<<

PHASE II REMEDIAL INVESTIGATION WORK PLAN

Moen Incorporated 2609 Cox Mill Road Sanford, NC

Prepared for:

Moen Incorporated 25300 Al Moen Drive North Olmsted, OH

Prepared by:

Groundwater & Environmental Services, Inc. Exchange Alley Building th 23 South 13 Street, Suite 201 Richmond, Virginia 23219

February 2010

Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

PHASE II REMEDIAL INVESTIGATION WORK PLAN

Moen Incorporated 2609 Cox Mill Road Sanford, North Carolina

Prepared for:

Moen Incorporated 25300 Al Moen Drive North Olmsted, Ohio

February 2010

Prepared by:

______Jonathan P. Waddell, EIT Project Manager

______Montgomery S. Bennett, PG Registered Site Manager Senior Project Manager / Principal Hydrogeologist

Groundwater & Environmental Services, Inc. Phone: (866) 222-7786 Fax: (804) 343-0770

Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

TABLE OF CONTENTS

1.0 INTRODUCTION...... 1 1.1 PRELIMINARY REMEDIATION GOALS ...... 1 1.2 SUMMARY OF PHASE I REMEDIAL INVESTIGATION ...... 2 1.3 SCOPE OF PHASE II REMEDIAL INVESTIGATION WORK PLAN...... 3 1.4 CERTIFICATION OF DOCUMENT...... 4 2.0 PROPOSED METHODS OF INVESTIGATION - SOIL ...... 5 2.1 SCOPE OF WORK ...... 5 2.1.1 Delineation of VOC and Metal Impacts...... 5 2.1.2 Leachability Evaluation...... 7 2.1.3 Background Metal Calculation...... 8 2.1.4 Collection of Site-Specific Geotechnical Samples ...... 9 2.2 MIP INVESTIGATION...... 9 2.3 SOIL BORING INSTALLATION ...... 10 2.4 SOIL SAMPLE COLLECTION AND ANALYSIS ...... 11 3.0 PROPOSED METHODS OF INVESTIGATION - GROUNDWATER...... 14 3.1 SCOPE OF WORK ...... 14 3.1.1 Well Installation and Sample Collection along Southwestern Property Line ...... 14 3.1.2 Volumetric Delineation of Groundwater Plume...... 15 3.1.3 Background Metal Concentration Calculation...... 16 3.1.4 Confirmation of 2L Exceedances...... 16 3.2 WELL CONSTRUCTION ...... 17 3.3 GROUNDWATER SAMPLE COLLECTION AND ANALYSIS ...... 18 4.0 PROPOSED METHODS OF INVESTIGATION – STRUCTURAL VAPOR INTRUSION...... 21 5.0 PROPOSED METHODS OF INVESTIGATION – DECONTAMINATION ACTIVITIES AND WASTE MANAGEMENT...... 23 5.1 DECONTAMINATION...... 23 5.2 WASTE MANAGEMENT ...... 23 6.0 REPORTING ...... 25 7.0 CONSULTANT INFORMATION...... 26 7.1 CONTACT NAME ...... 26 7.2 ADDRESS ...... 26 7.3 TELEPHONE NUMBER...... 26 7.4 QUALIFICATIONS AND CERTIFICATIONS...... 26 7.4.1 Registered Site Manager (RSM) ...... 26 7.4.2 Project Manager ...... 26 8.0 LABORATORY INFORMATION – SOIL AND GROUNDWATER...... 28

i Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

8.1 CONTACT NAME ...... 28 8.2 ADDRESS ...... 28 8.3 TELEPHONE NUMBER...... 28 8.4 QUALIFICATIONS AND CERTIFICATIONS...... 28 9.0 LABORATORY INFORMATION – SUB-SLAB VAPOR AND INDOOR AIR..... 29 9.1 CONTACT NAME ...... 29 9.2 ADDRESS ...... 29 9.3 TELEPHONE NUMBER...... 29 9.4 QUALIFICATIONS AND CERTIFICATIONS...... 29

LIST OF TABLES

Table 1 – GES Investigation Team Table 2 – Soil Collection and Analytical Matrix Table 3 – Groundwater Collection and Analytical Matrix Table 4 – Sub-Slab Vapor and Indoor Air Collection and Analytical Matrix

LIST OF FIGURES

Figure 1 – Proposed Phase II Remedial Investigation Soil Boring Locations Figure 2 – Proposed Phase II Remedial Investigation Well Locations Figure 3 – Proposed Phase II Remedial Investigation Sub-Slab, Indoor and Ambient Air Sampling Locations

LIST OF ATTACHMENTS

Attachment A – Site-Specific Health and Safety Plan Attachment B – Certification Statements Attachment C – Resumes and Qualifications Attachment D – Membrane Interface Probe Standard Operating Procedure

ii Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

1.0 INTRODUCTION

This document presents a Phase II Remedial Investigation (RI) Work Plan (Work Plan) for the Moen Incorporated (Moen) Facility located at 2609 Cox Mill Road in Sanford, North Carolina (NC), which shall be referred to interchangeably as “the site.” The site is approximately 38.3- acres in size and is located along Cox Mill Road to the south of the intersection between NC Routes 42 and 1529. As shown on Figure 1 of the Phase I RI Work Plan dated March 2009, the site has approximately 1,035 feet of frontage along Cox Mill Road and is situated in a mixed commercial, industrial, and residential area.

