REMEDIAL ACTION PLAN (RAP) for the DREDGING of 2080806 IMPACTED SEDIMENTS SDMS Docid at the FORMER UGI COLOMBIA GAS PLANT SITE Columbia, Pennsylvania

REMEDIAL ACTION PLAN (RAP) for THE DREDGING OF 2080806 IMPACTED SEDIMENTS SDMS DocID at the FORMER UGI COLOMBIA GAS PLANT SITE Columbia, Pennsylvania

Submitted To: Clean Sites Environmental Services, Inc. 635 Slaters Lane, Suite 130 Alexandria, Virginia 22314 Submitted By: OHM Remediation Services Corp. Northern Region 200 Horizon Center Boulevard Trenton, New Jersey 08691

DECEMBER 1997

OHM Remediation Services Corp. OHM Project 2024

d:\graphics\732412\ohmcv.ds AR400721 PARSONS ENGINEERING SCIENCE, iNC.

290 Elwood Davis Road, Suite 312- Liverpool, New York 13088 • (315) 451-9560 • Fax (315)451-9570

December 12, 1997

Clean Sites Environmental Services, Inc. Attn: Mr. Scott Miller Former UGI MGP Site Columbia, Pennsylvania 17512

RE: Former UGI Columbia Gas Plant Site Final Sediment Removal Remedial Action Plan (RAP)

Dear Mr. Miller:

Forwarded is one copy of the revised Final Sediment Removal Remedial Action Plan (RAP) for the Former UGI Columbia Gas Plant Site in Columbia, Pennsylvania. Revisions have been made in accordance with the November 19, 1997 meeting minutes and subsequent comments. Copies have also been forwarded to Steve Donohue of EPA (1), Tony Martinelli of PADEP(2) and Jim Villaume of PP&L (1).

Should you have any questions please feel free to call me at (315) 451-9560 or Mr. Michael Evanko of OHM at (609) 588-6382.

Sincerely,

PARSONS ENGINEERING SCIENCE, INC.

William J. Long Project Manager

CF: S. Donohue, EPA A. Martinelli, PADEP J. Villaume, PP&L M. Evanko, OHM

-WJSERSV10030\PPLSED\FinalWP\PPLLtrF2.DOC 12/12/97

PARSONS AR400722 fjSi»*il .i "-'•-)

OHM Remediation Services Corp. A Subsidiary of OHM Corporation

OPERA TIONS PLAN FOR THE DREDGING OF IMPACTED SEDIMENTS AT THE FORMER UGI COLUMBIA GAS PLANT SITE COLUMBIA, PENNSYLVANIA

Submitted to:

Clean Sites Environmental Services, Inc. 635 Slaters Lane, Suite 130 Alexandria, Virginia 22314

Submitted by:

OHM Remediation Services Corp. Northern Region 200 Horizon Center Boulevard Trenton, New Jersey 08691 -1904

Michael Evanko Project Manager

December 3, 1997 OHM Project 20240

AR400723 TABLE OF CONTENTS

1.0 INTRODUCTION 1-1

1.1 SCOPE OF WORK 1-1 1.2 SITE LOCATION/DESCRIPTION 1-2 1.3 SITE HISTORY 1-2 1.4 PREVIOUS INVESTIGATIONS 1-2 1.5 STATE AND LOCAL AUTHORITIES'ROLE 1-3

2.0 PROJECT ORGANIZATION 2-1

2.1 MANPOWER REQUIREMENTS 2-1 2.2 MANAGERIAL APPROACH TO CONSTRUCTION 2-1 2.3 PERSONNEL-DUTIES AND RESPONSIBILITIES 2-1

3.0 PRE-CONSTRUCTION ACTIVITIES 3-1

3.1 PERMITTING 3-1 3.2 PRE-CONSTRUCTION SUBMITTALS 3-1 3.3 PRE-CONSTRUCTION MEETINGS 3-1

4.0 MOBILIZATION AND SITE SETUP 4-1

4.1 SITE MOBILIZATION 4-1 4.2 SITE SETUP 4-1

5.0 DREDGE AREA WATER CONTAINMENT 5-1

6.0 DREDGING 6-1

7.0 AIR MONITORING 7-1

8.0 SAMPLING 8-1

8.1 CONFIRMATORY SEDIMENT SAMPLING 8-1 8.2 TREATED WATER SAMPLING 8-2 8.3 RIVER LEVEL MONITORING 8-2

9.0 TRANSPORTATION AND DISPOSAL 9-1

10.0 SHEETPILING/CUTOFF WALL INSTALLATION 10-1

11.0 BACKFILLING/PORTADAM REMOVAL 11-1

12.0 GEOTEXTILE AND RIPRAP INSTALLATION 12-1

OHM Project 20240 Columbia Gas-Columbia, PA December 3, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp.

AR400724 TABLE OF CONTENTS (CONTINUATION)

13.0 DEMOBILIZATION 13-1

14.0 CLOSURE REPORT 14-1

APPENDICES

APPENDIX A Personnel Resumes APPENDIX B Borough of Columbia Access Agreement APPENDIX C Treatability Study APPENDIX D Health and Safety Plan APPENDIX E Verification Sampling and Analysis Plan APPENDIX F Quality Assurance / Quality Control Plan APPENDIX G Contingency Plan APPENDIX H R3 Technologies Audit APPENDIX I Water Treatment System Standard Operating Procedures APPENDIX J Sheetpiling Specifications

FIGURES

FIGURE 1-1 Site Location Map FIGURE 1-2 Area Map FIGURE 1-3 Areal Extent of Coal Tar Impacted Sediments "Low End" FIGURE 2-1 Project Organization FIGURE 3-1 Schedule of Project Activities FIGURE 4-1 Details FIGURE 5-1 Portadam System FIGURE 6-1 Water Treatment System Detail FIGURE 6-2 Sediment Removal Plan FIGURE 6-3 Sediment Removal Section FIGURE 6-4 Atlantic Environmental Services Figure E-1 FIGURE 8-1 Confirmatory Sample Location Plan

AR400725 1.0 INTRODUCTION

OHM Remediation Services Corp. (OHM), in conjunction with Parsons Engineering Science, Inc. (Parsons ES), were retained by Clean Sites Environmental Services, Inc. (CSES) on behalf of Pennsylvania Power & Light (PP&L) Company to provide remediation services at the Former UGI Columbia Gas Plant Site in Columbia, Pennsylvania.

Subsequent reference to OHM and Parsons ES will be made as the "OHM Team" throughout the remainder of the text.

1.1 SCOPE OF WORK

The OHM Team was contracted to perform the dredging of approximately 496 cubic yards of coal-tar impacted sediments from the Susquehanna River, stabilize the river bank with geotextile and riprap material, and install a sheetpile cutoff wall along the shoreline of the Former UGI Columbia Gas Plant Site in Columbia, Pennsylvania.

The scope of work for the scheduled site remediation activities includes the following:

• Prepare the necessary permit applications required by the Pennsylvania Department of Environmental Protection (PADEP), United States Environmental Protection Agency (USEPA), and the Army Corps of Engineers (ACE).

• Prepare a Remedial Action Plan (RAP) for the project. The RAP includes an Operations Plan, Health and Safety Plan, Verification Sampling and Analysis Plan, Quality Assurance / Quality Control Plan and a Contingency Plan. The RAP includes all drawings necessary to perform the sediment removal. All specifications are included on the drawings.

• Mobilization to the site from the OHM Team Windsor, New Jersey shop location.

• Site setup activities which will include a survey of existing conditions in the dredge area, clearing and grubbing of the work area, office trailer setup, decontamination area setup, access road construction, and the installation of two 12,000-galIon containment pools (one influent or settling tank and one effluent or filtrate tank).

• Portable dam installation around the dredging limits and dewatering of the contaminated area.

• Dredging of impacted sediments from within the contaminated area, stockpiling of excavated sediments, and gravity dewatering of the excavated sediments.

• Water treatment and discharge.

• Air monitoring and post-excavation soil sampling.

• Transportation and disposal of impacted sediments.

• Sheetpile cutoff wall installation

• Backfilling of dredge area and the placement of geotextile and riprap.

• Demobilization of all equipment, materials, and personnel.

1.2 SITE LOCATION/DESCRIPTION

Site Location

The Former UGI Columbia Gas Plant Site is located at 441 South Front Street in the Borough of Columbia, Lancaster County, Pennsylvania and currently owned by PP&L. The property is approximately 1.6 acres in size and is enclosed by chain-link fencing. A Site Location Map is included as Figure 1-1.

Work Area Description

The work area scheduled for the remediation activities consists of an approximately 35,000 square foot area extending along the river bank of the site and into the Susquehanna River. Figure 1-2 has been included depicting the limits of the work area. Referring to Figure 1-2, the work area is situated approximately 300 feet west of the Municipal Authority of Columbia Wastewater Treatment Plant and approximately 300 feet south of the Columbia Borough Municipal Garage.

1.3 SITE HISTORY

The site was historically utilized as a gas manufacturing facility from approximately 1851 to 1948. The site was first utilized as a gas manufacturing facility in 1851, wherein gas was generated by the wood carbonization process. By 1886, the Lowe Process of water gas production had replaced the wood gas process. The property was owned and operated by Columbia Gas until 1935, when the property was transferred to PP&L. In 1949, the property was transferred to the Lancaster County Gas Company, which later merged with UGI Corporation (UGI). In 1976, a portion of the property was purchased by Thomas Grouse from UGI. In October 1979, George Roach purchased two-thirds of the property from UGI and began operating a boat dealership. In 1992, the property was inherited by George Roach's daughter and on January 27, 1994 re-purchased by PP&L. The site was placed on the National Priorities List in 1994.

1.4 PREVIOUS INVESTIGATIONS

From 1985-1986, PP&L sponsored several site investigations and several remedial measures were instituted onsite, including the capping of two former holding pits. In 1985, PP&L and UGI contracted TRC Environmental Consultants, Inc. (TRC) to perform a site investigation. In the "Final Report of Investigations" (TRC, 1986), TRC reported that a former gas plant employee stated that overflows from the tar/water separator at the gas plant were directed offsite to the Susquehanna River, in a shallow open trench. Sediment samples collected immediately downgradient of the former manufacturing gas plant indicated elevated levels of coal-tar constituents in a limited portion of the Susquehanna River and adjacent riverbank of the site. Additional sediment and soil sampling was performed to delineate the areal extent of coal-tar contamination as required by PADEP. The areal extent of coal-tar impacted

OHM Project 20240 Columbia Gas-Columbia, PA Decembers, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 1-2 AR400727 ^•^==. OHM Remediation V^^'»^L INTRODUCTION sediments has been identified and is represented on Figure 1-3.

Analytical results from the mid- to late-1980's investigation indicated total polynuclear aromatic hydrocarbon (PAH) concentrations as high as 2,630 parts per million (ppm) in the river sediments. Contaminated soils with total PAH concentrations of 11,000 ppm were observed in soils on the riverbank adjacent to the impacted river sediments. Analytical samples collected from the riverbed beyond the area exhibiting physical signs of tar yielded low contaminant concentrations in most cases, and may be a result of sources other than the former manufacturing gas plant.

1.5 STATE AND LOCAL AUTHORITIES' ROLE

The OHM Team believes that the participation and cooperation of federal, state and local authorities is essential to the environmental restoration process and to ensure the protection of the public interest and health. Participation of these authorities will be ensured through continuous communication throughout the project. All federal, state and local regulations will be met for all actions taken at this site.

NOTE: TAKEN FROM ATLANTIC ENVIRONMENTAL SERVICES. INC DATED MARCH, 1997 COLUMBIA RIVER SEDIMENT ADDENDUM

OHM Remediation FIGURE 1-1 Services Corp. SITE LOCATION MAP OHM Project No. 20240 FORMER UGI COLUMBIA GAS PLANT SITE COLUMBIA, PENNSYLVANIA f Drawn By: Checked By: Approved By: PREPARED FOR D. Leech E. Peper M. Evanko CLEAN SITES ENVIRONMENTAL SERVICES, INC. Date: Scale: Drawing No. ALEXANDRIA. VIRGINIA , 10/15/97 None 20240-A2 j AR400729 .AND OF SAFE HARBOR WATER POWER :ORPORATION CONTAMINANT^ O REDUCTION ZONE

GRAPHIC SCALE IN FEET SfOHBIV ffUCHM. AREA : LAKE CLARK FIGURE 1-2 SUSQUEHANNA ff/MEff PENNSYLVANIA POWER & UGHT COMPANY CLEAN SITES ENVIRONMENTAL SERVICES \SEE FIGURE 6.2 SEDIMENT REMOVAL PLAN SITE PLAN MAIN RIVER FORMER UGI COLUMBIA GAS PLANT r~| WATER INTAKE STRUCTURE COLUMBIA, PENNSYLVANIA L—' (APPROXIMATELY 400' OFFSHORE) DATE: 12/01/97 (GTCR) PARSONS ENGINEERING SCIENCE, INC. Xref. or WBW(S): H:\CAD\732412\32412G02.DWG DESIGN • RESEARCH • PLANNING no Eunoo wvts «o*o • suit jia. UVERRXX. H.T. IOTO • sa/m-tsn PLOT: XXXXXXX P/M SPACE: 1:1 PCP: FILE USED omco H i

AR400730 CO I o•* CM O CN WASTEWATER sQ TREATMENT PLANT

BASELINE --

HUB7 Gp_0? CD ' NGP-01 -230 -^

STAFF GAUGE (TOP ELEV=230.17)

SUSQUEHANNA RIVER

TOTAL ESTIMATED SEDIMENT VOLUME ^ 496.1 CUBIC YARDS

NOTE: TAKEN FROM ATLANTIC ENVIRONMENTAL SERVICES, INC 40 FEET FIGURE 5-1, DATED JANUARY, 1995.

"> General Notes and Legend f FIGURE 1-3 o ;. OHM Remediation CN 230- CURRENT GROUND SURFACE AREAL EXTENT OF COAL TAR IMPACTED SEDIMENTS CONTOUR Services Corp. "LOW END" OHM Project No. 20240 QWB1 SEDIMENT BORING LOCATION FORMER UGI COLUMBIA GAS PLANT SITE O COLUMBIA, PENNSYLVANIA O Drown By: Checked By: Approved By: CO A: HUEJ9 LOCATION CONTROL POIhfT PREPARED FOR D. Leech E. Peper M. Evanko AREAL EXTENT OF Dote: Scale: Drawing No. CLEAN SITES ENVIRONMENTAL SERVICES, INC. I TAR IMPACTS No. Revision/Issue Date ALEXANDRIA, VIRGINIA V J V ^ 10/15/97 AS SHOWN 20240-B1

AR400731 2.0 PROJECT ORGANIZATION

This section discusses project manpower requirements and the project organization.

2.1 MANPOWER REQUIREMENTS

The OHM Team will utilize the following personnel and equipment to support this project:

Personnel Equipment

Executive Sponsors Pick-up Truck Project Manager Van Senior Project Engineer Office Trailer Project Superintendent (2) 12,000-gallon storage pools Site Safety and Health Officer High Visibility Fencing Geotechnical Engineer Pressure Washer Civil Engineer CAT 320 Excavator Project Accountant CAT D3 Bulldozer Equipment Operators Over-the-Road Tractor Recovery Technicians Low Boy Trailer Subcontractors (Sheetpiling, Waste Transportation (2) Bag Filters and Disposal, Surveying) (2) 6" Dry Prime Pumps (or as required) (2) 2" Trash Pumps (2) Liquid Granular Activated Carbon Vessels

2.2 MANAGERIAL APPROACH TO CONSTRUCTION

Professional project management is the key to meeting client objectives for successful project completion within prescribed cost and time limits. The OHM Team project management structure is broken down into elements of project planning, project control, and project execution. The project management structure combines the various functional areas performing work on a project into a coordinated team reporting directly to the Project Manager. The objectives of the OHM Team project management approach are to produce quality work that meets all contract requirements and to complete the project within budget and schedule to the satisfaction of CSES.

The OHM Team offers to CSES a project management approach that ensures the safe, timely, and cost- effective completion of the project. Resumes of key project personnel are presented in Appendix A.

2.3 PERSONNEL-DUTIES AND RESPONSIBILITIES

The success of any project depends heavily upon the personnel involved. We have assembled an experienced team to design and implement remedial actions at the UGI Columbia Gas Plant site. Our proposed management organization is presented in Figure 2-1.

The project team will include the following functions reporting to the Project Manager:

• Safety • Design and quality assurance/quality control OHM Project 20240 Columbia Gas-Columbia, PA Decembers, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 2-1 AR400732 _>=p^ OHM [Icmcdialion v^^-^i. PROJECT ORGANIZA TION

• Operations • Contract administration • Project accounting

Project Manager

Mr. Michael Evanko will act as OHM's Project Manager. Mr. Evanko has experience managing projects with work similar elements, including dredging and sheetpiling. The Project Manager's responsibilities are to plan, organize, monitor, and control the overall project scope, schedule, and cost. It is also the responsibility of the Project Manager to administer the change-control system; provide overall project direction, oversight, and coordination; and interface with CSES's project representative. The Project Manager issues progress and status reports as necessary; conducts interim project reviews as required; and will assist CSES in any matters relating to the successful completion of the project. The Project Manager will generate weekly progress reports for submission to CSES, EPA and PADEP. The weekly reports will include a summary of work completed and pending work.

Project Superintendent

Mr. Mark Friar will be the Project Superintendent. He has extensive project experience in all aspects of the work, and will be onsite full time during the project's duration. The Project Superintendent has the responsibility for planning, organizing, leading, and controlling the day-to-day field activities. In addition, the Project Superintendent will coordinate and provide day-to-day liaison with CSES's project representative regarding the details of the day-to-day field work, including daily reports.

Senior Project Engineer

Mr. Kris Alzheimer will fulfill the role of Senior Project Engineer and will oversee and coordinate all technical aspects of the work. Mr. Alzheimer or his designee will perform construction quality control and prepare the Closure Report.

Project Design / Permitting

A portion of the technical support is staffed by Parsons Engineering Science, Inc. (Parsons), which is responsible for design and permitting. Particular strengths that Parsons brings to the project team include:

• Specialized experience in remedial projects involving simultaneous excavation and onsite consolidation, remediation, and removal of non-aqueous and tar-like materials from rivers.

• Strong in-house geotechnical experience in earthwork, cap design and soil slope stability.

• Proven performance in public meetings and community relations, specifically involving USEPA, PADEP, and local community groups

The responsibility of the Site Safety and Health Officer (SSHO) is to define, implement, and enforce the project safety program and procedures. The SSHO or the project superintendent will conduct safety "tailgate" meetings and will interface, as required, with CSES's safely group in order to coordinate all safety aspects of the project.

The Project Accountant is responsible for capturing resource usage on each Work Breakdown Structure OHM Project 20240 Columbia Gas-Columbia, PA December 3, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 2-2 AR400733 s. OHM Remediation PROJECT ORGANIZATION

(WBS) element. These daily resource usages, along with the work performed each day, represent the key input data to OHM's project management system. This system is designed to ensure that an up-to-date status of the project is available on a daily basis, and that trends and/or problem areas are identified quickly and addressed in a timely manner. In addition, it is the responsibility of the Project Accountant to maintain the project control sheets and the project filing and records retention system.

OHM Project 20240 Columbia Gas-Columbia, PA December 3, 1997 Information herein is proprietary and confidential and to be used or released lo others only with explicit written permission of OHM Remediation Services Corp. 2-3 AR400734 J>==-_ OII.M llcrnccliiilion ~ ^^p=" Services Cor)). V^^^ AA>WUlvjWOBHCM^*JUa PROJECT ORGANIZATION

Executive Sponsors Gary Gardner, Vice President, Northern Region Clean Sites Environmental Martin Battisloni, Services, Inc. Director of Regional Operations \

Project Manager Michael Evanko

fc^^^*"^^ „ ^fcxj&^-j&fe'*****^

sj Site Safetv and Health Officer >£ Senior Proiflct Engineer Charles Green ! Mark Friar Kn's Alzheimer

1 i

Subcontractors countant i;1 Equipment Operators Recovery Technicians pannns ^f; peolechnical •i Sheetpiling, Transportation D 4 and Disposal, Survey Don DelNero, RE. :s3 j&i&3&£xi<&<&& 1-W&

Parsons ES Civil Engineer Figure 2-1 William Long Project Organization UGI Columbia Gas Plant Site, Columbia, Pennsylvania Clean Sites Environmental Services, Inc., Alexandria, VA OHM Project 20240

OHM Project 20240 Columbia Gas-Columbia, PA October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 2-4 AR400735 3.0 PRE-CONSTRUCTION ACTIVITIES

3.1 PERMITTING

Prior to the start of the onsite activities, the OHM Team prepared and received approval of the following permits as required by the PADEP, USEPA, USACOE, and local governing agencies:

1) Environmental Assessment Form (Form 3200-PM-DWWOOO) 2) Cultural Resource Notice (Form 0120-PM-Y0003) 3) Supplement No. 1 - PA Natural Diversity Inventory Search (Form 3200-FM-DWW0016) 4) PA State Programmatic General Permit (PASPGP-1) 5) PADEP & USACOE Joint Application USACOE Section 404 Permit and PA Water Obstruction and Encroachment Permit...Form 3200-PM-WW0002 6) Letter of Intent to Discharge Pretreated Waters to the Surface Water - Division of Water PADEP 7) Borough of Columbia Building Permit.

3.2 PRE-CONSTRUCTION SUBMITTALS

Prior to mobilizing to the site, the OHM Team will prepare and submit this Remedial Action Plan (RAP). The RAP includes an Operations Plan, Construction Schedule, Health & Safety Plan, Verification Sampling and Analysis Plan, Quality Assurance / Quality Control Plan, and Contingency Plan. A schedule of the project activities has been included as Figure 3-1.

The OHM Team has prepared seven design drawings for the project, in CADD 12 format: 1) Portadam System, 2) Water Treatment System Detail, 3) Sediment Removal Plan, 4) Sediment Removal Detail, 5) 4-ppm Low End Sediment Cross Section, 6) Confirmatory Sampling Location Plan and 7) Details. All specifications are included on the drawings.

3.3 PRE-CONSTRUCTION MEETING

A draft RAP was submitted to CSES and PP&L for review. CSES and PP&L comments were incorporated into a draft final RAP which was submitted to the USEPA and PADEP. The OHM Team attended a one-day meeting with PADEP and the USEPA at the PADEP headquarters in Harrisburg, Pennsylvania on November 19, 1997 to discuss the draft final RAP. USEPA and PADEP comments have been incorporated into this final RAP.

\»7 •Iht Early Wt HOV DEC JWI Days Finish ; Start * # |1» P* (ST ' ,W -]1» ,1T « .1 fS* \* fl ?4 p4 pi fi> 0 ODOCTB7 * Not ceTo Proceed o 12 D3OCT97 20OCT97 Prepare Dra ft Remedial Act on Plan i

12 B3DCT97 200CT97 Prepare Dreft Perm 1 Docurrentation

3 itocm 230CT9T CSES PP&LFReview

5 24OCT97 30OCT97 Rev iseRAP' / Perm ts . . . 1 310CT97 31OCT97 Fin;il RevieN of Plais by C£ ES

t3 D3NOV97 19NOV97 PADEP EPA Review

1 0*DEC97 OSDEC37 Mobiliza lion /a 7 09DEC97 t7DEC»7 Site Pnsparatio 1 A

5 IJOECsr 24OEC97 EXC£ yate/S age / A nalyze SedimentS ; ' 2 2SDEC97 29DEC97 Ba Mill Excavation n —-ii 2 30OEC97 31DEC97 Install Sheetpil ng

2 D2JAN98 105JAN98 Ins all Geotextile & Rip-Rap 3k 3 OBJAN96 DS^ANM SiteR storation i i t 09 JAN 94 090AN08 De nobiliza ion

Sediment Removal - Former \K>] Columbia Gas Plant Site

Schedule ot Pro(e« ActivWes CUon Sites Environmental Ser/fccs. Inc.

Presented By. OHM Remediation Services Coqx. Project* 20240 AR400737 4.0 MOBILIZATION AND SITE SETUP

4.1 SITE MOBILIZATION

An access agreement has been obtained from the Borough of Columbia allowing access to the river for sediment removal (Appendix B). The OHM Team will mobilize the required site personnel, equipment, and materials from its Windsor, New Jersey shop location. Management and support resources will mobilize from the Trenton, New Jersey office. The anticipated crew sizes for each phase of the work are as follows:

ACTIVITY LABORERS OPERATORS SUB LABORERS Site Prep 324 Excavation 2 1 Sheetpiling - 1 3 Install Riprap 2 1 Restoration 1 1

Upon completion of mobilization, the OHM Team will commence site setup activities.

Mobilization will be contingent upon the depth of the river. Mobilization will proceed if the river depth in the dredge area is less than or equal to five feet, but will be postponed if the river depth is greater than five feet. In the event of a postponement, the OHM Team will monitor the river depth then mobilize once the river returns to a depth less than or equal to five feet. Additionally, the decision to mobilize may be effected by weather conditions such as extreme cold.

4.2 SITE SETUP

The first site setup activity to be performed will be a survey of existing conditions in the dredge work area. The survey will be performed by a Pennsylvania licensed surveyor. The surveyor will establish the limits of the dredging, the location of the sheetpile cut off wall, and the topographic baseline of the existing sediment surface prior to dredging for use in quantifying the material removed. The baseline survey will be consist of elevations taken on 10-foot centers. The area in which the riprap will be placed will be cleared and grubbed, taking care to protect the large willow trees. Work zones will be established with 4-foot tall orange color temporary high visibility fencing, to control access to the site and direct the flow of traffic. A small office trailer will be brought to the site as a meeting place and for storage of documents.

Two (2) decontamination areas will be constructed at the site as indicated on Figure 1-2. One decontamination area will be situated adjacent to the soil stockpiling area. The second decontamination area will be located at the top of the hill. Each decontamination area will be constructed with two layers of 10 mil visqueen, 20' x 25'in size, covered with stone. Each area will be bermed with hay bales and graded to drain to a collection sump to allow for the containment, collection and removal of decontamination liquids (Figure 4-1). The OHM Team will utilize the "Clean Road Loading Process" for the site decontamination activities adjacent to the stockpiled soil. All machinery entering this decontamination area will be powenvashed. The machinery exiting the site will then go to the second decontamination area where the tires will be cleaned. A log will be kept of all vehicles entering the contaminant reduction zone, whether decontaminated or not and the inspector who permitted the vehicle OHM Project 20240 Columbia Gas-Columbia, PA December 3, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 4-1 AR400738 ^/^==- OHM Remediation S^IF ^£^L MOBILIZA TIONAND SITE SETUP

to leave.

Upon completion of the installation of the decontamination areas, OHM Team will delineate the work zones using 4-foot tall orange colored temporary high visibility fence. This will control access to the excavation area and minimize the potential for cross-contamination. The OHM Team will establish a lay-down area in the Support Zone to store necessary supplies and equipment.

An access road will be installed down to the river's edge. The road will be placed from the parking area of the Columbia Borough Municipal Garage (CBMG) southward to the river edge as depicted on Figure 1-2. The proposed access road will require minimal grading and disturbance of the site. OHM will place approximately six inches of clean gravel over a geotextile fabric for the access road. The access road will be installed with a ditch and hump configured to direct runoff away from the work area.

A water treatment system will be installed in the temporary water treatment area as shown on Figure 1-2. The water treatment system will consist of two 12,000-gallon containment pools, two bag filters, two liquid phase granular activated carbon vessels and process piping.

Temporary silt fencing will be installed as shown on Figures 1-2, 1-3 and 4-1. Silt fencing will be installed uphill to minimize runoff entering the work area. The bottom of the silt fencing fabric will be buried approximately four inches in the ground. Additionally, all erosion control fencing will hook uphill at their ends.

Vegetation will chipped, stored adjacent to the water treatment system and reused as mulch for site restoration.

2 LAYERS OF 10 MIL VISQUEEN

DECON PAD DETAIL

NOT TO SCALE :

FIGURE 4-1 PENNSYLVANIA POWER & LIGHT COMPANY CLEAN SITES ENVIRONMENTAL SERVICES AR400740 DETAILS FORMER UGI COLUMBIA GAS PLANT / POST

REINFORCEMEN1 NETTING HAY BALES (TYP BOTH SIDES) : CLEAN STONE FILTER FABRIC-

. 0 i 1 CM

; BACKFILL

FLOW

°"°.s \ 2 LAYERS OF 10 MIL VISQUEEN V

EROSION CONTROL FENCE DETAIL DECQN PAD DETAIL NOT TO SCALE NOT TO SCALE

NOTE:

SILT FENCE SHALL BE ENVIROFENCE MANUFACTURED BY MIRAFI, INC. OR EQUIVALENT.

FIGURE 4-1 PENNSYLVANIA POWER & LIGHT COMPANY CLEAN SITES ENVIRONMENTAL SERVICES DETAILS FORMER UGI COLUMBIA GAS PLANT COLUMBIA, PENNSYLVANIA

DATE: 12/02/97 (GTC) PARSONS ENGINEERING SCIENCE. INC. Viaw(s): AS NOTED DESIGN • RESEARCH • PLANNING H:\CAD\732412\32412GCH.DWG no axxo uva KM) • un in • uvana. U.T. me • Ji»/«i-«w PLOT: 1-1 P/M SPACE: 1:1 POP: 32412G04.PCP omen w pftwcpM. aro

AR400741 5.0 DREDGE AREA WATER CONTAINMENT

The OHM Team has subcontracted Portadam, Inc. of Hammonton, New Jersey for the installation of a portable dam around the dredging limits. Portadam, Inc. will provide the Portadam system which consists of a highly flexible cofferdam for use in open water to depths of nine feet for all types of excavations where a dry work area is required. Figure 5-1 illustrates a cross-sectional view of the Portadam system. All Portadam installers will be 40-hour OSHA trained.

The Portadam concept utilizes the mechanical, resistive and flexible properties of modern synthetic fabrics to provide both temporary and semi-permanent barriers for fluid impoundment and control. The system support members are designed to transfer fluid loading to a near vertical downward load, thereby permitting installation on solid impenetrable foundations. As opposed to driven sheetpiling, the Portadam stands on the river bed surface, eliminating the need for pile driving equipment, crossbracing and anchorage.

The Portadam will be placed at least 20 feet from the known horizontal extent of the 4 ppm high end contamination area to minimize clean water seepage into the work area and allow for limited "chasing" of horizontal contamination if encountered. The Portadam supports require five feet of undisturbed sediment from the support structure with a maximum excavation slope of one foot horizontal to one foot vertical.

The Portadam system utilizes a sliding clamp arrangement for assembly of structural framework members in the field. This sliding clamp arrangement allows adjustment of frame alignment every 15" along the desired installation line. Horizontal adjustment allows turning or curving of the installation line while vertical adjustment allows working up or down slopes as well as over irregular contours and obstructions. Two lower swivel links are attached before the framework assembly is stood in place and one additional single bolt connection is made near the top after positioning. This bolting arrangement is used to eliminate underwater connections, thereby making installation in deep water simpler.

Handling equipment which can access and reach to the installation point, such as a forklift, small crane or backhoe, are often used for installation of the Portadam sections which weigh approximately 80 pounds each. A small crane will be used at the Columbia site to lift Portadam sections out to the divers to prevent disturbance of the contaminated sediments. Small wooden barges may also be used for Portadam locations beyond the reach of the crane. When being installed in deep water, topside labor assistance is required to perform some preliminary bolting, to assist the installers in the water and to fill sandbags for placement at the outer edge of the fabric sealing sheets.

The Portadam system is suitable for installation over irregular bottom contours. The Portadam framework is adjustable every 15" or less and the flexible liner can seal over irregular surfaces. However, in some underwater installations, such as where large boulders (over 200 pounds) are encountered, the installation alignment must be adjusted or the obstruction removed. Realignment or obstruction removal, though not anticipated at the Columbia site, will be performed if needed during installation of the Portadam.

Foundation consistencies relating to load bearing capacity must be evaluated prior to installation based on the anticipated water depth (hydraulic loading). In general, the Portadam system works best on solid foundations. Rock and concrete foundations afford good support under the framework and good surfaces for the liner sealing apron. In certain situations where a frame heel stop is not readily available, OHM Project 20240 Columbia Gas-Columbia, PA December 11, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 5-1 AR400742 J*^=±- 01IM Remediation ~~ ^^^~ Services Coi'j). V^^^" ASlUMUrrtfOMUCwwlU*! DREDGE AREA WATER CONTAINMENT

additional small anchors may be required to resist the minimal sliding forces not overcome by the back leg of the frame structure "digging in". Additional anchors are not anticipated at the Columbia site.

On most river bed situations where clay, hard mud, sand, gravel or cobbles are found, the Portadam develops proper lateral support by digging in at the heel of the support frames. The extended liner apron is designed to seal on the surface of the river bed material because of its' flexibility and the heavy hydraulic loading encountered by differential pressure when the inside area is pumped out. These conditions are expected at the Columbia site.

Soft foundation materials, though not anticipated at the Columbia site, may present a settlement problem if there is inadequate foundation consistency to stop the framework from settling beyond the height limitation of the Portadam used. The standard framework has attachment locations for extra bracing if required. Alternatively, stable foundation material could be added to provide the necessary support if needed. These adjustments, if needed, will be performed during installation of the Portadam.

Basic Installation Procedure

Steel Framework:

1. Individual steel frame components will be prepared on-shore. Two pinned connectors will be attached at the bottom horizontal brace of two separate frames in order to construct a frame "pair" consisting of two frames and two bar connectors.

2. Frame pairs will then be placed directly into position by hand and by crane along the desired installation line with progressive connections made using an adjustable clamp (one bolt) arrangement. Final elevation and/or direction adjustments will be made at this time. Obstruction removal, if required, is also performed at this time.

3. The frame pairs will be lowered into vertical position, adjusted and then spread at the top to form a "V". A steel spacer link is installed in the "V" to maintain distance. The frame pair is then attached to the previous frame pair using a steel, two-part, bolted clamp designed to clamp anywhere on the frame member. This adjustment permits the frame pairs to be installed at different elevations to adjust for irregular contours and slopes. Standard frame spacing is 15" or 30" per pair. Spacing can be increased for shallower water or decreased for deeper water.

4. To create a turn along the installation line, single frame members will be placed vertically plumb with inside toes tight together and outside toes separated to produce a fan shape. Only the adjustable top clamp will be used in corners, the upper and lower connectors are not needed.

5. To complete the assembly, heavy steel poles can be added through steel loops at the back of each frame member, both vertically and horizontally, to increase stability in soft foundation areas. This step is not anticipated at the Columbia site.

Fabric sealing membraneC'Liner"):

1. Fabric sealing sheets will be provided in 25' and 50' horizontal sections and special outside corners (fan-shaped) which will be joined by waterproof, pinned end seams. Preparation is done on-shore by laying out individual liner sections and joining into the desired configuration. There are no special tools required for this operation. The assembled liner is then folded, rolled and tied into a long "sausage" shape for ease of installation on the framework structure.

2. The entire assembled liner section will then be placed around the perimeter of the framework and secured to the top at each frame pair location. Once secured at the top of the frame structure, the liner is then unrolled down the diagonal face of the framework and extended out onto the existing bed at the toe of the frames. An extension of the liner is pulled horizontally out away from the toe of the framework to form a "sealing apron". The outside perimeter of the sealing apron contains a heavy chain which assists with sinking the liner. The outside perimeter is normally sandbagged into place but can be buried in soft material to form a cutoff to assist with sealing, if needed.

3. Preparations at the shoreline ends and at the turns will then be completed to ensure a proper seal. At each intersection with the shoreline, the Portadam will be installed up the bank to an elevation equal to the top elevation of the lowest Portadam section. The liner will be sealed at the bank with sandbags.

4. Pumping equipment will be positioned in the enclosed area in sump holes, if possible. Once the pumps are started, the differential water head between the enclosed area and the main body of water presses the liner membrane tightly onto the framework and the surrounding bed area. Final liner adjustments will then be made. Minor leaks under the sealing apron will be located and sealed with sandbags.

After the Portadam is installed, the river water in the enclosed area will be pumped out using the six-inch dry prime pumps and discharged directly back to the river. Once the water level is within one foot of the river bottom, the water will be discharged through 25 micron bag filters to prevent the inadvertent discharge of sediment. The area enclosed by the Portadam will be pumped down and maintained free of standing water as far as practical. Pumping operations will be maintained 24 hours per day during the active use of the Portadam. An employee will be onsite at all times during pumping.

A survey of the Portadam top elevations and the pre-excavation sediment elevations will be conducted upon dewatering of the enclosed area.

After the area enclosed by the Portadam is sufficiently dewatered to gain access into the area, a wall of sand bags will be placed around the interior perimeter of the enclosure. The sand bags will be placed in an overlapping manner to a height of approximately two feet and the inside, or contamination side, of the sandbags will be lined with visqueen. The sand bags and visqueen will provide a physical barrier between the potentially "contaminated" water from the sediment removal area and river water seeping under the Portadam.

All entry into the Portadam enclosure will be restricted to those personnel essential to the performance of the work. All personnel entering the Portadam enclosure area will be required to wear a personal flotation device (PFD). Ladders will be placed along the sloped edge of the work area for easy egress.

Lights to alert night boaters of the Portadam will be installed at the outside corners of the Portadam.

RETAINED WATER STEEL UP TO 9 FEET DEEP SUPPORT FRAME FABRIC MEMBRANE

UNOBSTRUCTED WORK AREA

IMPERVIOUS BED SEALING SHEET

Installation of frames Placing membrane De-watering by pumping

PORTADAM SYSTEM

Legend OHM Remediation FIGURE 5-1 Services Corp. PORTADAM SYSTEM OHM Project No. 20240 FORMER UGI COLUMBIA GAS PLANT SITE COLUMBIA, PENNSYLVANIA Drown By: Chocked 8y: Approved By: PREPARED FOR D. Leech E. Peper M. Evonko CLEAN SITES ENVIRONMENTAL SERVICES, INC. Dot«: Scot*: Drawing No. ALEXANDRIA, VIRGINIA , 10/15/97 None 20240-A4 _, AR400745 6.0 DREDGING

After the Portadam installation and dewatering activities are complete, the OHM Team will commence with the dredging activities. The dredging will consist of the excavation of sediments with a CAT 320 or equivalent excavator equipped with a smooth cutting blade. Excavation will proceed from the southeast corner to the northwest corner. This approach will minimize cross contamination by not tracking across the work areas. Excavation depths will vary as shown in Figure 6-4. An additional area measuring 5 feet by 5 feet will be excavated an additional six inches at location WB-11, if possible. The excavator will remove and stockpile the sediments near the shore in a contaminated sediment area.

A downgradient trench will be installed adjacent to the stockpile to allow for water collection from the stockpiled sediment. Collected water in the trench will be pumped with a 2-inch trash pump to the 12,000-gallon influent containment pool located in the temporary water treatment area. Dredging will generally occur in a dry condition. The water removed from the disturbed dredging area will be pumped to the containment pool for treatment. The water level in the dredge area will not be allowed to rise above the top of the sandbag containment wall.

As an alternative to stockpiling the sediment at the river's edge, the sediment may be stockpiled on the Borough of Columbia property or across Front Street at the former manufactured gas plant site. The sediment will be stored in two 50,000-gallon storage pools. First, the pool structures which consists of steel panels will be bolted together . Second, the interior pool areas will be covered with sand. Third, 20-mil liners will be installed over the sand to protect the liner. Lastly, commercial grade pool liners will be installed and secured by draping them over and clipping them to the panels. Only three sides of the pools will be erected to allow equipment access for sediment placement. The entrance area into each pool will be bermed temporarily to prevent water from entering or exiting the pools. A drum will be placed in the low end of each pool to collect water draining from the sediment. The sediment will be dumped into the pool and piled using a rubber tired backhoe.

The water collected from the stockpiled sediment and the disturbed dredging area will be treated through a series of two (2) bag filters and two (2) liquid phase granular and discharged into the 12,000-gallon effluent containment pool. Each bag filter will consist of a 25 micron filter followed by a 10 micron filter. The activated carbon vessels will contain 2,000 pounds of carbon each which can be increased to 4,000 pounds each if required. Figure 6-1 has been prepared illustrating the water treatment system setup. Treated water will be temporarily stored in the second containment pool for testing. The sampling requirements prior to discharge are discussed in Section 8. Upon analytical confirmation of successful treatment, the water will be discharged into the Susquehanna River.

The treated effluent water will be tested as discussed in the Verification Sampling and Analysis Plan, Appendix E. The current NPDES discharge requirements for the site have been amended for the treatment of contaminated water from the sediment removal. The permitted discharge limits are: benzene, 30 ug/1; naphthalene, 50 ug/1; and total suspended solids (TSS), 30 units. Testing will be performed for treated water once for every 5,000 gallons for the first 10,000 gallons. Each 5,000 gallon batch of treated water will not be discharged to the river until analysis confirms that the discharge limits have been met. Once the treatment system has proven it effectively meets the discharge limits, the treated water will be sampled once for every 50,000 gallons. The treatment system will be operated with a continuous discharge, not with a batch discharge, after the first 10,000 gallons if the system has been proven to effectively treat the water with one pass through the system. The treated water will be analyzed for benzene and naphthalene by EPA Method 8260 and for TSS by EPA Method 160.2. All OHM Project 20240 Columbia Gas-Columbia, PA December 3, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 6-1 AR400746 ^=^ OHM Remediation ~~ ^^^ Services Corp. V -^ IfabuUrKfOHMCwwulH DREDGING treatment will be performed in accordance with OHM's standard operating procedures (SOP) (Appendix I)-

According to the treatability study performed by the OHM Team, the excavated material will gravity dewater within approximately 24-hours of stockpiling to a point where it will pass paint filter testing without the addition of any chemical agents. The treatability study is attached as Appendix C. If the material does not pass the paint filter test within 24 hours, the material will be allowed to dewater for another 24 hours. If the material does not pass the paint filter test at this point, an additive such as Portland cement will be mixed with the sediment to increase stability as measured by passing the paint filter test. The dewatered material will be loaded directly into lined dump trailers for transportation to an approved disposal facility. As a precaution against spills or leakage during transport, a small amount of Portland cement will be placed in the tailgate area of the transport vehicles and on top of the load to absorb any free liquids.

Excavation will continue until all contaminated sediment from the 4 ppm Low End Area is removed. OHM has calculated the material to be removed from the 4ppm Low End Area to be 496 cubic yards, however, the final quantity may vary depending on the extent of actual contamination. After confirmation that all excavation activities are completed, the OHM Team will perform a topographic survey of the excavated area to determine final quantities of material removed.

The last area to be excavated, the area under the sediment stockpile, will be excavated and placed on an upland area lined with two layers of 60 mil polyethylene sheeting. The sheeting will be protected with plywood to prevent damage to the sheeting during loadout activities. The area will also be bermed with hay bales.

Trucks will be backed down the access road to a loading area adjacent to the sediment stockpile. The loading area will be covered with visqueen to allow for easy cleanup of spilled material. Trucks will back onto the visqueen for loading. If material being loaded happens to miss the truck it will land on the visqueen and be removed by technicians. This will eliminate cross contamination in the working area and will keep the trucks from tracking contamination across the site and onto the roadways. In addition, all vehicles will be pressure washed at the decontamination area at the top of the hill to remove any soil adhered to the vehicle. The decontamination water will be pumped to the water treatment system using a 2" trash pump and flexible hoses for treatment.

O (N CO O CO UJ o Q

I (O

2:0: OQ

o £

* ° I* N s

o -£ CO

• CO

I CM

£g •-1 o ^,

o o 01

AR400748 MUNICIPAL AUTHORITY OF COLUMBIA WASTEWATER TREATMENT PLANT TEMPORARY LEGEND ~" WATER TREATMENT AREA — CURRENT EDGE OF RIVER CURRENT GROUND SURFACE TEMPORARY 230- FENCING CONTOUR

6"-9" RIPRAP WB1 SEDIMENT BORING LOCATION

4PPM LOW END SEDIMENT REMOVAL AREA / / MONITORING WELL 4PPM HIGH END SEDIMENT REMOVAL AREA DIJCH/AND/ HUMP ACRO /ACCESS ROAD

-10"-12" \RIPRAP

SHEETPILE RETAINING WALL NOTES: 1 EXACT LOCATION OF PORTADAM MAY VARY. SEDIMENT STOCKPIE AREA^ PORTADAM TO BE INSTALLED A MINIMUM OF 10' OUTSIDE CONTAMINATION BOUNDARIES. -230 r__:-<,£. _ L-L_j y_+- y PORTADAM TO BE 10' HEIGHT AND UP TO 310' IN LENGTH. 2 SEE FIGURE 6-4 FOR APPROXIMATE EXCAVATION DEPTHS OF CONTAMINATED SEDIMENT. 3 CS-69 SHEETPILING TO BE DRIVEN 6-7 FEET BELOW EROSION CONTROL EXISTING GRADE AND CUT FLUSH WITH GROUND FENCING EROSION CONTROL SURFACE. 4 BACKFILL SEDIMENT EXCAVATION AREA WITH SAND FENCING AND GRAVEL TO ORIGINAL GRADE. BACKFILL SHALL BE WELL GRADED MATERIAL WITH LESS THAN 10% BY WEIGHT LARGER THAN 6 INCHES AND LESS THAN 15% BY WEIGHT FINES. 5. GEOTEXTILE FABRIC SHALL BE 8oz. WOVEN POLYESTER. 6. RIPRAP SHALL BE 10-12 INCHES A DISTANCE OF 10 FEET EACH SIDE OF THE SHEETPILE RETAINING WALL. RIPRAP SHALL BE 6-9 INCHES FROM 10 TO 35 FEET UPLAND OF THE SHEETPILE RETAINING WALL. 7 ACCESS ROAD TO BE 8oz. WOVEN POLYESTER GEOTEXTILE COVERED WITH 6 INCHES OF GRAVEL. ACCESS ROAD SHALL REMAIN AT COMPLETION OF PROJECT. 8. SEDIMENT EXCAVATION TO PROCEED FROM SOUTHEAST TO NORTHWEST. APPROXIMATE PORTADAM1 LOCATION FIGURE 6-2 PENNSYLVANIA POWER * LIGHT COMPANY CLEAN SITES ENVIRONMENTAL SERVICES SEDIMENT REMOVAL PUN FORMER UGI COLUMBIA GAS PLANT COLUMBIA, PENNSYLVANIA

PARSONS ENGINEERING SCIENCE, INC. DATE: 12/02/97 (GTC) DESIGN . RESEARCH • PLANNING no avow DAMS now • sum in • uwmou H.T. txte • iwwi-MCa Xref. or View(s): omxs M PDMOPU. ana PLOT: XXXXXXX P/M SPACE: 1:20XP PCP: 32412G01.PCP

AR400749 4ppm LOW END SEE NOTE 1 SEDIMENT REMOVAL AREA 6-9" RIPRAP-

4ppm HIGH END SEDIMENT REMOVAL AREA COLLECTION TRENCH ->

CLEAN WATER -COLLECTION AREA

SEDIMENT REMOVAL SECTION NOT TO SCALE

FIGURE 6-3 PENNSYLVANIA POWER & LIGHT COMPANY CLEAN SITES ENVIRONMENTAL SERVICES

NOTE: SEDIMENT REMOVAL SECTION EXTEND RIPRAP 10' RIVERSIDE FORMER UGI COLUMBIA GAS PLANT OF SHEETPILE AFTER COMPLETION OF SEDIMENT REMOVAL COLUMBIA, PENNSYLVANIA DATE: 10/28/97 (JAR) Xref. or View(s): DESIGN • RESEARCH • PLANNING H:\CAD\732412\32412G03.DWG PLOT: XXXXXXXX MS/PS: X:X PCP: SAME »0 Q.WOO DAVn MUD • Mlt J1J • UWOOL N.Y. 1XM • 315/«l-»3eO

AR400750 WB23 WB24 WB26 WB14 WB4 WB1 1 WB3 230 230 230 230

CRAY SILTY CLAY

BLACK SILT/COAL FINES

225 • - 225 225 225

TAR ODOR

COMPACT COARSE SAND GRAVEL. COBBLES COMPACT COARSE SAND. -FINE-GRAINED GRAVEL. COBBLES LIMESTONE BEDROCK 220 220 220 U 220 JO 40 50 60 70 10 20 30 40 50 60 70 STATION 1 STATION 4

WB22 V/B2 WB12 WB1 WB13 WB15 WB21 230 230 230 230

133.68 SF 105.12 SF

SHEEN

225 225 225 UJ 225 % GO

COMPACT COARSE SAND, COMPACT COARSE SAND. FINE-GRAINQD GRAVEL, COBBLES GRAVEL. COBBLES LIMESTONE BEDROCK' 220 220 220 220 10 20 30 10 50 60 70 10 20 30 -tO 50 60 70 STATION 2 STATION 5

WB17 WB18 WB19 WB20 WB6 • WB10 WB5 230 230 230 230

72.12 5F

ORGANIC SILT

225 - 225 225 ORGANIC SILT, 225 XXXXXX: .. _ ^GRAVEL, SAND. SILT/V

COMPACT COARSE SAND COMPACT COARSE SAND. GRAVEL. COBBLES COMPACT COARSE SAND. GRAVEL. COBBLES GRAVEL. COBBLES 220 220 220 220 60 70 10 20 30 40 50 60 70 ATLANTIC ENVIRONMENTAL SERVICES, INC.

429 4 8 FIGURE E-1 4.0 ppm - LOW END HORIZONTAL GRAPHIC SCALE IN FEET VERTICAL GRAPHIC SCALE IN FEET COLUMBIA FORMER MGP SITE COLUMBIA. PENNSYLVANIA L OOI\0201IB\SCC-

Due to the nature of the contaminants and materials being excavated, the OHM Team does not anticipate a high concern for exposure to vapors. The OHM Team will monitor the area with a photoionization detector (PID) and record the results. Air monitoring will be performed at the start of every new activity and every 2 hours during operations. The PID will remain in the work area at all times for more frequent monitoring if required by site conditions. If additional monitoring is required, it will be performed as detailed in the HASP.

One air sample for each worker will be collected and analyzed by NIOSH Method 5508 for the first two days of excavation. NIOSH Method 5508 includes the five compounds of OSHA Method 58 plus naphthalene. The compounds and their limits of quantification (LOQ) are as follows:

Compound LQQ fug) anthracene 2.0 benzo(a)pyrene 0.06 chrysene 0.06 naphthalene 2.0 Phenanthrene 0.3 pyrene 0.9

The air monitoring results will be used to ensure the proper selection of protective clothing and equipment, including respiratory protection, to protect onsite personnel and offsite receptors from exposure to unacceptable levels of site contaminants. Additional air monitoring details and the action levels are included in Appendix D, Health and Safety Plan.

8.1 CONFIRMATORY SEDIMENT SAMPLING

Once the contaminated sediment has been removed to the proposed excavation limits or engineering limits, such as limestone or bedrock, confirmatory sediment samples will be collected to confirm that the removal action was effective. The hardpan underlying the sediment is not considered an engineering limit if it can be excavated with a track excavator using a smooth-edged bucket.

The cleanup goal for the project is 4 ppm total PAHs, however, a secondary cleanup goal of 44 ppm total PAHs will be used for contaminated hardpan that is difficult to remove.

Prior to obtaining the samples, a one time complete dewatering of the excavation will be performed. This dewatering step will remove any potentially contaminated water that has accumulated in the excavation during sediment removal. The removed water will be pumped to the onsite water treatment system for treatment.

A total of two composite bottom samples will be taken from the excavation at a depth of 0 to 6 inches for analysis. Each composite sample will be composed of five grab samples which will be held be the laboratory for possible analysis as shown in Figure 8-1. One of the grab samples will be from sample location WB-11 which was shown to be contaminated at the interface of the hardpan and bedrock. Should a composite bottom sample fail, the five grab samples will be analyzed to determine the contaminated grab sample locations. Should a grab sample indicate contamination above 44 ppm total PAHs, an additional excavation not less than 5 feet by 5 feet will be removed to a depth of 1 foot. The additional excavation will be resampled and remain open until receipt of the analytical results, generally 24 hours. Excavation of 1 additional foot and resampling will continue until results less than 44 ppm total PAHs is achieved. Should a grab sample indicate contamination between 4 and 44 ppm total PAHs, an additional excavation not less than 5 feet by 5 feet will be removed to a depth of 6 inches. The area will be resampled then backfilled with riprap to the original hardpan elevation then backfilled with sand.

A total of four composite sidewall samples will be taken from the excavation. Each composite sample will be composed of five grab samples which will be held be the laboratory for possible analysis as shown in Figure 8-1. Should a composite sidewall sample fail, the five grab samples will be analyzed to determine the contaminated grab sample locations. Should a grab sample indicate contamination above 4 ppm total PAHs, additional horizontal excavation will be performed. The exact amount of additional horizontal excavation will be determined by the contamination level and field conditions. The area will be resampled and re-excavated as necessary until the cleanup goal is reached or the minimum horizontal distance to the Portadam is reached.

Grab samples comprising both the bottom and sidewalls composite samples will not be analyzed if the composite sample analyses indicate PAH contamination less than the cleanup goal.

A total of four composite sediment samples will be collected for characterization prior to removal from the site. The composite samples will consist of five grab samples from various locations of the stockpile. The number of samples, analytical parameters and methods, as required by the disposal facility, are summarized in the Verification Sampling and Analysis Plan, Appendix E.

A paint filter test will be performed on every load of sediments prior to shipment to ensure that no free OHM Project 20240 Columbia Gas-Columbia, PA December 3, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 8-1 AR400753 ^^^- OHM Remediation SAMPLING liquids will drain from the sediment during transportation to the disposal facility. The paint filter test will be performed in accordance with EPA Method 9095-SW846. The test will be performed and documented by the OHM Team at the site.

A copy of the chain-of-custody is included in the Verification Sampling and Analysis Plan (SAP), Appendix E. Chain-of-custody forms will be maintained for all samples. All analytical results will be sent to the USEPA via facsimile for USEPA approval prior to backfilling.

8.2 TREATED WATER SAMPLING

The treated water will be analyzed for naphthalene and benzene utilizing EPA Method 8260 and for total suspended solids utilizing EPA Method 160.2.

8.2 RIVER LEVEL MONITORING

OHM will record the river level both inside and outside of the Portadam enclosure on a daily basis. Two staff gauges, one inside and one outside the enclosure, will be installed to perform this task.

