or reconstructed ion chromatograms · • quantitation reporis ' • m~s spectra • analyst bench sheets and calculation worksheets . . Field Data - Data reduction for level 2 results (physical parameters and GC field 1 screening volatiles) will follow the req~irements set forth in Appendix B• Data deliverables for physical parameters will include tabula~d results.

'9.2.2 Data Validation The need for data validation is determined by the DQO, as presented ih Table 1-3.

•· Level4- Validation of QC Summary Package and 10% of Raw Data Package ()uallly Assuranc~ Pro,l'=ct l'ldn Rev1s1on: I Date: Januar~ 28. 199-1 ~.._·ctinn: 9 . Pa;!c 3 of -1

• Modified Level4- Validation of QC Summary Package only • Level3- Validation ofQC Summary Packa&e only

Ten percent of the Level IV data will be completely validated. For all Level IV data, the QC summaries will be reviewed and blank contaminants qualified. Level IT and III data will not be validated.

Data Validation of QC Summary Package and Raw Data Package- Validation provides a systematic review of the analytical data for compliance with the QC criteria set forth in the method SOP based on the calibration, spike, duplicate, blank, and sample raw data and results provided by the laboratory. The data validation procedure will identify any out of control data points, an~ data omissions or errors.

Data Validation of QC Summary Package Only- Validation provides a systematic evaluation of the calibration; spike,. duplicate, and blank results provided in the QC Summary Package for compliance with the QC criteria set forth in the m~thod SOP. Raw data is not evaluated. The data review procedure will identify any out of control data points ..

For data validation, results are qualified to indicate whether the data are: 1) usable as a quantitative concentration, 2) usable with caution as an estimated concentration, or 3) unusable due to out of control QC results.

Organics data generated under a DQO level of 3 or 4 will be validated by the Environmental Contractor technical staff. Validation as described above will be consiste~t with U.S. EPAs Nationa!Functions Guidelines for Original. Data Review, June 1991. Project specific QC limits, included in the SOPs in Appendix B, will be substituted for CLP-SOW limits where presen,ted in the Guidelines. Analytical hold times are specified in Table 1-2. ·

Inorganic data generated tinqer a DQO level ~f 3 or 4 will be validated 'by the Environmental <;::ontractor technical staff. Validation as described above will be consistent with U.S. EPA, Laborat01y Data Validation Functional Guidelines for Evaluating Inorganics Analyses, July 1988. Project specifi~ QC limits, included in the SOPs in Appendix B, will be substituted for CLP-SOW limits where presented in the Guidelines. Analytical hold times are specified in Table i-2.

Groundwater screening GC volatile organics generated under a DQO level of 2 will be reviewed to ensure procedures were followed and QC requirements were met. Qualuy As.,urance Project Plan Revision: I Date: January 28. '1994 Section: 9 Page 4 of 4

Physical characteristic data (DQO level 2) will be reviewed .as described above to ensure procedures were followed and QC requirements were met.

9.2.3 Data Reporting Analytical data generated for the PPG-Oak Creek facility will be computerized in . a fo~mat organized to facilitate data review and evaluation. The computerized data set will include the data qualifiers provided by the performing laboratory as well as qualifiers added by the data reviewer in accordance with the data validation procedures noted in Section 9.2.2 of this QAPP.

The laboratory-provided qualifiers will include,

• non-detects • concentration ~elow required detection limit • . estimated concentration • concentration of chemical also found in the laboratory blank.

The data validation qualifiers will indicate whether .the data arer

• usable as a quantitative concentration • usable with caution as an estimated concentration • unusable due to out-of-control QC results.

A summary of the validated data will be incorporated into the RFI report. \JUallt)' AssUfAOCe t'rO_Ject t'lan Revision: I Date: January 28, 1994 Section 5 Page I of 4

5

SAMPLE CUSTODY AND DOCUMENTATION t

sample custody, or chain-of-custody protocol~ described wm be consistent with NEIC Policies and Procedures, EPA-330/9-78-DDI-R, Revised June 1985. This custody is in tliree parts: sample collection, laboratory analysis, and final f evidence files. Final evidence files, including all originals of laboratory reports and purge files, are maintained under document control in a secure area.