OHM Project 20240 Columbia Gas-Columbia, PA December 12, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 8-2 AR400754 MUNICIPAL AUTHORITY OF COLUMBIA LEGEND

WASTEWATER CURRENT EDGE OF RIVER TEMPORARY TREATMENT PU\NT - 230 CURRENT GROUND SURFACE ~ WATER CONTOUR TREATMENT AREA • WB1 SEDIMENT BORING LOCATION

BOTTOM GRAB SAMPLE LOCATION

SIDEWALL GRAB SAMPLE LOCATION

MW-07D -*- MONITORING WELL SD01 GRAB SAMPLE AREA BOUNDARY

4PPM HIGH END SEDIMENT REMOVAL AREA

J / DITCHxAND / ,s tiUMP ACROS ' / ApCESS ROAD /

SHEETPILE RETAINING WALL (75') SEDIMENT STOCKP1\E

EROSION CONTROL FENCING

APPROXIMATE WB5 PORTADAM LOCATION FIGURE 8-1 PENNSYLVANIA POWER & LIGHT COMPANY CLEAN SITES ENVIRONMENTAL SERVICES COMPOSITE SAMPLE LOCATION PLAN FORMER UGI COLUMBIA GAS PLANT COLUMBIA, PENNSYLVANIA GRAPHIC SCALE IN FEET DATE: 12/02/97 (GTC) PARSONS ENGINEERING SCIENCE. INC. Xrof. or Viow(s): DESIGN • RESEARCH • PLANNING H:\CAD\70S24I2\32412G05.DWG no ELWXC OAVB now * sum 313 • UWRPOOU H.Y. IJOM PLOT: XXXXXXX P/M SPACE: 1:20XP PCP: 32 + 12G01.PCP omxi H HttKfH. cms

AR400755 9.0 TRANSPORTATIONAND DISPOSAL

The OHM Team will procure the necessary transportation and disposal vendors for the removal of impacted material. The material will be transported by licensed haulers, who are approved to transport non-hazardous material and debris in the Commonwealth of Pennsylvania. All trucks will be decontaminated and their loads covered prior to leaving the site. The truck drivers will be required to remain in their vehicles at all times while at the site.

The contaminated sediments will be transported to R3 Technologies in Morrisville, Pennsylvania for disposal by thermal treatment. R3 Technologies is a residual waste desorber for non-hazardous coal tar hydrocarbons. A copy of the CSES November 11, 1997 audit of R3 Technologies is included in Appendix H. R3 Technologies will issue a certificate of destruction for all thermally treated material.

Oversized crushable material will be run through a crusher at R3 Technologies and treated with the sediments.

Any large debris encountered during excavation such as shopping carts, tires, etc. will be segregated, stockpiled onsite and pressure washed, if necessary. The debris will then be shipped to the WMX Modern Landfill in York, Pennsylvania for disposal.

The OHM Team has subcontracted with Terra Environmental of Malvern, Pennsylvania for the installation of a "CS-69" type sheetpile wall. The sheetpiling will be driven along the river's edge extending from Test Pit F in an easterly direction to the approximate location of geoprobe boring location "GP-01" (Figure 6.2).

The sheetpiling will be driven into the compacted gravel layer to a depth of approximately 6 to 7 feet below grade. Approximately 75 feet of steel sheeting will be installed in a straight line in the general location of the river's edge as indicated on Figure 6-2. The exact location and length of sheetpiling will be based on the presence of visually impacted material. OHM's sheetpile subcontractor will have at least 100 feet of sheetpiling onsite should additional sections be required. The installed sheets will be cut flush with ground surface and the cut pieces sent off-site as scrap metal. Appendix J contains vendor- supplied specifications for the "CS-69" sheetpiling.

The excavated area will be backfilled with bank-run sand or gravel material. This material is locally available and is similar in nature to the sediments which will be removed as per Figure 6.2. The backfill material will be tested for PAHs prior to backfilling to ensure that clean material is used. The backfill will be placed to pre-excavation elevations. The fill will be brought down the access road and then placed using a CAT D3 or equivalent bulldozer. No compaction testing will be required because the area will be flooded and the material will self compact. After backfilling is completed, a topographic survey of the river bottom will be conducted to confirm the quantity of backfill placed and consistency with the original contours.

All sandbags will be cut open and the sand placed in the excavation as backfill. The bags and visqueen will be disposed of offsite at the WMX Modern Landfill in York, Pennsylvania.

Upon completion of all backfilling, the enclosed area will be flooded by opening the seams in the Portadam, thereby equalizing pressure on the structure and liner. The fabric liner will be removed first; then the steel framework will be lifted out using the reverse of the installation method.

All components will be checked for damage, inventoried and packaged for shipping and reuse. All Portadam components will be accounted for. Divers will check the river bottom for components left in the work areas, if necessary.

OHM Project 20240 "" " "' " Columbia Gas-Columbia, PA December 3, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 11-1 AR400758 .1. ..«!»« •v ; 12.0 GEOTEXTILE AND RIPRAP INSTALLA TION

An 8 oz., woven geotextile will be placed along the river bank over the area of concern (see Figures 6-2 and 6-3). Geotextile and riprap will be placed along the same run as the sheetpile (Test pit F to GP01) to help stabilize and protect the river bank from future flood events. The geotextile and riprap will extend 10 ft. to the south of the sheetpile wall, into the river, and approximately 35 feet to the north of the sheetpile wall to approximately elevation 242 feet. The geotextile will be overlapped at the seams and skirted around the large willow trees. Once the geotextile is installed, riprap will be placed on top of it. Different sizes of riprap will be installed. From 10 feet out into the river to 10 feet up the bank, OHM will install 10 inch to 12 inch riprap. From 10 feet up the bank to elevation 242, OHM will install 6 inch to 9 inch riprap.

The installation of the riprap will be performed with the assistance of an excavator.

The access road will be left in place for future use by the Borough. Equipment will be decontaminated by pressure washing as needed. The water treatment plant and containment pools will be dismantled and the underlying cushion sand spread over the access road. The filter bags will be disposed with the sediment at R3 Technologies in Morrisville, Pennsylvania or with the debris at the WMX Modern Landfill in York, Pennsylvania. Disturbed areas will be seeded and mulched. The OHM Team will then demobilize its remaining personnel, equipment, and materials from the project site.

Erosion control devices will remain in place until the grass has reached at least 70 percent establishment.

Upon completion of the site activities, the OHM Team will prepare a closure report. The closure report will include the following:

List of Figures Executive Summary

1.0 Introduction 1.1 Closure Report Contents 1.2 Site Description 1.3 Mobilization 1.4 Field Changes

2.0 Description of Activities 2.1 Site Preparation 2.2 Excavation 2.3 Laboratory Data 2.4 Waste Water Treatment 2.5 Sheetpiling Installation 2.6 Geotextile and Riprap Installation 2.7 Backfilling 2.8 Demobilization

3.0 Waste Management Plan 3.1 Descriptions of Wastes 3.2 Waste Characterization 3.3 Disposal 3.4 Transportation 3.5 Documentation and Submittals

4.0 Health and Safety Report

5.0 Quality Control Summary Report

6.0 Summary of Record Documents

Appendices

Appendix A Daily Project Reports Appendix B Daily Safety Meeting Reports Appendix C Waste Manifest, Weight Tickets, and Certificates of Disposal Appendix D Post Excavation Soil Sampling Analytical Results Appendix E As built drawings (Final Graphic and Excavation Foot Print) Appendix F Weekly Project/Progress Meeting Minutes Appendix G Chain of Custody Forms

AR400762 Oll.M Remediation Services Corp. PROJECT MANAGER

MICHAEL EVANKO

- V,;... .j*~ "*^fe•£•;••••>--î:••^•Z&'ZX-^ZS&v&iSft.-l^l&ff^^Ss^ff^^yS^SSSîS«SS^^SK .Mr,.Eyankpjoined £)HM_in;19.90 and possesses;extejîve ;hanas pn;expenence mana >nazafd6us^waste>îtes%pntain1n"g''rnuid^^ "dredglingr'de'waterihg^rderôlin^ Management staff,"he is responsible for planning'arid implementing projects, client/contractor' relations'"ancf project administration"arid c6ordihaôn::He^

Experience

• Project Manager for an excavation, dredging, sheet piling, demolition, and dewatering project at the Columbus McKinnon Corporation site in Tonawanda, New York. This project's greatest challenge was the limited access and working area provided for the execution of the work. OHM removed over 2,500 cubic yards of soil in 2 cubic yard super sacks. OHM also dredged and dewatered over 2,500 cubic yards of PCB contaminated sediments. A successful partnering agreement was utilized on this project.

• Project Manager for a major manufacturer in Philadelphia, Pennsylvania, Project work involved the interior demolition/decontamination of a l.J million square foot facility. PCBs was the contaminant of concern. Interior demolition consisted of the removal of cranes, interior offices and buildings, catwalks, process equipment, and piping. OHM decontaminated the scrap, and shipped over 2,000 tons of material for recycling. Interior decontamination included pressure washing all areas using 10,000 psi water lasers. OHM completed the project without an injury sustained. The project work consisted of more than 20,000 man hours. OHM used an on-site laboratory, which conducted more than 2,000 analyses, using portable GCs.

• Project Manager for a private contractor who worked directly for the U.S. Navy at the Naval Surface Warfare Center in Dahlgren, Virginia. Project work consisted of dewatering two polishing ponds. OHM used a treatment system which included: a hydraulic dredge pump; mix tank; 100 cubic foot recessed chamber filter press; and storage tanks. OHM successfully reduced the volume/weight for transportation and disposal, and saved the client hundreds of thousand of dollars in transportation and disposal costs. The contaminants of concern were F006 constituents. The ponds were contaminated by a former plating facility. OHM also performed an extensive sampling program. This information was statistically analyzed and input into the Commonwealth of Virginia risk analysis program (REAMS). The risk analysis determined the future action required by the Commonwealth of Virginia.

• Project Manager for the removal of 2,000 cubic yards of soil at the Tobyhanna Army Depot in Tobyhanna, Pennsylvania. This project was performed for the U.S. Army Corps of Engineers under OHM's Rapid Response Contract. Work included the excavation, stockpiling, characterization, and transportation and disposal of TCE and PCE contaminated soils. OHM was aided in determining the extent of the contamination by using an on-site GCMs.

• Project Manager for a U.S. Navy project at the Naval Surface Warfare Center in Dahlgren, Virginia. Work included the RCRA closure of two sludge drying beds. The beds were excavated until proven clean,, backfilled, and restored. The project offered many challenges as they relate to performing a RCRA closure using a risk analysis.

Project Manager for Ogden Environmental, who was contracted by the Pennsylvania Department of Environmental Resources. Project work wa-, performed at the former Leighton Industries site in Phoenixville,

Informalinn herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 1 Rev. 8/97 AR400763 J^^^ OFLM Remediation ^^==" Services Corp. X_-=~- -^ AfcWUUrrrfOKM C*r**mu PROJECT MANAGER

Pennsylvania. Work included the gathering, segregation, staging, and characterization of over 600 drums and containers. Additional work included lab packing, test pit excavation, equipment decontamination, and small construction.

Project Manager for a Pennsylvania Department of Environmental Resources project at the SE Fire Apparatus site in Reading, Pennsylvania. Project work included the gathering, segregating, staging, and characterization of drums, small containers, and cylinders. There had been several fires at the site, requiring the removal of debris to access containers..

Project Manager for USEPA ERCS Removal, Stratford, Connecticut. Project work consisted of building decontamination, soil excavation, transportation, and soil bagging. The media were contaminated with asbestos, lead, and PCBs. One of the unique challenges was that small contaminated sites (1 to 5 acres) existed throughout the town of Stratford. This project included an overall workforce of more than 100 people who worked around the clock. Project managed only a 2 month phase. During this phase, approximately 50,000 cubic yards of material were handled and 30,000 cubic yards were bagged in super sacks.

Project Manager for a National Response Corporation (NRC) refinery oil spill in Westville, New Jersey. Work consisted of cleaning beaches, piers, and boats in New Jersey and Pennsylvania. At project peak, over 130 employees were on site. OHM had over 100 people on site in less than 48 hours. Approximately 15,000 man ' hours were completed in less than two weeks.

Project Manager for a Pennsylvania Department of Environmental Resources project in Whitpain Township, Pennsylvania. The work consisted of segregating drums, sampling, field testing, excavation, building decontamination, and transportation and disposal of waste. The project was performed at a former electroplating facility, and the contaminants of concern were acids, heavy metals, and cyanide. All work was completed ahead of schedule and under budget. Project duration was two months.

Project Manager of a facility decontamination for a major producer of asbestos brake pads in Mississauga, Ontario. Project work included high pressure washing; demolition; transportation and disposal; excavation; water treatment; electrical, chiller, compressed air, HVAC duct work, and dust collector duct work systems removal; and mechanical disassembly of a Bag House. Completing the work outside of the United States presented many challenges for the project. The project was compleied on schedule, to the client's satisfaction, and within budget. Project duration was four months.

Project Manager of a facility decontamination for a major communications producer in Camden, New Jersey. Project work included high pressure washing, scarification, process duct work removal, and surface re-sealant. The contaminants consisted of heavy metals, PCBs, and plating wastes. Work was finished in four months, and ahead of schedule, enabling our client to complete a major real estate transaction as planned.

Project Manager for an ECRA driven project at a linoleum producing facility in Trenton, New Jersey. This project involved the excavation and disposal of over 500 cubic yards of PHC and phalaies contaminated soils. The project also included the cleaning of several vaults, which involved confined space work.

Project Manager for an NRC member who spilled approximately 2,000 gallons of #4 oil on the deck and hull of barge. OHM worked 24 hours a day, until project completion. The barge decontamination was completed in half the time estimated by both the client and marine surveyor.

Project Manager for the removal of a former plating neutralization vault in East Windsor, New Jersey. All project work activities were completed within schedule and at 75% of budget.

Project Manager for the neutralization and decontamination of mercaptan contaminated tanks. The project involved the construction of ah air tight containment area where the tanks could be treated. Vapor scrubbing system was put in place to treat the release of mercaptan in the containment area. Due to the volatile nature of mercaptan, a reactor system was implemented to slowly bleed and treat the tanks.

Information herein is proprietary and confidential and to be used or released lo others only with explicit written permission of OHM Remediation Services Corp. 2 ' Rcv.'s/97 AR400764 ^•^==. OHM Remediation !X.' _£=^~ Sen-ices Corp. >=- ^UM^O^C-^. PROJECT MANAGER

Project Manager for sludge dewatering project at a chemical plant in Delaware City, Delaware. The project *• consisted of the dewatering of 30,000 gallons of mono-chlorobenzene contaminated sludge. Dewatering resulted in better than projected solids removal.

• Project Manager for many emergency responses and spills in the Northeast Region, including traffic incidents, shipping incidents, and facility spills.

Contract Auditor for U.S. EPA ERGS contract for approximately 1 Vi years. U.S. EPA ERCS contract was a *- • 5 option year term contract with a total value of $88 million. Responsibilities included: maintained communications between program management and ERCS billing; coordinated submittals and receipt of 1900- 55 forms; prepared 1900-55s for small and standby projects; preparing program management reports, month end closings, and project accounting ERCS training.

• Project Accountant at the Turnpike Dump No. 5 site for USEPA in Jersey City, New Jersey. Prepared daily 1900-55s for USEPA, and was responsible for government procurement of goods and services, field purchasing, VJ time card approval, invoicing approval, resource allocations, filing, maintaining document control and purchasing logs as well as other site-specific logs, and client interface! Project duration was May to August 1991.

^^•. • Project Accountant at the Valley Bumper Plating site in Richmond, Virginia for USEPA. Responsible for hazardous waste manifesting, disposal coordination, field purchasing, client interface, and maintaining document control. Project was conducted April 1991.

!—* • Project Accountant at a major tanker oil spill in the Kill van Kull off Staten Island, New York. Responsibilities included daily reporting, progress reporting, site documentation, and on-site purchasing. Project duration was ^ June to August 1990.

Academic Background v— B. A., Economics & Business Administration, 'Ursinus College, 1990 Graduate Course Work towards Master's Degree in Environmental Science, New Jersey Institute of Technology \_ Specialized Training

40 Hour OSHA Trained "^v^x . 8 Hour OSHA Supervisor Course 8 Hour Refresher Course ' • . • ERCS Management Training Seminar ^, Government Procurement Training Underground Storage Tank Removal Training

References •>_• Craig Sams, DuPont Environmental Remediation Services, (302) 992-6987 Tony Roche, U.S. Army Corps of Engineers, (609) 893-0983 ^ Jim DeSantis, Public Service Electric & Gas Company, (201 ) 430-6675

Information herein is proprietary and confidential and to be used ar released to others only with explicit written permission of OHM Remediation Sen'ices Corp. 3 Rev. 8W AR400765 _^=g^_ OIIi\l Remediation ~ ^^S1" Scniccs Corp. N-" 1 I 1 'UN] -fflH" CnjijlMii PROJECT SUPERINTENDENT

MARK M. FRIAR

£5**r

1 K 1 ;: i 1 i N • -;<•••-**• i.-. ,v* f*b,f-,- ^.f « - • v'"^^-/v 5*/«™«?S-' » '* * -"?~~*^- T > •** A'-TI—^«s •J" 2 «^r ^î^*-*T'*^v^**^5t^^" ™^ '^îl?*^?**' *1' *-•-***. •S'v- ^--rf.-^ ^J-* \jTv^\.r /* *.•"•»-• ••.v^,;r.>*-.7::;^r;*V^:~-^ His on-site experienc r e include - s development and execution of approved wbfk.plans, developmen1 J t of detailed cost. -. - . :>, • .'• - .. , :- • *. - •• ?• ."• .^ <;.<• -•, '. \iw; ..- .*^ • •; *-y^'••'?.-."."">* ^tjfiT^-i'îr-^v;.^- ,*?,-*,-,*> ,,< j'. %;«•!.- ..s-'.'-^-.'f /v^" ^ -r^~^* ; ^»s\(p» v^^^^îîi^^^^v ^rf-^ estimates and approved site and spill safety plans; application"of heavy equipment an3'field construction require-"- mehts, working in confined spaces','performance:.pf assessmentsrahd evaluations;at^^â hazardous. wast'

Experience

Mr. Friar's experience with environmental technologies includes:

• Drum recovery and repackaging • Wastewater treatment • Groundwater treatment • Landfill closures PCB cutting/bulking Contaminant sampling • Hazardous waste disposal • Underground recovery • Shock-sensitive/explosive/ • Filtration reactives handling and disposal • Dewatering • Compressed gas cylinder identification • Air monitoring handling/neutralization • Soil excavation • White phosphorous • Facility decontamination Air/water reactives handling • Derailments • Bioremediation • Drum repackaging Soil treatment • Pesticide cleanups • Building demolition « Labpacking

Detailed below are some of the projects in which Mr. Friar has been involved:

• Supervised a crew of 14 for a U.S. EPA Region II ERCS project at the Li Tungsten Superfund site in Glen Cove, New York. The site consisted of 242 storage tanks, ranging in size from 1,000 gallons to 500,000 gallons. The crew accessed, hazcatted, and bulked samples for off site analysis. Once tank contents were' characterized, liquids were bulked into like bulk groups. The site contained various contaminants including acids, bases, PCBs, DDT, and friable and non-friable asbestos. Other materials found on site contain low level radioactivity, primarily isotopes, thorium, uranium, and radium. All radioactivity on site is considered to be Naturally Occurring Radioactive Material (NORM). Tasks completed to date include sampling and analysis of tanks and drums; labpacking of small jars and materials used in a laboratory; friable asbestos removal; tank decommissioning; tank decontamination; bulking and disposal of wastes in tanks; bulking of drummed material; and decommissioning of transformers containing PCB oils and water.

• Supervised the excavation and removal of an underground storage tank (UST) for a U.S. EPA Region II ERCS project at the Denzer and Schafer X-Ray Company site in Bayville, New Jersey. The tank was removed, cleaned, decommissioned, and loaded out for scrap. OHM sampled and backfilled the excavation.

• Supervised the decontamination of a 1,100,000 square foot railroad manufacturing facility in Philadelphia, Pennsylvania. OHM decontaminated the facility using a 10,000 psi high pressure washer. OHM used an on-site laboratory to analyze PCB samples, to confirm cleanliness of pervious and impervious surfaces. Mr. Friar also supervised a demolition subcontractor for the demolition of interior steel and structures. OHM constructed and implemented a water treatment system to treat collected rinse waters to acceptable levels, for discharge to the

Information herein r'j proprietary and confidential and to be used or released tu others only'v/ith explicit written permission of OHM Remediation Services Corp. 1 Rtv. 8/97 AR400766 J/'^^=- OHM Remediation SL^ _^==" Services Con). >g ^-«~^~»c~r~- PROJECT SUPERINTENDENT

local POTW. OHM cleaned and loaded out scrap steel that was generated from the selective demolition of the building's interior. OHM also loaded out and disposed TSCA and non-TSCA debris and solids that were generated from the building decontamination and demolition procedures.

• Supervised the excavation of kaylo material and asbestos containing insulation and soil at the Owens Corning Fiberglas site in Berlin, New Jersey. Approximately 60,000 cubic yards of material was.relocated within one month. A clay lined cap and perimeter run-off controls were also installed at the site. The site was backfilled and restored at project completion. Mr. Friar supervised a crew that averaged 3Q to 37 on-site personnel.

Supervised the excavation, dredging, and dewatering of PCB-contaminated soil and creek sediment at the Columbus McKinnon site in Tonawanda, New York. The project also involved sheet pile wall installation. Mr. Friar supervised a crew of 24 personnel, including subcontractor personnel. Project operated on a 24 hour per day basis.

« Supervised the dewatering of a one million gallon storage tank (coal gas relief holder) at the Environmental . Science and Engineering plant in Concord, New Hampshire. Contaminants of concern were benzene, petroleum hydrocarbons, coal tar, and volatiles. Sludge was dewatered using pre-press chemical treatment, which consisted of emulsion breaker, polymer, acid adjustment, and dietemaceous earth. Treated filtrate water was discharged to local Publicly Owned Treatment Works (POTW), and the filter cake was shipped off site for disposal.

• Supervised the excavation, relocation, and packaging for disposal of lead and asbestos contaminated soil at a site in Stratford, Connecticut, under the direction of the USEPA Region I. Approximately 45,000 cubic yards of clean soil was backfilled. Mr. Friar supervised a crew of approximately 80 on-site personnel.

• Supervised the decommissioning, cleaning, and removal of 32 tanks containing xylene, formaldehyde, fuel oil, ethylene glycol, ortho cresol, sylvesso, and various resins in Schenectady, New York. He was responsible for implementing the work plan, health and safety plan, on-site relations, project scheduling, estimating, and submitting change order work.- Mr. Friar oversaw all aspects of tank decommissioning, cleaning, cutting and removal; air monitoring; and internal cost tracking of the project.

• Supervised operations involving dumpsite assessment, drum segregation and overpacking, debris removal and installation of perimeter fencing at the Turnpike Dump No. 5 site in Jersey City, New Jersey for the USEPA. Contaminants involved were PCB, lead, petroleum hydrocarbons, unknown chemicals in drums, gas in cylinders, tires and general debris. Responsibilities included implementation of work plan, site safety plan, On- Scene Coordinator relations, field management and supervision of a foreman and cleanup crew.

Supervised drum removal and labpack crushing at the Muratti Drum Dump site in Penuelas, Puerto Rico for the USEPA. Contaminants involved were solvents, oils, sludge, paint and unknown chemicals. Supervised a crew of one chemist, two sample technicians and four recovery technicians on this project.

• Supervised drum excavation, overpacking, sampling, and disposal of 980 drums of contaminated waste for the USEPA at the Chesnutis site in Beacon Falls, Connecticut. Ninety waste streams were discovered to contain PCBs, pesticides, organics, inorganics, MEK, benzene, and other pollutants. Mr. Friar implemented the work plan, and operated a 215 trackhoe equipped with a 360 degree grappler, a 936 rubber tire loader, and a 580K trackhoe outfitted with a punch. His crew consisted of 20, including recovery technicians, equipment operators, sample technicians, surveyors, and chemists.

Supervised buried drum and soil excavation for the USEPA at the Hooper Sands site in South Berwick, Maine. . The project involved removing 2,000 cubic yards of soil and approximately 400 drums. Mr. Friar supervised a crew of eight, including cleanup and sample technicians, and chemists. He also operated the 215 trackhoe, equipped with a 360 degree grappler to excavate the drums.

• Supervised a landfill closure with a recovery system and a methane gas recover)' at a pharmaceutical manufacturing facility in New Haven, Connecticut.' It was discovered that the landfill's lead contamination was

Information herein is proprietary and confidential and to be used or released to others only -with explicit written permission of OHM Remediation Services Corp. 2 R«- 8W7 AR400767 ^^^s. OHM Remediation % .ss1" Services Corp. -, ^>^= ...^o~c^ PROJECT SUPERINTENDENT

100,000 ppm. It was also polluted with sludge containing various solvents and hydrocarbons. Mr. Friar ^. supervised four equipment operators and 10 recovery technicians. He operated a 225 excavator, a 215 trackhoe, and a bulldozer.- • . '

• Operated a 215 trackhoe for a tank excavation involving gasoline and fuel oil contamination at a manufacturing *"* • • facility.in Worcester, Massachusetts.

• Supervised the excavation of gasoline and fuel oij-contaminated soil around numerous one-rnillion-gallon tanks -^. at an oil refinery facility in Newark, New Jersey. Supervised the team of equipment operators and recovery technicians.

• Supervised the excavation of soil contaminated with mercury at an aluminum manufacturing facility for a """ confidential client in Vineland, New Jersey. Oversaw a crew of four recovery technicians during the project.

• Supervised for the USEPA at the Fried Industries Superfund site in East Brunswick, New Jersey. Project V- involved drum overpacking and sampling a variety of pesticides, caustics, and acids with various volumes of these contaminants due to labpack and unknown crushing. Supervised the sample technicians and equipment operators.

\^s * Supervised the dewatering of a lagoon, the installation of a plate and frame sludge press, and the initiation of a water treatment system for the USEPA at the Valley Plating Superfund site in Richmond, Virginia. The contaminants were heavy metals, cyanides, acids, caustics, chromium, and lead. Oversaw a crew of seven, r- including equipment operators and a recovery technician.

• Supervised the excavation of soil for bioremediation as a result of a diesel fuel spill for a railway corporation in Lancaster, Pennsylvania (confidential client). Approximately 3,000 cubic yards were excavated, staged, and disposed. Supervised a crew of equipment operators and a recovery technician, and operated a 215 trackhoe.

• Supervised building decontamination, consolidation of contaminated spilled fluids, sampling, and removal of "** hazardous wastes for the USEPA at the Silsonix site in Irvington, New Jersey. Contaminants included a large quantity of acids and caustics, and a lesser volume of cyanide. Oversaw a crew of 12 recovery technicians.

•> • Supervised the dredging and dewatering of approximately 3,500 cubic yards of PCB-contaminated river sediments at the Aluminum Company of America (ALCOA) plant in Massena, New York. Two thousand linear feet of silt curtains were installed at the site. Dredging operations consisted of two phases: 1.) boulder excavation from a floating barge using a long stick excavator and 2.) dredging of sediments using a horizontal vx^x auger dredge. The sediments were treated using lime, then pressed through four 100 cubic foot presses. The sediments were desanded through a V-bottom tank/incline auger and desander shaker before reaching the lime mix station. Materials were processed at approximately 1,500 gpm through the raw sediments, and at _J approximately 600 gpm through the press filtrate and water treatment. Mr. Friar supervised a crew of 27 employees and three subcontractor employees.

^^ Specialized Training

OSHA Site-Safety and Related Training V, OSHA 8-Hour Refresher Training, Annually OSHA 8-Hour Supervisory Training, Annually First Aid, 1994 OSHA 40-Hour Training, 1987 '"•" Tank Patch course (40 hour), 1985 Asbestos Supervisory course (40 hour), 1988 Welding training, 1980 •w Automobile Mechanics training, 1978-1981

Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3 R«- *m AR400768 ^••^s. OHM Rcmcdialion ^^p" Services Corp. V^ t**MttvT*OU

References

Anthony Sturtzer, ALCOA, (315) 764-4775 Joe Rotola, U.S. EPA, (908) 321-6652 Jack Harmon, U.S. EPA, (908) 906-6872

Information herein is proprietary and confidential and So be used or released to others only with explicit written permission of OHM Remediation Sendees Carp. 4 Rev. 8/97 AR400769 ^^^=- OIl.M Remediation ~~ j^jT Services Corp. X - i r^iuiirj ifrirn r SENIOR PROJECT ENGINEER/MANAGER

KRIS ALZHEIMER

iCv"v "_ •., *\ . j'1"- •** •"";' >•* i*«\*Kfc%i

'"currently seryes''^^'^^ engineers, CADD operatbrs*'aht3 field QC/civil engineers. His responsibilities include trie design/build of landfill""

Experience

Mr. Alzheimer's overall experience is detailed as follows.

OHM Remediation Services Corp., 1997 - Present, Senior Project Engineer/Manager. Mr. Alzheimer is currently serving as the Senior Project Engineer at the Sterling Hilton Davis site in Cincinnati, Ohio. The project entails low temperature thermal desorption of contaminated, soils, using the X*TRAX system. He is responsible for overseeing the design and installation of the process piping for the low temperature thermal desorption unit. He provides daily design layouts and directs field CADD drawings for the piping and structural supports during the critical installation phase of this lump sum project.

Rust Environment & Infrastructure, 1995 -1997, Engineering Group Manager/Senior Project Manager. In this position, Mr. Alzheimer organized and guided group efforts, acted as liaison between staff and management, and mentored and assisted junior staff engineers in the development of project management skills. Performed the functions of construction Quality Assurance Officer and/or Certifying Engineer at multiple project locations. Developed contract documents for earth construction, synthetic liner construction, landfill gas collection systems, force main piping, and gravity piping systems construction.

As Senior Project Manager (1992-1995), Mr. Alzheimer was involved in direct consultations/negotiations between clients and regulatory agencies to develop sound engineering, environmentally sensitive, permits and monitoring requirements. Planned, scheduled, and distributed workload to project team on multiple projects. Estimated cost and tracked project performance to ensure project completion within budget and on schedule. Developed construction cost estimates and material schedules.

His project experience includes the following:

Supervised the activities of a team of engineers, technicians, and administrators in the development of an application for an operating permit at -Blue Ridge Recycling and Disposal Facility in Ervine, Kentucky. Obtained

Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 1 AR400770 _^=-^==-_ OHM Remediation *V •r^S1' Services Corp. >^==- t~~*«*mc—u. SENIOR PROJECT ENGINEER/MANAGER

. the development and operating permit in expeditious manor, thus minimizing interest expense on capito! investment.

• Led a team of engineers in the development of a construction quality assurance plan for Laraway Recycling and Disposal Facility in Elwood, Illinois. This required review of RCRA applicable regulations and development of monitoring and testing strategies. Result'of implementing the plan saved a $25,000 contingency budget by eliminating rework and maintaining construction schedule.

His project management experience is listed below.

1994 - Laraway RDF, Elwood, Illinois

. Managed and served as the Construction Quality Assurance Officer/Certifying Engineer for the installation of a Cell 5 liner and leachate collection system, which consisted of 2-feet of compacted clay (lxlO"7cm/s) overlain by a 60 mil HDPE liner. Construction materials consisted of a granular drainage media and 16oz/sq.yd. geotextile on base. Geocomposite on side slopes comprised the leachate collection system.

1995 - Laraway RDF, Elwood, Illinois

Managed and served as the Construction Quality Assurance Officer/Certifying Engineer for the installation of a Phase 1 final cap, which consisted of a 12-inch compacted clay overlain with 35 mil VLDPE/HDPE composite material. Coverseal®, a 2 ft protective layer, was then placed over the 35 mil synthetic.

1996 - Laraway RDF, Elwood, Illinois

Managed and served as the Construction Quality Assurance Officer/Certifying Engineer for the installation of a Cell 6 liner and leachate collection system (same as Cell 5).

1996 - Kankakee RDF - MSW Landfill

Managed and served as the Construction Quality Assurance Officer/Certifying Engineer for the installation of a Cell 1 Area 4 clay liner and leachate collection system. The base liner consisted of a 5ft compacted clay liner (IxlO'7 cm/s) and 1ft granular drainage layer.

1996 - KI Sawyer AFB, Marquette, Michigan

Designed and served as Construction Technical Manager and Certifying Engineer for the construction of a closure system. The system consisted of a 45 acre composite final cap, consisting of a 12-inch gas vent layer, a 40 mil HDPE liner, a 26-inch drainage layer, and 4-inches of topsoil.

Waste Management, Inc., 1989 - 1992, Project Engineer.

As a Project Engineer, Mr. Alzheimer planned, scheduled, and distributed the workload on project tasks; reviewed staff engineer work for compliance with project specifications and accuracy; developed construction specifications and contract documents .for landfill gas management construction projects; and performed construction management activities, including selection of vendors and contractors for the construction of landfill gas collection systems.

As Staff Engineer (1985-1989), Mr. Alzheimer performed complex engineering calculations and designs, and compiled engineering reports. He also served as Resident Engineer (RE) on numerous projects, including landfill gas collection systems at Parklands Landfill (NJ), L & D Landfill (NJ), Modern Landfill (PA), closure cap work at Cinnaminson Landfill (NJ) and Cape May Landfill (NJ). .

Wehran Engineering, 1982 -1985, Engineer In this position, Mr. Alzheimer performed design engineering, calculations, and field monitoring and testing. Served as Construction Manager, responsible for ordering materials, hiring contractors, and coordinating materials and labor

Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 2 Rev. 8/97 AR400771 ^IP^. OHM Remediation *X. J=~ Services Corp. >^ "•—'"°"c^— SENIOR PROJECT ENGINEER/MANAGER

for multiple landfill gas to electric facility projects. Assisted in development of new technologies in landfill gas collection as part of the research and development team. .

United States Army r Corps of Engineers, 1974 -1977, Specialist - Cartographer Developed military maps from satellite and aerial photography and field reconnaissance.

Academic Background

Bachelor of Science - Civil Engineering, West Virginia Institute of Technology, Montgomery, West Virginia, 1982. Ocean County Community College, Toms River, New Jersey, Interpretation of Contract Documents - Deans List, 1978. United States Army Engineering School, Belvoir, Virginia, Cartography, 1974.

Specialized Training

OSHA 40-Hour Certification Effective Supervision I - Professional Management Series by Dr. John Sherwood Effective Supervision II - Professional Management Series by Dr. John Sherwood Project Scheduling and Management 40-Hour course Designing with Geosynthetics by Dr. Robert Koerner

References

Bob Lewis, Waste Management, Inc., (847) 520-8230 Bert Maline, Laraway RDF, (815) 727-6148 Colonel Rod Irey, Rust Environment and Infrastructure, (630) 574-2006

Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3 Rev. Wl AR400772 =- OHM Remediation ^= Services Corp. SENIOR HEALTH AND SAFETY TECHNICIAN

CHARLES E. GREEN

communication system; maintaining the local. medical'surveillance' arid, emergency cbn'ductujs site-SDecific erhblovee' rrainine' an^'informarion'sessiohsfconductuiE t

Experience

Mr. Green's OHM project experience is highlighted below.

• Allied Signal. Ashland. Kentucky - Senior Health and Safety Technician at a 25-acre site that formerly manufactured chemicals and roofing paper products. The project involved the remediation of soils contaminated with high concentrations of heavy metals.

• USEPA Region I ERCS. Fresco Silver. Maplewood. New Jersey - Senior Health and Safety Technician for a project involving cleaning aboveground storage containers containing solvents and unidentified compounds. The project also involved the removal, segregation, characterization, and temporary storage of waste. Mr. Green was responsible for the implementation of the site-specific health and safety plan.

US. Navy LANTDTV. Russell Road Landfill. Quanfico. Virginia - Senior Health and Safety Technician for a project involving the excavation and redistribution of contaminated site soils, abandonment of monitoring wells, installation of new pipe and liner, and placement and compaction of a clay cap. Mr. Green was responsible for the implementation of the site-specific health and safety plan.

• AFCEE. Pittsburgh AFB. Pittsburgh. New York - Senior Health and Safety Technician for a project involving the cleaning of 75-100 aboveground and underground storage tanks containing fuel oil and gas. Mr. Green was responsible for the implementation of the site-specific health and safety plan.

• Industri-Plex Superfund Site. Woburn. Massachusetts - Site Safety Officer on 245-acre site that formerly manufactured chemicals, leather, textile, and paper products. Soils were contaminated with high concentrations of heavy metals, including chromium, lead, and arsenic. Scope of work included surface and subaqueous capping, thermal treatment of collected gases, extensive wetlands remediation and restoration, and on-site treatment of site waters utilizing flocculation and carbon filtration.

• Whitmover Laboratories Superfund Site. Jackson Township. Pennsylvania - Site Safety Officer responsible for field coordination of the safety, health, and emergency response plan for this Superfund project involving the removal, segregation, characterization, and temporary storage of waste; buried drum excavation; demolition; and construction.

« Schmalz Landfill Superfund Site. Harrison. Wisconsin - Site Safety Officer responsible for field coordination of the safety plan for this Superfund project involving the excavation and redistribution of site soils contaminated with trivalent chromium and lead, abandonment of existing monitoring wells, installation of. new monitoring wells, and placement and completion of a clay cap.

• USDA Beltsville Agricultural Research Center. Beltsville. Maryland - Site Safety Coordinator responsible for field coordination of the site-specific health and safety plan, conducing personal and real-time air

Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Sen-ices Corp. 1 Rtv. 8/97 AR400773 ^IP^ OHM Kemedialion =X. -•==• Services Corp. >^ *.—,-,-.» c^— SENIOR HEALTH AND SAFETY TECHNICIAN

monitoring, and overseeing personnel decontamination on project involving excavation and relocation of unregulated waste in a newly constructed cell at the site.

• Model City Cell Construction and Site Upgrades. Model City. New York - Site Safety Coordinator reporting to Certified Industrial Hygienist. Responsible for conducting personal and real-time air monitoring, coordinating and assisting in development and coordination of health and 'safety plans for various projects at this permitted RCRA/TSCA disposal facility.

• DuPont Pompton Lakes. Pompion Lakes. New Jersey - Site Safety Officer responsible for conducting real- time air monitoring, personal pump monitoring, blood and urine testing for mercury and lead, and coordinating and assisting in the writing of health and safety plans for the various remedial projects at the site. Mr. Green was a member of the DuPont Safety Committee, which established safety procedures and protocols. The site was used as a disposal area for off-spec blasting caps which resulted in the release of heavy metal compounds. The project consisted of physical separation, solidification, dewatering, construction, and extensive soil and erosion controls.

Specialized Training

8-Hour Site Supervisors Training, 1989 40-Hour Site Safety Officer Training, 1989 OHM 8-Hour Site Safety Supervisors Training, 1995 Confined Space Entry, 1994 SCBA Repairing Air Equipment, 1995 Professional Driver Improvement Canada Safety Council, 1995

Information herein 15 proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corn.

2 Rev. 8/97 AR400774 DONALD E. DEL NERO, II Senior Geotechnical Engineer

Experience Summary

Mr. Del Nero's experience includes planning, studies, design, and construction oversight in the areas of civil, environmental and geotechnical engineering. Significant projects completed in the area of civil engineering include gravity and low pressure sewer studies and design, traffic analysis and design, and storm water analysis and design. In the area of environmental engineering, his significant experience is in solid and hazardous waste management. He had been involved in over 20 landfill closure designs consisting of cover system evaluations, piping design, site drainage analysis, culvert design, access road design and leachate management. Geotechnical engineering experience includes subsurface investigations and foundation system analyses and designs for buildings; over 10 water storage and treatment facilities; various pipelines including natural gas, water, and sewer; slope stability analyses; seismic analyses; retaining wall design; and geosynthetic design.

Experience Record

4/94-Date Parsons Engineering Science, Syracuse, New York

5/89-3/94 Stearns & Wheler Engineers, Cazenovia, New York

Foundations Design

Project Geotechnical Engineer for the evaluation and design of foundations systems for the 94 cfs Hiawatha Combined Sewer Overflow Regional Treatment Facility for the Buffalo New York District Army Corps of Engineers and the Onondaga County, New York Department of Drainage and Sanitation. The project consisted of a concrete influent diversion structure; a 30' diameter, 15' deep swirl concentrator; a 275,000 gallon, 30' deep storage tank; a 160,000 gallon disinfection tank; and a control building. The final design included deep mat foundations, end-bearing H-piles, and shallow continuous footings. The geotechnical constraints included substantial uplift conditions from a groundwater depth of less than 5 feet, very weak and heteorgeneous soils for the first 40 feet of subgrade, critical connections to existing facilities to avoid differential settlements, and construction excavation and dewatering issues. Special provisions were considered in the design such as lightweight backfills for reduction of geostatic stresses, pipe trench backfill transition zones for existing pipeline connections, groundwater relief ports or flap valves in the tankage, groundwater monitoring during constructions to inhibit excavation blowout, and the use of non-frost susceptible soils to reduce the depth of shallow foundations.

Project Geotechnical Engineer for a design investigation and evaluation for on-site soils and waste areas and off-site borrow sources for construction of environmental facilities at the Fernald Environmental Management Project in Fernald, Ohio for the U.S. Department of Energy. The project consisted of the development of geotechnical sampling and testing plans, review of previous geotechnical data, geotechnical field oversight, and geotechnical engineering reports to provide subsurface soil properties and parameters to support development of design criteria, and to provide parameters for excavation, disposal facility design, and site restoration.

Project Geotechnical Engineer for the site investigation and foundation design for the 28 MGD West Side Pump Station Upgrade for Onondaga County, New York. The project included a generator building, a

-1-

AR400775 __ diversion structure, and two wet wells. The geotechnical scope of work included review of geotechnical record information, evaluation of subsurface conditions, development of geotechnical parameters, an evaluation of shallow and deep foundation options, and design of H-pile foundations for all four site structures and preparation of a geotechnical report summarizing the geotechnical findings and recommendations.

Project Engineer responsible for the geotechnical evaluations of three separate natural gas transmission line design projects. These geotechnical evaluations involved design of subsurface investigations, evaluation ~ of the need for additional investigations, designed appropriate geotechnical laboratory testing, and evaluation of pipe performance and recommendations for special piping foundations.

"* Project Engineer responsible for the geotechnical aspects of over 10 water storage or treatment facilities. These facilities have included standpipe storage tanks, storage tanks, elevated storage tanks, clarifiers, clearwells, and aeration tanks. Clients included the Village of Rockville Centre, New York (2001 — high elevated water storage tank), Calvert County, Maryland (46' diameter sequencing batch reactor), Village of Cooperstown, New York (35'X35' clearwell), Harford County, Maryland (Sludge Pumping Station and 40' diameter clarifier), Erie County, New York Sewer District #2 (Aerobic Digester and 100' diameter secondary clarifier) ~^—^ Specific engineering responsibilities were: 1) evaluated the proposed structures from a geotechnical __ standpoint; 2) designed subsurface investigation programs for the projects; 3) provided oversight during the field investigation or supervised the field investigation; 4) designed a laboratory testing program to characterize the engineering properties of the soils; 5) developed a geotechnical characterization of the subsurface; 6) evaluated the proposed foundation and made recommendation for its use or an alternative foundation type; 7) ~ calculated the bearing capacity and settlements that could be expected from the structure loadings; and 8) prepared a geotechnical report summarizing findings and recommendations for special foundations or backfills.

"" Construction engineering for site pre-consolidation for the Sam's Wholesale Club in Syracuse, New York. The project included excavation of peat and normally consolidated clays, the placement of a pre-load, and the installation of geosynthetic wick drains. m* Slurry/Cutoff Walls

•>^ Geotechnical review of a slurry wall stability analysis and slurry trench stabilization for the Buffalo Color Area "D" Site for Allied-Signal, Inc. The project consisted of a 40 foot deep soil/bentonite slurry wall for groundwater containment. Geotechnical conditions included high groundwater, loose debris and heterogeneous fill materials, and a close proximity to the Buffalo River with up to 20 feet of water level fluctuation. The geotechnical scope of work included an evaluation of active soil pressure, short-term and long-term stability analyses, and stabilization methods for short-term stability.

Slope Stability

Geotechnical Engineer for the stability evaluation of proposed channel banks for the Bergstrom Air Force Base, Austin, Texas. The site consisted of a 3,000 to 4,000 cfs stormwater channel with varying channel geometry and stabilization methods. The geotechnical aspects of the project included evaluating soil test boring logs, geotechnical laboratory data to develop soil shear strength parameters, and rotational stability evaluations for both drained and undrained conditions.

-2-

AR400776 Project Geotechnical Engineer for the stability evaluation and closure plan for the Upper and Lower, approximately 1.5 MM gallon, Phossy Ponds at the Rhone-Poulenc Basic Chemicals elemental phosphorus production facility near Mt. Pleasant, Tennessee. The project consisted of a geotechnical evaluation of current, construction, and post-closure dike integrity. Specific tasks included the review of record information, evaluation of closure alternatives for the 30' high, pond dikes as it relates to translational and rotational stability, sampling and testing of dike materials and on-site borrow soils, and the identification and resolution of closure construction issues. Special geotechnical constraints included the inability to extract dike samples for testing because of the risk for spontaneous combustion of materials.

Landfill Engineering & Geosynthetics Design

Project Geotechnical Engineer for the design, and Project Manager for the construction of a 5-acre double-lined landfill for Delaware County, New York. Project included geotechnical evaluation and design, liner systems design including geosynthetics, site stormwater analysis and design including detention basin sizing and culvert design, and perimeter access road design including a leachate transfer station. The geotechnical aspects of the project included landfill subgrade bearing capacity evaluation, landfill subgrade settlement evaluation, veneer stability evaluation, liner system blowout, and leachate impoundment berm stability.

Design engineer on a design team for the final design phase of a regional solid waste management facility for the Franklin County, New York Solid Waste Management Authority. The facility includes a 20-acre landfill which is subdivided into 4 cells with a double composite liner and pore pressure relief system, leachate conveyance and storage facilities, and a two acre construction and demolition (C&D) landfill. These facilities were designed to meet New York State Regulations, Title 6 NYCRR Part 360, governing solid waste management facilities.

Project Manager/Project Engineer on MSW landfill closure design projects: Clients included: Southwest Oneida County, NY; Town of LeRay, NY; City of Watertown, NY; Town of Manlius, NY; Chenango County, NY; Town of Webb, NY; Town of Wilna, NY; German Flatts, Ilion, and Mohawk, NY; City of Auburn, NY; Orange County, NY; Griffiss AFB Hardfill Designs, NY, Air Force Center for Engineering Excellence (AFCEE); Schatz Landfill, NYSDEC; Cherry Farm/River Road Site, NY, Allied-Signal and Niagara Mohawk; Buckingham County, VA; Camp Verde, AZ; Metro-Dade County, FL; and Buffalo Color Area "D", Allied-Signal. Civil and geotechnical engineering tasks included:

• analysis and design of storm water control facilities; • design of soil and geosynthetic cover system components; • design of gas control systems; and • veneer and global slope stability analyses;

Education '

M.S., Geotechnical Engineering, May 1994, Syracuse University, Syracuse, New York

B.S., Civil and Environmental Engineering, May 1989, Clarkson University, Potsdam, New York (Graduated with Distinction)

Geology Concentration, May 1987, Potsdam State University, Potsdam, New York

-3-

AR400777 OSHA 24-hour Training .

CPR/First Aid Training

Software Expertise

U.S.D.A. Soil Conservation Service TR-55 Urban Hydrology for Small Watersheds

U.S.D.A. Soil Conservation Service TR-20 Hydrology Model

Federal Highway Administration HY8 for hydraulic analysis and design of culverts

Transportation Research Board; Highway Capacity Manual Software

Hydraulic Evaluation of Landfill Performance (HELP) Model

Geopro Geotechnical Engineering Program Collection

PCStable Geotechnical Slope Stability Software

PCSLOPE Geotechnical Slope Stability Software

WESHAKE Seismic Stability Software

Professional Affiliations

Registered Professional Engineer, 1994, New York, No. 070933 Construction Specification Institute - Certified CDT American Public Works Association - CNY Branch Secretary American Society of Civil Engineers

Honorary Affiliations

Chi Epsilon, Marshal (1988-89) TauBetaPi

Publications

"Seismic Response of Solid Waste Landfills", Earthquake Design and Performance of Solid Waste Landfills, Geotechnical Special Publication No. 54, American Society of Professional Engineers, 1995, Coauthors.

"Leachate Reduction: The Simple Solution", MSW Magazine, May/June 1994, (coauthor Scott R. Gladstone).

References

Ed Hemig, Wyeth-Ayerst, Inc., (610) 902-3533 Kevin O'Brien, P.E., City of Niagara Falls, New York, (716) 286-4410 Janet Krolczyk, Southdown Inc., (713) 650-6200

-4-

AR400778 WILLIAM J. LONG Civil Engineer/Manager

Experience Summary

Mr. Long has 16 years of civil engineering experience in remediation design, work plan preparation, cost estimating, closure report preparation, hazardous materials management, feasibility study preparation, environmental assessments, permitting, and construction management.

Experience Record

1992-Date Parsons Engineering Science. Civil Engineer/Manager. Responsible for civil engineering related to hazardous waste treatment and remediation projects including the preparation of Feasibility Study alternatives analyses, work plans, operation and maintenance plans, closure reports, constructability reviews, cost estimates and the design of hazardous waste remediation projects. Prepared Feasibility Studies for three sites involving metals, PCB and PAH contamination of soil, sediments, buildings, and debris; prepared the work plan and cost estimate for the installation of an LNAPL recovery system; prepared decontamination plan for the closure of PCB and hazardous waste storage areas; and prepared specifications, construction cost estimates, design calculations, design drawings and. specifications for closure of five landfills, three of which are 40-acre landfills listed on the New York State registry of Inactive Hazardous Waste Disposal Sites. Other projects involved oversight for test pits conducted at suspected drum burial sites, UST closures, and RCRA storage area closures.

York Oil Site, Design Project Manager. Project involved the design of a passive LNAPL collection system consisting of a lined collection trench, recovery sumps and belt skimmer system. Responsibilities included the preparation of drawings, specifications, and the construction cost estimate; and the coordination/supervision of the design staff.

Lehigh Industrial Site, Lackawanna, NY, Design Project Manager. Project involved design services for the remediation of a former metal scrapyard, including the demolition of abandoned site structures; asbestos removal; removal and off-site disposal of hazardous PCB contaminated soil, transformer carcasses and industrial resin; on-site consolidation of non-hazardous waste soil and debris; drainage improvements and installation of a clean soil cover over the entire site. Responsibilities included the preparation of drawings, specifications and the construction cost estimate, and the coordination/supervision of the design staff.

GFIM Landfill Closure, German Flatts, NY, Senior Construction Engineer/Manager. Project involved the closure of a 50-acre municipal landfill under the New York State Title 3 program. Closure included the relocation of 100,000 cubic yards of waste; the recovery and disposal of drums containing hazardous waste and the construction of two passive leachate, monitoring wells and a 37-acre multi-media cover consisting of a sand gas venting layer, 40-mil PVC geomembrane liner, sand drainage layer, barrier protection layer, topsoil layer, drainage system, access road and fencing. Responsibilities during design included the preparation of drawings, specifications and the construction cost estimate. Responsibilities during construction included full-time on-site supervision of Parsons ES personnel, verifying contractor compliance with the plans and specifications, design modifications, issuance and resolution of change orders and claims, review and approval of submittals and payment requests, progress documentation, conducting job meetings, interfacing with the client and the NYSDEC and preparation of the closure report.

-1-

AR400779 Napanoch/Schatz Remediation, Napanoch and Poughkeepsie, NY, Senior Construction Engineer/Manager. Project involved the remediation of three separate hazardous waste sites under one contract for the New York State Department of Environmental Conservation (NYSDEC). The Napanoch Paper Mill site involved the removal and offsite disposal of PCB contaminated materials including 800 tons of waste paper, 3,900 tons of non-hazardous soil, 1,700 tons of hazardous soil and 3,500 tons of pond sediment; onsite treatment of 400,000 gallons of water and diversion of Rondout Creek around the pond by constructing a temporary Port-A-Dam and diversion channel. The Schatz Plant site involved the removal and offsite e disposal of 1,200 tons of hazardous and 1,100 tons of non-hazardous PCB contaminated soil. The Schatz Landfill site involved removal and offsite disposal of 1,600 tons of hazardous PCB contaminated soil, stabilization/solidification of 4,800 cubic yards of metals contaminated slag waste, relocation of 54,000 cubic yards of waste and the construction of a 5-acre multi-media cover consisting of a geosynthetic clay layer, 40-mil HDPE geomembrane liner, geocomposite drainage layer, barrier protection layer, topsoil layer, drainage system, access road and fencing. Responsibilities during construction included full-time onsite supervision of Parsons ES personnel at all three sites, verifying contractor compliance with the plans and specifications, design modifications, issuance and resolution of change orders and claims, review and approval of submittals and payment requests, progress documentation, conducting job meetings, interfacing with the client and preparation of the closure reports.

Manufactured Gas Plant (MGP) Remediation, Hudson, NY, Senior Construction Engineer/Manager. Project involved the removal and offsite disposal of 2,800 tons of hazardous MGP waste. Prepared the work plan, specifications and cost estimate during the design. Responsibilities during remediation included full-time onsite supervision, verifying contractor compliance with the work plan, review and approval of payment requests, progress documentation, collection of samples for laboratory analysis to confirm cleanup goals' were achieved and interfacing with the client. He also prepared the final closure report.

Low Temperature Thermal Desorption, Kelly AFB, San Antonio, TX, Senior Construction Engineer/Manager. Project involved the treatment of 4,300 tons of petroleum contaminated soil by low temperature thermal desorption. Responsibilities included full-time onsite supervision, verifying contractor compliance with the work plan, review and approval of payment requests, progress documentation, collection of samples for laboratory analysis to confirm cleanup goals were achieved and interfacing with the client.

1991 David Christa Construction, Inc., Victor, New York. Project Manager/Estimator. Responsible for the construction of the Primary Teaching Center, Cornell University, Ithaca, NY ($6.8 Million), a 32,000 square - foot addition to the Veterinary Medicine College. The building was a structural steel frame with masonry backup and precast exterior panels. The project included a new utility tunnel and extensive utility relocation, lecture halls, atrium, library, laboratory classrooms, and site improvements. Responsibilities included preparation of cost estimates for bids; project scheduling; budget control; submittals; change order, purchase order and subcontract negotiations; safety and quality control.

1987-1991 Spoleta Construction & Development Corp, Rochester, New York. Project Manager/Estimator. Managed multi-million dollar construction projects including supervision of field and office staff, subcontractors, and design professionals. Estimated and bid projects and change orders; negotiated subcontracts, purchase orders, and change orders; coordinated construction and required inspections; prepared schedules; obtained building permits and approvals; managed project budgets; presented oral reports for government agencies and news media; selected architects for design projects; managed submittal process; and ensured safety and quality control. Project experience includes:

-2-

AR400780 801 Army Family Housing, Calcium, NY, ($24.5 Million). Responsible for construction of 300 units (150 duplexes) of wood frame housing units for Fort Drum, NY under the US Army's 801 Program (build-to-lease). The project included all site work and infrastructure and the renovation of an existing barn for offices, housing manager residence and equipment storage. All units were completed on time or early over a period of 14 months despite severe northern New York weather. In addition, the development, testing and construction of water wells and pump house/treatment facility costing an additional $1 million were completed simultaneously for the local town to supply water to the project.

New Canandaigua Academy, Canandaigua, NY, ($13.1 Million - GC Only). Responsible for construction of a new 205,000 square foot steel frame and masonry high school. The project included 30 acres of site improvements with athletic fields and parking, gymnasium, indoor swimming/diving pool, classroom wing with science laboratories, cafeteria, auditorium, entrance atrium, and cathedral ceiling library.

New York National Guard Armory, Rochester, NY, ($8.0 Million - GC Only). Responsible for construction of five steel frame and masonry buildings totaling 135,000 square feet. The buildings were an aircraft hangar, office building with arms vaults and indoor pistol range, vehicle maintenance shop, fuel dispensing building and storage building. Site improvements included taxiways, helicopter tie-down area, utility piping, parking areas and security fencing.

1983-1987 U.S. Army Corps of Engineers, Fort Drum, New York. Project Manager (1986-1987). Provided coordination between involved parties to solve contractual, construction and design problems. Prepared reports on progress of billion dollar expansion program.

Senior Project Engineer (1983-1986). Provided supervision and administrative control of multi-million dollar construction contracts with responsibility for job safety, quality control, contract compliance, and timely completion; supervised management team of project engineers; reviewed submittals and shop drawings; prepared requests for proposals and cost estimates for contract changes and negotiated settlements; conducted jobsite inspections; prepared pay estimates and contractor performance evaluations; reviewed contract plans and specifications during design for constructability and recommended changes; and conducted asbestos surveys and managed removal contracts. Project experience includes:

Army Family Housing, Fort Drum, NY, ($50.1 Million). Responsible for construction of 700 units of wood frame housing units including all site work and infrastructure. Buildings were of various multi-family sizes located in five separate areas covering over 150 acres.

US Army Reserve Center, Webster, NY, ($2.3 Million), Responsible for renovation of an existing 70,000 square foot school building and the construction of a new 15,000 square foot vehicle maintenance shop. Both buildings were steel frame and masonry with a portion of the shop being a metal building. The renovation included asbestos removal; new roofing, windows, electrical and mechanical systems; structural alterations and site improvements.

Ammunition Storage Magazines, Fort Drum, NY, ($723 Thousand). Responsible for construction of three steel plate / earth covered quonset-type ammunition storage bunkers with reinforced concrete end sections and blast doors, electrical service and access roads.

-3-

AR400781 Renovation Projects, Fort Drum, NY & Pittsburgh AFB, NY, (Varied) Responsible for renovation of various buildings or building systems including: • seven wood frame chapels; • one wood frame bank; • installation of energy conservation components for heating systems including heat exchangers, control valves, piping, air handling units and duct work; • an FM radio control system with tower, transmitter and control equipment to control the heating systems of 90 buildings; • asbestos removal; and • energy conservation improvements including window upgrades and insulation.

1981-1983 Fort Drum Department of Engineering and Housing, Fort Drum, New York. Environmental Engineer Intern. Prepared environmental assessments; authored environmental training manual; conducted PCB transformer and hazardous materials inventories; conducted PCB testing; managed waste oil collection and disposal program; managed paper recycling program; managed historic and archaeological site preservation program; prepared a study of a sewage treatment plant operation during periods of design overload; obtained environmental permits; prepared construction contracts for maintenance of facilities; performed as project engineer for two construction projects; and prepared energy usage reports for energy conservation program.

Education

B.S., Civil and Environmental Engineering, 1981, Clarkson University, Potsdam, New York.

Parsons Engineering Science, Inc. Training: 40-Hour Hazardous Waste Operations (29 CFR Part 1910.120(e)) 8-Hour Supervisory Instruction (29 CFR Part 1910.120(e)) • Quality Improvement Fundamentals • Construction Services and Safety

US Army Corps of Engineers Courses: • Advanced Construction Management • General Construction Inspection • Mechanical Inspection • Electrical Inspection • Cost Estimating for Modifications and Claims • Environmental Laws and Regulations • Environmental Assessment Preparation

Sanitary Landfill Operations (NYSDEC) Tank Installer/Closure Training (NYSDEC)

Professional Affiliations

Engineer in Training (New York State, 1981)

-4-

AR400782 References

Joe Yavonditte, New York State Department of Environmental Conservation, (518) 457-9280 John Dumin, New York State Department of Environmental Conservation, (518) 457-9285 Dave Chiusano, New York State Department of Environmental Conservation, (518) 457-9285

-5-

AR400783 APPENDIXB BOROUGH OF COLUMBIA A CCESS A GREEMENT

AR400784 REMOVAL ACTTVmES SITE ACCESS AGREEMENT THIS AGREEMENT is made as of this L d«y of -ti^b 1907. by tad between Clean Sites Environmental Services, Inc. ("CSES") and the Borough of Columbia. (•'Owner"). Pe* good »nd valuable consideration, the receipt and sufficiency of which are hmby acknowledged. OSES tad Owaer (collectively the 'Tarties") agree u follows: '

1. Porpote of Access. CSES. on behalf of Pennsylvania power and Ughl Company ('TP&l/*;. will conduct river sediment excavation, sampling, restoration, backfilling, measurement, river bank mbilization with rip rap and sheet piling, and/or other related activities (collectively "Cleanup Activities") °Ho r *n>ai the property located it the Colombia Borough Municipal Qarngc and the Municipal Authority of Columbia Wascewwter Treatment Plant (the "Property"!) »* approved by the Pennsylvania Department of Environmental Protection ("PADEP") and the U.S. Environmental Protection Agency ("USEPA"). '

Z. Graato^Aeetas.. Owner hereby jraats access to the Property to CSES and its employees, contractors, agents, consultants, designers and representatives for the purpose of conducting the Cleanup Activities. Owner also grants access to the Property to PADS*. USEPA and PP&L employees. 'contractor*, Agent*, consultants. 'decignecs and representatives for the purpose of oversight of die Cleanup ' Activities, CSES shall give Owner ax least seven (7) days prior notice of the initiation of Cleanup Activities on the Property,

3» Restoratitonof Protxrtv. Upon completion of Cleanup Activities. CSES will restore the Property CO a condition substantially similar to iu cohdition at the time Cleanup Activities. The Owner may approve leaving the access ramp to the river.

4. Term of Agreement Thecermof this Agreement will be. three hundred siwy-five (365) days from die date of execution, w»vt»»

5. Indemnification. CSES agrees to indemnify and hold harmless Owner from and against any and all manner of claims, demands, actions, suits, judgment*, fetters of execution, !o*sea and attorney's fees for personal injury or property damage sustained during the term of this Agreement and caused&fai? by CSES and its employees, contractors, and consultants in conducting Cleanup Activities. All of the obligations tinder this Section shall survive the term of this Agreement.

6. Irtfirraace. CSES Agrees to add and cause its major contractor to add. the Borough of Columbia to their comprehensive general liability policies as ''additional intured". Limits tre in excess of $2.000,000.

7. ' Entirt Atrecmtnt. This Agreement constitutes the entire agreement between the Partie* with respect to Cleanup Activities. 8. Modification of Agreenxart. The terms and conditions of this Agreement can be varied only upon the mutual, written agreement of the Parties.

IN WITNESS WHEREOF, the Parties have caused (his Agreement to be duly e»ecuted.

CLEAN SITES ENVIRONMENTAL SEH^ICES, INC. BOROUGH OF COLUMBIA . ' ' •// / /*•

By: kJ(SJ**4^ *•-- Lofr'/-.^-^ BV.

Its:

Date:

Q/C ' J AR400785 ld3Q 50^3 WHO Wd22:20 Z6, 10 03Q APPENDIX C TEE A TABILITY STUD Y

AR400786 OHM Remediation Services Corp. A SnlMidlary of OHM Corporation

TREATABILITY TESTING REPORT FOR THE GRAVITY DEWATERING OF THE RIVER SEDIMENT FROM THE PENNSYLVANIA POWER AND LIGHT, COLUMBIA, PA

Prepared By:

OHM Remediation Services Corp. Findlay, OH

rcatability Lab Manager

July 24,1997 OHM Proposal 111 116

AR400787 evi OHM Remediation Services Corp. TREAT ABILITY TESTING

Testing Objective

The objective of the treatability study for the sediment material from the Pennsylvania Power and Light facility in Columbia, PA was to test gravity dcwatering and if necessary, determine the amount and type of solidification reagent required to produce a treated material which will pass paint filter testing.

Sample Characterization

OHM's Treatability Laboratory received 2-5 gallon samples of the river sediment material from the containment pond on July 23,1997. The sediment samples were characterized for pH, solids content, and bulk density. The results arc summarized below:

Table 1. Sediment Characterization Results

Sample EPA 160.3 Bulk EPA 9045 Solids Density PH (%)' Ob/ft3) (s,u.) North Side 75,28 116.6 7.15 South Side 75.14 115.4 7.15

'Average of 2 measurements

Gravity Dewatering

Portions of each sediment sample were placed in a 100 mesh sieve and allowed to gravity dewater overnight. Moisture content was measured after 24 hours and gravity drained solids were subjected to paint filter testing.

PENNSYLVANIA TOWER AND LIGHT, COLUMBIA, PA July V, 1997

AR400788 E8 avi OHM Remedial! on Services Corp. TREATABILITY TESTING

Table 1 Gravity Dewatering Results

Sample Tune (Hr) Solids Content (%) Bulk Density Paint Filter (#/fV) 0 75.28 116.6 — 2.5 75.28 '— North Side — Sediment 24 80.44 98.86 Pass

0 75,14 115.4 — 2.5 75,49 South Side — — Sediment 24 79.55 94.54 Pass

Solidification Testing

Since the gravity dewalered solids passed the paint filter test after 24 hours drainage, solidification formulations were not necessary.

Conclusions

Sediment samples from the North Side and South Side of the lagoon were found to consist of course sand as indicated in characterization data provided by PP & L. Gravity dcwatering was found to produce a material that would pass paint filter testing after 24 hours. Removal of the sediment followed by placement on a drying bed for 24 hours would result in material with approximately 80% solids and have a bulk density of 95 - 100 tf/ft3.

As -with most treatability and laboratory studies, the results of this study -were obtained under laboratory conditions using a composite sample. Full scale processing under field conditions and/or variability in the materials to be treated may result in treated material which varies from the treated material produced under laboratory condition. The use of additional reagents, equipment and/or processing time may be required to produce a similar treated material to that produced under laboratory conditions.

OHMPropo«allini6 PENNSYLVANIA POWER AND LJGKT, COLUMBIA, t>A July 24,1997

AR400789 t>0 fZ'ZT APPENDIXD HEALTH & SAFETY PLAN

AR400790 OHM Remediation Services Corp. A Subsidiary of OHM Corporation

SITE-SPECIFIC HEALTH & SAFETY PLAN FOR RIVER SEDIMENTS EXACVAVTION UGI COLUMBIA GAS PLANT SITE COLUMBIA, PENNSYLVANIA

Submitted to:

Clean Sites Enviromental Services

Submitted by:

OHM Remediation Services Corp. Trenton, New Jersey

Prepared by:

. Paul A. Lawless, Cffl Regional Industrial Hygienist

Reviewed by:

Robert A. Brooks, CSP Health and Safety Manager

October 28, 1997 OHM Project 20240HS

AR400791 TABLE OF CONTENTS

1.0 INTRODUCTION 1-1

1.1 SITE HISTORY 1-1 1.2 SCOPE OF WORK 1-1

FIGURE 1.1 SITE MAP 1-3

2.0 KEY PERSONNEL AND MANAGEMENT 2-1

2.1 PROJECT MANAGER 2-1 2.2 SITE SUPERVISOR 2-1 2.3 SITE SAFETY OFFICER 2-1 2.4 HEALTH AND SAFETY MANAGER 2-2 2.5 PROJECT CERTIFIED INDUSTRIAL HYGIEN1ST 2-2 2.6 EMPLOYEE SAFETY RESPONSIBILITY 2-2 2.7 KEY SAFETY PERSONNEL 2-3

FIGURE 2.1 HEALTH AND SAFETY ORGANIZATION 2-4

3.0 JOB HAZARD ANALYSIS 3-1

3.1 CHEMICAL HAZARDS 3-1 3.2 PHYSICAL HAZARDS 3-2 3.3 ENVIRONMENTAL HAZARDS 3-2

FIGURE 3.1 POISONOUS PLANTS 3-4

3.4 VEHICLE SAFETY MANAGEMENT 3-6 3.4 TASK-SPECIFIC JOB SAFETY ANALYSIS 3-7

4.0 WORK AND SUPPORT AREAS 4-1

4.1 EXCLUSION ZONE 4-1 4.2 CONTAMINATION-REDUCTION ZONE 4-1 4.3 SUPPORT ZONE 4-1 4.4 SITE CONTROL LOG 4-1 4.5 GENERAL 4-2

5.0 PROTECTIVE EQUIPMENT 5-1

5.1 ANTICIPATED PROTECTION LEVELS 5-1 5.2 PROTECTION LEVEL DESCRIPTIONS 5-1 5.3 SUPPLIED-AIR RESPIRATORS 5-2 5.4 BREATHING-AIR QUALITY 5-2 5.5 AIR-PURIFYING RESPIRATORS 5-2 5.6 RESPIRATOR CARTRIDGES 5-2 5.7 CARTRIDGE CHANGES 5-3 5.8 INSPECTION AND CLEANING 5-3 5.9 FIT TESTING 5-3 5.10 FACIAL HAIR 5-3 5.11 CORRECTIVE LENSES '. " 5-3 5.12 CONTACT LENSES 5-3

AR400792 TABLE OF CONTENTS (CONTINUATION)

5.13 MEDICAL CERTIFICATION 5-3 5.14 SITE-SPECIFIC PERSONAL PROTECTIVE EQUIPMENT (PPE) PROGRAM 5-4

6.0 DECONTAMINATION PROCEDURES 6-1

6.1 PERSONNEL DECONTAMINATION 6-1 6.2 EQUIPMENT DECONTAMINATION 6-2 6.3 DISPOSAL 6-2

7.0 AIR MONITORING 7-1

7.1 WORK AREA AIR MONITORING 7-1 7.2 INSTRUMENTATION 7-2 7.3 AIR MONITORING LOG 7-4 7.4 CALIBRATION REQUIREMENTS 7-4 7.5 AIR MONITORING RESULTS 7-4

8.0 EMERGENCY RESPONSE 8-1

8.1 PRE-EMERGENCY PLANNING 8-1 8.2 EMERGENCY RECOGNITION AND PREVENTION 8-2

TABLE 8.1 EMERGENCY TELEPHONE NUMBERS 8-3

8.3 PERSONNEL, ROLES, LINES OF AUTHORITY, AND COMMUNICATIONS 8-3 8.4 SAFE DISTANCES AND PLACES OF REFUGE 8-5 8.5 EVACUATION ROUTES AND PROCEDURES 8-6 8.6 EMERGENCY SPILL AND RESPONSE PROCEDURES AND EQUIPMENT 8-7 8.7 EMERGENCY CONTINGENCY PLANS 8-10 8.8 MEDICAL EMERGENCY PROCEDURES 8-10 8.9 FIRE CONTINGENCY MEASURES 8-11 8.10 HAZARDOUS WEATHER CONTINGENCY MEASURES 8-12 8.11 SPILL/RELEASE CONTINGENCY MEASURES 8-13

9.0 TRAINING REQUIREMENTS 9-1

9.1 SITE ORIENTATION 9-1

10.0 MEDICAL SURVEILLANCE PROGRAM 10-1

TABLE 10.1 WORKER MEDICAL PROFILES 10-1

10.1 EXAMINATION SCHEDULE 10-1

APPENDICES APPENDIX A HEALTH AND SAFETY PLAN CERTIFICATION APPENDIX B OHM HAZARD COMMUNICATION PROGRAM APPENDIX C MATERIALS SAFETY DATA SHEET APPENDIX D SITE-SPECIFIC PERSONAL PROTECTIVE EQUIPMENT (PPE) PROGRAM

AR400793 1.0 INTRODUCTION

This Health and Safety Plan (HASP) has been developed for UGI Columbia Gas Plant Site.

This HASP documents the policies and procedures which protect workers and the public from potential hazards posed by work at this site and is a key component in the OHM Safety Improvement Process. OHM considers safety the highest priority during work at a site containing potentially hazardous materials and has established a goal of zero incidents for all projects. All projects will be conducted in a manner which minimizes the probability of injury, accident, or incident occurrence. This HASP is a key element in the proper planning of project work which is necessary to assure the goal of zero incidents is achieved. The HASP Certification (Appendix A) will be signed by all who actively participate at this project.

Although this plan focuses on the specific work activities planned for this site, it must remain flexible because of the nature of this work. Conditions may change and unforeseen situations may arise that require deviations from the original plan. This flexibility allows modification by the OHM supervisors and health and safety officials with approval from the project CIH.

1.1 SITE HISTORY

The former UGI Columbia Gas Plant Site is located at 441 South Front Street in Columbia, Pennsylvania. The property is approximately 1.6 acres in size and is enclosed by a chain-link fence.

The Site was operated as a gas manufacturing facility from approximately 1853 to 1948. Prior reports indicate the Columbia Gas Company, which was organized in 1851, was the first to operate the Site as a gas manufacturing facility. The property was owned and operated by Columbia Gas until 1935, when the property was transferred to he Pennsylvania Power and Light Company (PP&L). In 1949, the property was transferred to the Lancaster County Gas Company, which later merged with UGI Corporation (UGI). Private individuals owned the site between 1976 and 1994. The Site was repurchased by PP&L on January 27, 1994 and was listed on the National Priorities List later that year.

Numerous investigations have been conducted at the Site and adjacent areas, including the •Susquehanna River. Atlantic Environmental Services (Atlantic) prepared the "Draft Remedial Investigation Report" (April 1997) and is currently working on the final report. Atlantic also recently finalized the "River Sediment Investigation Addendum" (March 1997). Menzia-Cura and Associates prepared the "Draft Baseline Human Health Risk Assessment" (April 1997) and they are also working on the final report. Remediation Technologies, Inc. (RETEC) prepared the "Final Susquehanna River Sediment Engineering Evaluation/ Cost Assessment (EE/CA)" (July 1997) and is currently operating an enhanced recovery system remediating the source contamination in the two on-site holders.

1.2 SCOPE OF WORK

The principal tasks to be conducted are listed below.

• Mobilization site Setup • Site Survey • Install portable dam • Excavate River Sediments • Water Treatment Operations

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 1-1 AR400794 J?-=EE^ 01LM Remediation ^. -SEF" Services Con). _ x^= m,.,.mcj,,... INTRODUCTION

• Confirmation Sampling Install Sheetpile • Backfill Excavated Areas Install Geotextile and Riprap • Equipment Decontamination

These activities have been analyzed for potential hazards for which control measures are provided in Section 3.4 Job Safety Analysis.

This HASP has been prepared for the above scope of work. Any changes to the scope of work will require amendment of the plan to remain approved.

The Project Manager (PM), Site Supervisor (SS), Certified Industrial Hygienist (CIH), Health and Safety Manager (HSM), and Site Safety Officer (SSO) are responsible for formulating and enforcing health and safety requirements, and implementing the HASP. Reporting relationships are shown in Figure 2.1

2.1 PROJECT MANAGER

The PM has the overall responsibility for the project and to assure that the requirements of the contract are attained in a manner consistent with the HASP requirements. The PM will coordinate with the SS and the SSO to assure that the work is completed in a manner consistent with the HASP. The PM will conduct a periodic health and safety audit of the project using the Management Safety Improvement Report form as required in the Standard Operating Procedure. The PM reports to the Director of Operations. Specific Key Requirement Areas (KRA's) for safety performance include:

• Implementing a Site Specific Safety Awareness/ Recognition program Conduct periodic site audit (Management Safety Improvement Report); one report within 30 days of mobilization; followup reports every 90 days until job completion • Investigating and reporting findings for any OSHA recordable incidents; assuring corrective actions are taken

2.2 SITE SUPERVISOR

The SS is responsible for field implementation of the HASP. The SS will be the main contact in any on-site emergency situation. The SS will act as the SSO if one is not assigned. The SS will conduct periodic inspections (at least weekly) of the work site to confirm compliance with all health and safety requirements. The Project Safety Improvement Checklist shall be used to document inspections. The SS is also responsible for coordinating remedial actions for all deficiencies and for enforcing the OHM "Cardinal Safety Rules." The SS reports to the Project Manager. Specific Key Requirement Areas (KRA's) for safety performance include:

• Completing Site Specific Job Safety Analyses for all principle tasks Implementing Site Specific Safety Awareness/ Recognition program • Conduct weekly safety inspections of job sites • Correcting all deficiencies as noted on Management Safety Improvement Reports and safety department audits, within recommended time frames • Investigating and reporting findings for any OSHA recordable cases; assuring corrective actions are taken

2.3 SITE SAFETY OFFICER

The SSO has responsibility for administering the HASP relative to site activities, and will be in the field while site activities are in progress. The SSO's primary operational responsibilities include personal and environmental monitoring, coordination of job safety analyses, selection and care of personal protective equipment, assignment of protection levels and review of work permits. The SSO will monitor all field activities involved with safety and is authorized to stop work when an imminent health or safety risk exists. The SSO is responsible for informing all on-site personnel of essential safety requirements and facilitating the daily safety meetings. The SSO reports jointly to the Health and Safety Manager (HSM) and the Project Manager. Specific Key Requirement Areas (KRA's) for SSO performance include:

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 2-1 AR400797 _^^^^- OHM Remediation X. j^= Services Corp. rr n x~ ,Mte,,«n.a^a, KEY PERSONNEL

• Monitoring workers for signs of stress, such as cold exposure, heat stress, and fatigue • Reevaluating site conditions on an on-going basis. Coordinate protective measures including engineering controls, work practices and personal protective equipment • Assisting the SS in the preparation, presentation and documentation of daily safety meetings • Conducting and prepare reports of daily safety inspections of work processes, site conditions, equipment conditions and submit to SS. Discuss any ,iecessary corrective actions with the SS and review new procedures • Initiating revisions of the HASP as necessary for new tasks or modifications of existing operations and submit to the Project CIH for approval • Performing air monitoring as required • Assisting the PM and SS in accident investigations • Preparing permits for special operations, e.g., hot work, confined spaces, line breaking, etc. • Maintaining site safety records • Conducting weekly inspections of all fire extinguishers, supplied air respirators, first-aid kits, and eye washes/emergency showers • Ensuring that project management/ purchasing has pre-qualified sub contractors during the bidding stage. Inform subcontractors of the elements of the HASP/contractor pre-job checklist • Coordinating the preparation of Job Safety Analyses with the SS, team leader, and work crew • Coordinating the daily Safety Observer Program Coordinating the Site Specific Safety and Health Awareness and Recognition Program (SHARP) with Project Manager and Supervisor

2.4 HEALTH AND SAFETY MANAGER

The HSM is responsible for staffing health and safety personnel and monitoring projects for compliance with regulatory and OHM health and safety policies and procedures. This position reports to the Regional Health and Safety Director and may visit the site periodically to ensure compliance with this HASP.

2.5 PROJECT CERTIFIED INDUSTRIAL HYGIENIST

The Project Cffl is responsible for reviewing the HASP and ensuring that the HASP is complete and accurate. The Project CIH provides technical and administrative support for the Site Health and Safety Program. If necessary, the CIH can modify specific aspects of the HASP to adjust for on-site changes that affect safety. The CIH will coordinate with the HSM and SSO on necessary modifications to the HASP and will be available for consultation when required. The CIH may make periodic site visits to determine compliance. The CIH reports to the Regional Vice President/General Manager.

2.6 EMPLOYEE SAFETY RESPONSIBILITY

Each employee is responsible for personal safety as well as the safety of others in the area and is expected to participate fully in the Safety Improvement Process, particularly the Safety Observation Program. The employee will use all equipment provided in a safe and responsible manner as directed by the SS. All OHM personnel will follow the policies set forth in the OHM Health and Safety Procedures Manual, with particular emphasis on the OHM "Cardinal Safety Rules." Site personnel concerned with any aspect of health and safety shall bring it to the attention of the SS/SSO. If not satisfied, they should contact the Regional Health and Safety Director. All project personnel have the authority to stop work if in their judgement serious injury could result from continued activity. The SS and the SSO shall be notified immediately if this becomes necessary. To protect the health and safety of all personnel employees that knowingly disregard safety policies/procedures may be subject to disciplinary actions.

OHM Project 20240HS UG1 Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 2-2 AR400798 OIIM Remediation Services Corp. A BuMdlvf «< OHM C*rr»r*tUa KEY PERSONNEL

2.7 KEY SAFETY PERSONNEL

The following individuals share responsibility for health and safety at the site.

Project Manager Michael Evanko 609-588-6382 (office) 609-869-8952 (pager)

Site Supervisor TBD (site phone)

Site Safety Officer TBD (site phone)

Health and Safety Manager Robert A. Brooks, CSP 609-588-6423 (office) 800-818-2185 (pager)

Northeast Region Health and Kevin McMahon, M.S., CIH Safety Director/Project CIH 609-588-6375 (office) 609-421-7523 (pager)

Vice President, Health and Safety Fred Halvorsen, Ph.D., PE, CIH 800-231-7031

OHM Project 20240HS UGI Columbia Gas Plant Site October 28,1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 2-3 AR400799 OHM Remediation Services Coq>. «f OBH C*rporilloa KEY PERSONNEL

VICE PRESIDENT & GENERAL MANAGER GARY GARDNER

REGIONAL OPERATIONS DIRECTOR Martin Battistoni PROJECT CIH Kevin McMahon

PROJECT MANAGER Mike Evanko HEALTH & SAFETY MANAGER Robert A. Brooks, CSP

SITE SUPERVISOR TBD SITE SAFETY OFFICER TBD

FIGURE 2.1

HEALTH & SAFETY ORGANIZATION UGI Columbia Gas Site Columbia, PA OHM Project 20240

Prepared for

Clean Sites Environmental Services

This section outlines the potential chemical and physical hazards which workers may be exposed to during work on this project. Section 3.1 reviews hazards associated with chemicals/contaminants identified at the site. An MSDS list is included in Appendix C.

3.1 CHEMICAL HAZARDS

The primary routes of exposure for polycyclic aromatic hydrocarbons (PAHs) are inhalation and skin contact. Exposure to polycyclic aromatic hydrocarbons (PAHs) may occur during sediment excavation and water treatment activities.

EXPdstJRE - -^^r^ HEALTH' HAZARDS/''"' CHEMICAL PEL/TLV '* ROUTES'"'' ;,• PHYSICAL HAZARDS

Anthracene Skin, eye, 0.2 mg/m3 A skin, eye irritant and allergin; a questionable inhalation, carcinogen ingestion Reacts violently with fluorine; thermal decomposition emits toxic gases Benzo(a) pyrene Skin, eye, 0.2 mg/m3 A carcinogen; a nasal, respiratory tract, and skin inhalation, irritant ingestion Reacts with acids and oxidizers; produces acrid smoke, toxic gases when involved in fires, thermal decomposition

Chrysene Skin, eye, 0.2 mg/m3 A carcinogen, suspected human carcinogen; a nasal, inhalation, respiratory tract, and skin irritant ingestion Reacts with acids and oxidizers; produces acrid smoke, toxic gases when involved in fires, thermal decomposition Phenanthrene Skin, eye, 0.2 mg/m3 A human skin photosensitizer; a skin and eye irritant; inhalation, a possible carcinogen ingestion A combustible substance; reacts vigorously with oxidizers; releases acrid smoke, toxic gas during combustion

Pyrene Skin, eye, 0.2 mg/m3 A poison by inhalation; a skin and eye irritant; inhalation, questionable human carcinogenic potential; no ingestion evidence of animal carcinogenity

Reacts with acids and oxidizers; produces acrid smoke, toxic gases when involved in fires, thermal dppompo^ition

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Sendees Corp. 3-1 AR400801 .^^=- OHM Reniedialion N^?iTJ;?,so£°2i. JOB SAFETY ANALYSIS

Personnel will be removed from the work site and placed under observation immediately if the following symptoms occur:

• Dizziness or stupor • Nausea, headaches, or cramps • Irritation of the eyes, nose, or throat • Euphoria • Chest pains and coughing • Rashes or burns

3.2 PHYSICAL HAZARDS

To minimize physical hazards, OHM has developed standard safety protocols which will be followed at all times. Failure to follow safety protocols will result in expulsion of an employee from the site and appropriate disciplinary actions.

The SS and SSO will observe the general work practices of each crew member and equipment operator, and enforce safe procedures to minimize physical hazards. Hard hats, safety glasses, and steel-toe safety boots are required in all areas of the site. Site-specific hazards and all necessary precautions will be discussed at the daily safety meetings. The Health and Safety Procedures Manual will be maintained at the project site as a reference document.

Additional site-specific hazards are addressed in Section 3.5 Job Safety Analysis.

3.3 ENVIRONMENTAL HAZARDS

Environmental factors such as weather, wild animals, insects, and irritant plants pose a hazard when performing outdoor work. The SSO and SS will take all necessary measures to alleviate these hazards should they arise.

3.3.1 Exposure to Cold

With outdoor work in the winter months, the potential exists for hypothermia and frostbite.

Protective clothing greatly reduces the possibility of hypothermia in workers. However, personnel will be instructed to wear warm clothing and to stop work to obtain more clothing if they become too cold. Employees will also be advised to change into dry clothes if their clothing becomes wet from perspiration or from exposure to precipitation.

In cold weather, the potential for frostbite exists, especially in body extremities. Personnel will be instructed to pay particular attention to hands, feet, and any exposed skin when dressing. Personnel will be advised to obtain more clothing if they begin to experience loss of sensation due to cold exposure.

Employees will be encouraged to use the heated shelters on site at regular intervals depending upon the severity of ambient temperatures. Symptoms of cold stress, including heavy shivering, excessive fatigue, drowsiness, irritability, or euphoria necessitate immediate return to the shelter.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-2 AR400802 ^^^s=. OHM Keinediation a^SL. JOB SAFETY ANALYSIS

3.3.2 Biological Hazards

• POISON IVY (Rhus Radicans}

Poison Ivy may be found at the site. It is highly recommended that all personnel entering into an area with poison ivy wear a minimum of a tyvek coverall, to avoid skin contact.

The majority of skin reactions following contact with offending plants are allergic in nature and characterized by:

• General symptoms of headache and fever • Itching • Redness • A rash

Some of the most common and most severe allergic reactions result from contact with plants of the poison ivy group, including poison oak and poison sumac. Such plants produce severe rash characterized by redness, blisters, swelling, and intense burning and itching. The victim may develop a high fever and feel very ill. Ordinarily, the rash begins within a few hours after exposure, but may be delayed 24 to 48 hours.

Distinguishing Features of Poison Ivy Group Plants

The most distinctive features of poison ivy and poison oak are their leaves, which are composed of three leaflets each. Both plants have greenish-white flowers and berries that grow in clusters.

First Aid

a. Remove contaminated clothing; wash all exposed areas thoroughly with soap and water, followed by rubbing alcohol. 1% hydrocortisone cream (over-the-counter) will aid in healing and reducing itch.

b. Apply calamine or other soothing lotion if rash is mild.

c. Seek medical advice if a severe reaction occurs, or if there is a known history of previous sensitivity.

Contaminated Clothing

The irritating substances emitted by poison ivy group plants will remain on clothing for prolonged periods of time - up to weeks or months, if not washed thoroughly. It may be necessary to wash contaminated clothing separately and more than once before reusing.

Heavily vegetated areas of a site may have ticks. It is highly recommended that all personnel walking through such areas wear a tyvek coverall and latex boot covers taped at all joints. The ticks will stand out against the light colors. A tick or insect repellent containing DEBT is recommended.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or re/eased to others only with explicit written permission of OHM Remediation Services Corp. 3-3 AR400803 OII.M Remediation _^pF Services Corp. V- ASalMldUijofOHU Cerponuloo JOB SAFETY ANALYSIS

FIGURE 3.1 POISONOUS PLANTS

COMMON POISON IVY (RHUS RADICANS) • Grows as a small plant, z vine, and 2 shrub. • Grows everywhere in the United States except California and parts of adjacent states. Eastern oak leaf poison ivy is one of its varieties. • Leaves always consist of three glossy leaflets. • Also known as three-leaf ivy, poison creeper, climbing sumac, poison oak. mark weed, picry, and mercury.

WESTERN POISON OAK (RHUS OIVERSIL08A} • Grows in shrub and sometimes vine form. »Grows in California and parts of adjacent states. • Sometimes called poison ivy, or yeara, • Leaves always consist of three leaflets.

POISON SUMAC {RHUS VERNIX) * Grows as a woody shrub or small tree from 5 to 25 feet tall. * Grows in most of eastern third of United States. * Also known as swamp sumac. poison eider, poison ash, poison dogwood, and thunderwood.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-4 AR400804 s^ OII.VI Kemediation r gasaL. JOB SAFETY ANALYSIS

Ticks can transmit several diseases, including Rocky Mountain spotted fever, a disease that occurs in the eastern portion of the United States as well as the western portion, and Lyme disease. Ticks adhere tenaciously to the skin or scalp. There is some evidence that the longer an infected tick remains attached, the greater is the chance that it will transmit disease.

First Aid

a. Carefully (slowly and gently) remove the tick with tweezers, taking care that all parts are removed.

b. With soap and water, thoroughly, but gently, scrub the area from which the tick has been removed, because disease germs may be present on the skin; also wipe the bite area with an antiseptic.

c. If you have been bitten, place the tick in ajar labeled with the date, location of the bite, and the location acquired. If any symptom appears, such as an expanding red rash, contact a physician immediately.

• LYME DISEASE

Lyme disease may cause a number of medical conditions, including arthritis, that can be treated if you recognize the symptoms early and see your doctor. Early signs may include a flu-like illness, an expanding skin rash and joint pain. If left untreated, Lyme disease can cause serious nerve and heart problems as well as a disabling type of arthritis.

You are more likely to spot early signs of Lyme disease rather than see the tick or its bite. This is because the tick is so small (about the size of the head of a common pin or a period on this page and a little larger after they fill with blood), you may miss it or signs of a bite. However, it is also easy to miss the early symptoms of Lyme disease.

In its early stage, Lyme disease may be a mild illness with symptoms like the flu. It can include a stiff neck, chills, fever, sore throat, headache, fatigue, and joint pain. But this flu-like illness is usually out of season, commonly happening between May and October when ticks bite.

Most people develop a large, expanding skin rash around the area of the bite. Some people may get more than one rash. The rash may feel hot to the touch and may be painful. Rashes vary in size, shape, and color, but often look like a red ring with a clear center. The outer edges expand in size. Its easy to miss the rash and the connection between the rash and the tick bite. The rash develops from three days to as long as a month after the tick bite. Almost one third of those with Lyme disease never get the rash.

Joint or muscle pain may be another early sign of Lyme disease. These aches and pains may be easy to confuse with the pain that comes from other types of arthritis. However, unlike many other types of arthritis, this pain seems to move or travel from joint to joint.

In later stages, Lyme disease may be confused with other medical problems. These problems can develop months to years after the first tick bite.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Carp. 3-5 AR400805 _^^==- OHM lleniedialion JOB SAFETY ANALYSIS

Early treatment of Lyme disease symptoms with antibiotics can prevent the more serious medical problems of later stages. If you suspect that you have symptoms of Lyme disease, notify the SS or SSO; or if you have demobilized from the project site, contact your doctor.

Lyme disease can cause problems with the nervous system that look like other diseases. These include symptoms of stiff neck, severe headache, and fatigue usually linked to meningitis. They may also include pain and drooping of the muscles on the face, called Bell's Palsy. Lyme disease can also mimic symptoms of multiple sclerosis or other types of paralysis.

Lyme disease can cause serious but reversible heart problems, such as irregular heart beat. Finally, Lyme disease can result in a disabling, chronic type of arthritis that most often affects the knees. Treatment is more difficult and less successful in later stages. Researchers think these more serious problems may be linked to how the body's defense or immune system responds to the infection.

3.3.3 Noise

Hearing protection is required for workers operating or working near heavy equipment, where the noise level is greater than 85 dbA (Time Weighted Average) as well as personnel working around heavy equipment. The SSO will determine the need and appropriate testing procedures, (i.e., sound level meter and/or dosimeter) for noise measurement.

3.4 VEHICLE SAFETY MANAGEMENT

Motor vehicle incidents are the number one cause of occupational fatalities, accounting for one in three deaths. OHM employees involved in the operation and use of OHM and/or leased or rented vehicles will comply with the OHM Vehicle Management Policy (see Northern Region Safety Manual). OHM requires employees to use seat belts at all times when traveling in OHM owned or leased/rented vehicles. The SS and/or SSO will develop a parking area plan, including backing vehicles into parking spaces, using spotters for backing vehicles and policy mandated vehicle inspections.

OHM employees are expected to incorporate safe actions and preparations to avoid vehicle accidents and personal injury during work and off hours. Breaks should be planned into lengthy job mobilizations and demobilizations, including rotation of drivers at regular intervals. If parking areas are busy or crowded and more than one worker is traveling in the same vehicle, one worker should remain outside the vehicle as it leaves the parking space to assist the driver with traffic observation. Vehicles traveling before dawn and at dusk in rural or wooded areas should be prepared for wildlife, e.g. deer crossing roadways.

OHM employees arriving at work areas should park vehicles away from delivery, heavy equipment and vehicle loading/unloading locations to prevent parked vehicles from damage by various deliveries. Heavy equipment operators should inspect areas and request vehicles to be moved or spotters used if necessary, to maneuver equipment in tight areas. Employees who observe near misses or potential risks to parked or moving vehicles must report these to the SS or SSO immediately.

OHM employees are expected to use the vehicle inspection form and check/test the safety systems on the vehicle on a daily basis. Check the following: brakes, mirrors, seat belts, tires, leakage from the undercarriage, lights and rum signals. Vehicles with safety deficiencies must be reported immediately and not driven until properly repaired. Vehicles running errands from different project sites should have telephone numbers of the job site in the vehicle in case calls for assistance are required.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-6 AR400806 ^F^=H|^ OHM Remediation JOB SAFETY ANALYSIS

Because of the different ways alcohol can affect behavior, even in very small amounts, the best and safest course is not to drink before driving. At OHM, a driver with blood alcohol concentration (BAC) over 0.04% is considered to be under the influence and subject to disciplinary action. Personnel involved in motor vehicle incidents are subject to drug and alcohol testing.

Weather conditions can have a profound effect on driving. On slippery roads, drive more slowly. Stop and turn with care. Keep several car lengths from other vehicles. At speeds in excess of 35 mph, the chances of hydroplaning increase with speed. In general, keep back 1 car length for every 10 mph to prevent striking the car ahead.

In the event of a vehicle incident, notify your Site Supervisor immediately and complete all required reports.

3.5 TASK-SPECIFIC JOB SAFETY ANALYSES

This section of the Site-Specific HASP provides a breakdown of the hazards and control measures for each principal task. These Job Safety Analyses are general in nature and must be made project specific by the Site Supervisor prior to each task. The Job Safety Analyses will be field checked by the supervisor on an ongoing basis and revised as necessary. All revisions will be communicated to the work crew.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-7 AR400807 I I II I _^^=s=_L - OHMt" Remediatioi n ~ _^=r Services Corp. N ^==r A9ubiUUr;orOaUCorparitleo JOB SAFETY ANALYSIS

•3.5.lt : JOB SAFETY ANALYSIS FOR SITE PREPARATION

AIR MONITORING; "ACTION LEVELS" : INTEGRATED AIR SAMPLING: (PAHs) <0;2:MG/M3 LEVEL D, >0.2 MG/Ma;s 5.0 MG/M3, LEVEL C; >! 5.0 MG/M3, LEVEL B

Personal Protective Air Monitoring Task; Breakdown PotentialHazards . Hazard ;Controi: Measures ::. Equipment : Devices

Equipment/ Facility Slips, Trips, Falls Clear walkways work areas of equipment, tools, vegetation, Set-up excavated material and debris Mark, identify, or barricade other obstructions

Electrical Shock De-energize or shut off utility lines at their source before work begins Use double insulated or properly grounded electric power- operated tools Maintain tools in a safe condition Provide an equipment-grounding conductor program or employ ground-fault circuit interrupters Use qualified electricians to hook up electrical circuits Inspect all extension cords daily for structural integrity, ground continuity, and damaged insulation Cover or elevate electric wire or flexible cord passing through work areas to protect from damage Keep all plugs and receptacles out of water Use approved water-proof, weather-proof type if exposure to moisture is likely Inspect all electrical power circuits prior to commencing work Follow Lockout-Tagout procedures in accordance with OHM Health and Safety Procedures # 6-4

Handling Heavy Objects Observe proper lifting techniques Obey sensible lifting limits (60 Ib. maximum per person manual lifting) Use mechanical lifting equipment (hand carts, trucks) to move large, awkward loads

Sharp Objects Wear cut resistant work gloves when the possibility of Leather gloves lacerations or other injury may be caused by sharp edges or objects Maintain all hand and power tools in a safe condition Keep guards in place during use

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400808 3-8 i i i i I r i OHM Remediation jgp1' Services Corp. '— A SukiMUrj «t OEM OrporUl.n JOB SAFETY ANALYSIS

r : ; 3.5.1.' ;.-::-.\K-^. .^-K :'•:•.: X : : :J;, ; JOB SAFETY ANALYSIS FOR SITE PREPARATION ' . V;. • J ;-

AIR MONITORING "ACTION LEVELS" INTEGRATED AIR SAMPLING: (PAHs) < 0.2 MG/M3. LEVEL D, >0.2MG/M3 < 5.0 MG/M3, LEVEL C, > 5.0 MG/MJ, LEVEL B

Personal Protective Air Monitoring ;Task Breakdown •". Potential Hazards ; .. : .'.'':' .. i Hazard" Control Measures ^j; Equipment ' Devices

Equipment/ Facility High Noise Levels • Use hearing protection when exposed to excessive noise Ear plugs Set-up (Continued) levels (greater than 85 dBA over an 8-hour work period)

Low Ambient • Monitor for Cold stress in accordance with OHM Health and Temperature Safety Procedures # 3-5 • Provide fluids to prevent worker dehydration

OHM Project 20240HS UG1 Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400809 3-9 1 I 1 I I J="===._L _ OHMi Remediatioi n Jj^=" Services Corp. V— 19uk

3.5.2 • JOB SAFETY ANALYSIS FOR SITE SURVEY ACTIVITIES^: ; ! -i

: : v: AIR MONITORING: FACTION LEVELS" '• id < ••&!£. •• ' . :. . , : . : .. - . ., INTEGRATED AIR SAMPLING: (PAHs) < 0.2 MG/M' LEVEL D, >0.2 MG/M3 < 5.0 MG/M3,tEVEL C,i> 5.0 -MG/M3,: LEVEL B ;

.Personal Protective Air Monitoring 'Task Breakdown -s .-I potential Hazards -•.>.,:;.;>.>:,;..;.!,- Hazard Control Measures ;, ; " Equipment : ; i Devices

Survey of Site Struck By/ Vehicles/ • Use reflective warning vests worn when exposed to vehicular Hard hat, safety glasses Operating Equipment traffic • Isolate potential equipment swing areas • Avoid/isolate survey activities in high traffic areas, warehouse ship/receive areas • Make eye contact with vehicle operators before' approaching/crossing high traffic areas • Understand and review hand signals • Emphasize The Buddy System where injury potential exists

Slips, Trips, Falls • Clear walkways, work areas of equipment and tools • Mark, identify, or barricade other obstructions

Handling Heavy Objects • Observe proper lifting techniques • Obey sensible lifting limits (60 Ib. maximum per person manual lifting) • Use mechanical lifting equipment (hand carts, trucks) to move large, awkward loads

Sharp Objects • Wear cut resistant work gloves when the possibility of Leather gloves lacerations or other injury may be caused by sharp edges or objects • Maintain all hand and power tools in a safe condition • Keep guards in place during use • Close doors, windows on heavy equipment to prevent injuries from tree branches and other vegetation

Insect/ Animal Bites • Review injury potential with workers Tyvek coveralls, duct Avoid insect nests areas, habitats outside work areas tape bottom of coveralls • Emphasize The Buddy System where such injury potential to boots or latex boot exists covers • Use insect repellant to protect against sting injuries

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-10 AR400810 11 I f I I 1 OHM Remediation ^^ Services Corp. V ~ A Snbcldiu; e[ onu Cerpentlo JOB SAFETY ANALYSIS

3.5.2 •••• ;,.;':;'. :€,. '-.:$$, ^.V' '^'-^ ''ft 4;?: " -i-f JOB SAFETY ANALYSIS.FOR-SITESURVEY.ACTIVITIES : •; •':•.:; .-;:''- •'• •

; : : AIR MONITORING: "ACTION LEVELS". • . '^ ,-: ', ' ',. svV.W :.-••: . ^i..-,"'- '' - ;, ': . . ' : • •- INTEGRATED AIR SAMPL]uNG:(PAHs):;<'0.2;MG/M^LEV^ /

Personal Protective;: , Air Monitoring Task Breakdown ••'. • PotentialHazards '•'•, •:.;;";/; :[•;; Hazard ControlMeasures >: Equipment Devices

Survey of Site Contact Dermatitis • Wear long sleevcshirts / trousers to avoid skin contact with Tyvek coveralls, duct (Continued) plants or other skin irritants tape bottom of coveralls • Identify and review poisonous plants with workers to boots or latex boot • Avoid unnecessary clearing of plant/vegetation areas covers • Cover vegetation with plastic(visqueen) where survey position raises exposure potential

Low Ambient Monitor for Cold stress in accordance with OHM Health and Temperature Safety Procedures # 3-5 • Provide fluids to prevent worker dehydration

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400811 3-11 J I I I I I -=- OlliVl Remediation = Services Corp. A SBb*UlRT7 of OHM CorpormUflQ JOB SAFETY ANALYSIS

3.5.3 JOB SAFETY ANALYSIS FOR PORTABLE DAM CONSTRUCTION ;

AIR MONITORING: "ACTION LEVELS" INTEGRATED AIR SAMPLING: (PAHs) < 0:2 MG/MJ LEVEL D, >Q.2;MG/Mf < 5.0;TyiG/M3^LEVEL:C, > £0 MG/M3, LEVEL B :

Personal Protective Air Monitoring :Task Breakdown j. y Potential Hazards : Hazard Control Measures }; ; ; Equipment Devices

Portable Dam Slips, Trips, Falls • Clear walkways, work areas of equipment, tools, vegetation, Construction excavated material, and debris • Mark, identify, or barricade other obstructions

Struck/ Struck-by Hand • Hold stakes in place with tongs, vice-pliers or other remote Leather gloves, face Tools, Flying Debris grasping tools shield and goggles • Wear safety goggles when using sledge hammer, hatchet, maul or axe

Water Incursion/ • Wear USCG Approved personal flotation devices for work USCG approved Drowning activities on or near water flotation device • Provide a floating ring buoy with at least 90 feet in the immediate boat launch/land areas • Place ring buoys not more than 200 feet apart • Inspect portable dam daily, any time conditions change • Prohibit buildup of water around dam braces

Caught In/ Between Provide and use proper work gloves when the possibility of Moving Parts pinching, or other injury may be caused by moving/ handling large or heavy objects

OHM Project 20240HS UG1 Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400812 3-12 i i I f 11 II OHM Remediation -v ^^B=" Services Corp. ^•- A SubiUiu;

3.5.3 : v :v .':: : : JOB: SAFETY ANALYSIS FOR PORTABLE DAM CONSTRUCTION

.AIR MONITORING: "ACTION LEVELS" ; 3 3 3 J ^INTEGRATED AIR SAMPLING: (PAHs)5< 0.2 MG/M LEVEL D,;>0.2MG/M :<5.0 :MGM |LEVEL;Q;>|5.0;MG/M , LEVEL B ;\ : ; ':

Personal Protective Air Monitoring V !j Task Breakdown . ;; • Pofendal Hazards "• :. Hazard Control Measures , ;•.- ..:'fV : Equipment . • ' Devices

Portable Dam Low Ambient • Monitor for Cold stress in accordance with OHM Health and Construction Temperature Safety Procedures # 3-5 (Continued) • Provide fluids to prevent worker dehydration

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400813 3-13 I I I I ( r ^••^=1=_L - OHM< Remediatioi n " ^Z= Services Corp. X — A BuMdlw7 of OnH Corponllon JOB SAFETY ANALYSIS

: ' 3.5.4 -k '• ::.'•;•' ;:H ?^ ; ^mj;; -;; .; i: ^^^5; ;:s.: -JOB; SAFETY ANALYSIS FOR STREAM SEDIMENTS EXCAVATION :.v.;; • .• • ; . :•

AIR MONITORING: "ACTION LEVELS?' INTEGRATED AIR SAMPLING: (PAHs);< 0.2 MG/M3 LEVEL^D^O^MG/M^^OiMG/MVLEVELC i >]S.OMGM3v LEVELS p; x ; :

; Personal; Protective c ; Air Monitoring 1; Task Breakdown '•• ', >PotentiaI-HazardS; : I'" «..""';:",: •'.-" ' ' :.HazardjConlrol;:Measures>:i •'" \: '•"..'."..' '.' ; ''•- Equipment .: ;•- Devices

Excavation of Underground Utilities Identify all underground utilities around the excavation site Stream Sediments before, work commences • Cease work immediately if unknown utility markers are uncovered • Use manual excavation within 3 feet of known utilities

Struck By/ Against Heavy • Use reflective warning vests when exposed to vehicular Warning vests, hard hat, Equipment traffic safety glasses • Isolate equipment swing areas • Make eye contact with operators before approaching equipment • Understand and review hand signals

High Noise Levels • Use hearing protection when exposed to excessive noise Ear plugs levels (greater than 85 dBA over an 8-hour work period)

Slips, Trips, Falls • Clear walkways, work areas of equipment, vegetation, excavated material, tools, and debris • Mark, identify, or barricade other obstructions

OHM Project 20240HS UGI Columbia Gas Plant Site October 28. 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400814 3-14 1(11 J•^==L - OHMf Remediatior n ^^ Services Corp. — JOB SAFETY ANALYSIS

3.5.4 JOB SAFETY ANALYSIS FOR STREAM SEDIMENTS EXCAVATION

AIRMONITORING; FACTION LEVELS" *€&•.• INTEGRATED AIR SAMPLING: (PAHfe) < 0.2 MG/M3 LEVEL D, >0.2 MG/M? < 5.0 MG/M}, LEVEL C,> 5.0 MG/M3, LEVEL B ^ ;

Personal Protective • Air Monitoring Task Breakdown Potential Hazards : >"••'* :!-}:. 1 ;:"••• Hazard Control Measures.- Equipment : Devices

Excavation of Inhalation and Contact • Provide workers proper skin, eye and respiratory protection Tyvek coveralls, nitrile Air Sample Pump Stream Sediments with Hazardous based on the exposure hazards present gloves, neoprene boots (Continued) Substances • Review hazardous properties of site contaminants with (See Section 5.0 HASP) workers before operations begin • Dampen soil using light water spray to prevent fugitive dust emissions • Cover stockpiled soil with plastic sheeting to prevent fugitive dust emissions

Low Ambient • Monitor for Cold stress in accordance with OHM Health and Temperature Safety Procedures # 3-5 • Provide fluids to prevent worker dehydration

Backfilling Slips, Trips, Falls • Clear walkways, work areas of equipment, vegetation, excavated material, tools, and debris • Mark, identify, or barricade other obstructions

Struck By/ Against Heavy • Use reflective warning vests worn when exposed to vehicular Warning vests, hard hat Equipment traffic safety glasses • Isolate equipment swing areas • Make eye contact with operators before approaching equipment • Understand and review hand signals

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-15 AR400815 f. t r r ( j?=_^ 01IM Keincdialion £==? Services Corp. V =- A SuMdlvr tt OHU CorpanlloD JOB SAFETY ANALYSIS

3.5.5 : JOB SAFETY ANALYSIS FOR WATER TREATMENT OPERATIONS ; ^. /

AIR MONITORING: "ACTION LEVELS" ^ 3 1 3 3 INTEGRATED AIR SAMPLING: (PAHs) < 0.2 MG/M LEVEL D, >0.2 MG/M <5,tf;MG/M |LEVELC|^5,aMG/M ) LEVEL B |r

Personal Protective Air Monitoring Task Breakdown | •-f Potential Hazards . : .. . '. Hazard: Control Measures !•"•'•-. - : Equipment Devices

System Set-up Handling Heavy Objects • Observe proper lifting techniques • Obey sensible lifting limits (60 Ib. maximum per person manual lifting) • Use mechanical lifting equipment (hand cart, truck) to move large awkward loads

Sharp Objects • Wear cut resistant work gloves when the possibility of Leather gloves lacerations or other injury may be caused by sharp edges or objects • maintain all hand and power tools in a safe condition • Keep guards in place during use

High Noise Levels Use hearing protection when exposed to excessive noise Ear plugs levels (greater than 85 dBA over an 8-hour work period)

Caught In/ Between • Identify and understand parts of equipment which may cause Moving Parts crushing, pinching, rotating or similar motions • Assure guards are in place to protect from these parts of equipment during operation Provide and use proper work gloves when the possibility of pinching, or other injury may be caused by moving/ handling large or heavy objects • Maintain all equipment in a safe condition • Keep all guards in place during use De-energize and lock-out machinery before maintenance or service

Struck By/ Against • Isolate equipment swing areas Hard hat, Safety glasses Vehicles & Equipment • Make eye contact with operators before approaching equipment • Understand and review hand signals • Isolate areas under suspended loads

Slips, Trips, Falls • Clear walkways, work areas of equipment, ground debris, tools, and other materials • Mark, identify, or barricade other obstructions

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-16 AR400816 \ r r e t OHM Kcinedialion ~ ^^=^ Services Corp N -^ A 8abikliV7«r OH* Corporirportllofa i JOB SAFETY ANALYSIS

3.5.5 i JOB SAFETY ANALYSIS FOR WATER TREATMENT OPERATIONS

AIR MONITORING: "ACTION LEVELS" ;' • • • ,"- ' . . .-;•: '?• • ,V • i.i.p;- •. '' '. i ''•• • ' ' ' INTEGRATED AIR SAMPLING: (PAHs) < 0.2 MGfM3 LEVEL D, >0.2 MG/M3 < 5.0 MG/^Sl3, LEVEL C, > 5^0 MG/M3, LEVEL B

Personal Protective Air Monitoring fc Task Breakdown . : -'Potential Hazards & - • . : Hazard Control Measures Equipment ; Devices

System Set-up Low Ambient Monitor for Cold stress in accordance with OHM Health and (Continued) Temperature Safety Procedures # 3-5 Provide fluids to prevent worker dehydration

System Operation & Inhalation & Contact with Provide workers proper skin, eye, respiratory & splash Tyvek coveralls, latex Air Sample Pump Maintenance Hazardous Substances protection based on the exposure hazards present gloves, latex boots (see Review hazardous properties of site contaminants with Section 5.0 HASP) workers before treatment operations begin

Electrical Shock • De-energize or shut off utility lines at their source before work begins • Use double insulated or properly grounded electric power- operated tools • Maintain tools in a safe condition • Provide an equipment-grounding conductor program or employ ground-fault circuit interrupters • Use qualified electricians to hook up electrical circuits • Inspect all extension cords daily for structural integrity, ground continuity, and damaged insulation • Cover or elevate electric wire or flexible cord passing through work areas to protect from damage • Keep all plugs and receptacles out of water Use approved water-proof, weather-proof type if exposure to moisture is likely • Inspect all electrical power circuits prior to commencing work • Follow Lockout-Tagout procedures in accordance with OHM Health and Safety Procedures #38

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-17 AR400817 i t r r f -==- OHM lleinedialion j^^ Services Corp. JOB SAFETY ANALYSIS

3.5.5 JOB SAFETY ANALYSIS FOR WATER TREATMENT OPERATIONS

: AIR MONITORING; "ACTION LEVELS" J-.ji': -^;',':,. j ••• ...-.- , ". .,.;,' , -.-. ••' .;;y: igjjg.'.: • .-:.-• INTEGRATED AIR SAMPLING: (PAHs) < Ol2 MG/M* LEVEL D, >0.2 MG/M3 < 5.0 MG/M3,' LEVEL C, > 5.0 MG/M3, LEVEL B!