5.1 FIELD SPECIFIC CUSTODY PROCEDURES ... . . The sample packaging and s_hipment procedures summarized below will insure _;.::,_·:-~.- ··. that the samples will arrive at the laboratory with the chain of custody in~ct. The ~,:. .- -·- protocol for sample designations are included in the FSP, Appendix A of this ~~:;r-t.~·-,:: __ •.-.4.·:;::::.:.::::._._ _ QAPP.

.:~-;~t;::;~" =~:::-::.:_ :.:::..__ .: ~~:~--- :: .~': u .~~~-;;_?};!;:.:.::. ··-..-~ :··; :· 5.1.1 Initiation of Chain-of-Custody Field Procedures A designated field sampler will be personally responsible for the care and custody of the samples until they are transferred or properly dispatched to the laboratory. As few people as possible will handle the samples. / . - . Bottles will be tagged.with sample numbers and locations. Sample tags will be completed for each sample using waterproof ink unless prohibited by weather conditions. For example, a logbook notation would explain that a pencil was used to fill out the sample tag because the ballpoint pen would not function in freezing weather. ·

The RPW will review aU field activities to determine whether proper custody procedures were followed during the field work and decide if additionaJ samples are required. I..'Uallt) ASsurance rTOJCCl t'lan . Revision: I Da1e: January 28,'1994 Section 5 Page 2 of 4

5.1.2 Field Logbooks/Documentation Field logbooks will provide the means of recording the data collection activities performed. As such, entries will be described in the detail so that persons going to the site could re-construct a particular situation without reliance on memory.

Field logbooks will be bound field survey books or notebooks. Logbooks will be assigned to field personnel, but will be stored in the document control center when not in use. Each logbook will be identified by the proJ'ect-specific document number.

The title page of each logbook will contain the following:

.• person to whom the iogbook is assigned . · • logbook number • project name • project start date

Entries into the logbook will con~ a variety of information. At the beginning of each entry, the date, start time, weather, names of all sampling team members present, level of persqnal protection being used, and the signature of the person making the entry will be entered. The names of visitors to the site, field sampling - or investigation team personnel, and the purpose of their visit will. be recorded in ·.thefield logbook. .

Measurements made and samples collected will be recorded. All entries will be made in ink, and no erasures will be made. If an incorrect entry is made, the information will be crossed out with a single strike mark, and initialed and dated , by that person. Whenever .a sample is collected or a measurement is made, a detailed description of the location of the station~ which includes compass and distance measurements, shall be recorded. The number of the photographs taken of the station, if any. will also. be noted. All equipment used to make measurements will be identified, al'ong with the date of calibration.

Samples will be collected following the sampling procedures documented in the FSP. The equipment used to collect samples will be noted, along with the time of sampling, sample description, depth at,which the sample was collected, volume, and number of containers. A sample identification 'number will be assigneQ prior to sample collection. Field duplicate samples, which will receive an entirely separate sample identification number, will be noted under sample description. (Jualn y Assurance ProJ~Cl Plan Revision: I Date: January 28, 1994 SectionS Page 3 of 4

5.1.3 Transfer of Custody and Shipment Procedures Samples will be accompanied by a properly completed chain-of-custody form. The sample numbers and locations will be listed on the chain-of-custody form. When transferring the possession of samples, the individuals relinquishing and receiv,ing will sign; date, and note the time on the record. This record will document transfer of custody of the samples from the sampler to another person, to a mobile laboratory, to the permanent laboratory, or to/from a secure storage area. t " Samples will be properly packaged for shipment and dispatched to the appropriate laboratory for analysis, with a separate signed custody record enclosed in each sample box or cooler. Shipping containers will be locked and secured with strapping tape and custody seals for shipment to the laboratory. The procedure will include the use of a ·custody seal attache<;! to the front right and back left of the cooler. The custody seals will be covered with clear plastic tape.· The cooler will be strapped shut with strapping tape in at least two locations.