Personal Protective Air Monitoring ; Task Breakdown Potential Hazards Hazard Control Measures : Equipment : Devices

System Operation & Caught In/ Between • Identify and understand parts of equipment which may cause Maintenance Moving Parts crushing, pinching, rotating or similar motions (Continued) • Assure guards are in place to protect from these parts of equipment during operation • Provide and use proper work gloves when the possibility of pinching, or other injury may be caused by moving/ handling large or heavy objects • Maintain all equipment in a safe condition • Keep all guards in place during use • De-energize and lock-out machinery before maintenance or service

Pressurized Vessels, • Prepare written operating instructions for water treatment Hard hat, face shield and Hoses, Lines system goggles • Train all water treatment operators in conducting site operations • Assign qualified engineer to design water treatment system • Prepare process flow diagram and P and I D • All changes to equipment and procedures approved by qualified engineer • All water treatment system components shall be designed according to applicable codes • Maintain equipment according to manufacturer's recommendations • Wire quick connections, temporary lines closed before operating

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400818 3-18 _[_ I f I f I f I ^~*==._ OHM Remediation ~ _^=r Services Corp. N - A SoHldtuj «r OBll Comrttion JOB SAFETY ANALYSIS

3.5.5 JOB SAFETY ANALYSIS; FOR WATER TREATMENT;;OPERATIONS

AIR MONITORING; "ACTION LEVELS" ; s, INTEGRATED AIRJSAMPLING: (PAHs);<: 0.2 MG/M3 LEVEL D^>0.2:MG/M*< 5.ojMG/MVLEVEL C, > 5.0 MG/M3, LEVEL B

Personal Protective ; Air Monitoring ; Task Breakdown ::•• Potential Hazards = :; :Hazard: Control -Measures: > [ : Equipment ', Devices

System Operation & Fires Eliminate sources of ignition from the work area Maintenance Prohibit smoking (Continued) Provide ABC (or equivalent) fire extinguishers for all work and flammable storage areas, fuel powered generators and compressors Store flammable liquids in well ventilated areas Prohibit storage, transfer of flammable liquids in plastic containers Post "NO SMOKING" signs Store combustible materials away from flammables Store all compressed gas cylinders upright, secure, caps in place when not in use Separate Flammables and Oxidizers by 20 feet minimum

Flammable, Toxic, Test vessel atmosphere for flammable/toxic vapors, and Tyvek coveralls, latex Oxygen deficient oxygen deficiency gloves, latex boots (see Atmospheres Obtain Confined Space Entry Permit signed by Section 5.0 HASP) Supervisor/Safety Officer De-energize, lock-out and tag all energized equipment Provide written rescue plan Review hazardous properties of site contaminants with entrants, safety observer before starting work Review emergency procedures before work commences Provide safety observer outside vessel Wear proper level of PPE for the type of atmospheric contaminants Use body harness, safety belt with tripod winch for possible rescue

Slips, Trips, Falls Clear walkways, work areas of equipment, ground debris, tools, and other materials Mark, identify, or barricade other obstructions Clean up spills immediately

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-19 AR400819 i \ ir i -^==_L ^ OHM( Remediatior n -^=" Services Corp. JOB SAFETY ANALYSIS

3.5.5 JOB SAFETY ANALYSIS FOR WATER TREATMENT OPERATIONS

AIR MONITORING: "ACTION LEVELS" INTEGRATED AIR SAMPLING: (PAHs) < 0.2 MG/M3 LEVEL D, >0.2 MG/M3 < 5.0 MG/M3, LEVEL C, > 5.0 MG/M3, LEVEL B ,:. ;;

.Personal Protective Air Monitoring Task Breakdown ,K,,,r Potential Hazards : ,,. ;• Hazard: Control Measures: ; ; , : '• Equipment ^ Devices

System Operation & Low Ambient Monitor for Cold stress in accordance with OHM Health & Maintenance Temperature Safety Procedures # 3-5 (Continued) Provide fluids to prevent worker dehydration

Treatment Chemical Inhalation & Contact with Provide workers proper skin, eye, respiratory & splash Tyvek coveralls, latex Handling Hazardous Substances protection based on the exposure hazards present (See gloves, latex boots (sec Section 5.0 HASP) Section 5.0 HASP) Review water treatment chemical MSDSs with workers before treatment operations begin

Handling Heavy Objects Observe proper lifting techniques Obey sensible lifting limits (60 Ib. maximum per person manual lifting) Use mechanical lifting equipment (hand cart, truck) to move large awkward loads

Fires Eliminate sources of ignition from the work area Prohibit smoking in work areas Provide ABC (or equivalent) fire extinguishers in all work and flammable storage areas, fuel powered generators and compressors Store flammable liquids in well ventilated areas Prohibit storage, transfer of flammable liquids in plastic containers Post "NO SMOKING" signs Store combustible materials away from flammables Store all compressed gas cylinders upright, caps in place when not in use Separate Flammables and Oxidizcrs by 20 feet minimum

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-20 AR400820 I I [ / ( 1 1 1 / I 1 f 1 ' ^==. OHM Kern ediation ( ( •^ _f= Services C( ^ "~ A Sabfldkr; of OHM C~ JOB SAFETY ANALYSIS

3.5.5 JOB SAFETY ANALYSIS FOR WATER TREATMENT OPERATIONS ; ;

AIR MONITORING: "ACTION LEVELS" 3 J 3 INTEGRATED AIR SAMPLING: (PAHs) <0.2iMG/M LEVEL D, >0.2 MG/M'< 5.0:MG/M ,:LEVEL C,> 5,0;MG/M , LEVEL B

Personal Protective Air Monitoring • Task;Breakdown I Potential Hazards ;: ;t; S; ; Hazard Control Measures ^ Equipment : • Devices

Treatment Chemical Caught In/ Between • Identify and understand parts of equipment which may cause Handling Moving Parts crushing, pinching, rotating or similar motions (Continued) • Assure guards are in place to protect from these parts of equipment during operation • Provide and use proper work gloves when the possibility of crush, pinch, or other injury may be caused by moving/stationary edges or objects • Maintain all equipment in a safe condition • Keep all guards in place during use • De-energize and lock-out machinery before maintenance or service

Sharp Objects • Wear cut resistant work gloves when the possibility of Wizard or similar cut lacerations or other injury may be caused by sharp edges or resistant gloves objects • Maintain all hand and power tools in a safe condition • Keep guards in place during use

System Breakdown Handling Heavy Objects • Observe proper lifting techniques & Decontamination • Obey sensible lifting limits (60 Ib. maximum per person manual lifting) • Use mechanical lifting equipment (hand cart, truck) to move large awkward loads

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Sen'ices Corp. AR400821 3-21 re r f i OHM Remediation Services Corp. JOB SAFETY ANALYSIS

3.5.5 JOB SAFETY ANALYSIS FOR WATER TREATMENT OPERATIONS

: AIR MONITORING; "ACTION LEVELS" t > .--• •• ; :.' •. - H . :-- '^: :. '"••.. •' ~ . ' r ''..''•• ' , .. , INTEGRATED AIR SAMPLING: (PAHs) < O.i MG/M3 LEVEL D, >(U MG/M3 < 5.0 MG/M3, LEVEL C, > 5.0 MG/M3,LEVELB ;

Personal Protective Air Monitoring Task B reakdo wn ! i Potential Hazards ' . ;.: Hazard Control Measures .;:^ ." ;. : ''•• ^ " ""• ••' ••• •' Equipment Devices System Breakdown Caught In/ Between • Identify and understand parts of equipment which may cause & Decontamination Moving Parts crushing, pinching, rotating or similar motions (Continued) • Assure guards arc in place to protect from these parts of equipment during operation • Provide and use proper work gloves when the possibility of pinching or other injury may be caused by handling/moving large or heavy objects • Maintain all equipment in a safe condition • Keep all guards in place during use • De-energize and lock-out machinery before maintenance or service

Flammable, Toxic, • Test vessel atmosphere for flammable/toxic vapors, and Tyvek coveralls, latex Oxygen deficient oxygen deficiency gloves, latex boots (see Atmospheres • Obtain Confined Space Entry Permit signed by Section 5.0 HASP) Supervisor/Safety Officer • De-energize, lock-out and tag all energized equipment • Provide written rescue plan • Review contaminant MSDS with entrants and safety observer before starting work • Review emergency procedures before work commences • Provide safety observer outside vessel • Wear proper level of PPE for the type of atmospheric contaminants • Use body harness, safety belt with tripod winch for possible rescue

High Noise Levels • Use hearing protection when exposed to excessive noise Ear plugs levels (greater than 85 dBA over an 8-hour work period

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and la be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-22 AR400822 f f ir \ \ r' i \ ==•-_ 011M Remediation .5=^ Services Corp. ==r A SuMdlu; at 0011 CarforRtlon JOB SAFETY ANALYSIS

3.5.5 JOB SAFETY ANALYSIS FOR WATER TREATMENT OPERATIONS > '~ ^ |i : C

: : /: AIR MONITORING; "ACTION LEVELS" :•• '• •' . ,; - . '. -:: :•:•:. \!: :•':'•/• •. •" . .V . .';. . •...::„." .. ' ' , ' , INTEGRATED AIR SAMPLING: (PAHs) < 0.2 MG/M3 LEVEL D,>0.2MGM^5.()MG/M^LEVEL;G;>:54MG/M3, LEVELS, '? \: ^'. '••[•••

. Personal Protective ::: Air Monitoring Task Breakdown Potential Hazards ; • •"....:". : Hazard Control Measures ; . • ' •' •• '• • •« •. ; "Equipment ','- ; Devices

System Breakdown Low Ambient • Monitor for Cold stress in accordance with OHM Health & & Decontamination Temperature Safety Procedures # 3-5 (Continued) • Provide fluids to prevent worker dehydration

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-23 AR400823 _L ( f i 1 II ( I I ^H=^ OHM Itcmedialion c ^^^ Services Corp. ofOHM Orpor>llu JOB SAFETY ANALYSIS

3.5.6 JOB SAFETY ANALYSIS FOR CONFIRMATION SAMPLING

: : : : AIR MONITORING! "ACTION LEVELS" . • ' • • • ' • : ; '. ,: y. ".... "1 •.-, ::;.;••.: . ' '-^ . . ••;.;:;•,..•• •-...... — .•• -. INTEGRATED AIR SAMPLING: (PAHs) < 0.2 MG/M* LEVEL b,>0.2 MG/M*< 5.0 :MG/MVLEVEL^C,> S.OMG/M3, LEVELS ;: ;

^ ^ . . ,:;. '£ Personal Protective; .-;: Air Monitoring I ;;HTask:BreakdQwn; ; ";.;, .. Potential Hazards ,''.? ; ; ; :'?..;•' ''}• f . > Hazard Control Measures « !';•'!••'.: ..'.''.; '':«' Equipment ;>-• Devices "

Confirmation Sharp Objects • Wear cut resistant work gloves when the possibility of Wizard gloves or Sampling lacerations or other injury may be caused by sharp edges or equivalent objects • Maintain all hand and power tools in a safe condition • Keep guards in place during use

Handling Heavy Objects Observe proper lifting techniques • Obey sensible lifting limits (60 Ib. maximum per person manual lifting) • Use mechanical lifting equipment (hand carts, trucks) to move large, awkward loads

Slips, Trips, Falls • Clear walkways, work areas of equipment, tools, vegetation, excavated material, and debris • Mark, identify, or barricade other obstructions

Inhalation and Contact • Provide workers proper skin, eye and respiratory protection Tyvek coveralls, Air Sampling Pump with Hazardous based on the exposure hazards present neoprene boots, nitrile Substances • Review hazardous properties of site contaminants with gloves (see Section 5.0 workers before operations begin HASP)

Low Ambient • Monitor for Cold stress in accordance with OHM Health and Temperature Safety Procedures # 3-5 • Provide fluids to prevent worker dehydration

OHM Project 20240HS UG1 Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400824 3-24 i r I i i OHM Kemeclialion j^^r Services Corp. c N — A Sufcfldlirr e( OUM Corporation JOB SAFETY ANALYSIS

3.5.7 , ; '.-' .:• • •'• X; ..•'':• -'•;.' JOB SAFETY ANALYSIS FOR SHEETPILE INSTALLATION : •; :

AIR MONITORING! "ACTION LEVELS" ^INTEGRATED AIR SAMPLING: (PAHs):<|o.;2; MG/IVF LEVEL D*>o.2 MG/M^;< 5.0 MG/M', LEVEL c,>;s.oMG/M3, LEVEL B

Personal Protective Air Monitoring ' J; Task Breakdown > '.. J; Potential' Hazards; :; r-7 ". • '•• :;Hazard;Control Measures -f ' •• • ' '''• ; : Equipment Devices

Install Sheetpile Underground Utilities • Identify all underground utilities around the excavation site before work commences • Cease work immediately if unknown utility markers are uncovered

Struck By/ Against Heavy • Use reflective warning vests when exposed to vehicular Warning vest, Hard hat, Equipment, Flying, traffic Safety glasses Falling Objects, Debris • Isolate equipment swing areas Make eye contact with operators before approaching equipment • Understand and review hand signals

Sharp Objects • Wear cut resistant work gloves when the possibility of Leather gloves lacerations or other injury may be caused by sharp edges or objects « Maintain all hand and power tools in a safe condition • Keep guards in place during use

High Noise Levels • Use hearing protection when exposed to excessive noise Ear plugs levels (greater than 85 dBA over an 8-hour work period)

Slips, Trips, Falls • Clear walkways, work areas of equipment, vegetation, excavated material, tools, and debris • Mark, identify, or barricade other obstructions

Handling Heavy Objects « Observe proper lifting techniques • Obey sensible lifting limits (60 Ib. maximum per person manual lifting) • Use mechanical lifting equipment (hand carts, trucks) to move large, awkward loads

Low Ambient • Monitor for Cold stress in accordance with OHM Health and Temperature Safety Procedures # 3-5 • Provide fluids to prevent worker dehydration

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400825 3-25 i _r_ r i ( I 1 I f ^•^==- OHM Remediation ~ ^^ Services Corp. X A Subtldivj of OEM CArporltloQ JOB SAFETY ANALYSIS

3.5.8 : *^^

AIR MONITORING; "ACTION LEVELS" ' • "• \- } ••;;.::••'•• ::'' ->': '; I/ I;...' .-V : .J - •• •.••'/ INTEGRATED AIR SAMPLmG:(PAHs)< 0.2 MGM^ •

' TASK M ' . . ': •'-.':".' POTENTIAL HAZARDS HAZARD; CONTROL MEASURES) PERSONAL .;i AIR MONITORING

•;.; BREAKDOWN;:. . ,, .: '..-- v PROTECTIVE •< DEVICES '.,.'-' .' :.."'.' :" ' " ' EQUIPMENT

Install Geotextile, Slips, Trips & Falls • Clear walkways, work areas of vegetation, Riprap equipment, tools, debris, excavated material • Mark, identify, or barricade other obstructions • Wear rubber boots in areas of standing water, mud, marsh

Struck by/ Against Heavy • Use reflective warning vests, caution flags when Hard-hat, goggles and Equipment, Flying Debris, exposed to vehicular traffic face shield or safety Protruding Objects • Place barricades to isolate equipment swing areas glasses • Isolate areas under suspended loads Make eye contact with operators before approaching equipment • Barricade or enclose the work area Restrict entry to the work area to authorized personnel during work activities • Wear hard hats, safety glasses with side shields, face shields and goggles and steel-toe safety boots at all times • Understand and review hand signals

Sharp Objects • Wear cut resistant work gloves when the possibility Leather gloves, re- of lacerations or other injury may be caused by enforced palms sharp edges or objects • Maintain all hand and power tools in a safe condition Keep guards in place during use

Handling Heavy Objects • Observe proper lifting techniques • Avoid sudden movements, jerking motions • Obey sensible lifting limits (60 Ib. maximum per person manual lifting) • Prohibit running, jumping during geotextile deployment Use mechanical lifting equipment (hand carts, trucks) to move large, awkward loads

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information Herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400826 . 3-26 I 1 ( i i ( r OlliYJ Kcmcdiation Services Corp. ( A SalMiilur 01OBU Corportlloo JOB SAFETY ANALYSIS

3.5.8 JOB SAFETY ANALYSIS FOR INSTALLATION OF GEOTEXTILE, RIPRAP

: ; ; : v ; AIR MONITORING; "ACTION LEVELS" I ', \ • .- : ' , : ^ H ,i . ; - ' ' '••••^'' : -Xi^r ' • - : : . , : . •• • • ;• :;i ;' - 3 3 ! 3 INTEGRATED AIR SAMPLING: (PAHs) < 0.2 MG/M LEVEL ^D>0.2 MG/M < 5.0 MG/MVLEVELi:C (> S.O MG/M ,LEVEL B

TASK .iv;.;' .•;-..;4;^ POTENTIAL HAZARDS HAZARD'CONTROL MEASURES PERSONAL AIR MONITORING : : BREAKDOWNS ;f;r .• • ; ;: • r ." • '?• ;H , '. " . '. :: : ',• i • " *> ;?•' '.••'' r ' •' PROTECTIVE DEVICES EQUIPMENT

Install Riprap, Caught In/ Between • Identify equipment operations which may cause Leather gloves Geotextile (Continued) Moving Parts crushing, pinching, rotating or similar motions Provide and use proper work gloves when the possibility of pinching or similar injury may be caused by moving/handling heavy objects Maintain communication between equipment operators and ground personnel • Maintain all equipment in a safe condition • Keep all guards in place during use • Review positioning plan with workers before weir, riprap placement begins

High Noise Levels • Use hearing protection when exposed to excessive Ear plugs noise levels (greater than 85 dBA over an 8-hour work period)

Low Ambient Temperature • Monitor for Cold stress in accordance with OHM Health and Safety Procedures # 3-5 • Provide fluids to prevent worker dehydration

OHM Project 20240HS UGI Columbia Gas Plant Sile Oclobcr28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400827 3-27 i i 1 . C ( ^^==i ^ OHtM Rcmedialio.1 n ~ j^=r Services Corp. N- A Sutwldluj of OHM ConurtUen JOB SAFETY ANALYSIS

3.5.9 JOB SAFETY ANALYSIS FOR EQUIPMENT DECONTAMINATION ;

AIR MONITORING; "ACTION LEVELS" 1 3 3 3 INTEGRATED AIR SAMPLING: (PAHs):< -0.2 ..MG/M LEVEL D,>0.2MG/M ;<5.0;MG/M , LEVEL CV> 5.0;MG/M ,LEVEL:B ; "',,

Personal Protective Air Monitoring 'ii Task Breakdown '> ' -'Potential Hazards. : ' ' .;,•'••••"• .'•.- Hazard ^Control; Measures •;. . .:' J:': ;' Equipment Devices

Heavy Equipment & Slips, Trips, Falls • Clear walkways, work areas of equipment, vegetation, tools Vehicles and debris • Mark, identify, or barricade other obstructions

Struck by/Against Heavy • Use reflective warning vests when exposed to vehicular Warning vests hard hat Equipment, Protruding traffic safety glasses, goggles Objects, & Splashes • Isolate equipment swing areas and face shield • Make eye contact with operators before approaching equipment • Wear hard hats, safety glasses with side shields, or goggles with splash shields and steel-toe safety boots • Understand and review hand signals

Inhalation and Contact • Provide workers proper skin, eye and respiratory protection PVC rain suit or Tyvek with Hazardous based on the exposure hazards present coveralls, nitrile or latex Substances • Review hazardous properties of site contaminants with gloves, neoprene or latex workers before operations begin boots (See Section 5.0 HASP)

Burns • Use proper gloves, face shield/safety goggles, shin and toe Goggles and face shield, guards, and splash suits to protect workers from skin burns shin and toe guards and injury when operating laser (high pressure washers)

Sharp Objects Wear cut resistant work gloves when the possibility of Leather gloves lacerations or other injury may be caused by sharp edges or objects • Maintain all hand and power tools in a safe condition Keep guards in place during use

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400828 3-28 t i. r j i ( OHM Hcniedialion ^jjp' Services Corp. ^ A SaWdlwj of OHM Corpartlloa JOB SAFETY ANALYSIS

3.5.9 JOB SAFETY ANALYSIS FOR EQUIPMENT DECONTAMINATION

AIR MONITORING: "ACTION LEVELS" • ,. INTEGRATED AIR SAMPLING: (PAHs)< 0.2 MG/M3 LEVEL D,:>0.2MG/M^;5.Q;MG/M^LEVEL:C,>S.OMG/M3, LEVELS i':: ;

Personal Protective : Air Monitoring Task Breakdown ;;• ^Potential Hazards :.. ; . , :; Hazard,C6ntroI Measures : : •••..«4 :•.'..• Equipment •;" Devices : •>.<••• .• : ':' ... Heavy Equipment & High Noise Levels • Use hearing protection when exposed to excessive noise Ear plugs Vehicles levels (greater than 85 dBA over an 8-hour work period) (Continued)

Low Ambient • Monitor for Cold stress in accordance with OHM Health and Temperature Safety Procedures # 3-5 • Provide fluids to prevent worker dehydration

OHM Project 20240HS UG1 Columbia Gas Plain Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 3-29 AR400829 4.0 WORK AND SUPPORT AREAS

To prevent migration of contamination from personnel and equipment work areas will be clearly specified prior to beginning operations. OHM has designated work areas or zones as suggested by the NIOSH/OSHA/USCG/EPA'S document titled, "Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities." Each work area will be divided into three zones as follows:

• An Exclusion or "hot" Zone (EZ) • A Contamination-Reduction Zone (CRZ) • A Support Zone (SZ)

4.1 EXCLUSION ZONE

The EZ is the area suspected of contamination and presents the greatest potential for worker exposure. Personnel entering the area must wear the mandated level of protection for that area. In certain instances, different levels of protection will be required depending on the tasks and monitoring performed within that zone. The EZ for this project will include the sediment excavation area and the contaminated water storage and treatment areas.

4.2 CONTAMINATION REDUCTION ZONE

The CRZ or transition zone will be established between the EZ and SZ. In this area, personnel will begin the sequential decontamination process required to exit the EZ. To prevent off-site migration of contamination and for personnel accountability, all personnel will enter and exit the EZ through the CRZ. The CRZ for this project will include the access/egress routes to/from the EZ and the personnel and equipment decontamination stations.

4.3 SUPPORT ZONE

The SZ serves as a clean, control area. Operational support facilities are located within the SZ. Normal work clothing and support equipment are appropriate in this zone. Contaminated equipment or clothing will not be allowed in the SZ. The support facilities should be located upwind of site activities. There will be a clearly marked controlled access point from the SZ into the CRZ and EZ that is monitored closely by the SSO and the SS to ensure proper safety protocols are followed. The SZ for this project will include the crew and office locations, equipment storage areas, site parking areas and access roads.

4.4 SITE CONTROL LOG

A log of all personnel visiting, entering or working on the site shall be maintained in the main office trailer location. The log will record the date, name, company or agency, and time entering or exiting the site.

No visitor will be allowed in the EZ without showing proof of training and medical certification, per 29 CFR 1910.120(e), (f). Visitors will supply their own boots and respiratory equipment, if required. Visitors will attend a site orientation given by the SSO and sign the HASP.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used nr released to others only with explicit written permission of OHM Remediation Services Corp. 4-1 AR400830 ^=p^- OHM Remediation N^LCLV:?°LC£L. WORK AND SUPPORT AREAS

4.5 GENERAL

The following items are requirements to protect the health and safety of workers and will be discussed in the safety briefing prior to initiating work on the site:

Eating, drinking, chewing gum or tobacco, smoking, or any practice that increases the probability of hand to mouth transfer and ingestion of contamination is prohibited in the E7. and CRZs.

• Hands and face must be washed upon leaving the EZ and before eating, drinking, chewing gum or tobacco and smoking or other activities which may result in ingestion of contamination.

A buddy system will be used. Hand signals will be established to maintain communication.

• During site operations, each worker will consider himself as a safety backup to his partner. Off-site personnel provide emergency assistance. All personnel will be aware of dangerous situations that may develop.

Visual contact will be maintained between buddies on site when performing hazardous duties.

• No personnel will be admitted to the site without the proper safety equipment, training, and medical surveillance certification.

• All personnel must comply with established safety procedures. Any staff member who does not comply with safety policy, as established by the SSO or the SS, will be immediately dismissed from the site.

• Proper decontamination procedures must be followed before leaving the site.

• All employees and visitors must sign in and out of the site.

This section addresses the various levels of personal protective equipment (PPE) which are or may be required at this job site. OHM personnel are trained in the use of all PPE utilized.

5.1 ANTICIPATED PROTECTION LEVELS

PROTECTION TASK LEVEL COMMENTS/MODIFICATIONS

Site Setup, Site Survey, Setup Level D Hardhat, steel-toe work boots, safety eye wear (safety Portable Dam, Install Sheetpile, glasses with side shields or goggles and face shield if Backfill Excavations, Install splash or flying particles are likely) and hearing Geotextile and Riprap protection >85 dB A; Tyvek coveralls may be required for certain activities involving skin contact with dusts and irritant materials (check JSAs, Section 3.5 HASP)

Water Treatment Operations Level D/D+ PVC rain suit or Tyvek coveralls; latex gloves, latex boots

Excavate River Sediments, Level D+ Tyvek coveralls, nitrile gloves, neoprene boots and Confirmation Sampling hearing protection >85 dB A

Decontamination Level D+ PVC rain suit or Tyvek coveralls; latex gloves, latex boots

SZ Activities not otherwise Level D Classified

5.2 PROTECTION LEVEL DESCRIPTIONS

This section lists the minimum requirements for each protection level. Modification to these requirements will be noted above.

5.2.1 Level D

Level D consists of the following:

• Safety glasses with side shields • Hard hat • Steel-toed work boots • Work clothing as prescribed by weather • Hearing protection >85 dB A

5.2.2 Modified Level D

Modified Level D consists of the following:

• Safety glasses with side shields Hard hat

OHM Project 20240HS UGl Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 5-1 AR400832 _^==__ OHM Remediation r V~ ^-^== Service^^cj,,..s Con). . PROTECTIV_, E EQUIPMEN»-. T

Steel-toed work boots • Nitrile, neoprene, latex or PVC over boots • Outer nitrile, neoprene, or PVC gloves over latex sample gloves • Face shield (when projectiles or splashes pose a hazard) • Tyvek coverall [Polyethylene-coated Tyveks required when workers have a potential to be exposed to contaminated liquids or sludges.] • Hearing protection >85 dB A

5.2.3 Level C

Level C consists of the following:

• Full-face, air-purifying respirator with appropriate cartridges • Hooded Tyvek Coveralls [Polyethylene-coated Tyveks required when workers have a potential to be exposed to contaminated liquids or sludges]. • Hard hat • Steel-toed work boots Nitrile, neoprene, latex or PVC over boots • Nitrile, neoprene, or PVC gloves over latex sample gloves • Face shield (when projectiles or splashes pose a hazard) • Hearing protection >85 dB A

5.2.4 Level B

Level B protection consists of the items required for Level C protection with the exception that an air- supplied respirator is used in place of the air-purifying respirator.

5.3 SUPPLIED-AIR RESPIRATORS

If air monitoring shows that Level B protection is needed, OHM personnel will wear Survivair 9881-02 Hippack Airline respirators with 5-minute egress bottles. Personnel requiring Level "B" protection and high mobility will wear Survivair Mark 2 SCBA units.

5.4 BREATHING-AIR QUALITY

Code of Federal Regulations 29 CFR 1910.134 states breathing air will meet the requirement of the specification for Grade D breathing air as described in the ANSI/CGA Specification G-7.1-1989. OHM requires a certificate of analysis from vendors of breathing air in order to show that the air meets this standard. Breathing air will be obtained in cylinders exclusively and will be stationed in the exclusion zone (EZ).

5.5 AIR-PURIFYING RESPIRATORS

A NIOSH-approved full-face respirator with appropriate air-purifying cartridges will be used for Level C work.

5.6 RESPIRATOR CARTRIDGES

The crew members working in Level C will wear respirators equipped with air-purifying cartridges approved for the following contaminants.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 5-2 AR400833 ^=-^s^ OI1\I Hemedialion = -==r Services Corp. _-, —-. A BubildUrj 4( OEM Cerperalioa PROTECTIVE EQUIPMENT

• Organic vapors < 1,000 ppm • Chlorine gas <10 ppm Hydrogen chloride <50 ppm • Sulfur dioxide <50 ppm • Dusts, fumes and mists with a TWA <0.05 mg/m3 Asbestos-containing dusts and mists • Radionuclides • Pesticides

5.7 CARTRIDGE CHANGES

All cartridges will be changed a minimum of once weekly, or more frequently if personnel begin to experience increased inhalation resistance or breakthrough of a chemical warning property.

5.8 INSPECTION AND CLEANING

Respirators are checked periodically by a qualified individual and inspected before each use by the wearer. All respirators and associated equipment will be decontaminated and hygienically cleaned after each use.

5.9 FIT TESTING

Annual respirator fit tests are required of all personnel wearing negative-pressure respirators. The test will use isoamyl acetate or irritant smoke. The fit test must be for the style and size of the respirator to be used.

5.10 FACIAL HAIR

Personnel who have facial hair which interferes with the respirator's sealing surface will not be permitted to wear a respirator and will not be permitted to work in areas requiring respirator use.

5.11 CORRECTIVE LENSES

Normal eyeglasses cannot be worn under full-face respirators because the temple bars interfere with the respirator's sealing surfaces. For workers requiring corrective lenses, special spectacles designed for use with respirators will be provided.

5.12 CONTACT LENSES

Contact lenses will not be worn with any type of respirator.

5.13 MEDICAL CERTIFICATION

Only workers who have been certified by a physician as being physically capable of respirator usage will be issued a respirator. Personnel unable to pass a respiratory fit test or without medical clearance for respirator use will not be permitted to enter or work in areas on site that require respiratory protection. Employees receive a written physicians opinion that they are fit for general hazardous waste operations as per 29CFR 1910.120(f)(7).

OHM Project 20240HS . UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 5-3 AR400834 ^•^===- OHM Remediation X~ -====" Services Corp. _ — , £= — — ^- PROTECTIVE EQUIPMENT 5.14 SITE SPECIFIC PERSONAL PROTECTIVE EQUIPMENT TPPE^ PROGRAM

The primary objective of the PPE program is to ensure employee protection and to prevent employee exposure to site contaminants during site operations. Engineering controls are not feasible for many tasks and, therefore, require the use of PPE.

The SS will be responsible for implementing all aspects of the PPE program. This includes donning and doffing, temperature related stress monitoring, inspection, and decontamination (see Section 6.0). PPE selection is identified in Table 5.1 for each specified task. The SS in consultation with the SSO, if assigned, Health and Safety Manager and project CIH will direct changes in PPE based on changing conditions. The site specific HASP will served as written certification that the workplace was evaluated concerning PPE requirements. OHM Corporation's comprehensive PPE Program is described in Appendix D.

5.14.1 Site-Specific Respiratory Protection Program

The primary objective of respiratory protection is to prevent employee exposure to atmospheric contamination. When engineering measures to control contamination are not feasible, or while they are being implemented, personal respiratory protective devices will be used.

The criteria for determining respirator need have been evaluated based on the site contaminants; expected levels of protection are outlined in Section 5.1. Air monitoring will be conducted to confirm that respiratory protection levels are adequate (Section 7.0). All respirator users are OSHA trained in proper respirator use and maintenance. The SS and SSO will observe workers during respirator use for signs of stress. The SS, CIH, HSM, and SSO will also evaluate this HASP periodically to determine its continued effectiveness with regard to respiratory protection. All persons assigned to use respirators will have medical clearance to do so.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be lined or released to others only with explicit written permission of OHM Remediation Services Corp. 5-4 AR400835 6.0 DECONTAMINATION PROCEDURES

This section describes the procedures necessary to ensure that both personnel and equipment are free from contamination when they leave the work site.

6.1 PERSONNEL DECONTAMINATION

Decontamination procedures will ensure that material which workers may have contacted in the EZ does not result in personal exposure and is not spread to clean areas of the site. This sequence describes the general decontamination procedures for Level C. The specific stages will vary depending on the site, the task, the protection level, etc. Dry decontamination may be used if appropriate and there is insufficient space to support a full decontamination station as delineated with the steps below. The SS, or the SSO, if assigned, will ensure that the decontamination procedures are adequate.

Level D+ Decontamination

1. Go to end of EZ 2. Remove and discard latex booties 3. Remove outer gloves and discard 4. Cross into CRZ (dirty side of respirator wash area) 5. Remove protective suit (polycoated/regular tyvek) 6. Remove inner sample gloves and discard 7. Wash face and hands

Level C Decontamination

1. Go to end of EZ 2. a. Wash outer boots (Tingley or Robars) and stage to let dry; or b. Remove and discard latex booties 3. Remove outer gloves and discard 4. Remove outer suit (Saranex/polycoated/regular tyvek) 5. Remove outer sample gloves and discard 6. Cross into CRZ (dirty side of respirator wash area) 7. Remove inner suit and discard, (if applicable) 8. Remove and wash respirator (4 stages) a. Soap and water solution b. First rinse c. Disinfect respirator (1 cap full of bleach to 1 gallon of water) d. Final rinse 9. Hang respirator to dry 10. Remove inner sample gloves and discard 11. Wash face and hands

6.1.1 Suspected Contamination

Any employee suspected of sustaining skin contact with chemical materials will first use the emergency shower. Following a thorough drenching, the worker will proceed to the decontamination facility.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 6-1 AR400836 ^=-^=^ OHM Ileinediation S^^^L, _ DECONTAMINATION PROCEDURES

Here the worker will remove clothing, shower, don clean clothing, and immediately be taken to the first-aid station. Medical attention will be provided as determined by the degree of injury.

6.1.2 Personal Hygiene

Following decontamination and before any eating, smoking, or drinking, personnel will wash hands, arms, neck and face.

6.2 EQUIPMENT DECONTAMINATION

All contaminated equipment will be decontaminated before leaving the site. Decontamination procedures will vary depending upon the contaminant involved, but may include sweeping, wiping, scraping, hosing, or steaming the exterior of the equipment. Personnel performing this task will wear the proper PPE as prescribed by the SSO.

6.3 DISPOSAL

All decontamination liquids and disposable clothing will be treated as contaminated waste unless determined otherwise by accepted testing methods. Wastes will be disposed of according to state and federal reulationsregulations.

Air monitoring will be conducted in order to characterize personnel exposures and fugitive emissions from site contaminants. Principal contaminants of concern Eire listed in Section 3.0 of this HASP. The target compounds selected for air monitoring purposes for this site include anthracene, benio(a)pyrenc, chrysene, phenanthrenc and pyrene. Results of air monitoring will be used to ensure the proper selection of protective clothing and equipment, including respiratory protection, to protect on-sita personnel and off-site receptors from exposure to unacceptable levels of site contaminants. Descriptions of air monitoring strategies, procedures and equipment are provided below. Modification of this plan, including additional monitoring, may be considered as judged necessary by the Project CIH, in conjunction with the HSM and SSO.

7.1 WORK AREA ATR MONITORING

Personnel air monitoring at UGI Columbia Gas Plant site will include direct reading methods as well as integrated air sampling. Air monitoring will be conducted during river sediment excavations.

7.1-1 Direct Reading Air Monitoring

paring river sediment excavations; direct reading air monitoring will be performed in the EZ to determine exposure to workers, A PID will be used to monitor for possible VOC emissions during excavation activities. Monitoring for VOCs will be performed prior to and during excavation activities to document worker exposure levels. A summary of air monitoring information is provided in the table below.

•' . ' j| " •': ;;Momi»ribg,"'. .••' '':• rt; ,':•;:'' i.<:.: v'.',;,'^.1.]:'^;-1.'" '•"'' ,V'"' ''!';' '':'./ '•.•" I . '" \ y."* 'i I'V', •! '». , .1 M .. " '•' '' I ' : MbinWftig' • /\ ;'. .Monitoring:. ;•, l . . U; '• V . '•,<'" r/f'/tbciaidoD/; '•'.,'. i-.i.-,:." j;^;,-'A.y4; "• , l '. .• PersVqW;''';' •-.^rvj*-V?/X>.^.H* PTD EZ Excavation Continuous during 1-5 ppm* Level C aren/ EO, RT excavation 5-500 ppm* Level B >500 ppm* Level A *Sustained levels above background for 5 minutes

7.1.2 Integrated Air Monitoring

Integrated air sampling for personnel exposure characterization will be performed during river sediment excavations. Samples will be collected on the most at risk Equipment Operator andRecovery Technician. Sampling will be conducted for using OSHA Method 58. A summary of air monitoring information is given in the Table below.

OHM Prdject 20240HS UGI Columbia Gut; Plunt Site Di^tibdf 1, 1997 Information herein is proprietary and confidential and to hi used or reUasttl lu others only with ciplicit writttn pcrmisiiun of OHM Jtaned!ation Servicti Corp. 7-1 TT/8'd IcGd SDa3 WHO WdZT:0T Z6AR400838, 20 33Q j?^=- OHM Remediation ~ ^g=p~ Services Corp, N ^ 4«.WUU.|4f«A*6wi>*»^4* AIR MONITORING

Air Breathing 1 Sample each < O-img/m5 LevdD Sampling Zone/Equipment worker; first 2 > 0.2mg/m3<5.0 Pump Operator, days of mg/m3 Level C OSHA58 Recovery excavation ^ 5.0 mg/m5 Level B Technician

7.2 INSTRUMENTATION

The following is a description of the air monitoring equipment to be used at this site.

7,2.1 Photoionization Detector (PID)

7.2.1.1 Type and Operational Aspects

• PID Model PI 101 or equivalent

Principle of Operation

• lonization potential (IP) - The energy required to remove the outermost electron from a molecule; measured in electron volts (eV); characteristic property of a specific chemical.

« Photoionization - Using ultraviolet (UV) light to remove the outermost electron from a molecule.

• Energy of UV light (10.2, $.5, 11.7 eV) must be equal to or greater than the IP to photoionize the molecule.

» Fan or pump is used to draw air into the detector where the contaminants are exposed to a UV light source (lamp).

• Ions arc collected on a charged plate and produce a current directly proportional to the number of ionized molecules; current is amplified and displayed on the meter.

7-2-1-2 Calibration Method/Frequencies.

The PID Model PI 101 is designed for trace gas analysis in ambient air and is calibrated at HNU with certified standards of benzene, vinyl chloride, and isobutylene. Other optional calibrations are available (e.g., ammonia, ethylene oxide, HjS, etc.).

OHM will use a PDD with a 10.2 eV lamp. This lamp has been determined to be most responsive to the contaminants on site. Optional probes containing lamps of 9.5 and 11.7 eV are interchangeable in use within individual read-out assemblies for different applications.

OHM Prujea- 20240HS UGI Columbia Gas PLuu Sice December 1. 1997 Information litrein is proprietary and confidential &id to b< Ustd nf rtltostd to oiht'x Only with exjMf.ii written permission of OHM Remediation Services Cofp, 7-2 AR400839 ll/6'd IcGd SDd3 WHO Wd8T:0T 2.6, 20 D3d *>-^=r. OHM S^g^££. . AIR MONITORING

The approximate span settings for the probe that would give different readings of the amounts of trace gas of a particular species in a sample, are based opon the relative photoionization sensitivities of various gases twice daily (beginning and end of shift).

It is recommended that calibration be checked cwice each day (beginning and end of shift). The SSO will record and log such calibration information into an air monitoring notebook.

7.2.1.3 Rreventative Maintenance

Maintenance of the PID Model PI 101 consists of cleaning the lamp and ion chamber, and replacement of the lamp or other component parts or sub-assemblies.

7.2.2 Integrated Air Monitoring Program

7.2.2.1 Type and Operational Aspects

* Gilian Air Sampling Pump (or equivalent)

Principle of Operation

Air sampling pump is calibrated to draw a specified air flow rate (liters per minute) for a designated period of time.

• Volume of air sampled is then calculated as follows:

Flow rate (liter/min.) x sample time (min.)'= sample volume (liters)

* Use a bubble meter to calibrate air sampling pump; pump equipped with a rotameter that shows the flow rate during the sampling period.

* Equipped with a rechargeable battery for 8-hour average sampling times; must be recharged for at least 16 hours.

Collection Media: glass fiber filter.

7-2.2.2 Calibration Methods/Frequencies

Flow rate calibration can be accomplished by using primary standard soap and the Gilibtator Calibrator (or equivalent). The Gilibrator calibrator allows rapid flow rate determination with direct read-out on the butH-in display.

Connect the sampler to the calibrator, press the ON push button, and then push the plunger to start a bubble up the flow cell. The flow rate is automatically calculated and shown on the display. Subsequent readings are averaged with the previous readings. It is recommended that calibration of the sampler be checked prior to the start of and after each sampling period.

7.2.2.3 Preventative Maintenance

The Gilian air sampling pump should not require special maintenance or adjustments under normal conditions. However, as with all instruments, the sampling pump does require some basic care. Basic

OHM Projccc 20240HS UGI Columbia Gas Plant Site December 1, 1997 Infomiaiinn litrnin is p/Oprie.iUry and COnfldtntiul and to be used or released to others only with explicit wrinen permission of OHM Jternedutiio') Services Carp. 7-3 AR400840 IT/01"d IcGd S3y3 WHO WaBI:0T Z6, 20 330 »— ^^5==^ OHM Remediation V .^^ Services Corp. . _ _ x^gr ^^.M^LU. AIR MONITORING

""" maintenance of the consists of filter replacement, installing and removing battery packs, storage conditions, and electronic control assembly.

•—' 7,3 AIR MONITORING LOG

The SSO will ensure that all air-monitoring data is logged into a monitoring notebook. Data will «_ include instrument used, wind direction, work process, etc. The OHM Project CM and/or HSM may periodically review this data. w 7.4 CALIBRATION REQUIREMENTS

The sampling pumps with fixed-media will be calibrated daily before and after use. A separate log will be kept detailing date, time and name of person performing the calibration.

7.S AIR MONITORING RESULTS

*\ Air monitoring results will be posted for personnel inspection, and will be discussed during morning safety meetings. Personal air sampling results will be forwarded to the OHM Corporate Health and Safety Manager for Medical Surveillance, to be incorporated info the employee(s)' medical records.

OHM Prtytei 20240HS UQf Columbia G« Plant Site December 1, 1997 JnfurmaJiVTi herein fjr proprietary and confidential and to bt used or released irt nihers ftnly with explicit written permission flf OHM Remediation Service* Carp. 7-4 AR400841 U/TT'd IcGQ 33^3 WHO Wb6T:0T 2£>, 20 D3Q 8.0 EMERGENCY RESPONSE AND CONTINGENCY PLAN

8.1 PRE-EMERGENCY PLANNING

Prior to engaging in construction/remediation activities at the site, OHM will plan for possible emergency situations and have available adequate supplies and manpower to respond. In addition site personnel will receive training during the site orientation concerning proper emergency response procedures.

The following situations would warrant implementation of the Emergency Response and Contingency Plan (ERCP):

Fire/Explosion The potential for human injury exists. Toxic fumes or vapors are released. The fire could spread on site or off site and possibly ignite other flammable materials or cause heat-induced explosions. The use of water and/or chemical fire suppressants could result in contaminated runoff. An imminent danger of explosion exists.

Spill or Release of The spill could result in the release of flammable liquids or vapors, thus causing a Hazardous Materials fire or gas explosion hazard. The spill could cause the release of toxic liquids or fumes in sufficient quantities or in a manner that is hazardous to or could endanger human health.

Natural Disaster A rain storm exceeds the flash flood level. The facility is in a projected tornado path or a tornado has damaged facility property. Severe wind gusts are forecasted or have occurred and have caused damage to the facility.

Medical Emergency Overexposure to hazardous materials. Trauma injuries (broken bones, severe lacerations/bleeding, burns). Eye/skin contact with hazardous materials. Loss of consciousness. Heat stress (Heat stroke). Cold stress (Hypothermia). Heart attack. Respiratory failure. Allergic reaction.

The following measures will be taken to assure the availability of adequate equipment and manpower resources:

Sufficient equipment and materials will be kept on site and dedicated for emergencies only. The inventory will be replenished after each use.

• On-site emergency responders will be current in regards to training and medical surveillance programs. Copies of all applicable certificates will be kept on file for on-site personnel required to respond.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or relented hi others only with explicit written permission of OHM Remediation Services Corp. 8-1 AR400842 ^••=^=- OHM Remediation ^^ .===• Services Corp. EMERGENCY RESPONSE AND ( Corpantloa CONTINGENCY PLAN

• It will be the responsibility of the emergency coordinator to brief the on-site response team on anticipated hazards at the site. The emergency coordinator shall also be responsible for anticipating and requesting equipment that will be needed for response activities.

• Emergency response activities will be coordinated with the Local Emergency Management Agency (EMA) in compliance with SARA Title III requirements.

Communications will be established prior to commencement of any activities at the remediation site. Communication will be established so that all responders on site have availability to all pertinent information to allow them to conduct their activities in a safe and healthful manner. The primary communication device will be two-way radios. Air horns may be used to alert personnel of emergency conditions.

Primary communication with local responders in the event of an emergency will be accomplished using commercial telephone lines.

8.2 EMERGENCY RECOGNITION AND PREVENTION

Because unrecognized hazards may result in emergency incidents, it will be the responsibility of the Site Supervisor and Site Safety Officer (SSO), through daily site inspections and employee feedback (Safety Observation Program, daily safety meetings, and job safety analyses) to recognize and identify all hazards that are found at the site. These may include:

Chemical Hazards Materials at the site Materials brought to the site

Physical Hazards Fire/explosion Slip/trip/fall Electrocution Confined space IDLH atmospheres Excessive noise

Mechanical Hazards Heavy equipment Stored energy system Pinch points Electrical equipment Vehicle traffic

Environmental Hazards Electrical Storms High winds Heavy Rain/Snow Temperature Extremes (Heat/Cold Stress) Poisonous Plants/Animals

Once a hazard has been recognized, the Site Supervisor and/or the SSO will take immediate action to prevent the hazard from becoming an emergency. This may be accomplished by the following:

• Daily safety meeting • Task-specific training prior to commencement of activity • Lock-out/tag-out • Personal Protective Equipment (PPE) selection/use

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 8-2 AR400843 OHM Heincdiation _-^=7' Services Corp. EMERGENCY RESPONSE AND CONTINGENCY PLAN

Written and approved permits for hot work, confined space Trenching/shoring procedure Air monitoring Following all OHM standard operating procedures Practice drills for fire, medical emergency, and hazardous substances spills

: r , .. a^: ^..i^^Uo*;- ; $7**&*: ii'.r^/^&^^^-i,^' > ?^|^^^^?i^i||%ifeit^^l^ft^.5';-/-. •K;K.-:^;US:.;.s&i:^

<":i.E •'~f?V~.^*i~'J;^'':i--.i'^*.'.''r^'~f":

1 '•• . ' . --X;.-^,.: :'V< - ~^\'! :>' .. ' ;Y^, ^.. -. :'. . -. --^^w ^ ?i 'j.v.^-^^v -',*•<>*• ->3^P» »,!• ™V>; ^ '. . : . /V£ I* <^£3< Ks>." ^. • ,-r.^ -; '- > .,-- . . Local Agencies — Columbia. PA 9-1-1 Fire Department 717-684-5001 Police 717-6842120

LGH Susqehanna Division Hospital, 306 N 7th St., Columbia, PA 717-684-2841 Directions: From the Site turn Left follow Rt 441 North to Lawrence; turn Right on Lawrence St., follow to 2nd St., turn Left on 2 nd St., to Locust St., turn Right, follow Locust St. to N 7 th St., turn Left on N 7 th., Hospital is between Poplar and Maple Sts on N 7th.

Regional Poison Control Center 800-962-1253

State Agencies PADEP 610-861-2070

Federal Agencies EPA Region Branch Response Center - Edison, NJ 908-548-8730 National Response Center 800-424-8802

OHM Personnel Project Manager - Mike Evanko 609-588-6382 District Health and Safety Manager - Bob Brooks 609-588-6423 Director, Health and Safety - Kevin McMahon 609-588-6375

OHM Corporation (24 hour) 800-537-9540

Additional Phone #'s in Section 2 this HASP

8.3 PERSONNEL ROLES. LINES OF AUTHORITY. AND COMMUNICATIONS

This section of the ERCP describes the various roles, responsibilities, and communication procedures that will be followed by personnel involved in emergency responses.

The primary emergency coordinator for this site is the Site Supervisor. In the event an emergency occurs and the emergency coordinator is not on site, the Site Safety Officer or the highest ranking employee on site will serve as the emergency coordinator until he arrives. The emergency coordinator will determine the nature of the emergency and take appropriate action as defined by this ERCP.

The emergency coordinator will implement the ERCP immediately as required. The decision to implement the plan will depend upon whether the actual incident threatens human health or the environment. Immediately after being notified of an emergency incident, the emergency coordinator or his designee will evaluate the situation to determine the appropriate action.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 8-3 AR400844 m OHserviceM Remediatios Corp. n EMERGENCY RESPONSE AND - —— CONTINGENCY PLAN

8.3.1 Responsibilities and Duties

This section describes the responsibilities and duties assigned to the emergency coordinator.

It is recognized that the structure of the "Incident Command System" will change as additional response organizations are added. OHM will follow procedures as directed by the fire department, LEPC, State and Federal Agencies as required. OHM will defer to the local Fire Department chief to assume the role of Incident Commander upon arriving on site. Additional on-site personnel may be added to the Site Emergency Response Team as required to respond effectively.

8.3.2 On-Site Emergency Coordinator Duties

The on-site emergency coordinator is responsible for implementing and directing the emergency procedures. All emergency personnel and their communications will be coordinated through the emergency coordinator. Specific duties are as follows:

• Identify the source and character of the incident, type and quantity of any release. Assess possible hazards to human health or the environment that may result directly from the problem or its control.

• Discontinue operations in the vicinity of the incident if necessary to ensure that fires, explosions, or spills do not recur or spread to other parts of the site. While operations are dormant, monitor for leaks, pressure build-up, gas generation, or ruptures in valves, pipes, or other equipment, where appropriate.

• Notify local Emergency Response Teams if their help is necessary to control the incident. Table 8.1 provides telephone numbers for emergency assistance.

• Direct on-site personnel to control the incident until, if necessary, outside help arrives. Specifically:

• Ensure that the building or area where the incident occurred and the surrounding area are evacuated and shut off possible ignition sources, if appropriate. The Emergency Response Team is responsible for directing site personnel such that they avoid the area of the incident and leave emergency control procedures unobstructed.

• If fire or explosion is involved, notify local Fire Department.

• Have protected personnel, in appropriate PPE, on standby for rescue.

If the incident may threaten human health or the environment outside of the site, the emergency coordinator should immediately determine whether evacuation of area outside of the site may be necessary and, if so, notify the Police Department and the Office of Emergency Management.

When required, notify the National Response Center. The following information should be provided to the National Response Center:

• Name and telephone number • Name and address of facility

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 8-4 AR400845 °"-M Heco^tion EMERGENCY RESPONSE AND ~° CONTINGENCY PLAN

• Time and type of incident • Name and quantity of materials involved, if known • Extent of injuries • Possible hazards to human health or the environment outside of the facility.

The emergency telephone number for the National Response Center is 800-424-8802.

If hazardous waste has been released or produced through control of the incident, ensure that:

• Waste is collected and contained.

• Containers of waste are removed or isolated from the immediate site of the emergency.

• Treatment or storage of the recovered waste, contaminated soil or surface water, or any other material that results from the incident or its control is provided.

• Ensure that no waste that is incompatible with released material is treated or stored in the facility until cleanup procedures are completed.

• Ensure that all emergency equipment used is decontaminated, recharged, and fit for its intended use before operations are resumed.

• Notify the USEPA Regional Administrator that cleanup procedures have been completed and that all emergency equipment is fit for its intended use before resuming operations in the affected area of the facility. The USEPA Regional Administrator's telephone number is included in the Emergency Contacts.

• Record time, date, and details of the incident, and submit a written report to the USEPA Regional Administrator. Report is due to USEPA within 15 days of the incident.

8.4 SAFE DISTANCES AND PLACES OF REFUGE

The emergency coordinator for all activities will be the Response Manager. No single recommendation can be made for evacuation or safe distances because of the wide variety of emergencies which could occur. Safe distances can only be determined at the time of an emergency based on a combination of site and incident-specific criteria. However, the following measures are established to serve as general guidelines.

In the event of minor hazardous materials releases (small spills of low toxicity), workers in the affected area will report initially to the contamination reduction zone. Small spills or leaks (generally less than 55 gallons) will require initial evacuation of at least 50 feet in all directions to allow for cleanup and to prevent exposure. After initial assessment of the extent of the release and potential hazards, the emergency coordinator or his designee will determine the specific boundaries for evacuation. Appropriate steps such as caution tape, rope, traffic cones, barricades, or personal monitors will be used to secure the boundaries.

In the event of a major hazardous material release (large spills of high toxicity/greater than 55 gallons), workers will be evacuated from the building/site. Workers will assemble at the entrance to the site for a head count by their foremen and to await further instruction.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400846 R e alion s co?p EMERGENCY RESPONSE AND ^ ™r°r08''c~ CONTINGENCY PLAN

If an incident may threaten the health or safety of the surrounding community, the public will be informed and, if necessary, evacuated from the area. The emergency coordinator, or his designee will inform the proper agencies in the event that this is necessary. Telephone numbers are listed in Table 8.1.

Places of refuge will be established prior to the commencement of activities. These areas must be identified for the following incidents:

• Chemical release Fire/explosion • Power loss • Medical emergency • Hazardous weather

In genera], evacuation will be made to the crew trailers, unless the emergency coordinator determines otherwise. It is the responsibility of the emergency coordinator to determine when it is necessary to evacuate personnel to off-site locations.

In the event of an emergency evacuation, all the employees will gather at the entrance to the site until a head count establishes that all are present and accounted for. No one is to leave the site without notifying the emergency coordinator.

8.5 EVACUATION ROUTES AND PROCEDURES

All emergencies require prompt and deliberate action. In the event of an emergency, it will be necessary to follow an established set of procedures. Such established procedures will be followed as closely as possible. However, in specific emergency situations, the emergency coordinator may deviate from the procedures to provide a more effective plan for bringing the situation under control. The emergency coordinator is responsible for determining which situations require site evacuation.

8.5.1 Evacuation Signals and Routes

Two-way radio communication and an air horn will be used to notify employees of the necessity to evacuate an area or building involved in a release/spill of a hazardous material. Each crew supervisor will have a two way radio. A base station will be installed in the OHM office trailer to monitor for emergencies. Total site evacuation will be initiated only by the emergency coordinator, however, in his absence, decision to preserve the health and safety of employees will take precedence. Evacuation routes will be posted in each outside work area. Signs inside buildings will be posted on walls or other structural element of a building. Periodic drills will be conducted to familiarize each employee with the proper routes and procedures.

8.5.2 Evacuation Procedures

In the event evacuation is necessary, the following actions will be taken:

• The emergency signal will be activated.

• No further entry of visitors, contractors, or trucks will be permitted. Vehicle traffic within the site will cease in order to allow safe exit of personnel and movement of emergency equipment.

• Shut off all machinery if safe to do so.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 8-6 AR400847 ^^ s^-!cese co^ati011 EMERGENCY RESPONSE AND ^*—=F~ ABak>ldUrT*(001I C*rorallan CONTINGENC*~« Y PLA-m-^ N

• ALL on-site personnel, visitors, and contractors in the support zone will assemble at the entrance to the site for a head count and await further instruction from the emergency coordinator.

• ALL persons in the exclusion zone and contamination reduction zone will be accounted for by their immediate crew leaders (e.g., foreman). Leaders will determine the safest exits for employees and will also choose an alternate exit if the first choice is inaccessible.

• During exit, the crew leader should try to keep the group together. Immediately upon exit, the crew leader will account for all employees in his crew.

• Upon completion of the head count, the crew leader will provide the information to the emergency coordinator.

• Contract personnel and visitors will also be accounted for.

• The names of emergency response team members involved will be reported to the emergency spill control coordinator.

• A final tally of persons will be made by the emergency coordinator or designee. No attempt to find persons not accounted for will involve endangering lives of OHM or other employees by re-entry into emergency areas.

• In all questions of accountability, immediate crew leaders will be held responsible for those persons reporting to them. Visitors will be the responsibility of those employees they are seeing. Contractors and truck drivers are the responsibility of the Site Supervisor. The security guard will aid in accounting for visitors, contractors, and truckers by reference to sign-in sheets available from the guard shack.

• Personnel will be assigned by the emergency coordinator to be available at the main gate to direct and brief emergency responders.

• Re-entry into the site will be made only after clearance is given by the emergency coordinator. At his direction, a signal or other notification will be given for re-entry into the facility.

• Drills will be held periodically to practice all of these procedures and will be treated with the same seriousness as an actual emergency.

8.6 EMERGENCY SPILL RESPONSE PROCEDURES AND EQUIPMENT

In the event of an emergency involving a hazardous material spill or release, the following general procedures will be used for rapid and safe response and control of the situation. Emergency contacts found in Table 8.1 provide a quick reference guide to follow in the event of a major spill.

8.6.1 Notification Procedures

If an employee discovers a chemical spill or process upset resulting in a vapor or material release, he or she will immediately notify the on-site emergency coordinator.

On-site Emergency Coordinator will obtain information pertaining to the following:

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 8-7 AR400848 ^^ 0mn*e.nedZation EMERGENCY RESPONSE AND ^ -— CONTINGENCY PLAN

• The material spilled or released. • Location of the release or spillage of hazardous material. An estimate of quantity released and the rate at which it is being released. • The direction in which the spill, vapor or smoke release is heading. • Any injuries involved. • Fire and/or explosion or possibility of these events. • The area and materials involved and the intensity of the fire or explosion.

This information will help the on-site emergency coordinator to assess the magnitude and potential seriousness of the spill or release.

8.6.2 Procedure for Containing/Collecting Spills

The initial response to any spill or discharge will be to protect human health and safety, and then the environment. Identification, containment, treatment, and disposal assessment will be the secondary response.

If for some reason a chemical spill is not contained within a dike or sump area, an area of isolation will be established around the spill. The size of the area will generally depend on the size of the spill and the materials involved. If the spill is large (greater than 55 gallons) and involves a tank or a pipeline rupture, an initial isolation of at least 100 ft. in all directions will be used. Small spills (less than or equal to 55 gallons) or leaks from a tank or pipe will require evacuation of at least 50 ft. in all directions to allow cleanup and repair and to prevent exposure. When any spill occurs, only those persons involved in overseeing or performing emergency operations will be allowed within the designated hazard area. If possible the area will be roped or otherwise blocked off.

If the spill results in the formation of a toxic vapor cloud (by reaction with surrounding materials or by outbreak of fire) and its release (due to high vapor pressures under ambient conditions), further evacuation will be enforced. In general an area at least 500 feet wide and 1,000 feet long will be evacuated downwind if volatile materials are spilled. (Consult the DOT Emergency Response Guide for isolation distances for listed hazardous materials.)

If an incident may threaten the health or safety of the surrounding community, the public will be informed and possibly evacuated from the area. The on-site emergency coordinator will inform the proper agencies in the event this is necessary. (Refer to Table 8.1)

As called for in regulations developed under the Comprehensive Environmental Response Compensation Liability Act of 1980 (Superfund), OHM's practice is to report a spill of a pound or more of any hazardous material for which a reportable quantity has not been established and which is listed under the Solid Waste Disposal Act, Clean Air Act, Clean Water Act, or TSCA. OHM also follows the same practice for any substances not listed in the Acts noted above but which can be classified as a hazardous waste under RCRA.

Clean up personnel will take the following measures:

• Make sure all unnecessary persons are removed from the hazard area.

• Put on protective clothing and equipment.

• If a flammable material is involved, remove all ignition sources, and use spark and explosion proof equipment for recovery of material.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and ti> be used or released to others only with explicit written permission of OHM Remediation Services Corp. AR400849 ees co£alion EMERGENCY RESPONSE AND ^~=^~ A BubaWiwj »f OHM C«rpor»tlflB CONTINGENC^~* Y PLA-»-v N

• Remove all surrounding materials that could be especially reactive with materials in the waste. Determine the major components in the waste at the time of the spill.

• If wastes reach a storm sewer, try to dam the outfall by using sand, earth, sandbags, etc. If this is done, pump this material out into a temporary holding tank or drums as soon as possible.

• Place all small quantities of recovered liquid wastes (55 gallons or less) and contaminated soil into drums for incineration or removal to an approved disposal site.

• Spray the spill area with foam, if available, if volatile emissions may occur.

• Apply appropriate spill control media (e.g. clay, sand, lime, etc.) to absorb discharged liquids.

• For large spills, establish diking around leading edge of spill using booms, sand, clay or other appropriate material. If possible, use diaphragm pump to transfer discharged liquid to drums or holding tank.

8.6.3 Emergency Response Equipment

The following equipment will be staged in the support zone and throughout the site, as needed, to provide for safety and first aid during emergency responses.

• ABC-type fire extinguisher • First-aid kit, industrial size • Eyewash/safety shower • Emergency signal horn • Stretcher/backboard

In addition to the equipment listed above, OHM maintains direct reading instrumentation that may be used in emergency situations to assess the degree of environmental hazard. This equipment will only be used by the Site Safety Officer or other specially trained personnel. This equipment will be stored, charged and ready for immediate use in evaluating hazardous chemical concentrations. The equipment will be located at the OHM office trailer.

8.6.4 Emergency Spill Response Clean-Up Materials and Equipment

A sufficient supply of appropriate emergency response clean-up and personal protective equipment will be inventoried and inspected, visually, on a weekly basis.

The materials listed below may be kept on site for spill control, depending on the types of hazardous materials present on site. The majority of this material will be located in the support zone, in a supply trailer or storage area. Small amounts will be placed on pallets and located in the active work areas.

• Sand or clay to solidify/absorb liquid spills.

• Appropriate solvents e.g. CITRIKLEEN, for decontamination of structures or equipment.

The following equipment will be kept on site and dedicated for spill cleanup:

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used fir released to others only with explicit written permission of OHM Remediation Services Corp. 8-9 AR400850 sSlcS coq?lion EMERGENCY RESPONSE AND = ™r°'OB"c"T°""" CONTINGENCY PLAN

• Plastic shovels for recovering corrosive and flammable materials. Sausage-shaped absorbent booms for diking liquid spills, drains, or sewers. • Sorbent sheets (diapers) for absorbing liquid spills. • Overpack drums for containerizing leaking drums. • 55-gallon open-top drums for containerization of waste materials.

*NOTE: All contaminated soils, absorbent materials, solvents and other materials resulting from the clean-up of spilled or discharged substances shall be properly stored, labeled, and disposed of off-site.

8.7 EMERGENCY CONTINGENCY PLAN

This section of the ERCP details the contingency measures OHM will take to prepare for and respond to fires, explosions, spills and releases of hazardous materials, hazardous weather, and medical emergencies.

8.8 MEDICAL EMERGENCY CONTINGENCY MEASURES

The procedures listed below will be used to respond to medical emergencies.

8.8.1 Response

The nearest workers will immediately assist a person who shows signs of medical distress or who is involved in an accident. The work crew supervisor will be summoned.

The work crew supervisor will immediately make radio contact with the on-site emergency coordinator to alert him of a medical emergency situation. The supervisor will advise the following information:

• Location of the victim at the work site • Nature of the emergency • Whether the victim is conscious • Specific conditions contributing to the emergency, if known

The Emergency Coordinator will notify the Site Safety Officer. The following actions will then be taken depending on the severity of the incident:

• Life-Threatening Incident — If an apparent life-threatening condition exists, the crew supervisor will inform the emergency coordinator by radio, and the local Emergency Response Services (EMS) will be immediately called. An on-site person will be appointed who will meet the EMS and have him/her quickly taken to the victim.

Non Life-Threatening Incident — If it is determined that no threat to life is present, the Site Safety Officer will direct the injured person through decontamination procedures (see below) appropriate to the nature of the illness or accident. Appropriate first aid or medical attention will then be administered.

*NOTE: The area surrounding an accident site must not be disturbed until the scene has been cleared by the Site Safety Officer.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to other.': only with explicit written permission of OHM Remediation Services Corp. 8-10 AR400851 01 lJlcKemedialion EMERGENCY RESPONSE AND ^ ^^c.^.. CONTINGENCY PLAN

Any personnel requiring emergency medical attention will be evacuated from exclusion and contamination reduction zones if doing so would not endanger the life of the injured person or otherwise aggravate the injury. Personnel will not enter the area to attempt a rescue if their own lives would be threatened. The decision whether or not to decontaminate a victim prior to evacuation is based on the type and severity of the illness or injury and the nature of the contaminant. For some emergency victims, immediate decontamination may be an essential part of life-saving first aid. For others, decontamination may aggravate the injury or delay life-saving first aid. Decontamination will be performed if it does not interfere with essential treatment.

If decontamination can be performed, observe the following procedures:

• Wash external clothing and cut it away.

If decontamination cannot be performed, observe the following procedures:

• Wrap the victim in blankets or plastic to reduce contamination of other personnel.

• Alert emergency and off-site medical personnel to potential contamination, instruct them about specific decontamination procedures.

• Send site personnel familiar with the incident and chemical safety information, e.g. MSDS, with the affected person.

All injuries, no matter how small, will be reported to the SSO or the Site Supervisor. An accident/injury/illness report will be completely and properly filled out and submitted to the Regional Health and Safety Director/Project CIH, in accordance with OHM's reporting procedures.

A list of emergency telephone numbers is given in Table 8.1.

8.8.2 Notification

The following personnel/agencies will be notified in the event of a medical emergency:

• Local Fire Department or EMS • On-site Emergency Coordinator « Workers in the affected areas • Client Representative

8.9 FIRE CONTINGENCY MEASURES

Because flammable/combustible materials are present at this site, fire is an ever-present hazard. OHM personnel and subcontractors are not trained professional firefighters. Therefore, if there is any doubt that a fire can be quickly contained and extinguished, personnel will notify the emergency coordinator by radio and vacate the structure or area. The emergency coordinator will immediately notify the local Fire Department.

The following procedures will be used to prevent the possibility of fires and resulting injuries:

• Sources of ignition will be kept away from where flammable materials are handled or stored.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 8-11 AR400852 svces cSation EMERGENCY RESPONSE AND ^*-=~ •-" A BuMdUrv of OHM C4rpor»ilcn CONTINGENC-,—- Y PLA•—^ N

• The air will be monitored for explosivity before and during hot work and periodically where flammable materials are present. Hot work permits will be required for all such work.

• "No smoking" signs will be conspicuously posted in areas where flammable materials are present.

• Fire extinguishers will be placed in all areas where a fire hazard may exist.

• Before workers begin operations in an area the foreman will give instruction on egress procedures and assembly points. Egress routes will be posted in work areas and exit points clearly marked.

8.9.1 Response

The following procedures will be used in the event of a fire:

• Anyone who sees a fire will notify their supervisor who will then contact the Emergency Coordinator by radio. The emergency coordinator will activate the emergency air horns and contact the local Fire Department.

• When the emergency siren sounds, workers will disconnect electrical equipment in use (if possible) and proceed to the nearest fire exit.

Work crews will be comprised of pairs of workers (buddy system) who join each other immediately after hearing the fire alarm and remain together throughout the emergency. Workers will assemble at a predetermined rally point for a head count.

• When a small fire has been extinguished by a worker, the emergency coordinator will be notified.

8.10 HAZARDOUS WEATHER CONTINGENCY MEASURES

Operations will not be started or continued when the following hazardous weather conditions are present:

• Lightning • Heavy Rains/Snow • High Winds

8.10.1 Response

• Excavation/soil stock piles will be covered with plastic liner.

• All equipment will be shut down and secured to prevent damage.

• Personnel will be moved to safe refuge, initially crew trailers. The emergency coordinator will determine when it is necessary to evacuate personnel to off-site locations and will coordinate efforts with fire, police and other agencies.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 8-12 AR400853 scS coSalion EMERGENCY RESPONSE AND ^^-^ -~ A SaWldUrr of OHM C*r?or*tlaa CONTINGENC-—- Y PLA-v-V N

8.10.2 Notification

The emergency coordinator will be responsible for assessing hazardous weather conditions and notifying personnel of specific contingency measures. Notifications will include:

• OHM employees and subcontractors Client Representative • Local Emergency Management Agency

8.11 SPILL/RELEASE CONTINGENCY MEASURES

In the event of release or spill of a hazardous material the following measures will be taken:

8.11.1 Response

Any person observing a spill or release will act to remove and/or protect injured/contaminated persons from any life-threatening situation. First aid and/or decontamination procedures will be implemented as appropriate. First aid will be administered to injured/contaminated personnel. Unsuspecting persons/vehicles will be warned of the hazard. All personnel will act to prevent any unsuspecting persons from coming in contact with spilled materials by alerting other nearby persons. Attempt to stop the spill at the source, if possible. Without taking unnecessary risks, personnel will attempt to stop the spill at the source. This may involve activities such as up righting a drum, closing a valve or temporarily sealing a hole with a plug.

Utilizing radio communications, the emergency coordinator will be notified of the spill/release, including information on material spilled, quantity, personnel injuries and immediate life threatening hazards. Air monitoring will be implemented by the emergency coordinator and SSO to determine the potential impact on the surrounding community. Notification procedures will be followed to inform on-site personnel and offsite agencies. The emergency coordinator will make a rapid assessment of the spill/release and direct confinement, containment and control measures. Depending upon the nature of the spill, measures may include:

• Construction of a temporary containment berm utilizing on-site clay absorbent earth • Digging a sump, installing a polyethylene liner and • Diverting the spill material into the sump placing drums under the leak to collect the spilling material before it flows over the ground • Transferring the material from its original container to another container

The emergency coordinator will notify the Client Representative of the spill and steps taken to institute clean-up. Emergency response personnel will clean-up all spills following the spill clean-up plan developed by the emergency coordinator. Supplies necessary to clean up a spill will be immediately available on-site. Such items may include, but are not limited to:

• Shovel, rake • Clay absorbent • Polyethylene liner • Personal safety equipment • Steel drums • Pumps and miscellaneous hand tools

OHM Project 20240HS UGI Columbia Gas-Plant Site October 28, 1997 Information herein (.? proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 8-13 AR400854 OILVI^emedialion EMERGENCY RESPONSE AND g *m"°""* CONTINGENCY PLAN

The major supply of material and equipment will be located in the Support Zone. Smaller supplies will kept at active work locations. The emergency coordinator will inspect the spill site to determine that the spill has been cleaned up to the satisfaction of the Client. If necessary, soil, water or air samples may be taken and analyzed to demonstrate the effectiveness of the spill clean-up effort. The emergency coordinator will determine the cause of the spill and determine remedial steps to ensure that recurrence is prevented. The emergency coordinator will review the cause with the Client Representative and obtain his concurrence with the remedial action plan.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Sen-ices Corp. 8-14 AR400855 9.0 TRAINING REQUIREMENTS

As a requirement for work at this site, in any hazardous waste work area, all field personnel will be required to take a 40-hour training class. This training must cover the requirements in 29 CFR 1910.120: personal protective equipment, toxicological effects of various chemicals, hazard communication, bloodborne pathogens, handling of unknown tanks and drums, confined-space entry procedures, electrical safety, etc. In addition, all personnel must receive annual 8-hour refresher training and three day on-site training under a trained, experienced supervisor. Supervisory personnel shall have received an additional 8-hour training in handling hazardous waste operations.

All personnel entering the exclusion zone will be trained in the provisions of this site safety plan and be required to sign the Health and Safety Plan Certification in Appendix A.

Site-specific training for the UGI Columbia Gas Plant site, which will include potential site contaminants, Hazard Communication as per 29 CFR 1910.1200, site physical and environmental hazards, emergency response and evacuation procedures, and emergency telephone numbers and will be held at the site location by the SS and SSO before any site work activities begin.

Outlines of the orientation for OHM / OHM sub-contract personnel and visitors are presented below:

9.1 SITE ORIENTATION

OHM/SUBCONTRACTORS d. Work Zones in progress e. Hazard Communication a. HASP sign off f. Emergency plan/signals b. Sign in/out procedures g. Training/medical requirements c. Site background h. Zones/areas open to visitors d. Chain of command e. Rules and regulations f. Hours of work g. Absences h. Equipment I. Emergency Information • Emergency signal • Gathering point • Responsibilities/roles • Emergency phone numbers j. Contaminants and Material Safety Data Sheets (MSDS) [Hazard Communication Program] k. JSAs (Phase Safety Plans) 1. Forms, site-specific

VISITOR ORENTATION

a. Sign in/out procedures b. Observation platform safety c. Review of Site map

All OHM personnel participate in a medical and health monitoring program. This program is initiated when the employee starts work with a complete physical and medical history and is continued on a regular basis. A listing of OHM's worker medical profile is shown below. This program was developed in conjunction with a consultant toxicologist. Other medical consultants are retained when additional expertise is required.

The medical surveillance program meets the requirements of the OSHA Standard 29 CFR 1910.120 (0-

•••••' - . ;, ' • . . •:- .e-^.u. ;:;;^^SSffl£a

: .'. . -- ,-.""- "'-':,:. ;'?;:f> Item ".,;,".,.• v. ;^ ;.• :.Vr- Initial Annual Medical History X X Work History X X Visual Acuity and Tonometry X X

Pulmonary Function Tests X X Physical Examination X X Audiometry Tests X X Chest X-Ray X X Complete Blood Counts X X Blood Chem. (SSAC-23 or equivalent) X X

Urinalysis X X

Dermatology Examination X X

Electrocardiogram/Stress Test X X (based on age)

Specific tests are not required for this project.

10.1 EXAMINATION SCHEDULE

Employees are examined initially upon start of employment, biannually or annually thereafter, and may be examined upon termination of employment. Unscheduled medical examinations are conducted:

At employee request after known or suspected exposure to toxic or hazardous materials

At the discretion of the client, the CIH, SSO, or OHM occupational physician after known or suspected exposure to toxic or hazardous materials

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 10-1 AR400857 _^-=s=^ OHM Remediation V^?S!iiS&. MEDICAL SURVEILLANCE PROGRAM

• At the discretion of the OHM occupational physician

All nonscheduled medical examinations will include, as a minimum, all items specified above for periodic surveillance examination, with the exception of the chest X-ray, which will be conducted at the discretion of the occupational physician performing the examination.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. 10-2 AR400858 APPENDIX A HEALTH AND SAFETY PLAN CERTIFICATION

AR400859 HEALTH-AND-SAFETY PLAN CERTIFICATION

By signing this document, I am stating that I have read and understand the site health-and-safety plan for OHM Remediation Services Corp. personnel and visitors entering the Columbia Gas Plant site.

•&^m^A£^S&&. SIGNATURE .;:^-Iff|:

AR400860 APPENDIX B OHM HAZARD COMMUNICA TION PROGRAM

AR400861 APPENDIX B OHM HAZARD COMMUNICATION PROGRAM

'*•* 1. OBJECTIVE

A Site Specific Hazard Communication (Employee Right-To-Know) Program will be instituted at the UGI ^f Columbia Gas Plant Stie, Columbia, Pennsylvania.

2. PURPOSE

** The purpose of Hazard Communication (Employee Right-to-Know) is to ensure that the hazards of all chemicals located at field project sites, shops, and facilities are transmitted (communicated), according to 29 CFR 1910.1200 and 29 CFR 1926.59 to all OHM personnel and OHM subcontractors.

W 3. GENERAL REQUIREMENTS

3.1 It is the responsibility of site supervisors, shop supervisors, and facilities managers to ensure that the '"\Si-/ Hazard Communication Program for the area under their supervision is updated as necessary.

3.2 Container Labeling -- OHM personnel will ensure that all drums and containers are labeled according to ^ contents. These drums and containers will include those from manufacturers and those produced by on site operations. All incoming and outgoing labels shall be checked for identity, hazard warning, and name and address of responsible party.

*" 3.3 Material Safety Data Sheets (MSDSs) -- There will be an MSDS located on site for each hazardous chemical known to exist or which is being used on site. All MSDSs will be located in the site health and safety plan which can be found in the office trailer. MSDS's for products in use may be stored in a separate ^>** binder.

3.4 Employee Information and Site Specific Training - Training employees on chemical hazards is accomplished through an ongoing corporate and regional training program. Additionally, chemical hazards will be communicated to employees through daily safety meetings held at the project and by an initial site orientation program.

^^^ 3.5 OHM employees will be instructed on the following:

• Chemicals and their hazards in the work area • How to prevent exposure to these hazardous chemicals • What the company has done to prevent workers' exposure to these chemicals • Procedures to follow if they are exposed to these chemicals • How to read and interpret labels and MSDSs for hazardous substances V-' • Emergency spill procedures • Proper storage and labeling

.^ 3.6 Before any new hazardous chemical is introduced on site, each employee will be given information in the same manner as during the initial safety class. The site supervisor will be responsible for seeing that the MSDS on the new chemical is available. During the mandatory morning safety briefing, information on each new chemical will be presented.

Should any new chemical be brought on site, the appropriate MSDSs will be added and reviewed with the employees.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and ti> be used or released to others only with explicit written permission of OHM Remediation Services Corp. B-l AR400862 OHM Remediation Services Corp. „„„", OHM HAZARD COMMUNICATION PROGRAM

1. GENERAL

The following written Hazard Communication Program has been established for OHM Remediation Services Corp. (OHM). The purpose of this program is to transmit information to the workers about the chemical hazards in the work place using various media. The transmittal of information will be accomplished by means of a comprehensive Hazard Communication Program, which will include container labeling and other forms of warning, material safety data sheets (MSDSs), and employee training in accordance with 29 CFR 1910.1200 and 29 CFR 1926.59.

Upon mobilization at the job site the Hazard Communication Program will be reviewed with all employees. Upon reading the Hazard Communication Program employees will be asked to sign the "Worker Hazard Communication Acknowledgment Form". The Hazard Communication Program will also be reviewed with new employees and visitors as they arrive on site. These persons will also be asked to sign the acknowledgment form. The Hazard Communication Program shall be available for review by anyone on site any time during normal work hours. OHM will accomplish the hazard communication requirements through formal safety training, departmental safety meetings, and job-site safety meetings.

The Health and Safety Department shall update the Hazard Communication Program when personnel responsibilities change, a new non-routine task is introduced, or an extremely hazardous material needs particular attention. This new program will then be distributed throughout the company.

2. RESPONSIBILITIES

Overall responsibility for compliance with the Site Specific Hazard Communication Program Site Supervisor and SSO of OHM. A brief outline of responsibilities for those persons directly involved with the program will follow. These responsibilities are not all inclusive, but are designed to give guidance in initial and long-term program development. Since each area is different, these responsibilities may vary.

This program is intended to cover those employees who are directly involved with the handling of hazardous chemicals or supervision of activities that involve the use of hazardous chemicals.

2.1 Health and Safety Department Responsibilities

• Review operations with site supervisors to determine what tasks require hazard communication training.

• Advise supervisory people as to which materials may need to be considered hazardous initially and eventually to ensure that hazard task determination is being done according to the written policy.

• Follow up through safety meetings and safety audits to ensure that supervisors are carrying out prescribed company policy.

• Notify supervisors immediately of any operating changes affecting the hazardous chemicals being used.

2.2 Training Department Responsibilities

• Ensure that up-to-date records are maintained on training of all employees required to handle hazardous chemicals. The supervisor should keep copies of these records and should also send copies of the initial training to the corporate training secretary for the training file.

• Educate personnel upon initial 40-hour OSHA training to the requirements of the Hazard Communication Standard.

2.3 Site Supervisors' Responsibilities

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1 997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Sen-ices Corp. B-2 AR400863 ^F^=^ OHM Ileniedialion Jf Services Corp. A" '*0"'"° OHM HAZARD COMMUNICATION PROGRAM

• Identify jobs requiring the use of hazardous chemicals and develop a list of those jobs and chemicals.

• Provide the training required by the Hazard Communication Standard and document training of employees in the safe handling of hazardous chemicals.

• Ensure inspection of engineering controls and personal protective equipment before each use. The health and safety department shall help determine a suitable inspection plan for each application as needed.

• Make daily surveys of the work area to ensure that safe practices are being followed. Advise employees of and document unsafe work practices on the first occasion and consider further unsafe work practices as disciplinary violations. Use documentation as topics of safety meetings.

• Ensure required labeling practices are being followed. Labels should be affixed to the container when it arrives. If the contents are transferred to another container, then all label information (manufacturer, manufacturer's telephone number, product name, target organ(s) and product number) must also be affixed to the new container, so that all containers of the material, regardless of size, are labeled. Contact the health and safety department for proper labels.

• Enforce all applicable safety and health standards through periodic documented audits.

Before ordering a material, determine if a MSDS exists on file. Request a MSDS from the manufacturer for all new products.

2.4 Employee Responsibilities

• Read and understand entire Site Specific Hazard Communication Program.

• Obey established safety rules and regulations.

« Use all safety procedures and personal protective equipment as required by company procedures.

• Notify supervisor of the following:

Any symptoms or unusual effects that may be related to the use of hazardous chemicals. Any missing, incomplete, or unreadable labels on containers. - Missing, damaged, or malfunctioning safety equipment.

• Use approved labels on containers; do not remove labels (labels are available from the health and safety department).

• Use only approved containers for hazardous chemicals. (Is chemical and container compatible and appropriate?)

• Know where emergency equipment and first-aid supplies are located.

• Know location of MSDSs. These will be located in the break/decon area and the job-site office trailer.

• Know what you are expected to do in case of an emergency. Before the commencement of any task, emergency considerations shall be made.

2.5 Shipping/Receiving Personnel Responsibilities

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released tn other;: only with explicit written permission of OHM Remediation Services Corp. B-3 AR400864 =-==^ OHM Remediation \ PPJ7A7D7F ft ^ S^P Services Corp. AI't't.NUlA & ^ — '*"->•"•"--•- OHM HAZARD COMMUNICATION PROGRAM

-, • The Project Accountant (PA) or other persons assigned by the site supervisor shall ensure MSDSs are received with initial shipment of a hazardous chemical; if not, contact purchasing to request the appropriate MSDS and also call the health and safety department to determine if there is a MSDS available until the requested MSDS arrives.

• Ensure labels with required information are affixed to all containers.

<^> • Store hazardous materials in designated locations.

• Use proper personal protective equipment when handling hazardous chemicals.

• Report damaged containers or spills to the site supervisor and the site safety officer immediately.

3. HAZARD DETERMINATION

OHM will rely on MSDSs from chemical suppliers and manufacturers to meet hazard determination requirements. Other relevant data from laboratory analyses, chemical reference materials, and chemical manufacturers' written evaluation procedures will be utilized when warranted. No other method shall be used to determine a chemicals' >^^ hazards unless approved by the health and safety department.

4. LABELING *=• The site supervisor will be responsible for seeing that all containers arriving at OHM job sites are properly and clearly labeled. Site supervisors shall also check all labels for chemical identity and appropriate hazard warnings. If the hazardous chemical is regulated by OSHA in a substance specific health standard (29 CFR 1910), the site supervisor shall ensure that the labels or other forms of warning used are in accordance with the requirements of that standard. Any container that is not labeled shall be immediately labeled after initial discovery with the required information.

The site supervisor or Team Leader shall be responsible for seeing that all portable containers used in their work area are properly labeled with chemical identity and hazard warning. (Refer to MSDS for required labeling ^ information.)

The site supervisor or Team Leader shall also ensure that labels on hazardous chemical containers are not removed or defaced unless the container is immediately marked with the required information and that all labels >IN»-' are legible in English and prominently displayed on the container or readily available in the work area throughout each shift.

^ If any container is found and the contents cannot be identified, the site supervisor shall be contacted immediately. When proper identification is made, a label shall be affixed to the container immediately. If it is discovered that no MSDS is available, the manufacturer and the health and safety department shall be contacted to assist in locat- ing the proper MSDS. If there is no means of identifying the material in the container, the container shall be taken out of service, away from all personnel until it can be tested by the health and safety department or laboratory personnel. The site supervisor shall communicate their findings or awareness of such containers to all personnel working in the area and to the district health and safety manager. V 5. MATERIAL SAFETY DATA SHEETS fMSDS>

The site supervisor at OHM job sites will be responsible for maintaining a current MSDS relevant to the hazardous chemicals used on their job sites. The health and safety department will be responsible for compiling the initial MSDS file for the job site and aiding all job sites with the completion and maintenance of their respective MSDS files.

V OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. B-4 AR400865 ^="=^- OHM Remediation A ppi7\nrj7V ft C ^ Services Corp. APfLNDlX ff HT"'' ^-"=ir •• ASqWWUry *f OffM Corpormiloa OH^-. -~._ M— _. HAZAR-— s_ D COMMUNICATIO_~ N PROGRA—^ M

, All MSDSs shall be readily available for review by all employees during each work shift. Each job site will designate a clearly marked "Employee Right-to-Know" station where employees can immediately obtain a MSDS and the required information in an emergency. MSDSs shall also be made available, upon request, to designated OHM representatives, other employer's employees, and to any OSHA inspector in accordance with the requirements of *"* 29CFR 1910.1200(e).

Although manufacturers are required to provide employers with MSDSs on an initial chemical shipment, OHM >-*• purchasing agents (and site supervisors purchasing their own material) shall request MSDSs and updates to MSDSs on all purchase orders. Site supervisors that are without proper MSDSs shall be responsible for requesting this information from chemical manufacturers. The site supervisor shall maintain a file of follow-up letters for all hazardous chemical shipments they receive without MSDSs.

6. EMPLOYEE INFORMATION AND TRAINING Ac s? It is the responsibility of the supervisor in charge of each employee to ensure that the employee is properly trained. Training employees on chemical hazards and chemical handling is accomplished at the time of initial employment at OHM, whenever a new chemical (or physical) hazard is introduced into the work area, and through ongoing formal and informal training programs. Additionally, chemical hazards are communicated to employees through v*-/ weekly and morning, job- site safety meetings, which shall be documented according to topic, major points discussed, and names of those attending (attendance is mandatory). Records of all formal training conducted at OHM are coordinated and maintained by the Training Department secretary. Cs- At a minimum, OHM will inform employees on the following:

• The requirements of 29 CFR 1910.1200-Hazard Communication-Evaluating the potential hazards of chemicals and communicating information concerning hazards and appropriate protective measures to employees. OHM shall accomplish employee training in several different ways including, but not limited, to 40-hour OSHA Hazardous Waste Worker Training (29 CFR 1910.120), shop safety meetings, job-site '** safety meetings, Health and Safety Department safety meetings, and formal and informal training about specific chemical hazards.

•^ • The location and availability of the written Hazard Communication Program, list of hazardous chemicals, and MSDSs will be periodically posted on the employee bulletin boards providing the location of the above material.

**+~S • Any operations in their work area where hazardous chemicals are present.

• How to work safety with chemicals present in the workplace and minimize potential exposure.

• Methods and observations that may be used to detect the presence or release of a hazardous chemical in ^*" the work area (monitoring instruments, visual appearance or odor, and acute and chronic health effects).

• The physical, chemical, and health hazards of the chemicals in the work area. V- • The methods of preventing exposure to hazardous chemicals including the measures OHM has taken to " ' protect the employees.

• Procedures to follow if OHM employees are exposed to hazardous chemicals (location of the nearest phone, emergency eyewash, and shower will be included). These discussions shall include proper operating procedures for all emergency equipment.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein /.t proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. B-5 AR400866 OHM Remediation A npj7\rr»rv J? ServiceSorvWcs P^rrCorp.. Ai~f CLLMJlA D OHM HAZARD COMMUNICATION PROGRAM

^ • The details of the OHM written Hazard Communication Program, including an explanation of the labeling system and the MSDSs, and how employees can obtain and use the appropriate hazard information.

• Procedures for workers involved in non-routine tasks.

Each site supervisor shall ensure that the above training is emphasized to OHM employees. The health and safety department will ensure that each job site is properly informing and training all employees through group meetings ^f and individual discussions. Whenever a new hazardous chemical is placed into use, the site supervisor shall inform the employees of the hazards said chemical may pose. The site supervisor shall also be responsible for obtaining and making available a MSDS for the new chemical.

** 7. HAZARDOUS NON-ROUTINE TASKS

* Occasionally, employees at OHM are required to perform tasks which are considered to be non-routine. All tasks ^3, OHM considers non-routine shall be carefully discussed among the supervisor and those performing the task. This safety briefing shall include all possible hazards an employee may encounter while completing the task, including:

• Hazard recognition *\^/ • Chemicals involved and their hazardous properties • Physical hazards • Methods of avoiding hazards (monitoring instruments, proper personal protective equipment, etc.)

The following is a list of some of the non-routine tasks which may occur at OHM job sites. These tasks are all covered in detail in various OHM standard operating Procedures.

7.1 Confined Space Entry 7.2 Excavation, Trenching, and Shoring 7.3 Decontamination of Equipment *^ 7.4 Laboratory Spills 7.5 High-Pressure Washer (Laser) Operation 7.6 Line Entry Procedure , 7.7 Hot Work

8. INFORMING CONTRACTORS

*-s^ It shall be the responsibility of the OHM site supervisor/SSO to provide subcontractors with the following information:

• Hazardous chemicals to which they may be exposed while performing a task including the following:

Chemical properties Physical properties **•- - Acute/Chronic health effects

• Location of "Employee Right-to Know" station which includes the following: V MSDS for work area Hazard Communication Program Other relevant safety material such as Project Health and Safety Plan (HASP) >sr- • Precautionary measures to be taken to protect employees from chemical and physical hazards.

w • Location of nearest emergency equipment (fire extinguisher, eyewash, shower, phone, first-aid kit, etc.)

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 information herein is proprietary and confidential and to be used or released tt> others only with explicit written permission of OHM Remediation Services Corp. B-6 AR400867 ^"^s-_ OHM Hemedialion % ^g=" Services Corp. = ^.o^... OHM HAZARD COMMUNICATION PROGRAM

• Procedures to follow in the event of employee exposure.

• Steps OHM has taken to reduce the risk of exposure to physical and chemical hazards including the following:

Safety meetings Hazard Communication Program Proper storage and labeling of hazardous chemicals Health and safety department shop audits

• The methods used to label all hazardous chemicals.

• Emergency evacuation signals and evacuation rally locations.

The health and safety department shall offer assistance in providing the above information to subcontractors working at OHM job sites. On initial visit by a subcontractor to OHM job sites, a "Contractor Right-to-Know" release form shall be completed. This form will state that the above information has been communicated to the perspective contractor.

Conversely, the site supervisor shall obtain the above information from subcontractors for hazardous materials they have brought to our projects.

8.1 Contractor Right-to-Know Acknowledgment

By signing this sheet, the signee is stating that an OHM employee or representative has briefed said signee on the essentials of OHM's Hazard Communication Program, including hazardous chemical(s) to which one may be exposed, location of program and MSDS, precautionary measures taken to protect contractors from chemical and physical hazards, location of nearest emergency equipment, procedures to follow in the event of employer's employee chemical exposure, and method used to label all hazardous chemicals.

Name Date Company

>- 9. LIST OF HAZARDOUS CHEMICALS

The following is a list of hazardous chemicals used on this OHM job site. Further information on each v, hazardous chemical listed below can be found in the MSDS which are included in the site specific health and safety plan. The SS and/or the SSO will complete this list for chemicals found at the site.

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. B-7 AR400868 ^^r^. OHM Remediation C ^^=" Services Corp. APPENDIX B rJof OEM Co/partita OHM HAZARD COMMUNICATION PROGRAM

Typical OHM Job-Site Hazardous Chemical Inventory List

Available On Site Chemicals

Acetone Acetylene Activated Charcoal, Powder Alum (Aluminum Sulfate) Anti-fog Bausch & Lomb Argon/Methane (95%/5%) Brake Fluid Calcium Hydroxide (Hydrated Lime) Calibration Check Gas Carbon Caustic Soda (Sodium Hydroxide) Citrilcleen Coal Fly Ash Compressed Air Diatomaceous Earth Diesel Fuel Dry Ice (Solid Carbon Dioxide) Ethylene Glycol Ferric Chloride Freon Gear Grease - Delta Helium Hexane Hydraulic Fluid Hydrochloric Acid Hydrogen Isobutylene Kiln Dust Methanol Nitrogen Nitrous Oxide Oxygen Penetone Pentane Polymers (Flocculants) Premium Unleaded Gasoline PVC Solvent Cleaner PVC Cement Regular Leaded Gasoline Starting Fluid V- Stoddard Solvent Sulfuric Acid 10W-40 Motor Oil-Shell Tube Grease - Kendall TU Type 555 Thread Sealing Compound 2-Cycle Oil - Wolfs Head

OHM Project 20240HS UGI Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. B-8 AR400869 OHM Keniedialion • Services Corp. OHM HAZARD COMMUNICATION PROGRAM

Site-Specific Hazardous Chemical Inventory

OHM Project 20240HS UG1 Columbia Gas Plant Site October 28, 1997 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp. B-9 AR400870 APPENDIX C MATERIAL SAFETY DATA SHEETS

•w

AR400871 Genium Publishing Corp. Material Safety Data Sheet Collection One Genium Plaza Schenectady, NY 12304-4690 Anthracene MSDS No. 917 (518)377-8854 Date of Preparation: 6/94 Section 1 - Chemical Product and Company Identification 44 Product/Chemical Name: Anthracene Chemical Formula: (Cgr^CH^ CAS No.: 120-12-7 Synonyms: anthracin, green oil, paranaphthalene, Tetra Olive N2G Derivation: Occurs naturally in smoke (gasoline, coal, cigarette, etc.), charbroiled foods, and coal tar pitch volatiles. Obtained by distilling crude anthracene oil with alkali carbonate in iron retorts (phenanthrene is removed via carbon disulfide) or by salting out from crude anthracene oil and draining; the crude salts are then purified by pressing and the use of various solvents (phen-anthrene and carbazole are removed). General Use: Used in chemical manufacture (phenanthrene, carbazole, anthraquinone), in calico printing; as a component of dyes, scintillation fluid, smoke screens; and in organic semi-conductor research. ^ Vendors: Consult the latest Chemical Week Buyers' Guide. ^^ Section 2 - Composition / Information on Ingredients Anthracene, ca 90 to 95 %wt (commercial grade); 90 to 98 %wt (technical grade) Trace Impurities: Include phenanthrene, carbazole, chrysene, pyridine (0.2%), iron (0.03%) OSHA PEL* NIOSH RELt DFG (Germany) MAK 8-hr TWA: 0.2 mg/m3 10-hr TWA: 0.1 mg/m3 None established ACGffl TLV* IDLH Level TWA: 0.2 mg/m3 Ca, 700 mg/m3 *Coal tar pitch volatiles (benzene soluble). OSHA defines coal tar pitch volatiles as the fused polycyclic hydrocarbons that volatilize from the distillation residues of coal, petroleum, wood, and other organic matter, and includes anthracene. tCoal tar products (cyclohexane extractable fraction), including anthracene. Section 3 - Hazards Identification

Emergency Overview Wilson Risk Anthracene is a polyaromatic hydrocarbon present in coal tar pitch volatiles. It exists as colorless crystals with a violet fluorescence when pure and as yellow crystals with a green fluorescence. Anthracene is Scale R 1 irritating to the eyes, skin, and respiratory tract. Exposure to the sun can aggravate skin irritation and cause dermatitis. It is combustible. I 3 S 2* Potential Health Effects K 1 *Skin Primary Entry Routes: Inhalation, skin/eye contact absorption Target Organs: Eyes, skin, respiratory and digestive tracts. HM1S Acute Effects H it Inhalation: Symptoms include irritation of the respiratory tract, headache, nausea and vomiting, loss of appetite, F 1 slowed reactions, and adynamia (lack or loss of strength due to disease or other outside agent). Eye: Irritation of the conjunctiva with burning, itching and watering. R 0 Skin: Irritation with burning, itching, and edema (fluid build-up). Volunteers with a 2% crude tar solution applied Chronic to the skin showed anthracene absorption via blood tests. Effects Ingestion: Gastrointestinal tract irritation. Carcinogenicity: Coal tar pitch volatiles (in general) are considered to be carcinogens by the Nl'F, IARC, DFG, PPE* NIOSH, and ACGIH. However, anthracene has been specifically evaluated by IARC and designated as Class 3 *Sec.8 (unclassifiable as to carcinogenicity with no human evidence and limited animal evidence). Medical Conditions Aggravated by Long-Term Exposure: Dermatitis. Chronic Effects: Repeated skin contact can cause pigmentation of the skin with cornification of surface layers and telangioectasis (an abnormal dilatation of capillary vessels that often form small, raised, red, wart-like spots). Sensitization (including photosensitization) may also occur. Other: Acute symptoms disappear within several days of last exposure. Anthracene appears to concentrate in the fat and liver. Section 4 - First Aid Measures Inhalation: Remove exposed person to fresh air and support breathing as needed. Eye Contact: Do not allow victim to rub or keep eyes tightly shut. Gently lift eyelids and flush immediately and continuously with flooding amounts of water for at least 15 minutes. Consult an ophthalmologist if pain and irritation persist.

Copyright© 1994 by Genium Publishing Corporation. Any commercial use or reproduction without ihe publisher's permission is prohibited. Judgments as to the suitability of information herein for the purchaser's purposes are necessarily the purchaser's responsibility. Although reasonable care has been taken in the preparation of such information. Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser's intended purpose or for consequences of its use. AR400872 _, MSDSNo.917 Anthracene 6/94 Skin Contact: Quickly remove contaminated clothing. Rinse with flooding amounts of water for at least 15 min. Wash exposed area with soap and water. For reddened or blistered skin, consult a physician. Ingestion: Never give anything by mouth to an unconscious or convulsing person. Contact a poison control center. Unless the poison control center advises otherwise, have the conscious and alert person drink 1 to 2 glasses of water to dilute. Vomiting may be spontaneous. After first aid, get appropriate in-plant, paramedic, or community medical support. Note to Physicians: Treatment is symptomatic and supportive. Section 5 - Fire-Fighting Measures Flash Point: 250 °F (121 *C) Genium Flash Point Method: CC Autoignition Temperature: 1004 "F (540 °C) LEL: 0.6% v/v UEL: Not reported. Flammability Classification: Combustible Extinguishing Media: Use water spray, carbon dioxide, dry chemical, or foam. Unusual Fire or Explosion Hazards: May explode in air. Hazardous Combustion Products: Include carbon oxide(s) and irritating, acrid smoke. Fire-Fighting Instructions: Do not release runoff from fire control methods to sewers or waterways. Fire-Fighting Equipment: Because fire may produce toxic thermal decomposition products, wear a self-contained breathing apparatus (SCBA) with a full facepiece operated in pressure-demand or positive-pressure mode. Section 6 - Accidental Release Measures Spill /Leak Procedures: Notify safety personnel, isolate and ventilate area, deny entry, and stay upwind. Cleanup personnel should protect against inhalation and skin/eye contact. Small Spills: Carefully scoop up or vacuum (with appropriate filter) and place in suitable containers for disposal. Large Spills Containment: Use water to flush large spills to containment area for later disposal. Do not release into sewers or waterways. Cleanup: Damp mop any residue. Regulatory Requirements: Follow applicable OSHA regulations (29 CFR 1910.120). Section 7 - Handling and Storage Handling Precautions: Do not use near heat or flame. Wear appropriate PPE. Storage Requirements: Store in a cool, dry, well-ventilated area away from heat, ignition sources, and incompatibles (Sec. 10). Section 8 - Exposure Controls /Personal Protection Engineering Controls: To prevent static sparks, electrically ground and bond equipment used with and around anthracene. Enclosure of equipment and mechanization of processes will aid in exposure control. Ventilation: Provide general or local exhaust ventilation systems to maintain airborne concentrations below OSHA PELs (Sec. 2). Local exhaust ventilation is preferred because it prevents contaminant dispersion into the work area by controlling it at its source. (l03) Administrative Controls: Consider preplacement and periodic medical exams of exposed workers with emphasis on the skin. Respiratory Protection: Seek professional advice prior to respirator selection and use. Follow OSHA respirator regulations (29 CFR 1910.134) and, if necessary, wear a MSHA/NIOSH-approved respirator. For any detectable concentration, use a SCBA or supplied-air respirator with a full facepiece and operated in pressure-demand or other positive-pressure mode in combination with an auxiliary SCBA operated in pressure-demand or other positive-pressure mode. For emergency or nonroutine operations (cleaning spills, reactor vessels, or storage tanks), wear an SCBA. Warning! Air-purifying respirators do not protect workers in oxygen-deficient atmospheres. If respirators are used, OSHA requires a written respiratory protection program that includes at least: medical certification, training, fit-testing, periodic environmental monitoring, maintenance, inspection, cleaning, and convenient, sanitary storage areas. Protective Clothing/Equipment: Limit work in sunlight as much as possible to prevent photosensitization. Photoprotective creams or pastes must be applied to bare skin regions. Wear chemically protective gloves, boots, aprons, and gauntlets to prevent prolonged or repeated skin contact. Polyvinyl chloride is a suitable material for PPE. Wear protective eyeglasses or chemical safety goggles, per OSHA eye- and face-protection regulations (29 CFR 1910.133). Contact lenses are not eye protective devices. Appropriate eye protection must be worn instead of, or in conjunction with contact lenses. Safety Stations: Make emergency eyewash stations, safety/quick-drench showers, and washing facilities available in work area. Contaminated Equipment: Separate contaminated work clothes from street clothes and place in closed containers until laundered. Remove anthracene from your shoes and clean personal protective equipment. Comments: Never eat, drink, or smoke in work areas. Practice good personal hygiene after using anthracene, especially before eating, drinking, smoking, using the toilet, or applying cosmetics. Skin cleansers (ex. 55% kaolin, 25% neutral soap, 20% bran) are recommended.

2 OI 4 Copyright O 1994 Genium Publishing Corporation. Any commercial use or reproductionwithou t the publisher'AR400873s permission is prohibited. 6/94 Anthracene MSDS No. 917 Section 9 - Physical and Chemical Properties Physical State: Solid Water Solubility: 1.29 mg/L at 77 'F/25 *C (distilled Appearance and Odor: Colorless crystals with a violet water), 0.6 mg/L at 77 *F/25 'C (salt water) fluorescence (pure), yellow crystals with a green Other Solubilities: 1 g in 67 mL absolute alcohol, 70 mL fluorescence (due to tetracene and naphthacene) methanol, 62 mL benzene, 85 mL chloroform, 200 mL Vapor Pressure: 1mm Hg at 293 *F (145 *C) ether, 31 mL carbon disulfide, 86 mL carbon tetrachloride, Formula Weight: 178.22 and 125 mL toluene. Also soluble in acetone. 3 Density (H2O=1, at 4 °C): 1.25 g/cm at 80.6 °F (27 °C) Boiling Point: 644 T (340 'Q Octanol/Water Partition Coefficient: log Kow = 4.45 (calc.) Melting Point: 423 "F (217 °C)

Section 10 - Stability and Reactivity Stability: Anthracene darkens upon exposure to sunlight (transformed to para -anthracene). Polymerization: Hazardous polymerization does not occur. Chemical Incompatibilities: Include calcium hypochlorite (exothermic), fluorine (explodes), chromic acid, and calcium oxychloride. Conditions to Avoid: Exposure to heat, ignition sources, sunlight, and incompatibles. Hazardous Decomposition Products: Thermal oxidative decomposition of anthracene can produce carbon oxide(s) and acrid, irritating smoke. Section 11- Toxicological Information ToxicityData:* Skin Effects: Acute Oral Effects: Mouse, skin: 118 ng caused mild irritation. Mouse, oral, LD: > 17 g/kg caused fatty liver degeneration. Mutagenicity: Tumorigenicity: Rat, liver cell: 300 |amoL caused DNA damage. Rat, oral: 20 g/kg intermittently for 79 weeks caused liver tumors.

'SeeNIOSH, RTECS (CA9350000), for additional toxicity data. Section 12 - Ecological Information Ecotoxicity: Leponis macrochirus (bluegill sunfish), LCso = 11.9 |ig/L/96 hr; Rana pipiens (leopard frog), LCso = 0.065 ppra/30 min & 0.025 ppm/5 hr. BCF (bioconcentration factor): goldfish (162), rainbow trout (4400-9200). Bioconcentration occurs most heavily in organisms which lack the enzyme microsomal oxidase. Anthracene can become concentrated on the waxy surface of some plant leaves and fruits. Environmental Degradation: If released to soil, anthracene is expected to absorb strongly and not leach to groundwater. It will not hydrolyze, but may be subject to biodegradation, the rate of which depends on soil type. In water, anthracene is subject to direct photolysis near the surface and undergoes significant biodegradation. Biodegradation in water is faster with increased temperature, increased oxygen, and acclimated microbes. Evaporation may also be significant with an estimated half-life range of 4.3 to 5.9 days from a river 1 m deep, flowing 1 m/sec, with a wind velocity of 3 m/sec. In the air, photolysis and reaction with photochemically-produced hydroxyl radicals (half-life: 1.67 days). Vapor phase anthracene is expected to degrade faster than particle-sorbed anthracene. Soil Absorption/Mobility: A Koc of 26,000 suggests anthracene is relatively immobile in soil and unlikely to leach to groundwater; it will absorb strongly to soil. :;'% Section 13 - Disposal Considerations Disposal: Anthracene is a waste chemical stream constituent which may be subjected to ultimate disposal by controlled incineration. Contact your supplier or a licensed contractor for detailed recommendations. Follow applicable Federal, state, and local regulations.