Whenever samples are split with another source or government agency, a separate sample custody record will be prepared for thos~ sample~. and marked to indicate ·. with whom the samples are being split. The person relinquishing the samples to the facility or agency will request the representative's signature acknowledging the sample receipt. If the representative is unavailable or refuses,.the person relinquishing the samples shquld note this il). the "received by" space of the , custody form. ·

, All shipments will be accompanied by the chain-of-custody record identifying the contents. The-original record will accompany the shipment, and any-additional copies will be retained by the sampler for returning to the sampling office.

If the samples are sent by common carrier, a bill-of-lading will be used. Receipts . of bills of lading will be retained as part of the permanent doc;umenla;tion. If sent by majl, the package will be registered with return-receipt-requested. Commercial carriers are not required to sign off on the custody forms as long as the custody forms are sealed inside the. sample cooler, and the custody seals remain intact. The person shipping the samples should note the carrier name and airbill number on the chain-of-custody record. \,/Udlll )' Assurance: ProjeCt Plan ' Revision: I Date: January 28, 1994 Section 5 Page 4 of 4

5.2 LABORATORY CHAIN-OF-CUSTODY PROCEDURES

Laboratory chain-of-custody procedures for the sample receiving and log-in; sample storage; tracking during sample preparation and analysis; and storage of data are described in the individual laboratory custody SOPs provided in Appendix D. Laboratory cha'in-of-custody procedures are considered facil.ity specific. ·

5.3 FINAL EVIDENCE FILE CUSTODY PROCEDURE

The Environmental Contractor is the custodian of the evidence file and main~ns the contents of evidence for the RFI, including all r~levanfrecords, reports, correspondence, logs, field logbooks, laboratory sample preparation and analysis logbooks/ documentation, analytical data packages, pictures, subcontractor reports, chain-of-custody records/forms, data review reports, etc.. The evidence file will be under custody of the file custodian i'n a secured area. The Environmental Contractor project manager has overall responsibility for file custody. Upon completion of the investigation or upon request of U.S. EPA or PPG, originals of all evidence files shalf be relinquished to PPG. Refer to the Data Management Plan for further details. Quah1y A'ISurance Project Plan . Revision: I Date: January 28, 1994 Section 6 Page I of2

6

CALIBRATION PROCEDURES

AND FREQUENCY tr,

This section-describes procedures for maintaining the accuracy of all the instruments and measuring equipment which are used for conducting field tests and laboratory analyses. These instruments and equipment will be calibrated prior to each use or on a sche~uled, periodic basis.

6.1 FIELD INSTRUMENTS/EQUIPMENT

Instruments and equipment used to gather, generate, or measure environmental. data will be calibrated with sufficient frequency and in such a manner that accuracy and reproducibility of results are consistent with the manufacturer's spe-cifications.

Equipment to be used during the field sampling will be examined to certify that it is in operating condition. This includes checking the manufacturer's operating

manual and the instructions for each instrument to ensure that an· maintenance > requirements are being observed. Field notes from previous sampling trips will be '~ reviewed so that the notation on any prior equipment problems are not overlooked, and all necessary. repairs to equipment have been cairied out

Calibration procedures and frequencies for field instruments are governed by the specific field SOPs provided in Appe.ndix B. Field measurements include pfi, conductivity, and temperature. ·

. . . In general, calibration of fi~ld instruments will be performed at the intervals f specified by the manufac~urer, or mo~e frequently as conditions dictate. The pH meters will be calibrated with standard buffer solutions as specified in the SOP in Appendix B pridr to field use. Conductivity meters are standardized prior to transport to the field, and daily thereafter in the field. 1Juallty Assurance ProJeCt Plan Revision: I Date: January 28. 1994 Section (i Page 2 of 2

6.2 LABORATORY INSTRUMENTS

Procedures f9r the calibration of laboratory instn~ments have been established and ·will be followed to ensure that equipment is functioning properly and that data collected are accurate and reliable. Requirements include step-by-:step calibration procedures, frequency of re-calibration, equipment maintenance logs, instrument accuracy criteria, corrective action procedures and equipment limitations (e.g., working ranges), as are described in detail in the SOPs provided in Appendix B.