AR400874 Copyright 6 1994 Genium Publishing Corporation. Any commercial use or reproduction without the publisher's permission is prohibited. Page 3 of 4 MSDSNo.917 Anthracene 6/94 Section 14 - Transport Information DOT Transportation Data (49 CFR 172.101): Shipping Name: Packaging Authorizations Quantity Limitations Environmentally hazardous a) Exceptions: 173.155 a) Passenger, Aircraft, or Railcar: None substances, solid, n.o.s.* b) Non-bulk Packaging: 173.213 b) Cargo Aircraft Only: None Shipping Symbols: — c) Bulk Packaging: 173.240 Hazard Class: 9 Vessel Stowage Requirements ED No.: UN3077 a) Vessel Stowage: A Packing Group: in b) Other: — Label: Class 9 Special Provisions (172.102): 8, B54, N50

: Classified as a hazardous substance when anthracene is in a quantity, in one package, which equals or exceeds the RQ of 5000 Ib (2270 kg) Section 15 - Regulatory Information EPA Regulations: RCRA Hazardous Waste (40 CFR 261.33): Not listed Listed as a CERCLA Hazardous Substance (40 CFR 302.4) per CWA, Sec. 311 (b)(4) CERCLA Reportable Quantity (RQ), 5000 Ib (2270 kg) Listed as a SARA Toxic Chemical (40 CFR 372.65) SARA EHS (Extremely Hazardous Substance) (40 CFR 355): Not listed OSHA Regulations: Listed as an Air Contaminant (29 CFR 1910.1000, Table Z-l, Z-l-A) Section 16 - Other Information References: 73, 103, 124, 132, 136, 149, 159, 176, 184, 187, 189, 192

Prepared By M Gannon, BA Industrial Hygiene Review DJ Wilson, CIH Medical Review T Thoburn, MD, MPH

Disclaimer: Judgments as to the suitability of information herein for the purchaser's purposes are necessarily the purchaser's responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser's intended purpose or for consequences of its use.

r 3....C 4 01 ^ Copyright © 19W Genium Publishing Corporation. Any commercial use orreproductio n wUhom the publisher'AR400875s permission is prohibited. Genium Publishing Corp. Material Safety Data Sheets Collection One Genium Plaza Schenectady.NY 12304-4690 Benzo(a)pyrene MSDS No. 164 (518)377-8854 Date of Preparation: 2/94 Section 1 - Chemical Product and Company Identification 43 Product/Chemical Name: Benzo

Copyrijhi C I99J by Gcfliun Publilhini Coporaton Ajw eomm«rci»l ate or rcpro* ...... nan herein for purpo»rt tn MCdurily the purchAKT'i rwponlibiliry Amcugh reuonible cart hu fc no wvnnQ'ct, mikes no npmottotfit, m4 luumcioorcspOTiitiility u totrvc Accuracy or tuiability of fach 3 uu.AR400876 _MSDS No. 164 Benzo(a)pyrene 2/94 Eye Contact: Do not allow victim to rub or keep eyes tightly shut. Gently lift eyelids and flush immediately and continuously with flooding amounts of tepid water for at least 15 min. Consult an ophthalmologist if irritation or pain persist. Skin Contact: Quickfy remove contaminated clothing. Rinse with flooding amounts of water (less than 15 min). Wash exposed * •»—•«^vith soap and water. For reddened or blistered skin, consult a physician. lion: Never give anything by mouth to an unconscious or convulsing person. Contact a poison control center. Unless the poison control center advises otherwise, have the conscious and alert person drink 1 to 2 glasses of water to dilute. Inducing vomiting is not necessary since bcnzo(a)pyrene has a low acute toxicity and therefore, is generally an unnecessary procedure. Consider activated charcoal/cathartic. After first aid, get appropriate bt-plant, paramedic, or commun try medical support. Note to Physicians: Monitor CBC and arterial blood gases, conduct liver, renal, and pulmonary function tests (if respiratory tract . irritation is present), and urinalysis. Biological monitoring techniques testing for metabolites in blood or urine, or DNA adducts in blood or tissues are useful for epidemiological studies mat determine if exposure has occurred. Because neither normal nor toxic levels have been established, those techniques may not be useful for evaluating individual patients. Special Precautions/Procedures: Emergency personnel should protect against exposure. Section 5 - Fire-Fighting Measures Flash Point: None reported. Benzo(a)pyrene may burn, but doesnot readily ignite. Genium —Autoignition Temperature: None reported. LEL: None reported. UEL: None reported. r%~tinguishing Media: For small fires, use dry chemical, sand, water spray, or foam. For large fires, use "Siter spray, fog, or foam. unusual Fire or Explosion Hazards: None reported. Hazardous Combustion Products: Carbon monoxide and carbon dioxide. Fire-Fighting Instructions: Isolate hazard and deny entry. If feasible and without undue risk, move containers from fire hazard area. Otherwise, cool fire-exposed containers with water spray until well after fire is extinguished. Do not release runoff from fire control methods to sewers or waterways. Fire-Fighting Equipment: Because fire may produce toxic thermal decomposition products, wear a self-contained breathing ^ apparatus (SCBA) with a full facepiece operated in pressure-demand or positive-pressure mode and full protective clothing. Section 6 - Accidental Release Measures ( /Leak Procedures: Notify safety personnel of large spills, remove heat and ignition sources, and provide adequate *"" ventilation. Cleanup personnel should protect against dust inhalation and skin or eye contact. Clean up spills promptly. Small Spills: Carefully scoop up spilled material and place into appropriate containers for disposal. For liquid spills, take up with a noncombustible, inert absorbent and place into appropriate containers for disposal. \^.Large Spills Containment: For large spills, dike far ahead of liquid spill or contain dry spill for later disposal. Do not release into sewers or waterways. "teanup: Do not dry sweep! Use a vacuum with a HEPA fiher or a wet method to reduce dust. After cleanup is complete, *-x^,oroughly decontaminate all surfaces.Do not reuse contaminated cleaning materials. I Regulator}- Requirements: Follow applicable OSHA regulations (29 CFR 1910.120). Section 7 - Handling and Storage T Handling Precautions: Handle with extreme caution and take all necessary measures to avoid exposure to benzo(a)pyrene ' because it is a carcinogen and mutagen. Follow good personal hygiene procedures and thoroughly wash hands with soap and water after handling. Use safety pipettes for all pipetting. Storage Requirements: Store in tightly closed and properly labeled containers in a cool, well-ventilated area. Section 8 - Exposure Controls / Personal Protection Engineering Controls: Use a Class I, Type B, biological safety hood when working with benzo(a)pyrene in a laboratory. Decrease the rate of air extraction, so that benzo(a)pyrene can be handled without powder being blown around the hood. Keep Iglove boxes under negative pressure. Use vertical laminar-flow, 100% exhaust, biological safety cabinets for containment of in vitro procedures. The exhaust air flow should be sufficient to provide an inward air flow at the face opening of the cabinet. Ensure contaminated air sheaths that are under positive pressure are leak-tight Never use horizontal laminar-flow hoods or safety cabinets where filtered air is blown across the working area towards the operator. Test cabinets before work begins to ensure they are functioning properly. Ventilation: Provide general or local exhaust ventilation systems to maintain airborne concentrations as low as possible. Local -haust ventilation is preferred because it prevents contaminant dispersion into the work area by controlling it at its source?103) T inistrative Controls: Consider preplacement and periodic medical examinations with emphasis on the oral cavity, bladder, kidneys, skin, and respiratory tract. Conduct urinalysis including specific gravity, albumin, glucose, and microscopic examination of centrifuged sediment for red blood cells. Also, include 14" x 17" chest roentgenogram, FVC + FEVj, and CBC to detect any leukemia or aplastic anemia. It is recommended that this exam be repeated on an annual basis and semi-

Page 2 of 4 Copyii|)n O 1W4 Gvmn fuMiita'«t Capanrian. Aay taumeatl UM or rcpreduaioo wirfuju tit publitfce'i pemtuiaAR400877n if prohibited. _. 2/94 Benzo(a)pyrene MSDS No. 164 annual basis for employees 45 yr of age or older or with 10 or more years of exposure to coal tar pitch voiatiles. Train workers about the hazards of benzo{a)pyTene and the necessary protective measures to prevent exposure. Periodically inspect lab atmospheres, surfaces such as walls, floors, and benches, and interior of fume hoods and air ducts for contamination. Post appropriate signs and labels on doors leading into areas where benzo(a)pyrene is used. Respiratory Protection: Seek professional advice prior to respirator selection and use. Follow OSHA respirator regulations (29 CFR 1910.134) and, if necessary, wear a MSHA/NIOSH-approved respirator. The following respirator recommendations are for coal tar pitch voiatiles. For any unknown concentration, wear any SCBA with a full facepiece and operated in a pressure demand or other positive pressure mode, or any supplied-air respirator with a full facepiece and operated in a pressure-demand or other positive pressure mode in combination with an auxiliary SCBA operated in pressure-demand or other positive pressure mode. For escape, wear any air-purifying full facepiece respirator (gas mask) with a chin-style or front- or back-mounted organic vapor canister having a high-efficiency paniculate filter, or any appropriate escape-type SCBA. Select respirator based on its suitability to provide adequate worker protection for given working conditions, level of airborne contamination, and presence of sufficient oxygen. For emergency or nonroutine operations (cleaning spills, reactor vessels, or storage tanks), wear an SCBA. Warning! Air-purifying respirators do not protect workers in oxygen-deficient atmospheres. If respirators are used, OSHA requires a written respiratory protection program that includes at least: medical certification, training, fit-testing, periodic environmental monitoring, maintenance, inspection, cleaning, and convenient, sanitary storage areas. Protective Clothing/Equipment: Wear chemically protective gloves, boots, aprons, and gauntlets to prevent prolonged or repeated skin contact. In animal laboratories, wear protective suits (disposable, one-piece and close-fitting at ankles and wrists), gloves, hair covering, and overshoes. In chemical laboratories, wear gloves and gowns. Wear protective eyeglasses or chemical safety, gas-proof goggles, per OSHA eye- and face-protection regulations (29 CFR 1910.133). Because contact lens use in industry is controversial, establish your own policy. Safety Stations: Make available in the work area emergency eyewash stations, safety/quick-drench showers, and washing facilities. Contaminated Equipment: Shower and change clothes after exposure or at the end of the workshift. Separate contaminated work clothes from street clothes. Launder before reuse. Remove benzo(a)pyrene from your shoes and clean personal protective equipment. Use procedures to ensure laundry personnel are not exposed. Comments: Never eat, drink, or smoke in work areas. Practice good personal hygiene after using this material, especially before eating, drinking, smoking, using the toilet, or applying cosmetics. Section 9 - Physical and Chemical Properties Physical State: Solid Other Solubilities: Ether, benzene, toluene, xylene, Appearance and Odor: Pale yellow monoclinic needles concentrated hydrosulfuric acid; sparingly soluble in with a faint, aromatic odor. alcohol, methanol. Vapor Pressure :>1 mm Hg at 68 F(20 C) Boiling Point: >680 F(>360 C); 540 F(310 QatlOram Formula Weight: 252.30 Hg Specific Gravity (H2CK1, at 4 Q: 1.351 Melting Point: 354 F(179 C) Water Solubility: Insoluble; 0.0038 mg (+/- 0.00031 mg) OctanolAVater Partition Coefficient: log Kow= 6.04 in 1 L at 77 F (25 C) Section 10 - Stability and Reactivity Stability: Benzo(a)pyrene is stable at room temperature in closed containers under normal storage and handling conditions. It undergoes photo-oxidation when exposed to sunlight or light in organic solvents and is also oxidized by chromic acid and ozone. Polymerization: Hazardous polymerization cannot occur. Chemical Incompatibilities: Strong oxidizers (chlorine, bromine, fluorine) and oxidizing'chemicals (chlorates, perchlorates, permanganates, and nitrates). Conditions to Avoid: Avoid heat and ignition sources and incompatibles. Hazardous Decomposition Products: Thermal oxidative decomposition of bcnzo(a)pyrene can produce carbon monoxide and carbon dioxide. Section 11- Toiicological Information ToiicityData:* Tumorigenic Effects: Teratogenicity: Rat, oral: 15 mg/kg produced gastrointestinal and Rat, oral: 2 g/kg administered 28 days prior to mating and 1-22 musculoskeletal tumors. days of pregnancy produced a stillbirth. 3 Mouse, inhalation: 200 ng/m /6 hr administered R^ ora]: 40 mg/kg on the 14th day of pregnancy caused changes intermittently over 13 weeks produced tumors of ^ ^e extra embryonic structures. the lungs. Mouse, oral: 75 mg/kg administered to the female during the 12- Rabbit skm: 17 mgjcg admumtered rntermmently Of pregnancy produced biochemical and metabolic effects over 57 weeks produced tumors of the skin and ,J r, " if appendages. on the newborn.

1 Copyright O 1»4 Groiimi PubluUn! Corpniioa Aay cornmotiil UK or mjjrwfcoioo wi*out *K publisher ! |»noif»on il prdiihiied. AR400878PagC 3 Of 4 ^SDSNo.164 Benzo(a)pyrene 2/94 Skin Effects: Mutagenicity: Mouse: 14 jig caused mild irritation. Human, liver cell: 100 nmol/L caused DNA damage. Human, lung cell: 1 umol/L caused DNA damage. Human, HeLa cell: 1500 nmol/L caused DNA inhibition. KTECS (DJ3675000), for additional toxicity data. Section 12 - Ecological Information Lcotoxlclty: Oysters, BCF (bioconcentration factor): 3000; rainbow trout, BCF: 92Q;Daphniapu!ex, BCF: 13,000. Environmental Transport: Some marine organisms such as phytoplankton, certain zooplankton, scallops (Placopecten sp\ - snails (Liaernia littorea), and mussels (Mytilus edulis) lack a metabolic detoxification enzyme system to metabolize bcnzo(a)pyrene and therefore, tend to accumulate benzo(a)pyrene. Humic acid in solution may decrease bioconcentration. Environmental Degradation: If released to water, benzo(a)pyrene adsorbs very strongly to particulate matter and sediments, bioconcentrates in aquatic organisms which cannot metabolize it, but does not hydrolyze. Direct photolysis at the water surface, •• evaporation, or biodegradation may be important, but adsorption may significantly retard these processes. Adsorption to particulates may also retard direct photolysis when benzo(a)pyrene is released to air. Benzo(a)pyrene may be removed from air by reaction with nitrogen dioxide (half-life, 7 days) or ozone (half-life, 37 minX or photochemically produced hydroxyl radicals _ (estimated half-life, 21.49 hr). "Soil Absorption/Mobility: It will adsorb very strongly to the soil. Although it is not expected to appreciably leach to the groundwater, groundwater samples indicate that it can be transported there. It is not expected to significantly evaporate or hydrolyze from soils and surfaces. However, it may be subject to appreciable biodegradation in soils. Section 13 - Disposal Considerations Disposal: Small quantities: 10 mL of a solution containing 0.3 mol/L of potassium permanganate and 3 mol/L of sulfuric acid will degrade 5 mg of benzo(a)pyrene. Abo, can treat with sodium dichromate in strong sulfuric acid (1-2 days). Benzo(a)pyrene " is also a good candidate for fluidized bed incineration at a temperature range of 842 to 1796 F (450 to 980 C) or rotary kiln incineration at 820 to 1600 C. Contact your supplier or a licensed contractor for detailed recommendations. Follow applicable Federal, state, and local regulations. Section 14 - Transport Information DOT Transportation Data (49 CFR 172.101): dipping Name: Environmentally Packaging Authorizations Quantity Limitations hazardous substances, solid, n.o.s.* a) Exceptions: 173.155 a) Passenger, Aircraft, or Railcar: None Shipping Symbols: — b) Non-bulk Packaging: b) Cargo Aircraft Only: None Hazard Class: 9 173.213 ID No,: UN3077 c) Bulk Packaging: 173.240 Vessel Stowage Requirements Packing Group: III a) Vessel Stowage: A Label: Class 9 b) Other: — Special Provisions (172.102): 8, B54

* If ft is in a quantity, in one package, which equals or exceeds the importable quantity (RQ) of 1 Ib (0.454 kg) Section IS - Regulatory Information EPA Regulations: Listed as a RCRA Hazardous Waste (40 CFR 261.33) RCRA Hazardous Waste Number: U022 ''-Listed as a CERCLA Hazardous Substance (40 CFR 302.4) per RCRA and CWA, Sec. 307(a) CERCLA Reportable Quantity (RQ), 1 Ib (0.454 kg) SARA 311/312 Codes: 1,2 ,,SARA Toxic Chemical (40 CFR 372.65): Not listed SARA EHS (Extremely Hazardous Substance) (40 CFR 355): Not listed OSHA Regulations: Listed as an Air Contaminant (29 CFR 1910.1000, Table Z-l) ^Listed as an OSHA Specifically Regulated Substance, Coal Tar Pitch Volatiles, (29CFR 1910.1002) Section 16 - Other Information References: 73, 103, 124,127,132,133,136, 139,148, 164, 169,174,175, 184,187,189, 190 >ared By.. MJ Wurth, BS Industrial Hygiene Review ....PA Roy, MPH Medical Review.... T Thoburn, MD, MPH aimer: Judgments as to the suitability of information herein for the purchaser's purposes are necessarily the purchaser's responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser's intended purpose or for consequences of its use.

'age 4 of 4 Cc?yri|tit C 1994 Gaum Mliffciif Ccrpcnaaa. Aiqr cannvcuJ UM or rtpndunan wiiSout *i« pufcliiha'i penmaiarAR400879t ii pn*ibi»rA CHUANGHSINMYCIN SODIUM CML822 — MM tK

3 by various mmo-smc 1000ppm/16H ADVEM 51, 45,71 " •*••.• CONSENSUS REPORTS: 1ARC Cancer Review: :_> strong irri- ipr-mus LDLo:4 mg/kg CBCCT* £241,50 . •• Group 1 IMEMDT 7,56,87; Animal Limited Evidence I hydrochloric IMEMDT 32,247,83; Animal Sufficient Evidence IM- SAFETY PROFILE: Poison by intraperitoneal route. EMDT 3,159,73. 'EPA Genetic Toxicology Program. r-ent. Violent Mutation data reported. An irritant and an allergen. ; ohol, ethci, Reported in EPA TSCA Inventory. :, Combustible when exposed to heat or flame. When fitontact with 3 heated to decomposition it emits acrid smoke and fumes. OSHA PEL: 0.2 mg/m , ; . . e, phosphorus ACGIH TLV: Suspected Human Carcinogen i n-metal hy- CML800 CAS:2642-98-0 HR:3 DFG MAK: Animal Carcinogen, Suspected Human 'i_ogen phos- Carcinogen. lorus, sodium tfHRYSENAMINE f:C, H, N mw: 243.32 NIOSH REL: (Chrysene) To be controlled as a carcino- i iolently a- m 8 3 gen. I dichloride, PROP: Leaflets from ale. Mp: 210-211°. Sltly sol in ale, us" trichloride, benzene, ethyl acetate. SAFETY PROFILE: Confirmed carcinogen with exper- tr> decomposi- imental carcinogenic, neoplastigenic, and tumorigenic C IROMIUM SYNS: 6-AMC O 6-AMINOCHRYSENE O CHRYSENEX data by skin contact. Human mutation data reported. OCHRYSONEX . . When heated to decomposition it emits acrid smoke and TOXICITY DATA with REFERENCE fumes. . . HR:3 mmo-sat 2500 ng/plate CNREAS 44,3408,84 • -,: mma-sat 500 ng/plate MUREAV issues CML815 CAS: 15131-84-7 HR: 3 dnr-bcs20uL/disc MUREAV97,1,82 '.' CHRYSENE-5,6-EPOXIDE dns-rat:lvr 500 nmol/L ENMUDM 3,11,81 mf:C,8H]2O mw: 244.30 . > pounds are msc-ham:ovr 50 mg/L JTEHD613,531,84 SYNS:CHRYSENE-K-REGIONEPOXiDEOCHRYSENE-5,6-OXlDE skn-musTDLo:1100g/kg/39W-I:CAR EJCAAH 11,327,75 O 5,6-EPOX Y-5,6-DIHYDROCHRYS£NE —id nitrating CONSENSUS REPORTS: EPA Genetic Toxicology TOXICITY DATA with REFERENCE j z materials Program...... ••.-.-. : :rTrubber and mma-sat 50 ^g/plate PNASM 72,5135,75 it emits toxic SAFETY PROFILE: Questionable carcinogen with ex- dnr-esc 100^mol/L ZKKOBW 92,157,78 \ 'OUNDS. perimental carcinogenic data by skin contact. Mutation dns-esc 100/zmol/L ZKKOBW 92,157,78 "'••• 3,5-DlHYDRO-3-METHYL-2H- bisulfide, and glacial acetic acid; moderately sol in boil- THIOPYRANO(4,3,2-cd)INDOLE-2-CARBOXYLICACID ing benzene; insol in water. Chrysene is generally only silly sol in cold organic solvents, but fairly sol in these TOXICITY DATA with REFERENCE solvents when hot, including glacial acetic acid. orl-mus LD50:1770 mg/kg 85GDA25.i33,8i ipr-mus LD50:875 mg/kg SSGDAI 5.133,81 SYNS: 1,2-BENZOPHENANTHRENEO BENZO(a)PHENANTHRENE OU-BENZPHENANTHRENE o BENZ^JPHENANTHRENE 0.1,2,5.6- ivn-mus LD50:600 mg/kg 85GDA2 5,133,8) NBENZONAPHTHALENEO RCRA WASTE NUMBER U050 SAFETY PROFILE: Moderately toxic by ingestion, in- : travenous, and intraperitoneal routes. When heated to -RIHYDROXY-J- TOXICITY DATA with REFERENCE . ' iwna-sat 5 ftg/plate MUREAV 156,61,85 •- "' -'•• decomposition it emits toxic fumes of SO, and NO,. 6 nmol/L DTESDI10,227,82 . /., 12 fimol/L MUREAV 130,127,84 CML822 CAS: 102419-73-8 HR:2 Jin-musTDLo:3600/ig/kg:NEO CNREA838.i83i,78 CHUANGHSINMYCIN SODIUM sm-musTDLo:200mg/kg:ETA CNREAS 15,632,55 mf: C12H,0NO2'Na mw: 223.22

AR400880 Genium Publishing Corp. Material Safety Data Sheet Collection One Genium Plaza Schenectady, NY 12304-4690 Phenanthrene MSDS No. 905 (518)377-8854 Date of Preparation: 6/94 Section 1 - Chemical Product and Company Identification 44 Product/Chemical Name: Phenanthrene Chemical Formula: (C6H4CH)2 CAS No.: 85-01-8 Synonyms: Phenantrin Derivation: A polynuclear aromatic hydrocarbon found as a component of coal tar pitch volatiles (products of bituminous coal distillation). Produced from toluene, bibenzil, 9-methyl fluorene or stilbene by passage through red hot tubes or by diene synthesis of 1-vinyl naphthalene and maleic anhydride. General Use: "Used in the manufacture of dyestuffs and explosives; in biological research or drug synthesis. Vendors: Consult the latest Chemical Week Buyers' Guide. (73) Section 2 - Composition / Information on Ingredients Phenanthrene, ca 100 % wt

OSHA PEL* NIOSH REL* DFG (Germany) MAK 8-hr TWA: 0.2 mg/m3 10-hr TWA: 0.1 mg/m3, cyclohexane None established extractable fraction ACGffl TLV* TWA: 0.2 mg/m3

*Coal tar pitch volatiies (benzene soluble) Section 3 - Hazards Identification Emergency Overview Wilson Risk Phenanthrene exists as shiny crystals with a faint, aromatic odor. It can cause photosensitization of the skin. Scale Phenanthrene is combustible and reacts dangerously with oxidizers. R 1 Potential Health Effects I 3 S 3 Primary Entry Routes: Skin contact. K 1 Target Organs: Skin. Acute Effects Inhalation: Effects not reported. HMIS Eye: Effects not reported. H 1 Skin: Can cause photosensitization of the skin. F 1 Ingestion: Effects not reported. R 0 Carcinogenicity: Although it has produced skin cancer in experimental animals, the results were not statistically significant and IARC has assigned phenanthrene a Class 3 (unclassifiable as to carcinogenicity) designation. The PPE* NTP and OSHA do not list phenanthrene as a carcinogen. *Sec. 8 Medical Conditions Aggravated by Long-Term Exposure: Skin disorders. Chronic Effects: None reported. Section 4 - First Aid Measures Inhalation: Remove exposed person to fresh air and support breathing as needed. Eye Contact: Do not allow victim to rub or keep eyes tightly shut. Gently lift eyelids and flush immediately and continuously with flooding amounts of water until transported to an emergency medical facility. Consult a physician immediately. Skin Contact: Quickly remove contaminated clothing. Rinse exposed area with flooding amounts of water to remove loose material and then move quickly to a soap and water wash. For reddened or blistered skin, consult a physician. Ingestion: Never give anything by mouth to an unconscious or convulsing person. Contact a poison control center. Unless the poison control center advises otherwise, have the conscious and alert person drink 1 to 2 glasses of water, then induce vomiting. After first aid, get appropriate in-plant, paramedic, or community medical support. Note to Physicians: Treatment is symptomatic and supportive.

Copyright €> 1994 by Genium Publishing Corporation. Any commercial use or reproduction without the publisher's permission is prohibited. Judgments as to the suitability of information herein for the purchaser's purposes are necessarily the purchaser's responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warrantiesAR400881, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to ihc purchaser's intended purpose or for consequences of its use. MSDS No. 905 Phenanthrene 6/94 Section 5 - Fire-Fighting Measures Flash Point: 340 °F (171 *C) NFPA Flash Point Method: OC LEL: Not reported. UEL: Not reported. Flainmability Classification: Class IIIB Combustible liquid Extinguishing Media: Use dry chemical or carbon dioxide; water spray or foam may cause frothing. Unusual Fire or Explosion Hazards: None reported Hazardous Combustion Products: Carbon oxides (COX) and acrid smoke Fire-Fighting Instructions: Do not release runoff from fire control methods to sewers or waterways. Fire-Fighting Equipment: Because fire may produce toxic thermal decomposition products, wear a self-contained breathing apparatus (SCBA) with a full facepiece operated in pressure-demand or positive-pressure mode. Section 6 - Accidental Release Measures Spill /Leak Procedures: Notify safety personnel, isolate and ventilate area, deny entry, and stay upwind. Shut off ignition sources. Cleanup personnel should protect against skin contact. Small Spills: To avoid dust generation, do not sweep! Carefully scoop up or vacuum (with appropriate filter). Damp mop residue. Large Spills Containment: Flush large spill to containment area for later disposal. Do not release into sewers or waterways. Cleanup: Mop up any residue. Regulatory Requirements: Follow applicable OSHA regulations (29 CFR 1910.120). Section 7 - Handling and Storage Handling Precautions: Use nonsparking tools to open containers. Storage Requirements: Prevent physical damage to containers. Store in a cool, dry, well-ventilated area away from heat, ignition sources, and strong oxidizers. Section 8 - Exposure Controls / Personal Protection Engineering Controls: To prevent static sparks, electrically ground and bond all equipment used with and around phenanthrene. Ventilation: Provide general or local exhaust ventilation systems to maintain airborne concentrations below the OSHA PEL (Sec. 2). Local exhaust ventilation is preferred because it prevents contaminant dispersion into the work area by controlling it at its source.^^ Administrative Controls: Consider preplacement and periodic medical exams of exposed workers with emphasis on the skin. Respiratory Protection: Seek professional advice prior to respirator selection and use. Follow OSHA respirator regulations (29 CFR 1910.134) and, if necessary, wear a MSHA/NIOSH-approved respirator. The following respirator recommendation is for coal-tar pitch volatiles: For any detectable concentration, use a SCBA or supplied-air respirator (with auxiliary SCBA) with a full facepiece and operated in pressure-demand or other positive pressure mode. For emergency or nonroutine operations (cleaning spills, reactor vessels, or storage tanks), wear an SCBA. Warning! Air-purifying respirators do not protect workers in f oxygen-deficient atmospheres. If respirators are used, OSHA requires a written respiratory protection program that includes at least: medical certification, training, fit-testing, periodic environmental monitoring, maintenance, inspection, cleaning, and convenient, sanitary storage areas. Protective Clothing/Equipment: Wear chemically protective gloves, boots, aprons, and gauntlets to prevent prolonged or repeated skin contact. Wear protective eyeglasses or chemical safety goggles, per OSHA eye- and face-protection regulations (29 CFR 1910.133). Contact lenses are not eye protective devices. Appropriate eye protection must be worn instead of, or in conjunction with contact lenses. Safety Stations: Make emergency eyewash stations, safety/quick-drench showers, and washing facilities available in work area. Contaminated Equipment: Separate contaminated work clothes from street clothes. Launder before reuse. Remove this material from your shoes and clean personal protective equipment. Comments: Never eat, drink, or smoke in work areas. Practice good personal hygiene after using this material, especially before eating, drinking, smoking, using the toilet, or applying cosmetics. Section 9 - Physical and Chemical Properties Physical State: Solid Other Solubilities: 1 g in: 2.4 mL toluene, 2.4 mL carbon Appearance and Odor: Colorless, shiny crystals with a tetrachloride, 2 mL benzene, 1 mL carbon disulfide, 25 mL faint, aromatic odor. absolute alcohol, 60 mL cold 95% alcohol, 10 mL boiling 95% Vapor Pressure: 1 mm Hg at 244.76 °F (118.2 °C); alcohol and 3.3 mL anhydrous ether. Also soluble in glacial 400 mm Hg at 586.4 (308 °C) acetic acid, chloroform, and hot pyridine. Formula Weight: 178.22 Boiling Point: 644 °F (340 °C) Density (H2O=1, at4 °C): 1.179 g/Lat 77 °F(25 °C) Melting Point: 213 T (101 *C) Water Solubility: 1.6 mg/L at 59 °F (15 °C) Refraction Index: 1.59427 Octanol/Water Partition Coefficient: log Kow = 4.57

Page 2 Ot 4 Copyright C 1994 Genium Publishing Corporation. Any commercial use or reproduction without the publisher'AR400882s permission is prohibited. 6/94 Phenanthrene MSDS No. 905 Section 10 - Stability and Reactivity Stability: Phenanthrene is stable at room temperature in closed containers under normal storage and handling conditions. Polymerization: Hazardous polymerization does not occur. Chemical Incompatibilities: Strong oxidizers. Conditions to Avoid: Phenanthrene dust generation and exposure to heat ignition sources, or oxidizers. Hazardous Decomposition Products: Thermal oxidative decomposition of phenanthrene can produce carbon oxide(s). Section 11- lexicological Information ToxicityData:*

Acute Oral Effects: Mutagenicity: Mouse, oral, LD50: 700 mg/kg Rat) ijver cell: 3 mmol/L caused DNA damage Human, lymphocyte: 100 |imol/L caused mutation Carcinogenicity: Mouse, skin: 71 mg/kg produced tumors at site of application.

* See NIOSH, RTECS (SF7175000), for additional toxicity data. Section 12 - Ecological Information Ecotoxicity: Neanhes arenaceodentata, TLm = 0.6 ppm/96 hr, sea water at 71.6 *F (22 °C) Environmental Degradation: If released to soil, some phenanthrene may biodegrade but the majority will bind to the soil without much leaching to groundwater. Volatilization is not expected to be significant. In water, it will adhere to particulates and sediment. Photolysis may occur near the surface producing toxic substances. Photolysis/photooxidation half-life = 8.4 hr. In the air, it will react with photochemically generated hydroxyl radicals (half-life = 1.67 days). Soil Absorption/Mobility: Phenanthrene absorbs strongly to soil and sediment in water. Section 13 - Disposal Considerations Disposal: For treatment of phenanthrene contaminated water, the particulate bound portion can be removed by sedimentation, flocculation, and filtration. Chlorination is not recommended as it has been shown to produce mutagenic substances. The dissolved portion requires oxidation for partial removal. Contact your supplier or a licensed contractor for detailed recommendations. Follow applicable Federal, state, and local regulations. Section 14 - Transport Information DOT Transportation Data (49 CFR 172.101): Shipping Name: Packaging Authorizations Quantity Limitations Environmentally hazardous a) Exceptions: 173.155 a) Passenger, Aircraft, or Railcar: None substances, solid, n.o.s.* b) Non-bulk Packaging: 173.213 b) Cargo Aircraft Only: None Shipping Symbols: — c) Bulk Packaging: 173.240 Hazard Class: 9 Vessel Stowage Requirements ID No.: UN3077 a) Vessel Stowage: A Packing Group: HI b) Other: — Label: Class 9 Special Provisions (172.102): 8, B54, N50 * Classified as a hazardous substance when phenanthrene is in a quantity, in one package, which equals or exceeds the RQ of 5000 Ib (2270 kg) Section 15 - Regulatory Information EPA Regulations: RCRA Hazardous Waste Number: Not listed Listed as a CERCLA Hazardous Substance (40 CFR 302.4) per CWA, Sec. 307(a) CERCLA Reportable Quantity (RQ), 5000 Ib (2270 kg) SARA 311/312 Codes: 1 SARA Toxic Chemical (40 CFR 372.65): Not listed SARA EHS (Extremely Hazardous Substance) (40 CFR 355): Not listed OSHA Regulations: Listed (coal tar pitch volatiles) as an Air Contaminant (29 CFR 1910.1000, Table Z-l, Z-l-A) Section 16 - Other Information References: 23, 73, 103, 124, 132, 133, 136, 139, 159, 164, 187, 190 Prepared By M Gannon, BA Industrial Hygiene Review PA Roy, MPH, CIH

Copyright O 1994 Gcnium Publishing Corporation. Any coramerciaJ use or reproduction without the publisher's permission is prohibited. AR400883rage 3 Ol 4 MSDS No. 905 Phenanthrene 6/94 Medical Review W Silverman, MD

rage 4 01 4 Copyright O L994 Genium Publishing Corporation. Any commercial use or reproduction without the publisher's permission is prohibited. AR400884 PONOOO 1-PYRENAMINE orl-rat LD50:2 g/kg MDACAP 19,382,83 OSHA PEL: TWA 0.2 mg/m3 scu-rat LD50:645 mg/kg YACHDS 8.689,80 SAFETY PROFILE: Poison by inhalation. Moderate ivn-rat LD50:53 mg/kg IYKEDH 13,637,82 toxic by ingestion and intraperitoneal routes. A skin ir: orl-mus LD50:2 g/kg MDACAP 19,382,83 tant. Questionable carcinogen with experimental tumc scu-mus LD50:280 mg/kg IYKEDH n.637,82 igenic data. Human mutation data reported. Wh ivn-mus LD50:42 mg/kg IYKEDH 13,537,82 heated to decomposition it emits acrid smoke and irrii; SAFETY PROFILE: Poison by subcutaneous and intra- ing fumes. venous routes. Moderately toxic by ingestion. An experimental teratogen. Experimental reproductive effects. PON500 CAS: 1732-14-5 HR When heated to decomposition it emits NOA. and HC1. N-PYREN-2- YLA CETAMIDE mf:C,gH13NO mw: 259.32 - PONOOO CAS: 1606-67-3 HR: 3 SYN: 2-ACETYLAM1NOPYRENE 1-PYRENAMINE mf:C, H,,N mw: 217.28 TOXICITY DATA with REFERENCE 6 orl-rat TDLo:5508 mg/kg/32W-C:NEO CNREAS SYNS: 1-AMINOPYRENEO3-AM1NOPYRENE 15,188,55 TOXICITY DATA with REFERENCE SAFETY PROFILE: Questionable carcinogen with. mmo-sat SOOng/plate MUREAV 138,113,84 perimental neoplastigenic data. When heated to deco dnd-esc 10/xmol/L PNCCAZ 2,39,65 position it emits toxic fumes of NOX. orl-rat LD50:1070 mg/kg AI HAAP 30,470,69 ipr-mus LD50:250 mg/kg AIPTAK 135,376,62 PON750 CAS: 73529-24-5 HR CONSENSUS REPORTS: Reported in EPA TSCA In- 4-PYRENYLOXIRANE ventory. EPA Genetic Toxicology Program. mf: CI8H12O mw: 244.30 SYN: 4-EPOXYETHYLPYRENE SAFETY PROFILE: Poison by intraperitoneal route. Moderately toxic by ingestion. Mutation .data reported. TOXICITY DATA with REFERENCE When heated to decomposition it emits toxic fumes of mmo-sat 100 pmol/plate CNREAS 40,642,80 NO,. msc-ham:Ing 1 ^mol/L CNREAS 4o,642.so SAFETY PROFILE: Mutation data reported. \V PON250 CAS: 129-00-0 HR:3 heated to decomposition it emits acrid smoke and irr; PYRENE ing fumes. mf: C16H,0 mw: 202.26 PROP: Colorless solid, solutions have a slight blue POOOOO CAS:97-11-0 H. color. Mp: 156°, d: 1.271 @ 23°, bp: 404°. Insol in PYRETHRIN water; fairly sol in organic solvents. (A condensed ring mf: C,,H,8O, mw: 328.49 hydrocarbon). SYNS:2-CYCLOPENTENYL-4-HYDROXY-3-METHYL-2- CYCLOPENTEN-l-ONECHRYSANTHEMATEO3-(2-CYCLOPENTI SYNS: BENZO(def)PHENANTHRENEO PYREN (GERMAN) O fi-PYR- YD-2-METHYL-4-OXO-2-CYCLOPENTEN-1-YLCHRYSANTHEMU INE MATE O 3-U-CYCLOPENTENYD-2-METHYL-4-OXO-2- CYCLOPENTENYLCHRYSANTHEMUMMONOCARBOXYLATE TOXICITY DATA with REFERENCE OCYCLOPENTENYLRETHONYLCHRYSANTHEMATE CENT: skn-rbt 500 mg/24H MLD 28ZPAK -,26,72 mma-sat 300 ng/plate ENMUDM 6(Suppi 2>,i,«4 TOXICITY DATA with REFERENCE dns-hmn:fbr 100 mg/L TXCYAC 21,151,81 orl-rat LD50.-1410 mg/kg ARSIM* 20,7,66 skn-musTDLo:10g/kg/3W-I:ETA EUCAAI io,363,56 SAFETY PROFILE: Moderately toxic by ing«: orl-rat LD50:2700 mg/kg GTPZAB i5(2),59,7i 3 When heated to decomposition it emits acrid smoke ihl-rat LC50:170 mg/m GTPZAB 150,59.71 irritating fumes. See also other pyrethrin entries. orl-mus LD50:800 mg/kg GTPZAB i5(2),S9,7i ipr-mus LD50:514 mg/kg PMRSDJ i,682,si POOOSO CAS: 121-21-1 * CONSENSUS REPORTS: 1ARC Cancer Review: PYRETHRIN 1 Group 3 IMEMDT 7,56,87; Animal No Evidence IM- mf: C2IHJ8O3 mw: 328.49 EMDT 32,431,83. EPA Extremely Hazardous Sub- SYNS: CHRYSANTHEMUM MONOCARBOXYLIC ACID stances List. Reported in EPA TSCA Inventory. EPA PYRETHROLONE ESTER O PIRETR1NA 1 (PORTUGUESE) Genetic Toxicology Program. O PYRETHROLONE, CHRYSANTHEMUM MONOCARBOXU AR400885 APPENDIXD SITE-SPECIFIC PERSONAL PROTECTIVE EQUIPMENT (PPE) PROGRAM

AR400886 1 HEALTH & SAFETY PROCEDURES i s ^ OHM Remediation PERSONAL PROTECTIVE EQUIPMENT PROGRAM \JE= Services Corp, PROCEDURE NUMBER 4-1 Page 1 of 10 J LAST REVISED 1/95 APPROVED BY: FHH

1. OBJECTIVE

OHM Remediation Services Corp. (OHM) personnel will be protected for chemical, physical, and environmental hazards by the appropriate personal protective equipment (PPE) when engineering and administrative controls are not effective in controlling job hazards.

2. PURPOSE

The purpose of this procedure is to address the elements of the PPE program. This PPE program conforms to the requirements found in 29 CFR 1910.120 (g) Engineering controls, work practices, and personal protective equipment for employee protection; 29 CFR 1910 Subpart I - Personal Protective Equipment - .132 General Requirements, .133 Eye and Face Protection, .135 Head Protection, .136 Foot Protection, .138 Hand Protection; and 29 CFR 1910.1200 Hazard Communication.

• 3. RESPONSIBILITY AND AUTHORITY

The responsibility and authority for the selection, use, and maintenance of personal protective equipment is shared between management, supervisory, health and safety, and employee personnel.

3.1 .Management - Management has the responsibility to provide PPE appropriate for the hazard/s associated with expected work tasks.

32 Supervisors • Supervisors have the responsibility to conduct hazard assessments and ensure personnel to utilize PPE in compliance with this SOP. Supervisors may request assistance from or designate authority to health and safety personnel for hazard assessment, selection, inspection, and decontamination of PPE. The use of PPE by employees is the supervisor's responsibility.

33 Health and Safety Personnel - Health and safety personnel have the responsibility to assist supervisors in hazard assessment, selection, inspection, and decontamination of PPE. In the event of conflict, health and safety personnel have the authority to implement the necessary measures,

3.4 Employees - Employees have the responsibility to use, inspect, and decontaminate PPE as directed by supervisors.

AR400887 PERSONAL PROTECTIVE EQUIPMENT Procedure Number 4-1 Page 2 of 10 PROGRAM

4. PROGRAM ELEMENTS

Program elements define the regulatory requirements of a PPE program.

4.1 Hazard assessment - All tasks undertaken by OHM personnel will be assessed for chemical, physical, and environmental hazards present or likely to be present which necessitate the use .of PPE to ensure adequate protection. This assessment shall take place prior to commencement of work.

42 Hazard Reassessment - The level of protection or type of personal protective equipment shall be increased when additional information on site , conditions indicates that increased protection is necessary to reduce employee exposures below permissible exposure limits, published exposure levels for hazardous substances and health hazards, or other physical and environmental hazards.

43 PPE Selection - The regional health and safety director/manager or designee will initially select the level and types of PPE that will protect the affected employee from the hazards identified in the initial hazard assessment.

4.4 Written Certification - The site specific Health and Safety Plan (HASP) will serve as the written certification that identifies the workplace was evaluated. The HASP shall be dated. The signature line shall designate the person certifying that the evaluation has been performed.

4.5 .Communication of Selection - Employees will be informed of the PPE selection decisions through reading or verbally reviewing the HASP, attending pre-project safety briefings, job safety analysis (JSA) review, or attending safety meetings.

4.6 PPE Use and Fit - The supervisor will be responsible for the proper use and fit of PPE by workers under their direction and will monitor the effectiveness of these items. Heath and safety personnel will advise and assist the supervisor in these areas.

4.7 Work Mission Duration - The supervisor will be responsible for the establishment of the duration of specific work missions. The duration will be determined by the complexity of the assignment, PPE involved, physical factors, temperature, humidity, weather conditions, elevation of work, and acclimation of the worker to the demands of the task assigned. The supervisor will consider the recommendations of the health and safety personnel.

AR400888 PERSONAL PROTECTIVE EQUIPMENT Procedure Number 4-1 Page 3 of 10 PROGRAM

A sufficient amount of rest breaks will be allowed in order to avoid overexertion or thermal stress by the employees while maintaining productive work practices. Further guidance is offered in OHM Health and Safety Procedures entitled Heat Stress and Cold Stress.

4.8 PPE Maintenance and Storage - Each employee is responsible for the proper maintenance and storage of the standard issue equipment (e.g., hard hat, full-face piece negative pressure respirator, safety glasses). The supervisor will assure that proper maintenance is carried out

4.9 PPE Decontamination - Each employee is responsible for daily cleaning and decontamination of reusable PPE such as outer gloves, outer boots, reusable chemically resistant clothing, and standard issue PPE such as hard hats and respirators.

OHM will provide an area/s for decontamination operations, necessary cleaning agents, cleaning tools, such as brushes and wash basins, and a method to dispose of materials generated during decontamination activities.

OHM will attempt to reduce decontamination requirements through the use of disposable protective clothing and gloves as feasible.

4.10 PPE Training - All employees will receive training in the proper use of PPE . prior to wearing the equipment in a work situation. This training will be administered upon commencement of employment during HAZWOPER training. PPE refresher training will be reviewed annually during the HAZWOPER refresher training. Project specific training will be provided as required. 4.11 PPE Donning and Doffing Procedures - All employees will receive training upon commencement of employment and during annual refresher training concerning the donning and doffing of PPE. Periodic training will be provided as required,

4.12 PPE Inspection - Each employee shall inspect PPE for defects and proper function prior to each use. Defective or damaged PPE shall not be used Any PPE found to be defective or have missing parts will be replaced prior to use.

4.13 PPE In Use Monitoring - The supervisor is responsible for monitoring the effectiveness of selected PPE. If at any time level of PPE is to be downgraded, it is mandatory that the change be approved by the regional health and safety director/manager or designee.

AR400889 PERSONAL PROTECTIVE EQUIPMENT Procedure Number 4-1 Page 4 of 10 PROGRAM

4.14 Evaluation of PPE Program - Health and safety personnel%vili compile data on PPE in the field to determine that the PPE performs ,to OHM needs. Periodically, this information should be reviewed cognizant health and safety professional to ensure that PPE is providing the necessary level of protection, quality, and is appropriate for the work performed.

If at any time the failure of PPE causes injury to an employee or fails to perform as expected, the supervisor will take the unit or item out of service and investigate the incident The incident shall be immediately reported to the regional health and safety director/manager. If after scrutiny, the unit or item is determined to have a manufacturing defect, all identical units will be removed from use until corrective actions are taken.

4.15 Limitations During Temperature Extremes - Extreme temperatures exert stress on personnel and may alter the performance characteristics of PPE. During periods of extreme temperature, work assignments will be adjusted to protect the employee from overexertion or exposure. The supervisor will evaluate if temperature extremes are effecting performance characteristics of PPE and report these findings to the regional health and safety director/manager.

4.16 Unserviceable PPE - Any PPE which is no longer functioning properly or is no longer serviceable shall be removed from use and either repaired or destroyed.

5. SAFETY EQUIPMENT POLICY

OHM will provide, maintain, and replace personal protective equipment as detailed below.

5.1 Standard issue safety equipment - Standard issue safety equipment will be provided at no cost to field employees. These items consist of:

• Hard hat

• Safety glasses with dear and shaded lenses

• Full-face respirator with nose cup

52 Company provided equipment - OHM will provide at no cost to the employee the following items on a task specific or project specific basis:

• Chemical protective equipment such as gloves, boots, and clothing

• Specialty glasses or goggles

AR400890 PERSONAL PROTECTIVE EQUIPMENT Procedure Number 4-1 Page 5 of 10 PROGRAM

• Face shields

• Flame resistant clothing

• Hearing protection

• Fall protection 53 Employee provided equipment - The employee shall provide the following equipment:

• ANSI approved steel toed and shank boots/shoes (Note: Further guidance is provided in Section 7 Safety footwear) > • Outerwear for cold weather 5.4 Equipment replacement - OHM will replace worn-out or work-damaged equipment detailed in 5.1 and 52. OHM reserves the right to charge employees for the replacement cost of equipment which is lost or damaged though neglect or abuse.

5.5 Additional PPE - The regional health and safety director/manager or the supervisor may require additional company provided PPE on a task specific basis, 6. WORK CLOTHES

OHM employees, subcontractors, and visitors will observe the requirements for proper work clothing when on OHM project sites, facilities, and shops.

6.1 Pants - Long pants are required at all times. These pants must be in good repair. 62 Shirts - Shirts will be worn on the job. Shirts will be buttoned up the front and at the cuff unless rolled up. Shirt tails must be kept in the trousers. Sleeveless shirts are prohibited at all work locations. Supervisory personnel are expected to wear a shirt with a collar. T-shirts are permitted for personnel who wear protective clothing most of the day.

63 Clothing - Loose or ragged clothing will not be worn. 6.4 Modifications - Regional health and safety director/manager may modify work clothing requirements on a project specific basis.

AR400891 PERSONAL PROTECTIVE EQUIPMENT Procedure Number 4-1 Page 6 of 10 PROGRAM

6.5 Contaminated Clothing - Clothing (including shoes) saturated with petroleum products or chemicals will be removed immediately to prevent irritation and possible dermal exposure. 6.6 Jewelry - Rings and other jewelry (except watches) must be removed when working in areas where they could catch on moving objects, sharp protrusions, come in contact with electrical circuits or chemical agents, or compromise PPE ie. rings capable of cutting gloves. Additionally, the supervisor may deem other types of jewelry inappropriate for the work .task.

6.7 Hair Length - Hair long enough to constitute a hazard while working around moving machinery or rotating tools and equipment must be secured by a net or tied back. Hair styles must not interfere with the ability to properly wear safety headgear, safety spectacles, and respiratory protection.

7. EYE/FACE PROTECTION

All OHM employees, subcontractors, and visitors shall wear eye and face protection meeting the requirements of ANSI document Z87.1 - 1989 titled "Practice of Occupational and Educational Eye and Face Protection" during the tasks posing exposure to eye or face injury.

7.1 Requirements - To protect the face and eyes against injuries from flying objects, splashing liquids, and harmful rays, safety spectacles with side shields, goggles, face shields, cutting goggles, and welding helmets will be used as appropriate. The supervisor will be responsible to identify the need for eye/face protection and specify the eye/face protection required for each operation. A selection guide is attached in Table 1. 12 Safety spectacles - Safety spectacles are protective devices intended to shield the wearer's eyes from a variety of hazards. While they are primary protectors and may be used alone, they may also be used in conjunction with other protective devices such as goggles and iace shields. 73 Goggles - Goggles are protective devices intended to fit the face immediately surrounding the eyes in order to shield the eyes from a variety of hazards. While they are primary protectors and may be used alone, they also may be used in conjunction with other protectors.

7.4 Face shields - Face shields are protective devices intended to shield the wearer's face, or portions thereof, in addition to the eyes, from certain hazards. Face shields are secondary protectors and shall be used with primary protectors.

AR400892 PERSONAL PROTECTIVE EQUIPMENT Procedure Number 4-1 Page 7 of 10 PROGRAM

7.5 Cutting goggles - Cutting goggles are protective devices designed to protect the eyes from radiation and impact Goggles are primary protectors and in some situations must be supplemented with face shields. 'See Table 2 for selection guidelines.

7.6 Welding helmets - Welding helmets are protective devices intended to shield the eyes and face from optical radiation and impact Welding helmets are secondary protectors and shall be used only in conjunction with primary protectors such as safety spectacles or goggles. See Table 3 for selection guidelines. ^ 7.7 Prescription Spectacles - For personnel that wear prescription spectacles, OHM provides prescription safety spectacles with side shields. It is mandatory that prescription safety spectacles not be altered by the employee and be worn at all times when safety spectacles are required.

7.8 Contact lenses - Contact lenses are not permitted to be worn where accidental eye contact with chemical agents or physical materials is possible. OHM provides prescription spectacles and other protective devices for use in these situations. 7.9 Shaded lenses - Shaded lenses are not to be worn indoors or under low light conditions.

8. SAFETY HEADGEAR

All OHM employees, subcontractors, and visitors shall wear safety headgear meeting the requirements of ANSI document Z89.1-1986 titled "Protective Headwear for Industrial Workers - Requirements" when exposed to overhead hazards.

8.1 Requirement - Safety headgear shall be worn by all personnel while engaged in work where there is a hazard of falling objects, low overhead restrictions, and other overhead hazards exist Safety headgear may also be required to be worn by contractual requirements. 8.2 Use - Safety headgear must be worn as prescribed by the manufacturer in the bill front position unless the headgear was approved to be worn in another position.

83 Modifications - Safety headgear shall not be painted, drilled or modified in any manner. Use of safety related headgear stickers are permitted

AR400893 PERSONAL PROTECTIVE EQUIPMENT Procedure Number 4-1 Page 8 of 10 PROGRAM

8.4 Life Expectancy - No mayfmnm mandatory service life is sj»ecified by regulation for safety headgear. However, a hard hat should be removed from service if chemical corrosion, cracks, deformities, worn suspension, or discoloration is noted with the unit.

9. SAFETY FOOTWEAR

All OHM employees, subcontractors, and visitors that enter OHM project sites and are exposed to foot hazards shall wear footwear meeting the ANSI document Z41 - 1991 titled "Protective Footwear" during operations posing foot injury.

9.1 Project Sites - Steel toe and shank leather work boots shall be worn on all OHM project sites. High top or low top sneakers, western style boots, or other footwear even though ANSI approved are not appropriate for the activities encountered at hazardous waste and emergency response sites and shall not be worn.

92 OHM Facilities and Shops - Personnel working at OHM shops and facilities have the option of wearing other types of ANSI approved safety work shoes and boots provided they are appropriate for the tasks being performed. The supervisor of the work area is responsible to decide what type footwear is appropriate.

10. HAND PROTECTION/GLOVES

OHM employees, subcontractors, and visitors will don appropriate gloves when engaged in any operation that presents a hazard to the hands.

10.1 Use - Appropriate work gloves shall be available for hand protection against heat and flame, cold, chemicals, petroleum products, corrosive materials, moisture, mechanical abrasion, electricity, and sharp and rough surfaces.

10.2 Selection - Glove selection of the appropriate hand protection shall be based on an evaluation of the performance characteristic of the hand protection relative to the task(s) to be performed, chemical concentration and properties, physical conditions present, duration of use, and the hazards and potential hazards identified. The type of work gloves used must be approved by the regional health and safety director/manager and designee as specified in the HASP for the particular tasV.

10.3 Electrical - When working on high voltage (480 volts and above) electrical equipment, electrically tested high voltage gloves will be worn. Leather protection will be worn over these gloves. (NOTE: Only authorized personnel are permitted to work on High Voltage electrical equipment).

AR400894 PERSONAL PROTECTIVE EQUIPMENT Procedure Number 4-1 Page 9 of 10 PROGRAM

11. PROTECTIVE CLOTHING

OHM employees, subcontractors, and visitors will don appropriate protective clothing when engaged in any operation that presents a hazard to the body.

11.1 Use - Appropriate clothing shall be available for body protection against heat and flame, cold, chemicals, petroleum products, corrosive materials, moisture, mechanical abrasion, electricity, and sharp and rough surfaces.

11.2 Selection - Clothing selection of the appropriate body protection shallbe based on an evaluation of the performance characteristic of the body protection relative to the task(s) to be performed, chemical concentration and properties, physical conditions present, duration of use, and the hazards and potential hazards identified. The type of protective clothing used must be approved by the regional health and safety director/manager and designee and specified in the HASP for the particular task.

12. TOT AT T .Y-ENCAPSULATING CHEMICAL PROTECTIVE SUITS

Totally-encapsulating chemical protective suits (Level A) shall be used in conditions where skin absorption of a hazardous substance may result in a substantial possibility of immediate death, immediate serious illness or injury, or impair the ability to escape.

12.1 Use - OHM will only use Level A protection when all other reasonable efforts of controlling employee exposure through engineering or administrative means are not possible.

12.2 Authorization - Level A protection may only be used after authorization of the regional health and safety director/manager has been granted.

123 Health and Safety Personnel - An appropriately experienced health and safety employee must be assigned to the project site where Level A is to be used. They must evaluate that the following items are ready:

• Communications

• Decontamination

• Emergency rescue procedures and personnel

• Emergency medical attention

12.4 OHM will discard and properly dispose of any Level A suit which has come in contact with chemical contaminants or sustained physical damage at least at the end of the project

AR400895 PERSONAL PROTECTIVE EQUIPMENT Procedure Number 4-1 Page 10 of 10 PROGRAM

13. LOANING PERSONAL PROTECTIVE EQUIPMENT

OHM personnel should not loan OHM personal protective equipment to any client, subcontractor, or visitor personnel. If there are urgent circumstances, such as an emergency response where the equipment cannot be obtained elsewhere and chemical exposure is possible, OHM personnel can loan personal protective equipment such as respirators, protective clothing and other safety equipment to client personnel or personnel from other organizations. However because of the potential liability involved, approval of senior OHM management is required as well as the requirement that a representative of the company and the individual using the equipment .execute an OHM Indemnification and Release Agreement A copy of this agreement is attached in Appendix A. 13.1 Execution of Indemnification and Release Agreement - In general, the following will be required BEFORE the personal protective equipment may be loaned: • The OHM Regional Vice President (or designee) must specifically authorize the loaning of personal protective equipment on the particular project • An authorized representative of the company whose personnel will use the equipment must sign the Indemnification and Release Agreement

• The individual who will use the equipment must also sign the Indemnification and Release Agreement attesting to the fact that the individual is either experienced in the use of the equipment or has been" given instruction on the safe use of the equipment and is medically qualified to wear the equipment • An OHM representative must also sign the form as a witness to the above.

13.2 Contractual Requirement - An indemnification and release agreement is not required if providing personal protective equipment to clients or regulatory personnel is a contractual requirement 133 Exemptions - Hard hats, safety glasses, hearing protection, and protective clothing provided for cleanliness is exempted for the indemnification requirement Instruction should be provided to the individual prior to wearing. .

AR400896 ^=p^ OHM Remediation ^=_~ Services Corp.

APPENDIX A OHM REMEDIATION SERVICES CORP. INDEMNIFICATION AND RELEASE AGREEMENT FOR PERSONAL PROTECTION CLOTHING

FOR AND IN CONSIDERATION OF the use by the undersigned of property belonging to OHM Remediation Services Corp. (hereinafter referred to as "OHM") and which may include full-face mask respirators, self-contained breathing apparatus, and other equipment and supplies, and other good and valuable consideration, the undersigned , for himself and his successors, and assigns, does hereby release and discharge OHM, its officers, employees, agents, and subcontractors from any and all claims, actions, demands, damages, costs, loss of services, expenses, compensation, third-party actions, or suits,'including attorneys fees, arising and resulting from the aforementioned use of property, equipment, or supplies belonging to OHM

In addition, the undersigned, on behalf of his employer, principal, himself, and his successors, and assigns, agrees to release, save, and hold harmless, protect, indemnify, and defend OHM, and its officers, employees, agents, and subcontractors against any and all claims, actions, and expenses as above described, whether for bodily injury, property damage or destruction, or both, arising or resulting in any way from the use by the undersigned of property of OHM and agrees to save, hold harmless, protect, indemnify, and defend OHM against any such claims, actions, or expenses, referenced above, that might be brought against OHM by any third persons or the heirs, successors, executors or assigns of the undersigned.

The undersigned acknowledges by signing that he has carefully read this Agreement, understands the contents thereof, and has freely and voluntarily signed the same.

EXECUTED on , 19 .

1. OHM Regional Vice President (or designee) authorizing use of equipment:

2. CLIENT OR SUBCONTRACTOR REPRESENTATIVE AUTHORIZING EQUIPMENT USE: I authorize the individual(s) in 3. below to use OHM provided personal protective equipment Company Name Sign Name Print Name . Title .

3. INDIVIDUAL USING EQUIPMENT: I certify that I am familiar with the equipment and medically qualified to wear the equipment Company Name Sign Name ; Print Name NOTE: A continuation sheet can be used if more than one individual is to be certified to use equipment

4. OHM Representative Acknowledging Signatures:

Sign Name AR400897 OHM Remediation •^E^" Services Corp.

TABLE 1 FACE PROTECTION SELECTION GUIDELINES

Hazard Protection

Flying fragments, objects, large chips, particles, Safety spectacles or goggles sand, and dirt from chipping, grinding, Supplement with face machining, masonry work, riveting, and shield for severe exposure sanding

Chemical splash from corrosive and chemical Goggles handling, pressure washing operations Supplement with face shield for severe exposure

Nuisance dust from woodworking, buffing, Safety spectacles or goggles and general dusty conditions

Hot sparks from grinding operations Safety spectacles or goggles Supplement with face shield for severe exposure

Molten metal from torch cutting operations Shaded cutting goggles (see Table 3) and face shield

Welding operations Safety spectacles and shaded welding hood (see Tables 2)

AR400898 OHM RemedUtUai Service* Corp.

TABLE 2

GUIDE FOR CUTTING SHADE NUMBERS

Operation Plate Thicfciess ' Protective Shade

Gas Welding light Under 1/8 4 or 5 "~ Medium 1/8 to 1/2 5 or 6 Heavy over 1/2 6 or 8

Oxygen Cutting Light Under 1 3 or 4 Medium 1 to 6 4 or 5 Heavy Over 6 5 or 6

AR400899 Corp.

TABLES

GUIDE FOR WELDING SHADE NUMBERS

Minimum Suggested" Electrode Size Protective Shade No. Operation 1/32 inch Arc Current (A) Shade (Comfort)

Shielding metal Less than 3 Less than 60 7 y- arc welding 3-5 60-160 8 10 5-8 160-250 10 12 More than 8 250-550 11 14 __ Gas metal arc welding Less than 60 7 and flux cored arc 60-160 10 11 welding 160-250 10 12 250-500 10 14

150-500 10 14 Air carbon (Light) Less than 500 10 12 Air cutting (Heavy) 500-1000 11 14 Plasma arc welding Less than 20 6 6 to 8 20-100 8 10 100-400 10 12 400-800 11 14 Plasma arc cutting (Light) Less than 300 8 9 (Medium) 300-400 9 12 (Heavy) 400-800 10 14 Torch brazing 3 or 4 — Torch soldering 2 — Carbon arc welding j ._ 14

•As a rule of thumb, start with a shade that is too dark to see the weld zone. Then go to a lighter shade which gives sufficient view of the weld zone without going below the minimum. In oxyfuel gas welding or cutting where the torch produces a high yellow light, it is desirable to use a filter lens that absorbs the yellow or sodium line in the visible light of the (spectrum) operation.

AR400900 APPENDIXE VERIFICATION SAMPLING & ANALYSIS PLAN

AR400901 APPENDIX E

VEWFICA TION SAMPLING AND ANAL YSIS PLAN FOR THE DREDGING OF IMPACTED SEDIMENT AT THE FORMER UGI COLUMBIA GAS PLANT SITE COLUMBIA, PENNSYLVANIA

Submitted to:

Clean Sites Environmental Services, Inc.

Prepared By:

Parsons Engineering Science, Inc.

290 Elwood Davis Road, Suite 312 Liverpool, New York 13088

December 1997

FWRSOMS AR400902 TABLE OF CONTENTS

PAGE

SECTION 1 INTRODUCTION E-l-1

1.1 PROJECT BACKGROUND E-l-1

1.2. PLAN OBJECTIVES E-l-1

1.3 SCOPE OF WORK E-l-1

SECTION 2 GENERAL FIELD GUIDELINES E-2-1

2.1 SITE HAZARDS E-2-1

2.2 UNDERGROUND UTILITIES E-2-1

2.3 FIELD LOG BOOKS E-2-1

SECTION 3 FIELD EQUIPMENT DECONTAMINATION E-3-1

3.1 DECONTAMINATION AREA E-3-1

3.2 EQUIPMENT DECONTAMINATION E-3-1 3.2.1 Trucks and Excavation Equipment E-3-1 3.2.2 Sampling Equipment E-3-1 3.2.2.1 Materials E-3-1 3.2.2.2 Procedures E-3-1

SECTION 4 FIELD SAMPLING PROCEDURES E-4-1

4.1 INTRODUCTION E-4-1

4.2 SEDIMENT SAMPLING E-4-1 4.2.1 Equipment E-4-1 4.2.2 Sediment Sampling Method E-4-2

4.3 TREATED WATER SAMPLING E-4-2 4.3.1 Equipment E-4-2 4.3.2 Treated Water Sampling Method E-4-2

PARSONS ENGINEERING SCIENCE, INC. \\PARESSYR01\VOL1\USERS\40030\PPLSED\FINALWP\32412R1F.DOC DECEMBERS, 1997 i

AR400903 TABLE OF CONTENTS (CONTINUED) PAGE

SECTION 5 FIELD SAMPLE IDENTIFICATION AND CUSTODY E-5-1

5.1 SAMPLE LOCATION NUMBERING SYSTEM E-5-1

5.2 SAMPLE IDENTIFICATION E-5-1

5.3 CHAIN OF CUSTODY E-5-2

5.4 SAMPLE DOCUMENTATION E-5-2

LIST OF FIGURES

Figure 1.1 Composite Sample Location Plan E-l-3

Figure 5.1 Chain-of-Custody Form E-5-4

LIST OF TABLES

Table 1.1 Summary of Sediment and Water Sampling Program E-l-2

PARSONS ENGINEERING SCIENCE, INC. \\PARESSYRO IWOL1 \USERS\40030\PPLSED\FINALWPV32412R1 F.DOC DECEMBER 3, 1997 ii

AR400904 SECTION 1

INTRODUCTION

1.1 PROJECT BACKGROUND The former UGI Columbia manufactured gas plant (MGP) site is located on the Susquehanna River in Columbia, Pennsylvania. Coal tar contaminated sediments in the adjacent Susquehanna River will be removed during this Remedial Action.

1.2. PLAN OBJECTIVES This Verification Sampling and Analysis Plan (SAP) is intended to define the methods for conducting environmental sampling at the former UGI Columbia Gas Plant Site.

The objectives of the SAP are to: • Confirm that PAH levels in the remaining sediment are less than the primary cleanup criterion of 4 ppm or the secondary cleanup criterion of 44 ppm for contaminated hardpan that is difficult to remove (See Section 8.1 for additional details), • Characterize the removed sediment for disposal, and • Confirm that treated water meets discharge criteria.

1.3 SCOPE OF WORK The following field activities will be performed as part of the sediment remediation: • Sediment Sampling - A total of two composite sediment samples will be collected from the river bottom and four composite sediment samples will be collected from the excavation sidewalls after sediment removal. Each composite sample will consist of five grab samples. Sampling locations will be as shown on Figure 1.1. The number of samples, analytical parameters and methods are summarized on Table 1.1. • A total of four composite sediment samples will be collected from the sediment stockpile for characterization prior to removal from the site. The composite samples will consist of five grab samples from various locations of the stockpile. The number of samples, analytical parameters and methods are summarized on Table 1.1. • Treated Water Sampling - Water that has been in contact with the excavated sediment will be treated and then sampled. The number of samples, analytical parameters, and methods are summarized on Table 1.1.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOLl:\\PARESSYR01\VOLl\USERS\40030\PPLSED\FrNALWP\32412RlF.DOC DECEMBER 12, 1997 E-l-1 AR400905 TABLE 1.1

SUMMARY OF SEDIMENT AND WATER SAMPLING PROGRAM UGI COLUMBIA GAS PLANT SITE

Sampling Strategy Analytical Strategy

Media Number of Sampling Sampling Depths per Parameters Number of QA/QC EPA Analytical Locations Location Samples Samples Method (1) Analyzed

Sediment 2 at excavation bottom 0 to 6 inches in depth TCL Polynuclear Aromatic All samples 1 per 5 8270 4 at excavation sidewalls Sidewall surface Hydrocarbons (PAHs) (20%)

Sediment 4 0 to 6 inches in depth Total Metals All samples 6010/7000 Stockpile PCBs 8081 Ignitability 1010 Corrosivity 9045 Reactivity 7.3.3.2/7.3.4.2 Radioactivity Scan @ R3 Total Petroleum Hydrocarbons 418.1 EP Toxicity 450. 1M Toxicity Characteristic See Note 2. Leaching Procedure (TCLP) Total Organic Halogens 3540A/9020A

Treated Water 1 per 5,000 gal for the first 2 Benzene All Samples 8260 10,000 gal (Total of 2) Naphthalene Total Suspended Solids (TSS) 160.2 1 for every 50,000 gal NA thereafter

Notes: 1. Analytical method referenced in USEPA SW-846 Test Methods for Evaluating Solid Waste, Physical and Chemical Methods, 3rd edition, Revision 2, 1994. 2. TCLP Methods: VOCs, 8260; SVOCs, 8270; Pesticides/Herbicides, 8081/8150A; Metals, 6010A/7421; Mercury, 7471A; Extraction Method 1311.

PARSONS ENGINEERING SCIENCE, INC.

PARESS YRO1WOLIAMPARESS YRO1 \VOL 1\USERS\40030\PPLSED\HNALWP\32412RI F.DOC AR400906 DECEMBER 12, 1997 MUNICIPAL AUTHORITY OF COLUMBIA WASTEWATER CURRENT EDGE OF RIVER TEMPORARY TREATMENT PLANT - 230 CURRENT GROUND SURFACE ~ WATER CONTOUR TREATMENT AREA • WB1 SEDIMENT BORING LOCATION

TEMPORARY BOTTOM GRAB SAMPLE LOCATION FENCING

SIDEWALL GRAB SAMPLE LOCATION

MW-07D MONITORING WELL

SD01 GRAB SAMPLE AREA BOUNDARY

4PPM HIGH END SEDIMENT REMOVAL AREA

D(JCHxANDx fuMP ACROS X ApCESS ROAD

SHEETPILE RETAINING WALL (75') SEDIMENT STOCKPIE AREA,

-230 £*—^£.-

EROSION CONTROL EROSION CONTROL FENCING FENCING

FIGURE 1-1 PENNSYLVANIA POWER & LIGHT COMPANY CLEAN SITES ENVIRONMENTAL SERVICES COMPOSITE SAMPLE LOCATION PLAN FORMER UGI COLUMBIA GAS PLANT COLUMBIA, PENNSYLVANIA GRAPHIC SCALE IN FEET DATE: 12/02/97 (GTC) Xrnf. or View(s): DESIGN • RESEARCH * PLANNING H:\CAD\732412\32412G05.DWG no cunoo MM 10110 • junt»• UCTHCL N.T. uon [XXX P/M SPACE: 1:20XP PCP: 32412G01.PCP «n«o « MMM. em

E-l-3 AR400907 SECTION 2

GENERAL FIELD GUIDELINES

2.1 SITE HAZARDS Potential on-site surface hazards, such as sharp objects, overhead power lines, and building hazards, will be identified prior to initiation of field work. Generally, such hazards will be identified during a site visit that precedes the first day of field work.

2.2 UNDERGROUND UTILITIES All underground utilities, including electric lines, gas lines, and communication lines, will be identified prior to initiation of subsurface work. All on-site underground utilities in the vicinity of the proposed work area will be located and marked by a representative of the Underground Facilities Protective Organization (UFPO): (800) 962-7962. UFPO will be notified at least two working days and not more than ten working days before subsurface work is conducted.

2.3 FIELD LOG BOOKS All field activities will be carefully documented in field log books. Entries will be of sufficient detail that a complete daily record of significant events, observations, and measurements is obtained. The field log book will provide a legal record of the activities conducted at the site. Accordingly, • Field books will be assigned a unique identification number. • Field books will be bound with consecutively numbered pages. • Entries will be written with waterproof ink. • Entries will be signed and dated at the conclusion of each day of field work. • Corrections will be made by the person who made the original entries. Corrections will be made by drawing a line through the error, entering the correct information, and signing one's initials near and dating the time of the correction.

At a minimum, daily field book entries will include the following information: • Location of field activity; • Date and time of entry; • Names and titles of field team members; • Names and titles of any site visitors and site contacts; • Weather information, for example: temperature, cloud coverage, wind speed and direction;

PARSONS ENGINEERING SCIENCE, INC.

PARESSYRO1WOL1: \\PARESS YROIWOL1 \USERSV40030\PPLSED\FINALWP\32412R1 F.DOC DECEMBERS, 1997 E-2-1 AR400908 • Purpose of field activity; • Detailed description of the field work conducted; • Sample media (soil, sediment, groundwater, etc.); • Sample collection method; • Number and volume of sample(s) taken; • Description of sampling point(s); • Preservatives used; • Analytical parameters; • Date and time of collection; • Sample identification number(s); • Sample distribution (e.g., laboratory); • Field observations; • Any field measurements made, such as pH, temperature, conductivity, water level, etc.; • References for all maps and photographs of the sampling site(s); and • Information pertaining to sample documentation such as: - Bottle lot numbers; - Dates and method of sample shipments; - Chain-of-Custody Record numbers; and - Federal Express Air Bill Number.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOL1:\\PARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\32412R1F.DOC DECEMBERS, 1997 E-2-2 AR400909 SECTION 3 i_^ FIELD EQUIPMENT DECONTAMINATION

3.1 DECONTAMINATION AREA A decontamination pad will be constructed to remove potentially contaminated soil from "~ trucks and equipment prior to leaving the site. The decontamination pad will consist of two layers of 10-mil visqueen covered with stone. Decontamination will consist of pressure washing with potable water. Decontamination water will be treated in the onsite treatment system and then discharged to the river after sampling confirms that the discharge limits have been met.

_ 3.2 EQUIPMENT DECONTAMINATION 3.2.1 Trucks and Excavation Equipment All trucks and equipment that work in the contaminated areas will be pressure washed prior ^*»x to leaving the site.

3.2.2 Sampling Equipment 3.2.2.1 Materials • Potable water """ • Phosphate-free detergent (e.g., Alconox) • Reagent-grade methanol or isopropanol w • Distilled water • Aluminum foil —< • Plastic/polyethylene sheeting • Plastic buckets and brushes ^^ 3.2.2.2 Procedures • Prior to sampling, all non-dedicated bowls, spoons, bailers, and any other tools will be washed with potable water and a phosphate-free detergent, such as Alconox. •— Decontamination of sampling equipment will be performed at the decontamination pad. • The sampling equipment will then be rinsed with potable water followed by a reagent- grade methanol or isopropanol rinse and a distilled or deionized water rinse or steam cleaning. • Between rinses, equipment will be placed on polyethylene sheets or aluminum foil, if — necessary. At no time will washed equipment be placed directly on the ground. « Equipment will be wrapped in polyethylene plastic or aluminum foil for storage or transportation from the designated decontamination area to the sampling location.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01YVOL1:\\P ARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\32412R1F.DOC DECEMBERS, 1997 E-3-1 AR400910 SECTION 4

FIELD SAMPLING PROCEDURES

4.1 INTRODUCTION The following types of environmental sampling will be conducted at the site: • Sediment sampling • Treated water sampling

Procedures for obtaining samples of various environmental media are described in this section. At a minimum, sampling procedure standards will be in accordance with the most recent PADEP and USEPA guidelines and/or regulations. The procedures described here are derived primarily from the following guidance documents: • USEPA, 1979. Methods for Chemical Analysis of Water and Wastes. EPA 600-4-79- 020. • USEPA, 1984. Characterization of Hazardous Waste Sites - A Methods Manual: Volume II. Available Sampling Methods, 2nd edition. EPA 600/4-84-076. • USEPA, 1993. Subsurface Characterization and Monitoring Techniques - Volume 1: Solids and Ground Water, Appendices A and B. EPA 625/R-93/003a.

4.2 SEDIMENT SAMPLING The following method will be used to collect sediment samples at the site.

4.2.1 Equipment • Field book • Project plans • Personal protective equipment in accordance with the Health and Safety Plan • Decontamination supplies • Stainless steel bowls and spoons • Plastic sheeting • Camera • Clear tape, duct tape • Coolers • Laboratory sample bottles o Federal Express labels

PARSONS ENGINEERING SCIENCE, INC.

PARESSYROIWOL1 :\\PARESSYRO 1YVOL 1\USERS\40030\PPLSED\FINALWP\32412RI F.DOC DECEMBERS, 1997 E-4-1 AR400911 4.2.2 Sediment Sampling Method • The sediment excavation area or the sediment stockpile will be divided into five areas of approximately equal area. • Sediment samples will be collected from the upper six inches of sediment of each grid area or the stockpile using the stainless steel bowls and spoons. • Sediment from a minimum of five grab samples of equal volume will be placed into a decontaminated stainless steel mixing bowl. • The grab samples will be thoroughly mixed and then placed in appropriate containers for analysis. • The sample containers will be labeled, placed in a laboratory supplied cooler, packed on ice, and stored at a temperature of 4° C. • Chain-of-custody procedures will be followed as outlined in the Quality Assurance/Quality Control Plan. • The cooler will be shipped overnight or delivered to the laboratory for analysis. • The sampling equipment will be decontaminated on-shore between samples in accordance with procedures described in Section 3. • The sample locations, descriptions, and depth will be recorded in the field book.

4.3 TREATED WATER SAMPLING The following method will be used to collect treated water samples from the temporary water treatment plant.

4.3.1 Equipment • Field book • Project plans • Personal protective equipment in accordance with the HSP • 250-mL glass beaker • Decontamination supplies • Plastic sheeting • Clear tape, duct tape • Coolers and ice • Laboratory sample bottles • Federal Express labels 4.3.2 Treated Water Sampling Method • Prior to filling the sample bottles, one decontaminated 250-mL beaker will be filled with treated water. • Sample bottles will be filled.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOL1:\\PARESSYROUVOL1\USERSV4 0030VPPLSED\FINALWP\32412R1F.DOC DECEMBER 3, 1997 E-4-2 AR400912 The sample bottles will be labeled, placed in a laboratory-supplied cooler, packed on ice, and stored at a temperature of 4° C. Chain-of-custody procedures will be followed as outlined in the Quality Assurance/Quality Control Plan. The cooler will be shipped overnight or delivered to the laboratory for analysis. The sampling equipment will be decontaminated between samples in accordance with the procedures described in Section 3. The sample locations and descriptions will be recorded in the field book.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYROI\VOL1:\\PARESSYR01\VOL1\USERS\40030\PPLSED\FIN ALWP\32412R1F.DOC DECEMBERS, 1997 E-4-3 AR400913 SECTION 5

FIELD SAMPLE IDENTIFICATION AND CUSTODY

5.1 SAMPLE LOCATION NUMBERING SYSTEM Sediment Samples Sediment samples will be numbered consecutively beginning with SD01.

Treated Water Samples Water samples will be numbered consecutively beginning with WW01.

5.2 SAMPLE IDENTIFICATION Each sample will be given a unique alphanumeric identifier in accordance with the following classification system:

SAMPLE IDENTIFICATION LL* NN L LL Sample Type Sample Number Grab Sample Code QC Identifier Solid Water Sample Type: SD - Sediment MW - Monitoring Well SS - Surface Soil LC - Leachate SB - Soil Boring SW - Surface Water MW - Monitoring Well Boring DW - Drill Water TP - Test Pit/Tank Pit MH - Manhole DR - Drum Waste ST - Storm Water WA - Solid Waste WW - Waste Water OS - Other Solid Waste OL - Other Liquid AS - Air Sample WT - Surface Water Toxicity Sample Number Number referenced to a sample location map Grab Sample Code Grab sample location code for each composite sample QC Identifier: FB - Field Blank TB - Trip Blank WB - Wash Blank MS - Matrix Spike MD - Matrix Spike Duplicate MB-Matrix Blank L = Letter N = Number

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOLI:\\PARESSYR01\VOLUUSERS\40030\PPLSED\FINALWP\32412R1F.DOC DECEMBERS, 1997 E-5-1

AR400914 Each sample container will be labeled prior to packing for shipment. The sample identifier, site name, date and time of sampling, and analytical parameters wit! be written on the label in waterproof ink and recorded in the field book.

5.3 CHAIN OF CUSTODY • A chain-of-custody (COC) record (Figure 5.1) will accompany the sample containers during selection and preparation at the laboratory, during shipment to the field, and during return shipment to the laboratory. • The COC will identify each sample container and the analytical parameters for each, and will list the field personnel that collected the samples, the project name and number, the name of the analytical laboratory that will receive the samples, and the method of sample shipment. • The COC will be completed by field personnel as samples are collected and packed for shipment. • Erroneous markings will be crossed-out with a single line and initialed by the author. • After the samples have been collected and sample information has been listed on the COC form, the method of shipment, the shipping cooler identification number(s), and the shipper airbill number will be entered on the COC. • Finally, a member of the sampling team will write his/her signature, the date, and time on the first RELINQUISHED BY space. Duplicate copies of each COC must be completed. • One copy of the COC will be retained by sampling personnel. The other copy and the original will be sealed in a plastic bag and taped inside the lid of the shipping cooler. • Sample shipments will be refrigerated at 4°C, typically by packing with ice, to preserve the samples during shipment. • After the shipping cooler is closed, custody seals provided by the laboratory will be affixed to the latch and across the front and back of the cooler lid, and signed by the person relinquishing the samples to the shipper. • The seal will be covered with clear tape, and the cooler lid will be secured by wrapping with packing tape. • Then the cooler will be relinquished to the shipper, typically an overnight carrier. • The COC seal must be broken to open the container. Breakage of the seals before receipt at the laboratory may indicate tampering. If tampering is apparent, the laboratory will contact the OHM Project Manager to determine if the samples will be analyzed. • The samples must be delivered to the laboratory within 48 hours of collection.

5.4 SAMPLE DOCUMENTATION The sampling personnel leader will retain a copy of the COC and ensure that the following information about each sample is recorded in the field book:

PARSONS ENGINEERING SCIENCE, INC.

PARESSYRO 1\VOL 1 :\\PARESSYRO 1WOL 1\USERS\40030\PPLSED\FJNALWP\32412R1 F.DOC DECEMBERS, 1997 E-5-2

AR400915 Sample identifier; Identification of sampled media (e.g., soil, sediment, groundwater); Sample location with respect to known reference point; Physical description of sample location; Field measurements (e.g., pH, temperature, conductivity, and water levels); Date and time of collection; Sample collection method; Number of sample containers; Analytical parameters; Preservatives used; and Shipping information: Dates and method of sample shipments; Chain-of-Custody Record numbers; Federal Express Air Bill numbers; and Sample recipient (e.g., laboratory name).

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOL1-.\\PARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\32412R1F.DOC DECEMBERS, 1997 E-5-3

AR400916 { J 1 I \ 1 /

Form 0019 CHAIN-OF-CUSTODY RECORD Field Technical Services (Jl !M Corponilion N9 114138 Rev. 08/89

O.H. MATERIALS CORP. P.O. BOX 551 FINDLAY, OH 45839-0551 419-423-3526

(OJECTNAME PROJECT LOCATION ANALYSIS DESIRED :NDICATE ROJ. NO. PROJECT CONTACT PROJECT TELEPHONE NO. 8 EPARATE UJ lONTAINERS) ai: z- LIGNT'S REPRESENTATIVE PROJECT MANAGER/SUPERVISOR

o u_ O SAMPLE SAMPLE DESCRIPTION NUMBER DATE TIME (INCLUDE MATRIX AND POINT OF SAMPLE) REMARKS

REMARKS ITEM TRANSFERS TRANSFERS NUMBER RELINQUISHED BY ACCEPTED BY DATE TIME 9 $n•

SAMPLER'S SIGMATURE AR400917

LAB COPY ORIGINAL (Red)

APPENDIXF QUALITY ASSURANCE / QUALITY CONTROL PLAN

AR400918 ORIGINAL (Red)

APPENDIX F

QUALITY ASSURANCE/QUALITY CONTROL PLAN FOR THE SEDIMENT REMOVAL ACTION FOR THE FORMER UGI COLUMBIA GAS PLANT SITE COLUMBIA, PENNSYLVANIA

Prepared For:

Clean Sites Environmental Services, Inc.

Prepared By:

Parsons Engineering Science, Inc.

290 Elwood Davis Road, Suite 312 Liverpool, New York 13088

December 1997

PERSONAR400919S APPENDIX F TABLE OF CONTENTS

SECTION 1 INTRODUCTION F-l-1

1.1 PROJECT BACKGROUND F-l-1

1.2 PLAN OBJECTIVES F-l-1

1.3 SCOPE OF WORK F-l-1

SECTION 2 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) OBJECTIVES FOR MEASUREMENT OF DATA F-2-1

2.1 INTRODUCTION F-2-1

2.2 REPRESENTATIVENESS F-2-1

2.3 COMPLETENESS F-2-2

2.4 COMPARABILITY F-2-2

SECTIONS SAMPLING PROGRAM F-3-1

3.1 INTRODUCTION F-3-1

3.3 SAMPLE HOLDING TIMES F-3-1

SECTION 4 SAMPLE TRACKING AND CUSTODY F-4-1

4.1 INTRODUCTION F-4-1

4.2 FIELD SAMPLE CUSTODY F-4-1

4.3 LABORATORY SAMPLE CUSTODY F-4-2

SECTION 5 CALIBRATION PROCEDURES F-5-1

5.1 FIELD INSTRUMENTS F-5-1

5.2 LABORATORY INSTRUMENTS F-5-1

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\32412R2F.DOC DECEMBERS, 1997 F-i

AR400920 ORIGINAL i Red)

SECTION 6 ANALYTICAL PROCEDURES F-6-1

SECTION 7 DATA REPORTING F-7-1

SECTION 8 CORRECTIVE ACTION F-8-1

8.1 INTRODUCTION F-8-1

8.2 PROCEDURE DESCRIPTION F-8-1

SECTION 9 REFERENCES F-9-1

LIST OF FIGURES

Figure 4.1 Sample Custody F-4-3

Figure 4.2 Chain-of-Custody Record F-4-4

Figure 8.1 Sample Corrective Action Request (CAR) Format F-9-3

LIST OF TABLES

Table 3.1 Summary of Samples and Analyses F-3-2

Table 3.2 Sediment and Water Sample Containerization, Preservation, and Holding Times F-3-3

Table 6.1 Scope of Analytical Methods for Sediment and Water Samples F-6-2

Table 6.2 Target Compound List PAHs Practical Quantitation Limits (PQLs) F-6-3

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01WOL1\USERS\40030VPPLSED\F1NALWP\32412R2F.DOC DECEMBERS, 1997 F-ii

AR400921 SECTION 1

INTRODUCTION

1.2 PLAN OBJECTIVES This Quality Assurance/Quality Control Plan has been prepared by Parsons Engineering Science, Inc. (Parsons ES), for Clean Sites Environmental Services, Inc., and Pennsylvania Power and Light (PP&L) in support of the Sediment Removal Action. This plan specifies analytical methods to be used to ensure that data from the proposed remediation are representative and comparable.

1.3 SCOPE OF WORK The scope of the Sediment Removal Action at the former UGI Columbia MGP site is described in the project Work Plan. After contaminated sediment is removed, samples will be collected from the remaining sediment to confirm that PAH levels in the remaining sediment are less than the primary cleanup criterion of 4 ppm total PAHs or the secondary cleanup level of 44 ppm total PAHs. Samples will also be taken from the sediment stockpile for characterization prior to disposal offsite. Additionally, samples will be collected from water treated as a result of having come into contact with the excavated sediment to confirm that the treated water meets discharge criteria. These samples will be analyzed in compliance with USEPA SW-846 "Test Methods for Evaluating Solid Waste," 3rt^ edition.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01WOLUUSERS\40030\PPLSED\FrNALWP\32412R2F.DOC DECEMBERS, 1997 F-l-1

AR400922 SECTION 2

QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) OBJECTIVES FOR MEASUREMENT OF DATA

2.1 INTRODUCTION The quality assurance (QA) and quality control (QC) objectives for all measurement data include representativeness and comparability. These objectives are defined in the following subsections. They have been formulated to meet the requirements of the USEPA SW-846. The analytical methods and their Practical Quantitation Limits (PQLs) are given in Section 6.

2.2 REPRESENTATIVENESS Representativeness expresses the degree to which sample data accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, or an environmental condition. Representativeness is a qualitative parameter that is most concerned with the proper design of the sampling program (USEPA, 1987). Samples must be representative of the environmental media being sampled. Selection of sample locations and sampling procedures wil] incorporate consideration of obtaining the most representative sample possible.

Field and laboratory procedures will be performed in such a manner as to ensure, to the degree that is technically possible, that the data derived represents the in-place quality of the material sampled. Every effort will be made to ensure chemical compounds will not be introduced into the sample via sample containers, handling, and analysis. Decontamination of sampling devices and digging equipment will be performed between samples as outlined in the Verification Sampling and Analysis Plan (Appendix B). Laboratory sample containers will be thoroughly cleaned in accordance with procedures outlined in Section 3 of the Verification Sampling and Analysis Plan.

The assessment of representativeness also must consider the degree of heterogeneity in the material from which the samples are collected. The analytical laboratory will also follow acceptable procedures to ensure that the samples are adequately homogenized prior to taking aliquots for analysis, so that the reported results are representative of the sample received.

Chain-of-custody (COC) procedures will be followed to document that contamination of samples has not occurred during container preparation, shipment, and sampling. Details of COC procedures are presented in Section 4.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYROI\VOLI\USERSW0030\PPLSED\FINALWP\32412R2F.DOC DECEMBERS, 1997 F-2-1

AR400923 2.3 COMPLETENESS Completeness is defined as the percentage of measurements made that are judged to be valid (USEPA, 1987). The QC objective for completeness is generation of valid data for at least 90 percent of the analyses requested. Completeness is defined as follows for all sample measurements:

V %C= x 100 T

where:

%C - Percent completeness

V = Number of measurements judged valid

T = Total number of measurements

2.4 COMPARABILITY Comparability expresses the degree of confidence with which one data set can be compared to another (USEPA, 1987). The comparability of all data collected for this project will be ensured by:

• Using identified standard methods for both sampling and analysis phases of this project,

• Requiring traceability of all analytical standards and/or source materials to the U.S. Environmental Protection Agency (USEPA) or National Institute of Standards and Technology (MIST),

• Requiring that all calibrations be verified with an independently prepared standard from a source other than that used for calibration (if applicable),

• Using standard reporting units and reporting formats including the reporting of QC data,

• Requiring that all validation qualifiers be used any time an analytical result is used for any purpose.

These steps will ensure that all future users of either the data or the conclusions drawn from them will be able to judge the comparability of these data and conclusions.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\32412R2F.DOC DECEMBERS, 1997 F-2-2

AR400924 SECTION 3

SAMPLING PROGRAM

3.1 INTRODUCTION The sampling program will provide data concerning the nature and extent of contamination of the remaining sediment and the treated water. This section presents sample container preparation procedures, sample preservation procedures, and sample holding times. Sample parameters and the number of environmental samples to be taken are given in Table 3.1. Sampling procedures are presented in the Verification Sampling and Analysis Plan (Appendix B).

3.2 SAMPLE CONTAINER PREPARATION AND SAMPLE PRESERVATION

Sample containers will be properly washed and decontaminated prior to their use by either the analytical laboratory or the container vendor to the specifications required by the USEPA. Copies of the sample container QC analyses will be provided by the laboratory for each container lot used to obtain samples. The containers will be tagged, and the appropriate preservatives will be added. The types of containers are described in Table 3.2.

Samples shall be preserved according to the preservation techniques given in Table 3.2. Preservatives will be added to the sample bottles by the laboratory prior to their shipment in sufficient quantities to ensure that proper sample pH is met. Following sample collection, the sample bottles should be placed on ice in the shipping cooler, cooled to 4°C. with crushed ice, and delivered to the laboratory within 48 hours of collection. COC procedures are described in Section 4.

3.3 SAMPLE HOLDING TIMES The sample holding times for the analytical parameters are given in Table 3.2. These holding times must be strictly adhered to by the laboratory. Any holding time exceedances must be reported to the OHM project manager,

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYRO 1WOL! \USERS\40030\PPLSED\FINALWP\32412R2F.DOC DECEMBERS, 1997 F-3-1

AR400925 r

TABLE 3.1

SUMMARY OF SAMPLES AND ANALYSES UGI COLUMBIA GAS PLANT SITE

Field Samples QC Samples(2)Samples Total

Matrix Parameter Analytical Method (1) Sample Frequency Field Duplicate MS/MSD Trip Blank Field Blank

Sediment TCL PAHs 8270 6 1 1/1 1 1 11

Sediment Total Metals 6010/7000 4 4 Stockpile PCBs 8081 Ignitability 1010 Corrosivity 9045 Reactivity 733 2/7.3.4.2 Radioactivity Scan @ R3 TPH 418.1 EP Toxicity 450.1M TCLP See Note 3. TOH 3540A/9020A Treated Benzene 8260 1 for every 5,000 Will vary Water Naphthalene gallons for the first depending 10,000 gallons on water TSS 160.2 (Total of 2). volume. 1 for every 50,000 gallons thereafter.

Abbreviations: TCL PAHs - Target Compound List Polynuclear Aromatic Hydrocarbons TOH - Total Organic Halogens TPH - Total Petroleum Hydrocarbons TSS - Total Suspended Solids TCLP - Toxicity Characteristic Leaching Procedure Notes: 1. USEPA SW-846 Test Methods for Evaluating Solid Waste, Physical and Chemical Methods, 3rd edition, Revision 2, 1994. 2. QA/QC samples to be run once per every five (20%) confirmatory sediment samples. 3. TCLP Methods: VOCs, 8260; SVOCs, 8270; Pesticides/Herbicides, 8081 /8150A; Metals, 601OA/7421; Mercury, 7471 A; Extraction Method 1311.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\32412R2F.DOC DECEMBER 12, 1997 AR400926 TABLE 3.2 SEDIMENT AND WATER SAMPLE CONTAINERIZATION, PRESERVATION, AND HOLDING TIMES

Analysis Bottle Type Preservation (a> Holding Time

Semivolatile Organic Wide-mouth glass w/ Cool to 4°C 7 days* Compounds (SVOCs) teflon lined cap

(a) All samples to be preserved in ice during collection and transport w (b) Days from date of sample collection

• Sohxlet or sonication procedures for extraction and concentration of sediment samples for *~\^/ SVOCs must be completed within 7 days of sample collection. Extracts of water samples must be analyzed within 40 days of sample collection. Continuous liquid-liquid extraction is the required extraction for water samples for SVOCs and must be completed within 7 days of sample ,._. collection.

• Properly sized bottles to be provided by the testing laboratory.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01WOLUUSERS\40030\PPLSED\FINALWP\32412R2F.DOC DECEMBERS, 1997 F-3-3

AR400927 SECTION 4

SAMPLE TRACKING AND CUSTODY

4.1 INTRODUCTION This section presents sample custody procedures for both the field and laboratory. Implementation of proper custody procedures for samples generated in the field is the responsibility of field personnel. Both laboratory and field personnel involved in the chain of custody (COC) and transfer of samples will be trained as to the purpose and procedures prior to implementation.

Evidence of sample traceability and integrity is provided by COC procedures. These procedures document the sample traceability from the selection and preparation of the sample containers by the laboratory to sample collection, sample shipment, and finally to laboratory receipt and analysis. The sample custody flowchart is shown in Figure 4.1. A sample is considered to be in a person's custody if the sample is:

• In a person's possession;

• Maintained in view after possession is accepted and documented;

• Locked and tagged with Custody Seals so that no one can tamper with it after having been in physical custody; or

• In a secured area that is restricted to authorized personnel.

4.2 FIELD SAMPLE CUSTODY A COC record (Figure 4.2) accompanies the sample containers from selection and preparation at the laboratory, during shipment to the field for sample containment and preservation, and during return to the laboratory. Triplicate copies of the COC must be completed for each sample set collected.

Once all bottles are properly accounted for on the form, a sampler will write his or her signature and the date and time on the first "Relinquished by" space. The sampler will also write the method of shipment, the shipping cooler identification number, and the shipper airbill number on the top of the COC. Mistakes will be crossed out with a single line in ink and initialed by the author.

One copy of the COC is retained by sampling personnel and the other two copies are put into a scalable plastic bag and taped inside the lid of the shipping cooler. The cooler lid is closed, custody seals provided by the laboratory are affixed to the latch and across the back and front lids of the cooler, and the person relinquishing the samples signs their name across the seal.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYRO 1WOL1 \USERS\40030\PPLSED\FINALWP\32412R2F.DOC DECEMBERS, 1997 F-4-1

AR400928 The seal is taped, and the cooler is wrapped tightly with clear packing tape. It is then ' relinquished by field personnel to personnel responsible for shipment, typically an overnight carrier.

The COC seal must be broken to open the container. Breakage of the seals before receipt at the laboratory may indicate tampering. If tampering is apparent, the laboratory will contact the Project Manager, and the sample will not be analyzed.

4.3 LABORATORY SAMPLE CUSTODY The Project Manager will notify the laboratory of upcoming field sampling activities and the subsequent shipment of samples to the laboratory. This notification will include information concerning the number and type of samples to be shipped as well as the anticipated date of arrival.

The following laboratory sample custody procedures will be used: • The laboratory will designate a sample custodian who will be responsible for maintaining custody of the samples and for maintaining all associated records documenting that custody. • Upon receipt of the samples, the custodian will check cooler temperature and the original COC documents and compare them with the labeled contents of each sample container for correctness and traceability. The sample custodian will sign the COC record and record the date and time received. • Care will be exercised to annotate any labeling or descriptive errors. In the event of discrepant documentation, the laboratory will immediately contact the Project Manager as part of the corrective action process. A qualitative assessment of each sample container will be performed to note any anomalies, such as broken or leaking bottles. This assessment will be recorded as part of the incoming chain-of-custody procedure. • The samples will be stored in a secured area at a temperature of approximately 4 degrees Celsius until analyses commence. • A laboratory tracking record will accompany the sample or sample fraction through final analysis for control. • A copy of the tracking record will accompany the laboratory report and will become a permanent part of the project records. tSJ

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01WOLl\USERS\40030\PPLSED\FtNALWP\32412R2F.DOC DECEMBER 3, 1997 F-4-2

AR400929 FIGURE 4.1

SAMPLE CUSTODY

PREPARATION OF SAMPLE CONTAINERS

SAMPLES COLLECTED BY SAMPLING TEAM

SAMPLES LABELED

SEALED IN INSULATED COOLER WITH ICE*

CORRECTIVE ACTION SHIPMENT TO IF REQUIRED LABORATORY

SAMPLE RECEIPT AT LAB*

CHECK SAMPLE INTEGRITY*

STORAGE IN CHECK OUT RETURN TO STORAGE SECURE AREA FOR ANALYSIS* OR DISPOSAL

* REQUIRES SIGN-OFF ON CHAIN OF CUSTODY FORM.

PARSONS ENGINEERING SCIENCEAR400930 , INC D:\GRAPHICS\732412\SAMPCUST.DS4 F-4-3 / I 1 , ( ( /

Form 0019 CHAIN-OF-CUSTODY RECORD Field Technical Services OHM Corporation :9 114138 Rev. 08/89

O.H. MATERIALS CORP. P.O. BOX 551 FINDLAY, OH 45839-0551 419-423-3526

'F10JECT NAME PROJECT LOCATION ANALYSIS DESIRED WDICATE 'ROJ. NO. PROJECT CONTACT PROJECT TELEPHONE NO. C/5 (E SEPARATE 111 CONTAINERS) CLIENT'S REPRESENTATIVE PROJECT MANAGER/SUPERVISOR

SAMPLE SAMPLE DESCRIPTION NUMBER DATE TIME (INCLUDE MATRIX AND POINT OF SAMPLE) REMARKS

to n 10

REMARKS ITEM TRANSFERS TRANSFERS NUMBER RELINQUISHED BY ACCEPTED BY DATE TIME o

O- :

SAMPLER'S SIGNATURE cr> AR400931

LAB COPY SECTION 5

CALIBRATION PROCEDURES

5.1 FIELD INSTRUMENTS No field analytical equipment will require calibration for this sampling effort.

Calibration procedures for instruments used for monitoring health and safety hazards (e.g., photoionization detector and explosimeter) are provided in the Health and Safety Plan.

5.2 LABORATORY INSTRUMENTS The laboratory will follow all calibration procedures and schedules as specified in the sections of the USEPA SW-846 that apply to the instruments necessary for the analytical methods given in Section 6 (USEPA, 1994).

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01\VOLUUSERS\40030\PPLSED\FINALWP\32412R2F.DOC DECEMBERS, 1997 F-5-1

AR400932 SECTION 6

ANALYTICAL PROCEDURES

Samples will be analyzed according to the USEPA SW-846 Test Methods for Evaluating Solid Waste (USEPA, 1994). The methods to be used for the laboratory analysis of sediment and water samples are presented in Table 6.1. These methods were selected because (1) they meet the requirements of the USEPA Region II Administrative Order on Consent for Removal Action and (2) they attain the Practical Quantitation Limits (PQLs), which are compiled in Table 6.2.

The total PAHs will be calculated using the 18 compounds listed in Table 6.2. Estimated values given a "J" qualifier will be counted 100 percent. Non-detect results will not be counted in the total PAH values.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01\VOL1\USERS\40030\PPLSED\FINALWP\32412R2F.DOC DECEMBER 3, 1997 F-6-1

AR400933 TABLE 6.1

SCOPE OF ANALYTICAL METHODS FOR SEDIMENT AND WATER SAMPLES

Analytical Strategy

Media Parameters EPA Analytical Method (1)

Surficial Sediment TCL PAHs 8270

Sediment Stockpile Total Metals 6010/7000 PCBs 8081 Ignitability 1010 Corrosivity 9045 Reactivity 7332/7 3.4.2 Radioactivity Scan @ R3 Total Petroleum Hydrocarbons 418.1 EP Toxicity 450.1M

Treated Water Benzene 8260 Naphthalene Total Suspended Solids (TSS) 160.2

Abbreviations: TCL PAHs - Target Compound List Polynuclear Aromatic Hydrocarbons

Note: 1. Analytical method referenced in USEPA SW-846 Test Methods for Evaluating Solid Waste, Physical and Chemical Methods, 3rd edition, Revision 2,1994.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYROIWOL1\USERS\40030\PPLSED\FINALWP\324I2R2F.DOC DECEMBER 3, 1997 F-6-2

AR400934 Table 6.2

TARGET COMPOUND LIST PAHs PRACTICAL QUANTITATION LIMITS (PQLs)(1)

Target Compound Water (ug/H Soil / Sediment (ug/I)

Acenaphthene 3 100 Acenaphthylene 3 100 Anthracene 2 67 Benzo(a)anthracene 2 67 Benzo(a)pyrene 2 67 Benzo(b)fluoranthene 2 67 Benzo(g,h.,i)perylene 2 67 Benzo(k)fluoranthene 5 170 Indeno(l,2,3-cd)pyrene 2 67 Chrysene 2 67 Dibenzo(a,h)anthracene 2 67 Dibenzofhran 3 100 Flouranthene 2 67 Fluorene 3 100 l-Methylnaphthalene(2) NA NA 2-Methylnaphthalene 2 67 Naphthalene 3 100 Phenanthrene 3 100 Pyrene 2 67

(1) Quantitation Limits for soil and sediment are based on wet weight. Quanititation limits calculated by the laboratory on a dry weight basis, as required by the protocol, will be higher.

(2) 1-Methylnaphthalene is normally not included in EPA Method 8270. Results for 1-Methylnaphthalene will not be posted if it coalutes with another analyte during analysis.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\324I2R2F.DOC DECEMBERS, 1997 F-6-3

AR400935 SECTION 7

DATA REPORTING

The laboratory analytical results will be included in the closure report for the sediment removal action. The laboratory will assign one of the following qualifiers to each analytical result: • "U" - Not detected at given value; • "UJ" - Estimated not detected at given value; • "J" - Estimated value; • "N" - Presumptive evidence of a compound; • "R" - Result not useable, and • No Flag - Result accepted without qualification.

If a qualifier is not assigned, then the sample results is considered acceptable and compliant at the sample concentration given.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\32412R2F.DOC DECEMBERS, 1997 F-7-1

AR400936 SECTION 8

CORRECTIVE ACTION

8.1 INTRODUCTION The following procedures have been established to ensure that conditions adverse to quality, such as malfunctions, deficiencies, deviations, and errors, are promptly investigated, documented, evaluated, and corrected.

All project personnel have the responsibility, as part of the normal work duties, to promptly identify, solicit approved correction and report conditions adverse to quality. Corrective actions will be initiated under the following conditions: • When predetermined acceptance standards are not attained; • When procedure or data compiled are determined to be deficient; • When equipment or instrumentation is found to be faulty; • When samples and analytical test results are not clearly traceable; • When quality assurance requirements have been violated; • When designated approvals have been circumvented; • As a result of system and performance audits; • As a result of a management assessment; • As a result of laboratory/field comparison studies; and/or • As required by USEPA SW-846.

8.2 PROCEDURE DESCRIPTION When a significant condition adverse to quality is noted at the site or laboratory the cause of the condition will be determined and corrective action will be taken to preclude repetition. Condition identification, cause, reference documents, and corrective action planned to be taken will be documented and reported to the Project Manager at a minimum. Implementation of corrective action is verified by documented follow-up action.

The project manager and laboratory personnel will monitor on-going work performance in the normal course of daily responsibilities. Activities or documents ascertained to be non- compliant with quality assurance requirements will be documented and corrective actions implemented.

Personnel assigned to quality assurance functions will have the responsibility to issue and control Corrective Action Request (CAR) Forms (Figure 8.1). The CAR identifies the out-of- compliance condition, reference document(s), and recommended corrective action(s) to be

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01\VOU\USERS\40030\PPLSED\FINALWP\32412R2F.DOC DECEMBERS, 1997 F-8-1

AR400937 administered. The project manager will maintain the log for status of CARs, confirm the adequacy of the intended corrective action, and verify its implementation. CARs will be retained in the project file for the records.

OHM sampling personnel are responsible for documenting, numbering, logging and verifying proper sampling procedures. The project manager will be responsible for ensuring that all recommended corrective actions are implemented, documented, and approved.

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01\VOL1\USERS\40030\PPLSEDVFINALWP\32412R2F.DOC DECEMBERS, 1997 F-8-2

AR400938 Figure 8.1

CORRECTIVE ACTION REQUEST

Numbor Data

TO You aia n

CONDHDON:

REFERENCE DOCUMENTS:

RECOMMENDED CORRECTIVE ACTXDNS:

ORIGINATOR DATE APPROVAL DATE APPROVAL DATE

RESPONSE

CAUSE OF CONDmON:

CORRECTIVE ACTION

(A) RESOLUTION

(81) PREVENTION

(92) AFFECTED DOCUMENTS

SIGNATURE DATE.

V FOLLOWUP: CORRECTIVE ACTION VERIFIED: BY OATE_

ENGINEERING-SCIENCS

AR400939 F-8-3 SECTION 9

REFERENCES

Taylor, J. K., 1987. Quality Assurance of Chemical Measurements. Lewis Publishers, Inc., Chelsea, Michigan USEPA, 1994. SW-846 Test Method for Evaluating Solid Waste, Physical and Chemical Methods, 3T<^ edition, Revision 2. Washington, D.C.: U.S. Environmental Protection Agency, 1994. USEPA, 1987. Data Quality Objectives for Remedial Response Actions Activities: Development Process, EPA/540/G-87/003, OSWER Directive 9355.0-7-B. Washington, D.C.: U.S. Environmental Protection Agency, 1987. USEPA, 1992. Contract Laboratory Program Organics Data Review and Preliminary Review. SOP No. HW-6, Revision 8. USEPA Region II, dated January 1992

PARSONS ENGINEERING SCIENCE, INC.

\\PARESSYR01WOL1\USERS\40030\PPLSEDVF1NALWP\32412R2F.DOC DECEMBERS, 1997 F-9-1

AR400940 x - ,'Sed)

APPENDIX G CONTINGENCY PLAN

AR400941 (Ked)

APPENDIXG

CONTINGENCY PLAN FOR THE SEDIMENT REMOVAL ACTION AT THE FORMER UGI COLUMBIA GAS PLANT SITE COLUMBIA, PENNSYLVANIA

Prepared For:

Clean Sites Environmental Services, Inc.

Prepared By:

Parsons Engineering Science, Inc.

290 Eiwood Davis Road, Suite 312 Liverpool, New York 13088

December 1997

FWVRSOIMS AR400942 ORIGINAL !.Ked)

TABLE OF CONTENTS

PAGE

SECTION 1 INTRODUCTION G-l-1

1.1 PROJECT BACKGROUND G-l-1

1.2 PLAN OBJECTIVES G-l-1

SECTION 2 EMERGENCY COORDINATION G-2-1

2.1 EMERGENCY ORGANIZATION G-2-1

2.2 RESPONSIBILITIES OF THE EMERGENCY COORDINATOR G-2-1

2.3 EMERGENCY RESPONSE G-2-1

SECTION 3 EMERGENCY PROCEDURES G-3-1

3.1 EVACUATION PLAN G-3-1

3.2 ONSITE PERSONAL INJURY G-3-1

3.3 FIRE OR EXPLOSION G-3-1

3.4 SEDIMENT RELEASE IN RIVER G-3-2

3.5 SEDIMENT SPILL G-3-2

3.6 WASTEWATER SPILL G-3-2

3.7 WASTEWATER TREATMENT SYSTEM DOES NOT MEET DISCHARGE LIMITS G-3-4

3.8 EXCEEDANCE OF AIR MONITORING ACTION LEVELS G-3-4

SECTION 4 EMERGENCY PREVENTION G-4-1

4.1 PREVENTION G-4-1

4.2 PREVENTATIVE MAINTENANCE G-4-1

4.3 HOUSEKEEPING PROGRAM G-4-1

PARSONS ENGINEERING SCIENCE, INC. PARESSYROI \VOL 1 :\\PARESSYRO 1WOL1 \USERS\40030\PPLSED\FINALWP\32412R3F.DOC DECEMBER 3, 1997 G-i

AR400943 4.4 SECURITY G-4-1

4.5 EMPLOYEE TRAINING PROGRAM G-4-2

SECTION 5 EMERGENCY EQUIPMENT G-5-1

LIST OF TABLES

Table 2.1 Emergency Contacts G-2-3

PARSONS ENGINEERING SCIENCE, INC. PARESSYR01WOL1:\\PARESSYROI\VOL1\USERS\40030\PPLSED\FINALWP\32412R3F.DOC DECEMBER 3, 1997 G-ii

AR400944 SECTION 1

INTRODUCTION

1.2 PLAN OBJECTIVES This Contingency Plan is intended to define the procedures to follow in the event of an emergency during sediment remediation at the former UGI Columbia gas plant site. The plan includes the following information:

• Emergency coordination, including emergency contacts and reporting (Section 2);

• Emergency procedures (Section 3);

i • Emergency prevention (Section 4); and

• Emergency equipment (Section 5).

A copy of the Contingency Plan will be conspicuously posted in the project office trailer for the duration of the project.

PARSONS ENGINEERING SCIENCE, INC.

PARESS YRO1YVOL1 :\\PARESS YRO1YVOL1 \USERS\4003 0\PPLSED\FINALWP\32412R3 F. DOC DECEMBERS, 1997 G-l-1

AR400945 SECTION 2

EMERGENCY COORDINATION

2.1 EMERGENCY ORGANIZATION The OHM site superintendent will serve as the emergency coordinator for the project. The site superintendent has both the authority and responsibility to implement the necessary actions in the event of an emergency. In the absence of the site superintendent, the site Health and Safety Officer (HSO) will act as the emergency coordinator.

2.2 RESPONSIBILITIES OF THE EMERGENCY COORDINATOR The emergency coordinator will be responsible for implementing the necessary actions in the event of an emergency. The emergency coordinator will be thoroughly familiar with all aspects of the work plan, all operations and activities, the location and characteristics of all materials handled, the location of all records and the site layout. The responsibilities of the emergency coordinator will include: • Identifying all handled wastes and materials; • Keeping an updated inventory of all handled wastes and materials; • Identifying potential spill sources; • Conducting visual inspections; • Contingency Plan implementation; • Coordination of spill cleanup activities; and • Notification of authorities when necessary. In the event of a spill, fire, explosion, or other emergency, the emergency coordinator must assess the situation and quickly determine the best manner in which to proceed. The emergency coordinator must take all reasonable measures necessary to prevent the recurrence, continuance or spread of the emergency situation.

2.3 EMERGENCY RESPONSE In the event of a spill, fire, explosion, or other emergency, the emergency coordinator will immediately notify the applicable authorities as listed in Table 2.1. The following information will be reported as applicable: 1. Name of the person reporting the incident. 2. Name and location of the facility or waste transporter. 3. Phone number where the person reporting the spill can be reached. 4. Date, time and location of the incident.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOL1:\\PARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\32412R3F.DOC DECEMBERS, 1997 G-2-1 AR400946 5. A brief description of the incident, nature of the materials of wastes involved, extent of any injuries and possible hazards to human health or the environment. 6. The estimated quantity of the materials or wastes spilled and the shipping name, hazard class and U.N. number of the waste. 7. The extent of contamination of land, water, or air, if known. 8. The name and identification of the waste generator.

Within 15 days after the incident, the emergency coordinator must submit a written report on the incident to PADEP. The report must include the following: 1. Name, address and telephone number of the individual filing the report. 2. Name, address and telephone number of the facility. 3. Date, time and location of the incident. 4. Brief description of the circumstances causing the accident. 5. Description and estimated quantity by weight or volume of materials or wastes involved. 6. Assessment of any contamination of land, water or air that has occurred as a result of the incident. 7. Estimated quantity and disposition of recovered materials or wastes that resulted from the incident. 8. Description of what actions will be taken to prevent a similar occurrence in the future.

Additionally, if a spill occurs during transportation of waste, a spill report will be submitted to the Directors Office of Hazardous Materials Registration, Materials Transportation, Washington, D.C., 10590.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOL1:\\PARESSYR01\VOL1\USERS\40030\PPLSED\FIN ALWP\324I2R3F.DOC DECEMBERS, 1997 G-2-2 AR400947 Table 2.1 Emergency Contacts

ORGANIZATION CONTACT PERSON/PHONE NUMBER

FIRE 911 POLICE 911 AMBULANCE: 911

Capable of transporting contaminated personnel? Yes: X No: HOSPITAL: Columbia Hospital 631 Poplar Road Columbia, PA 17512

Chemical trauma capabilities? Yes: X No: Decontamination capabilities? Yes: X No: Directions from site to hospital: Exit site on Front St. At Locust St., take right to 3r(^ light (about 4 blocks); this intersection is Locust and Fifth. Take left, and go 3 blocks to watch tower and take a right. Go to stop sign. Hospital is on the left

CROZER-CHESTER MEDICAL BURN CENTER (610)447-2000 POISON CONTROL CENTER (215)433-3211 CENTER FOR DISEASE CONTROL (404) 488-4100 (24-hour line) ELECTRIC COMPANY: PP&L (800) 342-5775 Metropolitan Edison (800) 545-7750 PP&L EMERGENCY HOTLINE (610)774-5566 GAS COMPANY: Columbia Gas Transmission Corp. (717)529-2248 WATER COMPANY: Columbia Water Company (717)684-2188 AIRPORT: Lancaster Airport (717)569-1221 NATIONAL EMERGENCY RESPONSE CENTER (800) 424-8802 AT&F (explosion information) (800) 424-9555 CHEMTREC (800) 424-9300 STATE ENVIRONMENTAL AGENCY: PADEP Anthony Martinelli (717)657-4592 STATE EMERGENCY RESPONSE NUMBER (800)812-3782 Pennsylvania Emergency Management Agency (PEMA) (717) 783-5082 USEPA REGION III Steven Donohue (215)566-3215 USEPA REGION III Pennsylvania Spill Reporting No. (215)566-3255 OHM PROJECT MANAGER Michael Evanko (609)588-6382 OHM CORPORATE HEALTH AND SAFETY Robert Brooks (609) 588-6423 OHM SITE SUPERINTENDENT Mark Friar To Be Determined PORTADAM Don Boyer (609)561-7900 CLIENT CONTACT (PP&L) James F. Villaume (610)774-5094 CLEAN SITES CONTACT Scott Miller (703) 519-2140 (office) / (717) 684-1619 (site)

PARSONS ENGINEERING SCIENCE, INC.

J :\PPLSED\FIN ALWP\32412R3F.DOC DECEMBER 11, 1997 G-2-3 AR400948 SECTION 3

EMERGENCY PROCEDURES

This section contains procedures to be followed in the event of a spill, fire, explosion or other emergency.

3.1 EVACUATION PLAN If the emergency coordinator determines that evacuation of the site is necessary , the procedures to be followed are:

1. Site personnel will be immediately alerted of potential problems. An alarm system, such as three long blasts from an air horn, will be established, documented, and reviewed with site personnel prior to beginning work at the site.

2. Site equipment will be shut down.

3. Site personnel will proceed to the contaminant reduction zone, then to the support zone.

4. Appropriate emergency response agencies will be notified (Section 2).

3.2 ONSITE PERSONAL INJURY 1. Provide first aid for minor injury.

2. Notify ambulance and/or hospital.

3. Notify PP&L and CSES.

4. Document accident.

3.3 FIRE OR EXPLOSION 1. Extinguish immediately (if small fire).

2. Isolate area and remove personnel.

3. Notify fire department.

4. Notify PP&L and CSES.

5. Record incident.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOLl:\\PARESSYR01\VOLt\USERS\40030\PPLSED\FIN ALWP\32412R3F.DOC DECEMBERS, 1997

G-3-1 AR400949 ORIGINAL (Pad)

3.4 SEDIMENT RELEASE IN RTVER Storm events may potentially occur that could cause overtopping or failure of the Port-A- Dam and the release of sediment or excessive turbidity to the Susquehanna River. The procedures to be followed are:

1. Suspend site operations.

2. Isolate or control the sediment release or turbidity production area, if possible. Possible methods included additional sandbagging, temporary tarps or sheeting, and additional pumps.

3. Notify Portadam immediately for emergency repairs.

4. Notify PADEP, PP&L and CSES.

5. Evaluate and implement mitigation procedures.

3.5 SEDIMENT SPILL Sediment spills may potentially occur onsite during excavation, loading, or transportation or offsite during transportation to the disposal facility. The procedures to be followed are:

1. Isolate the spill area. Work in onsite spill areas will immediately be stopped to prevent the spread of contaminated sediment. Temporary fencing will be used to prevent truck, equipment and personnel access through the spill area. Offsite spills during material transport will be cleaned up by OHM and will likely require the assistance of emergency response personnel to control traffic and assist with the cleanup.

2. Notify PADEP, PP&L, CSES, and other authorities, as needed.

3. Clean up the spill. Spills, both onsite and offsite, will be cleaned up immediately following a spill.

3.6 WASTEWATER SPILL Wastewater spills, including spills of decontamination water and untested treated water, will be mitigated as follows:

1. Determine cause of spill or leak.

2. Shut off pumps, close valves and transfer stored wastewater as necessary to prevent further spillage.

3. Contain spilled wastewater onsite as much as practical to prevent discharge to the Susquehanna River.

4. Notify PADEP, PP&L and CSES if discharges occur to Susquehanna River.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOL1:J:\PPLSED\FINALWP\32412R3F.DOC DECEMBER 11, 1997 G-3-2 AR400950 5. Repair leak or source of spill.

6. Clean up spilled wastewater and contaminated soil, if any.

3.7 WASTEWATER TREATMENT SYSTEM DOES NOT MEET DISCHARGE LIMITS 1. Evaluate reasons why discharge limits were not met.

• 2. Adjust treatment plant operation or system as needed.

3. Re-treat wastewater.

4. Re-test treated wastewater.

If discharge limits continue to be exceeded:

5. Notify PADEP, PP&L and CSES.

6. Evaluate wastewater disposal options.

7. Implement remedial action plan.

3.8 EXCEEDANCE OF AIR MONITORING ACTION LEVELS 1. Suspend or adjust site operations to minimize contaminant levels. Dust or odors may be controlled by the use of water, tarps, foams or other methods, as applicable.

2. Upgrade personal protective equipment level.

3. Notify PADEP, PP&L and CSES.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYRO1WOL1 :\\PARESSYR01\VOL ] \USERS\40030\PPLSED\FINALWP\32412R3F.DOC DECEMBERS, 1997 G-3-3 AR400951 SECTION 4

EMERGENCY PREVENTION

4.1 PREVENTION As a preventative measure, the site superintendent will make frequent visual observations of storage tanks, pipes, hoses, loading and unloading areas waste, handling areas and storage areas. Also, the site superintendent will make a daily inspection of: • pipes, pumps, valves, fittings, and tanks for leaks; • areas around tanks for evidence of spilled materials; • housekeeping practices; • chemical containers for damage; • integrity of erosion control fences; • waste storage, treatment, or disposal sites for leaks, seeps, and overflows; and • emergency equipment.

4.2 PREVENTATIVE MAINTENANCE The site superintendent will immediately repair, adjust, or replace equipment showing signs of potential failure. All equipment will be properly maintained as serviced on a regular basis in accordance with the manufacturer's recommendations.

4.3 HOUSEKEEPING PROGRAM Due to the deficiency of open space and the proximity of site features, improperly or precariously placed materials may be unsafe to site personnel or may obstruct evacuation routes. The site superintendent is responsible for keeping materials in their proper locations and, in general, maintaining site order and cleanliness. In addition, the site will be kept free from obstructions, trash, and debris.

4.4 SECURITY Access to the sediment removal area will be restricted to persons having read the site- specific Health and Safety Plan and having attended a safety indoctrination meeting. Signs will be posted at the entrance to the site, stating, "DANGER - AUTHORIZED PERSONNEL ONLY - PROTECTIVE EQUIPMENT REQUIRED BEYOND THIS POINT." Access to the work area will be limited to personnel who must perform specific tasks within the site. Visitors will be escorted by OHM site personnel.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOL1:\\P ARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\324I2R3F.DOC DECEMBERS, 1997 G-4-1 AR400952 L The site will be kept secure by a combination of existing and temporary fencing. Whenever personnel are to be absent from the site for extended periods or overnight, the site superintendent will secure the site by closing the temporary fencing.

The site superintendent will verify that every person entering the exclusion zone has read and signed the site-specific Health and Safety Plan and familiarized themselves with all potential hazards associated with the site. Also, the individuals must have successfully completed an OSHA 40-hour training course to be allowed into the exclusion zone. No person may enter the exclusion zone without the site superintendent's knowledge and authorization.

"" 4.5 EMPLOYEE TRAINING PROGRAM An initial safety meeting and training session, as outlined in the site Health and Safety Plan, "** will be attended by all employees working at the site involved with the remedial action. The meeting will be run by the OHM safety officer or the site superintendent and will address pertinent issues associated with the remediation and the Health and Safety Plan. The following "\^ items will be covered:

. , • hazards associated with coal tar; **' • dangers and indications of cold stress;

** • dangers and indications of heat stress;

• location of hospital and maps to hospital;

• location of emergency contact names and phone numbers; v* • location of first aid kit and its contents;

• proper dress and personal protective equipment required for onsite work;

• dangers associated with working around railroad tracks and trains;

' • dangers associated with working around heavy equipment;

• decontamination procedures;

• water treatment system operation;

• component maintenance;

~ • contingency procedures; and

"""" • spill response procedures.

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01\VOL1:\\P ARESSYR01WOL1\USERS\40030\PPLSED\FINALWP\32412R3F.DOC DECEMBERS, 1997 G-4-2 AR400953 SECTION 5

EMERGENCY EQUIPMENT

The following is a list of emergency equipment to be available to site personnel for use in the event of an emergency. The equipment will be kept in the temporary office trailer or tool trailers located in the support zone.

Equipment Purpose

Fire extinguishers Extinguish small type A, B, and C fires to? First aid kits Perform first aid for minor injuries

Emergency eye wash station Clean chemicals or foreign objects from eyes

Air horn Notify site personnel of emergency situations

Absorbent pads and booms Absorb and contain spilled liquids

Extra silt fence Contain areas of erosion

Personal protective equipment Protection of site personnel (gloves, tyveks, safety glasses, etc.)

PARSONS ENGINEERING SCIENCE, INC.

PARESSYR01WOL1A\PARESSYR01\VOL1\USERS\40030\PPLSED\FINALWP\324J2R3F.DOC DECEMBERS, 1997 G-5-1

AR400954 APPENDIXH R3 TECHNOLOGIES AUDIT

AR400955 11/21/97 FRI 16:18 FAX 703 519 2141 CLEAN SITES ENV SERVICES i°02

L . O.MN SITES ENVIRONMENTAL SERVICES, (NC.

November 20, 1997

^ Mr. James Villaume Pennsylvania Power and Light Co. Two North Ninth Street Allentown, PA 18101-1179 in* Subject: Removal and Disposal of Sediments Associated with the Former UGI Columbia Gas Plant Site located in Columbia, Pennsylvania Audit of Disposal Facility - R3 Technologies, Inc.

Dear Mr. Viilaume:

^ Clean Sites Environmental Services, Inc. (CSES) is pleased to have audited the above referenced disposal facility on the behalf of Pennsylvania Power and Light (PP&L) and present our findings. Mr. Miller and Mr. Gillespie conducted the audit on November 11, 1997. They met with Mr. Mehesh Amln, the facility chemist and toured the support facilities, warehouse and process areas of the plant. Despite the numerous N. comments by CSES, we recommend the use of this facility due to its ability to process river sediment laced ^""^ with cobbles, and because of relative cost effectiveness.

CSES reviewed the latest Commonwealth of Pennsylvania, Department of Environmental Resources *~ (PADEP), Bureau of Waste Management Inspection Report — Residual Waste Incinerators and Other Processing Facilities, dated July 17, 1997, enclosed. R3 Technologies, Inc. (R3) passed the routine inspection without being cited for any violations. However in the narrative on page 4 it was noted that the .•wrf crusher was not operating, pending a permit modification. In a subsequent telephone conversation with Mr. Brown he Stated that the PADEP required the. r:nish«r be permitted as process equipment ac they generate dust and particulate matter. The crusher at R3 is inside its negative air warehouse. This issue has been resolved according to Mr. Brown. CSES will confirm this with PADEP. ** CSES's summary of the plant features:

1. Location:

#7 Steel Road East Latitude -40°, 10', 45" USX Industrial Park (off New Ford Mill Road) Longitude -74°, 45', 55" Falls Township (Morrisville (across from Trenton, NJ)), ^•"•^ Bucks County, Pennsylvania

2. Facility Contacts:

Robert "Bob" V. Brown Mahesh Am in Sales and Marketing Manager Laboratory Manager

-" (215)428-1700 1-800-762-3649 Fax: 1704

3. PADEP Permits:

""" » Residual Waste Processing (#301254). applied for December I, 1995, issued May 9, 1996, expires March 15, 2004 (enclosed):

'^t Permitted materials for processing: soil and/or aggregates contaminated with virgin petroleum hydrocarbons, No. 5 fuel oil, No. 6 fuel oil, crude oil, lubricating oil, asphalt, asphalt roofing material, greases, tar (asphalt, petroleum, coal), oxygenated hydrocarbons (alcohols, ethers, organic acids and ethylene glycol), and non-virgin coal or petroleum >~- hydrocarbons excluding radioactive, explosive, toxic or hazardous contaminants.

Cl£AN SITES €NV|RONMENTAL_5£RVIC£S, INC * 635 SL ATEJ*S_l AN = , SUJJJ J 30 •• ALEXANO FU A. VIRG1NIA 22 3 H * TEL: (705] 5 I 9-2 140 * FAX: (703) 519-71

AR400956 12)003 CLEAN SITES ENV SERVICES 11/21/97 FRI 16:18 FAX 703 519 2141

The re-issued permit allows for the acceptance of incinerator ash and sewage sludge incinerator ash to make recycled aggregates or hot mix asphalt and utilization of sewage sludge filter cake to cool thermally remediated contaminated soil.

R3 is permitted to process up to 2,000 tons of material per day. Its maximum theoretical 24-hour capacity is 2,280 tons per day. However it was CSES's impression that the plant maximum capacity is greatly reduced by the configuration of the warehouse and reliance on front-end loaders to move material. The facility chemist stated the plant's maximum capacity was closer to 1,000 to 1,100 tons per day. CSES believes the plant, due to its relative newness and lack of demand, operates only eight to ten hours per day. The plant runs soils and aggregate separately whenever possible, as the aggregate requires less time to process.

In a subsequent telephone conversation with Mr. Brown he stated that the plant expects to process between 125,000 to 150,000 tons of material during 1997. This averages to 300 to 400 tons per day. The plant processes material at approximately 100 tons per hour. The plant doesn't run but a few days per week. It takes 45 minutes to heat the kiln up to operational temperatures. The plant is called a "super insulation system" as the entire processing plant is insulated and the primary processing equipment is double insulated. During periods when the plant is not in operation the exhaust from the plant is run through a carbon unit at the rear of the facility,

• Water Quality Management (#0993205), issued March 15, 1994, amendment issued February 8, 1996, expires March 15, 1999 (enclosed).

The facility is authorized to use seepage beds.

• Air Quality Plan Approval (#09-330-011), Plan Approval Extension dated July 18, 1997, expires November 18, 1997 (enclosed). Mr. Brown will send CSES a copy of the next extension when R3 receives it from PADEP. Mr. Brown stated that these extensions are a stopgap measure by PADEP since it takes them years to amend an air quality permit. He further stated that these extensions are for six-month periods and are usually not delivered to R3 until the day prior to the expiration of the previous extension.

The warehouse doors were alt open (nearly empty, with a small pile of pond dredging material and hay bales at 57 % moisture content) and was not under "negative air" during the CSES site visit. This feature was not discussed during the tour, but is mentioned in the news brief, enclosed.

ALr cleaning devices associated with the process equipment: 2 High Efficiency Cyclones, I Afterburner, and 1 Baghouse. Of note is that the bags are not replaced in the Baghouse unless damaged by heat. The dust is drawn down the bag filters and collected in hoppers at the bottom of the Baghouse. Other process areas that generate dust, collect the dust and reroute the dust back into the pugmill where the hot soil and aggregates are mixed and cooled via water spray.

4. R3 issues a state approved "Certificate of Destruction". Mr. Brown noted that some of the larger corporations like to send their processed material to Waste Management's Grows Landfill as clean cover material. By doing so the companies receive Waste Management indemnification.

5. R3 is currently producing certified (PADER & PENNDOT Level A) clean fill material or mixing it with loam to produce manmade topsoil. R3 tests processed soils for TPH once every 50 tons generated.

6. Soil Remediation Process:

AR400957 11/21/97 FBI 16:19 FAX 703 519 2141 CLEAN SITES EOT SERVICES

• Testing: The table for Maximum Contamination Concentrations for Incoming Soils is enclosed. R3 tests incoming materials contaminated with Jars once during the first 900 tons for Total Metals, PCB's, Ignitability, Corrosivity, Reactivity, and Radioactivity. In the company literature R3 tests for TOX and TPH three times for waste streams up to 525 tons. However the chemist stated he tests for TPH once every 50 tons per waste stream. • R3 can separate the waste stream in one of its six bays within its 42,000-square-foot warehouse. Mr, Brown stated that the warehouse has a capacity to hold 25,000 tons, should a mechanical failure prevent or delay processing the materials. R3 keeps like contaminated materials together unless otherwise requested to treat a waste stream separately. Prior to processing, waste streams could be mixed together to produce moisture contents that are more easily treated. R3 removes the plastic liners for disposal at Waste Management's nearby Grows Landfill. • The stockpiled material is taken to the crusher by a front-end loader. Any stones or concrete smaller than 1 C.Y. can be crushed to at least 3 % inches. R3 is very proud of its Yonkers Contractors Crusher. • The crushed material is loaded into another hopper by another front-end loader. The material is taken via conveyor belt to be dropped into a 3 inch, high velocity screen. Anything larger than 2 3/4 inches is screened out and run back through the crusher. • Material passing the screen is taken out of the warehouse via a second conveyor. This conveyor drops the material on a third conveyor that drops the material into a relatively small rotary dryer or drum (kiln) for volatilization. Contaminates and gases are destroyed with a direct-fired burner reaching temperatures between 500-1200 DF. • The soil and aggregate is run through a pugmill and sprayed with water to cool the material and restore some of its moisture content and for dust control. This final product is dropped into a stockpile by a fourth conveyor. It is taken to a larger stockpile area via a third front-end loader. • Remaining gases from the kiln passes through the Cyclones and is converted to carbon dioxide and water vapor by thermal oxidation at temperatures reaching up (o 1800 DF. • The gases are cooled by water spray and sucked through the Baghouse unit and exhausted to the atmosphere.

CSES's facility inspection noted the following concerns:

Cross Contamination:

1. Din from facility entrance was accumulated across the cul-de-sac. 2. Material bouncing or falling off conveyor belts, contaminating areas from loading hopper (contaminated interior area) to rotary kiln (non-contaminated exterior area). 3. Only one entrance/exit to the plant. Single scale house at entrance services all trucks clean or dirty. 4. No signs directing truck drivers not to uncover their loads until inside the (negative air) warehouse. 5. No barriers directing incoming loads into the warehouse area. 6. No barriers preventing incoming loads from dumping load into already processed material stockpiles or other clean areas of the plant yard. 7. There were no barriers preventing front-end loaders in the warehouse from entering and working in the "clean" areas of the plant yard. 8. Laborers had two of their personal privately owned vehicles inside the plant yard. 9. Entrance floor into the scale room, laborers bathroom, and laboratory was dirty. 10. There was no apparent decontamination area.

Safety:

1. No hearing protection signs posted around noisy process equipment. 2. Material bouncing or falling off conveyor belts, without overhead protection for workers. 3. Limited warning signs associated with hot process equipment. 4. Laborers smoking cigarettes in the plant yard or while operating equipment. 5. Two large front-end loaders operating inside the large, shadowy warehouse could easily back over persons on the ground.

AR400958 11/21/97 FRI 16:20 FAX 703 519 2141 CLEAN SITES ENV SERVICES i">05

Other Potential Impacts/Problems:

1. Due to the fine nature of the processed soil, it has a large surface area and mixes readily with water to form fine, silty mud slurry that could cause NPDES permit compliance problems. CSES did not observe or ask to observe the seepage beds. 2. On the PADEP inspection list the inspector checked that R3 had an alternate facility available during temporary shutdown. Mr. Brown stated that this was not the case and as mentioned previously the warehouse can store up to 25,000 tons should the plant be temporarily shut down. R3 is required to maintain a bond with the PADEP for the cost of treating of 25,000 tons of material at a like facility should the PADEP ever shut R3 down for whatever reason. 3. Liability Insurance expires 3/1/98. However CSES has enclosed a copy that is marked "sample". The facility has been in operation approximately 2 1A years. The large six bay warehouse was mostly empty. The yard contained approximately 25,000 tons of processed soils. The question of financial stability could be a hidden issue. However Mr. Brown stated that R3 is owned by the largest privately owned construction company on the cast coast (Yonkers).

Despite the numerous comments CSES has presented above, CSES recommends the use of this facility due to the nature of the waste stream that will be generated by the Sediment Removal Project. Should you require addition information or have any questions concerning this audit please feel free to telephone me at (703) 519-2135, Scott Miller at (717) 684-1619, or John Gillespie at (703) 519-2138.

. Ammon, P.E. Preside^ CSES, Inc.

Enclosures (7) 1. PADEP - Bureau of Waste Management- Inspection Report 2. Excerpts: PADEP - Bureau of Waste Management - Permit for Solid Waste Processing Facility (5/9/96) 3. Excerpts: PADEP - Water Quality Management Permit (2/8/96) 4. Excerpts: PADEP - Field Ops, Bureau of Air Quality - Plan Approval, (7/18/97) 5. R3 Tech News Brief 6. Maximum Contamination Concentrations for Incoming Soils 7. Certificate of Insurance

JMG cc: Scott Miller, P.E. John M. Gillespie File

AR400959 11/21/97 FRI 16:21 FAX 703 519 2141 CLEAN SITES ENV SERVICES

2500-FM-WM0402 Rev. 3/95 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES BUREAU OF WASTE MANAGEMENT INSPECTION REPORT- RESIDUAL WASTE INCINERATORS AND OTHER PROCESSING FACILITIES

Site 1.0. *,/) 1 of*? T Telephone # ( af/^/ r ^^ —/ /&& Site Name J\ "3 J ffjjflJl/',rtlC-t Operator Name Address ~~7 $+ee/. R f •s ^if Address — A/1 fifr /<••>/>// ' > ?A le70G'7 Municipality fi^sf // < it**/} County •£ ti £K c Responsible Official pruj^* _/)/ fci&H cent 2 Title A/^^^f/n^^ Person Interviewed M#lrs<;h /-l^hJ^ Title u^Vn~/ // Inspector (.^ rh -fr/LT0/*r, Time //^ •" *fy) or t~*i Due Date Inspection Date Inspection Type Facility Type Inspector ID # Violation ^/?A/

1-No Violation Observed 2-Not-Applicable 3:Not-Determined 4-Non-Compliance STATUS Requirement CHAPTER LINE 1 2 3 4 CITATION ITEM GENERAL PROVISIONS K Facility issued permit from the Department. 297.201(a) 400* Y Operation in accordance with approved plans and permit 297.20 1(b) 401 7=> No unapproved wastes accepted. 297.201 (c),(e) 402* Ban on explosive waste and mixing or storing waste to create a risk of fire, 297.20 1(d) 403 X explosion, or hazardous gas adhered to. Inspection of loads, maintains records, reports changes to waste analysis 297.203(a)-(c) 404 plans. DAILY OPERATIONS * (k Proper signs posted. 297.211(a} 405 >< Permit area markers and site perimeter dearly marked and maintained. 297.211 (b)-(c) 406 x: Proper barriers installed and access controlled when attendant not present 297.21 2(a)-{c) 407 Access road maintained in accordance with Chapter 105 and 283. and 297.21 3(a}-(h} 408 < negotiable by collection vehicles. X Approved means of measuring waste utilized. 297.214(a),(b) 409 Adequate equipment on-site and standby equipment available. 297.2 15(a)-(d) 410 ^A Approach and unloading areas of adequate size, design and construction. 297.21 6(a),(b) 411 X Wheel curb and tie downs at unloading pits. 297.2 16(c) 412 >< Attendant or signs to direct vehicles. 297.216(d) 413 X Collection vehicles promptly unloaded. 297.21 6(e) 414 X Solid waste confined to unloading and approved storage areas. 297.21 6(f) 415 Areas within building kept clean 297.21 7(3), (b), 416 (d), (e) . ^

•'Page 1 of V AR400960 1007 11/21/97 FRI 16:22 FAX 703 519 2141 CLEAN SITES ENV SERVICES

•' 2500-TM-WMC402 Rev. 3/95 COMMONWEALTH OF PENNSYLVANIA Site Name A ' ,'' DEPARTMENT OF ENVIRONMENTAL RESOURCES BUREAU OF WASTE MANAGEMENT ID Number ?f> Date 7//7/f7 INSPECTION REPORT- RESIDUAL WASTE INCINERATORS AND OTHER PROCESSING FACILITIES (Cont'd) 1-No Violation Observed 2-Not-Applicafale 3-Not-Determined 4-Non-Compliance STATUS CHAPTER LINE 1 2 3 4 .. CfTATlON ITEM Plumbing properly maintained, floors wefl drained. 297.2 17(c) 417 X* Dally inspection conducted. 297.2 17(f) 418 X No open burning (*) or other fugitive dust emissions. 297.21 8(a),(c) 419* x Ambient air quality maintained. 297.21 8(b) 420 tf Effective vector control implemented and public nuisances prevented. 297.21 9(a),(b) 421 K Salvaging in accordance with regulations. 297.220(a). (b) 422 Utter controlled/collected and barriers/fences in place 297.22 1(a>-(c) 423 * SOIL AND WATER PROTECTION Surface water (*), groundwater (*}, and soil discharges prevented unless 297.23 1(a),(b), 424* otherwise authorized by the Department. (d), 427 % sedimentation. X Soil and groundwater monitoring conducted as required. 297.233 428 X Restoration of water supply adversely affected by operator. 297.234(a)-(c) 429 SAFETY AND OPERATIONS X Operational safety plan on-site and implemented. 297.241 (a)-(c) 430 Facility ventilated in a manner consistent with Section 297.218 (relating to air 297.241 (d) 431 X resources protection). At least one set of up-to-date as-buiit construction drawings and up-to-date 297,242

Facility operated and maintained to prevent and minimize potential for fire, 297.251 433 X explosion, or environmental release. X Internal communication or alarm system operable. 297.252(a)<1) 434 Communications systems capable of summoning emergency assistance from 297.252(a)(2) 435 r outside agencies. Adequate fire and safety equipment available, maintained and accessible. 297.252(a)(3), 436 x (c), (d> / Contingency plan implemented in emergency. 297.253(a)-(c) 437

Page 2 of <•/

AR400961 11/21/97 FRI 16:23 FAX 703 519 2141 CLEAN SITES ENV SERVICES

' 7SCO-FM-WMM02 Rev! 3/95 COMMONWEALTH OF PENNSYLVANIA Site Name _A ? 7* s /,*„./,, DEPARTMENT Of ENVIRONMENTAL RESOURCES BUREAU Of WASTE MANAGEMENT ID Number ___ Date "7/X 7/f 7 INSPECTION REPORT- RESIDUAL WASTE INCINERATORS AND OTHER PROCESSING FACILITIES (Cont'd) 1-No Violation Observed 2-Not-Applicable 3-Not-Oetermined 4-Non-Compliance STATUS CHAPTER RECORDKEEPING/REPORTING LINE 1 2 3 4 CITATION ITEM Daily and annual operational records maintained, available and submitted as 297.26 1(a)-{c) 438 X required. 297.262(a)-(c) tf Alternate facility available during temporary shutdown. 297.271(a},

UNPERMITTED FACILITIES (UNTIL PERMITTED) No new wastes processed after Juiy 4, 1992. 287.1 14(c)(1) 445 No expansion of capacity after July 4, 1 992. 287.114(c)(4) 448 PERMITTED FACILITIES (until repermitted after July 4, 1992). No increase in average daily volume beyond that which existed as of July 4, 287.1 16(c)(3) 452 X 1992 (unless authorized in writing from the Department) No change in the method or technology used to process waste from that 287.116(0(4) 453 >c which was employed on July 4, 1992 (unless authorized in writing from the Department.)

.Page 3 of_

AR400962 @]009 11/21/97 FRI 16:24 FAX 703 519 2141 CLEAN SITES E.NV SERVICES

ER-WM-12S: Rtv. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF LAND RECYCLING AND WASTE MANAGEMENT

INSPECTION REPORT COMMENTS Data of inspection "7//7/V 7 Identification Number Company/Facllfty/SJte Name A 1 Tr cL u? JrtrtJ &•/•<&{ /f 7 ft Y - ;*r,t£h >- ;.x. C s/t/<-* , A '

.„. r r // Si >\< _ •j,f/t>* ,^,- STJ r r-/ / h ^ . l—i - / ^ rt -b '.c *-.. ZL •y/-/ 7•/ £>. *•& /' / /> r l t; r n / tx/

Th«t inspection report is notice of the findings of an inspection c*x*ducted by a representative of m« Department. This report is formal notification of any violations observed during the inspection. Additional notification of violations may be issued concerning either violations noted h*r»in, or other violations identified as * result of review of laboratory anafys« or Department records. This report does not constitute an order or other appealaWe action of the Department Nothing contained herein shall be deemed to grant or impry immunity from legal action for any. viotetion noted herein. Signature by the person interviewed does not necessariry impry concurrence wrth the findings on this report, but does acknowledge that the person was shown the report or that a copy was left with the person.

{rrUrvf«w«C: («ignatunt)_ D.U 9//?/?y lrwp«ctor (• Dat«

Page of AR400963 10 11/21/97 FRI 16:24 FAX 703 519 2141 CLEAN SITES ENV SERVICES . f t_| , , t lt_»XO«l^?

R3 Technologies, Inc. 7 Steel Road East NEWS BRIEF P.O. Box 847 MorrfsvUle, PA 19067-0847 Phone: 215.428.1700 Toll Free: 800.762.3649 Fix: 2)5.428.1704

R3 TECHNOLOGIES UPDATE

FALLS TOWNSHIP, PA..PADEP Residual Waste Processing (#301254), Water Quality Management (#0993205), and Air Quality Plan Approval (#09-330-011) permits have been issued for state-of-the-art R3 Technologies, located in Falls Township, Bucks County, Pennsylvania.

The facility thermally remediates, recycles and beneficially reuses non-hazardous residual waste materials such as petroleum contaminated soils and aggregates and waste-to-energy plant residue. After processing, a "Certificate of Destruction and Release of Liability" is provided for the remediated material which is accepted for use in R3*s recycling process or'sold as certified clean fill (PADEP Quality A). Segregated storage, processing and indemnification certificates are also available. The plant will also process inert recyclables such as ground up old tires, crushed glass, rubber products, plastics, roofing shingles, worn out asphalt and concrete to produce recycled hot mix asphalt pavements.

All unloading, storage, and feed operations are conducted within an enclosed building under negative air. R3 Technologies handles materials in a safe, clean manner with no adverse affect on and/or exceed PADEP and PENNDOT quality standards for environmental and structure integrity.

The new facility is conveniently located at #7 Steel Road East in the USX Industrial Park off New Ford Mill Road in Falls Township, Morrisville, Pennsylvania. For information on processing of non-hazardous petroleum contaminated soils, contact Bob Brown, Sales and Marketing Manager of R3 Technologies, Inc., at 1-215-428-1700.

AR400964 11/21/97 FRI 16:25 FAX 703 519 2141 CLEAN SITES ENV SERVICES 1)011

'IHI!; d-WMlUt!' ftl'iSSUbP 'AJ>" A UAllfcH OFJflpaWMIRW ONLV CONFERS NO WCHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE Ain«d Cov«r*s> Corp. DOES NOT AMEND, EXTEND Oft ALTER THE COVERAGE AFFORDED BY THE 390 North Bro«dwiy POLICIES BELOW. J.rJcho, NY 11753 COMPANIES AFFORDING COVERAGE

616-733-9200 IEJ1ER St.. Paul Fir« ft Marine Ins Co

CO>PAW 0 thlltH D

R3 T«chrtologf« Inc. (PA) COWW LEIIER 7 St««l Re«d East MorrlsvllJ«

PA 1S006-7 p. lEtTBl E etm

THS IS T O CERTIFY THAT THE POLICES OF NSUR ANCE LSTEO BELOW HAVE SEEN ISSUED TO THE NSUREO NAMED ABOVE FOR THE PQUCY PERIOD NCXCATED. NOTWITHSTANDING ANY RECttJWEMENT. TERROR CONCSTONOF ANY CONTRACT OB OTHER DOCUMENT WITHRESPECT TO WHO) THIS CERTFCATE MAY BE ISSUED OR MAY PERTAIN. THE NSURANCE AFrORDEO BY THE POLlOES DESCnfiED HEREN IS SUBJECT TO ALL THE TEPMS. EXCLUSIONS AND CONOtTtONS OF SUCH POUCES. LMTS SHOWNMAY HAVE BEEN REDUCED BY PAO CLAMS.

KXJOt NUMBER WXJOYOTICTIW UMirs

2.000.000 UlBlUtY 4/01/97 4/01/S8 1 .000.000 X 1 OCDK. GENERAL AGGREGATE KRSOW. 4 ACT. INJUW 1.000.000 OWtR'S «. CONtI!ACTDR-S PHOT. APPLIES PER PROJECT JACK _1. OOP,000 C»»y gut firt) 100.000 fXftfCt W«v one ocfton s.ooo OMSIWB BNGU IIMI! AW AUTO KK02900029 4/01/97 4/01/98 .000,000 AII owwo AUTO: (fer AUTOS

W^Mn«Nto AUTOS IPu Kd

SMUtt UASIHTY DAMAGE

EACH OOMBKNCt 25.000.000 fORM KK0290Q023 4/01/97 4/01/98 * 25 .000.000 OTWR THAN IM6RE1LA

OOMPOfltATJON WVK2S0012Q 4/01/97 4/01/98 EACH AMD * 1.000.000

OTHER Pol l ion KCQ2S00081 3/01/97 3/01/9Q 1,000,000 Lt. Lt«fa) I ity Occ/Agg 100.000 Deduct ible OCSC*»TK»4 Of OraMTIOSCflOCMIOtaSVtHKXCStO'ecfM. (TCMC Verification of lnsur«nc«

|| SHOULD ANV OF THE ABOVEDESCRIBED POLICES BE CANCELLED BEFORE THE S^ EXPIRATION DATE THEREOF. THE ISSUtNQ COMPANY Wtt.L ENOEAVOR TO :0j MAO. 60 DAYSWBITTENNOTICETOTHECERT1F1CATEHOLDERNAMEDTOTHE SflMPLt p (.err. OUT PAH.UHC TO WA«. cua-i NOTICE SHAU. MOOCC NO OOLICATIOH OR P LIABLlTYOP ANY KINO UPON THE COMPANY. )TS AGENTSORREPRESENTATtveS *« ^t /I I -

?^^^^^

AR400965 11/21/87 FRI 16:27 FAX 703 513 2141 CLEAN SITES ENV SERVICES (g]0i2

*SOO-PM-W

WATER QUALITY MANAGEMENT PERMIT

A. PERMITTEE (Name & Address): R3 Technologies, Inc. 7 Steel Road East, P.O. Box 847, MorrisviUe,PA 19067 PROJECT (Name, County, Municipality) R3 Technologies, Inc. Falls Township Bucks County C- THIS: Permit X Permit Amendment

APPROVES: The construction/operation of: Modification^) to the construction/operation of: Sewage Treatment Facilities ~~X Industrial Waste Treatment Facilities Land Application Facilities X Other - Permit Transfer Average Design Flow of ( 18 ) MOD consisting oft Stonnwater Sub-surface Seepage Beds The Authorization to discharge shall expire at Midnight March 15,1999. See Special Condition No. IV. Sewers and Appurtenances Pump Station^) Impoundment(s) Injection WelUs) Soil Erosion & Sedimentation Control Plan Stream Crossing(s} Outfall & HeadwalKs)

D. APPROVAL GRANTED BY THIS PERMIT IS SUBJECT TO THE FOLLOWING CONDITIONS:

1. a. All construction, operations, and procedures shall be in accordance with the Water Quality Management Permit/Permit Amendment Application dated , its supporting documentation, and addendums dated J 2/4/95 Such application, its supporting documentation and uddendums are hereby made a part of this permit. b. Water Quality Management Permit No. 0993205 dated 3/15/94 and conditions, supporting documentation and addendums are (except for any modifications to the original permit herein permitted) also made a part of this permit amendment. 2. Conditions numbered' 2,3,4,6,7,6,9,10,1142,13,16,17,18,19,20 and 21 of the Industrial Waste standard conditions dated g/91 and conditions numbered of the erosion control standard conditions dated are attached and made part of this permit, 3. Special conditions numbered J, II, III, IV are attached and made part of this permit

£, THE AUTHORITY GRANTED BY THIS PERMIT IS SUBJECT TO THE FOLLOWING FURTHER QUALIFICATIONS:

1. If there is a conflict between the application or its supporting documents and amendments and the standard or special conditions, the standard or special conditions shall apply. 2. Failure to comply with the rules and regulations of the Department or with the terms or conditions of this permit shall void the authority given to the permittee by the Issuance of the permit. 3. This permit is issued pursuant to Ihe Clean Stream law Act of June 22,1937, P.L. 1987, as amended 35 P.S. §691.1 £1 S£Q., and/or the Dam Safety and Encroachments Act of November 26,1978, P.L. 1375, as amended, 32 P.S. §693.1 a atq. Issuance of this permit shall not relieve the permittee of any responsibility under any other law. 4. Industrial Facilities - If the herein permitted facilities or modifications are not completed with two (2) years of the issue dale below, this permit will become null and void and reapplication shall be required.

PERMIT ISSUED: ¥ DEPARTMENT OF ENVIRONMFJSTAL PROTECTION DATE "arch 15, 1994 -. -. i • i '- ,, ^ .-•,,^_ ..___,,— AMENDMENT ISSUED: BY: -^

DATE . February 8f 1996TITLE: tjRegion^l Manager. Water Management

(SMQ3<5-1 This Permit supcrcedes Permit No. 0993205 issued on March 15, 1994.

AR400966 11/21/97 FRI 16:28 FAX 703 519 2141 CLEAN SITES ENV SERVICES 12)013

ER-SWM-S: Rev. 9/80 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE MANAGEMENT Permit For Solid Waste Disposal and/or Processing Facility FORM NO. 8

Permit No. 301254

Date Issued Uav q. 10-06 Date Expired March 15, 2004

Under the provisions of the Pennsylvania Solid Waste Management Act of July 7,1980, Act 97, a

permit for a solid waste disposal and/or processing facility at (municipality) fails Township in the County

of.Bucks is granted to (applicant) R3 Tecnnpjogfe?. Inu.

(address) 7 Steef Koari East. PO Box 847. Mnrrisvflle. PA 19067

This permit is applicable to the facility named as ft3 Technologies. Inc.

and described as:

Latitude-4QMJT, 45"

Longitude-24°, 45', 55."

This permit is subject to .modification, amendment and supplement by the Department of Environmental

Protection and is further subject to revocation or suspension by the Department of Environmental

Protection for any violation of the applicable laws or the rules and regulations adopted thereunder,

for failure to comply in whole or in part with the conditions of this permit and the provisions set

forth in the application no. 301254 wliich is made a. part hereof, or for causing any condition

inimical to the public health, safety or welfare.

3cc Attachment for -wojcta limitation? anct/or special conditions FOR THE DEPARTMENT OF ENVERONMF.NTAL PROTECTION

THIS PERMIT IS NON -TRANSFERABLE Page i of 7

AR400967 11/21/97 FRI 16:29 FAX 703 519 2141 CLEAN SITES ENV SERVICES lg]014

2500-FM-WM0008A Rer. 1/86 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE MANAGEMENT Permit For Solid Waste Disposal and/or Processing Facility FORM NO. 8

Permit No. 301254 Date Issued May 9, 1996 Date Expires March 15,2004

This waste management permit is re-issued to R3 Technologies, Inc. based upon application No. 301254 which w*w nveived in the Southeast Regional Office of the Department of Environmental Protection on December 1,1995. This permit is for the reissuance of a waste management permit to R3 Technologies, Inc. from Mix Design Methods, Inc. for the continuing operation of a road recycling and remediation center for the processing of soil and/or aggregates contaminated with virgin petroleum hydrocarbons, No. 5 fuel oil, No. 6 fuel oil, crude oil, lubricating oil, asphalt, asphalt roofing material, greases, tar (asphalt, petroleum, coal), oxygenated hydrocarbons (alcohols, ethers, organic acids and ethylene glycol), and non- virgin coal or petroleum hydrocarbons excluding radioactive, explosive, toxic or hazardous contaminants. The re-issued permit allows for acceptance of incinerator ash and sewage sludge incinerator ash to make recycled aggregates or hot mix asphalt and utilization of sewage sludge filter cake to cool thermally remediated contaminated soil.

This approved application includes Form R, Waste Analysis and Classification Plan, revised on April 23,1996.

The contents of all the above listed documents are hereby incorporated in the permit as conditions with which the permittee must comply.

Nothing in this permit shall be construed to supersede, amend, or authorize violation of, the provisions of any valid and applicable local law, ordinance, or regulation, provided that said local law, ordinance, or regulation is not pre-empted by the Pennsylvania Solid Waste Management Act, the Act of July 7,1980, Act 97,35 P.S. 6018.101, etseq.

As a condition of this permit, and of the permittee's authority to conduct the activities authorised by this permit, the permittee hereby authorizes and consents to allow authorized employees or agents of the Department, without advanced notice or a search warrant, upon presentation of appropriate credentials, and without delay, to have access to and to inspect all areas on which solid waste management activities are being or will be conducted. The authorization and consent shall include consent to collect samples of waste, water or gases, to take photographs,, to perform measurements, surveys and other tests, to inspect any monitoring equipment, to inspect the methods of operation, and to inspect and/or copy documents, books or papers required fay the Department to be maintained. This permit condition is referenced in accordance with Section 608 and 610 (7) of the Solid Waste Management Act, 35 P.S. Sections 6018.608 and 6018.610 (7). This condition in no way limits any other powers granted under the Solid Waste Management Act.

THIS PERMIT IS NON -TRANSFERABLE Pag« 2 of V

AR400968 11/21/97 FRI 16:30 FAX 703 519 2141 CLEAN SITES ENV SERVICES

COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION FIELD OPERATIONS - BUREAU OF AIR QUALITY

PLAN EXTENSION

Application No. 09-330-0116 ' Source(s) Asphalt Plant/Soil Remediation Facility

Owner R3 Technologies, Inc. • Air 2 High Efficiency Cyclones

Address 7 Steel Road East, PO Box 847 Cleaning 1 Afterburner ~_

Morrisville, PA 19067 Device 1 Baghouse

Attention Mr. James Doe ._ Location No. 7 Steel Road East

Plant Manager Falls Township

Bucks County

In accordance with provisions of the Air Pollution Control Act, the act of January 8, 1960, P.L 2119, as amended, and with Chapter 127 of the rules and regulations of the Department of Environmental Protection, the Department on approved plans for the installation of the above indicated air contamination source(s).

This PLAN APPROVAL EXTENSION expires 11/18/97.

The plan approval extension is subject to the following conditions:

1. The asphalt plant/soil remediation facility is to be installed in accordance with the plans submitted with the application (as approved herein).

(SEE ADDITIONAL CONDITIONS ATTACHED)

Notify the person noted below when the installation is completed so that the source(s) can be inspected for issuance of an OPERATING PERMIT.

NOTE: Reid Operations - Bureau of Air Quality Lee Park, Suite 6010 555 North Lane Conshohocken, PA 19428 610-832-6242

Fra/fbine Cariini Regional Manager Air Quality cc: Division of Permits, RCSOB Assistant Director SEFO Re (SMC) 181-8

AR400969 11/21/97 FRI 16:31 FAX 703 519 2141 CLEAN SITES ENV SKKVICES

technologies

R3 Technologies, Inc. 7 Steel Raid East P.O. Box 847 MorrisvilJe, PA 19067-0847 Phone: 215.428.1700 Fax- 215.428.1704 5 of 5 CONTAMINATED SOIL OR AGGREGATES CERTIFICATION FORM - TABLE 2A

Maximum Contamination Concentrations For Incoming Soils1

Analytical Test for Average Maximum Limits TPH 45,000 ppm3 Total Organic Halogens 20 ppm Ignitability Not ignftable* Corrosivity Not corrosive4 Reactivity Not reactive" Radioactivity Background or 20mR/hr PCB Non Detect

Metals Average Total (ppm) Arsenic 100 Barium 2000 Cadmium 20 Chromium, Total 50 Copper 700 Lead 100 Mercury • 2 Nickel . 200 Selenium 20 Silver • 100 Zinc 1000

(1) The presence of any contaminant or combination of contaminants at their maximum allowable levels will not reduce the effectiveness of the air pollution control equipment at R3 Technologies, Inc.

(2) R3 Technologies, Inc. will evaluate the test data to determine if the levels of contamination are within R3 Technologies, Inc. acceptance criteria.

(3) Contaminant concentrations > 10,000 pprn and < 45,000 ppm will require PADEP Form U approval.

(4) As defined by 40 CFR 261, Subpart C.

R-31 REV 3 - 05/S6

AR400970 APPENDIXl WATER TREATMENT SYSTEM STANDARD OPERATING PROCEDURES

AR400971 STANDARD OPERATING PROCEDURE FOR OHM DUAL FILTER BAG SYSTEM

START UP

1) One filter housing is a. spare and will not be used. Leave the inlet and outlet ball valves dosed on the spare unit for change out periods. 2) Check inside filter unit to be sure basket and filter bag are in housing. 3) Check that filter unit cover is securely fastened to housing. 4) Check that all ball valves on the filter units are closed. 5) Check that all cam-lock fittings ire securely fastened. 6) Slowly open the 6-inch globe valve 25% of full open position to fill the line with water. The 6-inch outlet valve should be slowly cracked open 25%. 7) Once line is full, slowly open the inlet 2-inch ball valves to each filter housing 25% of full open position (open slowly so that filter bag inside the housing is not displaced). 8) Vent the air inside of the housing with the small ball valve on the side of each housing until water displaces all air in each housing. 9) Once each filter unit is pressurized and vented, slowly open outlet service valve until completely open. 10) Complete opening of 6-inch globe valves. 11) Complete opening of each 2-inch inlet service ball valve until desired flow is obtained 12) Record pressure gauge reading for each housing.

NORMAL OPERATION

1 ) Once desired flow rate is established the filter units will operate efficiently until dirty. 2) The filter bags must be changed out once the differential pressure across tlie dual pair exceeds 1 5 psig. The differential pressure is determined by adding 1 5 psig to the previously recorded pressure reading. (e.g.4 If the initial reading is 50psig, then the filter bag will need changed out at 65 psig) 3) NEVER LET THE DIFFERENTIAL PRESSURE EXCEED 25 PSIG!!

FILTER BAG CHANGE-OUT

1) Bring the spare unit into service by doing the following: A) Slowly open inlet valve of the standby unit 25% of full open position (open slowly so that filter bag inside the housing is not displaced). B) Vent the air inside of the housing with the small ball valve on the side of the housing until water displaces all air in the housing. C) Once the standby filter unit is pressurized and vented, slowly open outlet service valve until completely open.

AR400972 9/2'd . IdBQ SDd3 WHO Wd12:20 Z6, 10 03Q 2) Close the outlet ball valve and then the inlet ball of the unit needing bag filter changeout. 3) Relieve the pressure from the filter vessel being serviced with the small ball valve on the side of the housing. 4) Drain housing sufficiently to access the filter basket. 5) Verify pressure gauge reading for 0 psig on the unit. 6) Remove cover by loosening the cover eyenuts. The eyenuts in the slotted corners should be loosened sufficiently to swing free. Loosen the third eyenut sufficiently to allow the top cover and closure assembly to swing away from the top of the unit. 7) Remove filter basket and clean thoroughly, remove the filter bag and throw away. 8) Remove debris and sludge (if any) from inside the inlet portion of the housing to avoid interference with cover seal or flow of fluid being filtered 9) Install clean filter basket and filter bag. Place the basket into the filter housing, and make sure the basket flange is firmly seated into the basket collar. Insert bag on top of the bag basket flange making sure filter bag ring is firmly seated inside the basket flange. For best results, be sure filter bag is installed fully extended to the bottom of the basket. 10) Inspect cover gasket for cuts or other signs of failure and make sure it is properly seated. 11) Move cover back into position, and alternately tighten the three clamp assemblies evenly to ensure a leak proof seal between the cover and housing body. The recommended torque value for 5/8"-11 closure assemblies is 150 ft-lbs. 12) Place unit back on line as described in the START-UP steps 7) through 9)

AR400973 9/£-d IcGQ SDH3 WHO WdI2:20 2£>, 10 D3Q APPENDIXJ SHEETPILING SPECIFIC A TIONS

AR400974 1 TERRA ENVIRONMENTAL CONTRACTORS INCORPORATED

FAX COVER SHEET

To: Date:

Company: Fax No:

From:

Pages following this cover page:

Original Copies Mailed: Yes No

RE:

Comments:

» Environmental Remediation CORPORATE CENTER * Demolition 2413 YELLOW.SPRINGS ROAD » 5j/« Development , PENNSYLVANIA 19355 (610) 647-1300 FAX (610) 296-4331 AR400975 CS-69 Steel Sheet Piling

WIDTH - 27.58 in.

HEIGHT - 5.91 in.

THICKNESS -

PERIMETER - 30.60

AREA - 4.17 in.2/l.ft

WEIGHT OF PILE - 32.58 Ib/Lft.

WEIGHT OF WALL - 1^.19 lb./ft2

3 SECTION MODULU/S - 8.D6 in. /Lft

MOMENT OF INERTIA - 23.76 in.4/ft

RADIUS OF GYRATION- 2^6 in.

AR400976