Under the auspices of the NC Department of Environment and Natural Resources (NCDENR) - Registered Environmental Consultant (REC) Program, RIs are generally conducted in two (2) separate phases. The Phase I RI for the site was conducted from March to July 2009.

The Phase II RI will be implemented in accordance with a site-specific Health and Safety Plan (HASP), which was prepared in accordance with Section .0306(d) of the Registered Environmental Consultant Program Implementation Guidance dated October 2009, includes measures to protect the surrounding community (i.e., all persons on- and off-site) from exposure to site contaminants, and is included as Attachment A.

1.1 Preliminary Remediation Goals

The results of the Phase I RI were presented in the Phase I RI report dated January 2010 and compared to the following remediation goals:

 Soil analytical results were compared to soil remediation goals (SRGs) including Preliminary Health-Based PSRGs and Protection of Groundwater SRGs as provided in the Inactive Hazardous Sites Branch Soil Remediation Goals (SRG) table dated October 2009;

 Groundwater analytical results were compared to groundwater remediation goals, which are equal to the lower of the following levels:

o NCDENR 2L groundwater quality standards as provided in paragraphs (g) and (h) within the North Carolina Administrative Code (NCAC) Title 15A Subchapter 2L dated 07 September 2006; and

o US EPA MCLs and Public Health Goals (i.e., MCLGs) as provided in the National Primary Drinking Standards dated June 2003 (EPA 816-F- 03-016).

 Sediment analytical results were compared to Preliminary Health-Based PSRGs and US EPA Region 4 ecological risk screening levels; and

1 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

 Vapor analytical results were compared as follows:

o Sub-slab sample analytical results were compared against Acceptable Soil Gas (Csg’s) as provided in the IHSB Industrial/Commercial Vapor Intrusion Screening Table dated 11/10/2009; and o Indoor and ambient air results were compared against Acceptable Indoor Air Concentrations (Cia’s) provided in the IHSB Industrial/Commercial Vapor Intrusion Screening Table dated 11/10/2009 as well as the US EPA Industrial Air Screening Levels included within the US EPA Regional Screening Level Table dated 19 May 2009.

1.2 Summary of Phase I Remedial Investigation

The following summarizes the primary areas where environmental impacts were observed above preliminary soil, groundwater, sediment, and vapor remediation goals.

 Three (3) primary chlorinated solvent source areas were identified within the unsaturated soil zone underlying the Facility at areas of concern (AOCs) including AOC-13 (Former Brite Dip Pit), AOC16C (former Parts Degreaser) within the former Tool Room (Cafeteria), and AOC-21 (former Cast Bar Department). AOC-13 was characterized by exceedances of the Protection of Groundwater SRGs for 1,1-dichloroethene (DCE), 1,1-dichloroethane (DCA), and methylene chloride. Similarly, AOC-16C was characterized by 1,1-DCE, 1,2- DCA, and 1,4-dioxane in excess of Protection of Groundwater SRGs. Conversely, AOC-21 was impacted by trichloroethene (TCE) and vinyl chloride in excess of Protection of Groundwater SRGs.

 Four (4) metals (e.g., arsenic, cadmium, mercury, and manganese) were detected in soil at concentrations above their average background concentration and exceeding either the Preliminary Health-Based PSRG or Protection of Groundwater SRGs. As detailed within Section 8.1.3 of the Phase I RI Report:

o Arsenic was detected in seven (7) soil borings (e.g., AOC2-SB04, AOC4- SB01, AOC5-SB01, AOC16C-SB01, AOC16C-SB02, AOC18-SB01, and AOC23-SB01) at concentrations exceeding the Preliminary Health-Based PSRG, and of these, two (2) detections in soil borings AOC16C-SB01 and AOC23-SB01 exceeded the Protection of Groundwater SRG;

o Cadmium was detected in soil borings AOC16C-SB01 and AOC23-SB01 at concentrations exceeding their respective Protection of Groundwater SRGs;

o Mercury was detected in soil boring AOC13-SB01 at a concentration exceeding the Protection of Groundwater SRG; and

2 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

o Manganese was detected at concentrations exceeding the Protection of Groundwater SRG in borings AOC1-SB02, AOC2-SB01, AOC2-SB02, AOC2-SB04, AOC3-SB01, AOC4-SB01, and AOC13-SB01.

 Groundwater monitoring was conducted within the new well nests and the majority of the existing monitoring wells to provide a synoptic snapshot of groundwater impacts at the site. The analytical results revealed that the downgradient contaminant plume, which consisted primarily of chlorinated solvents (e.g., 1,1-DCE and TCE), was primarily confined to shallow alluvial hydrostratigraphic units (e.g., sand channel) underlying the site. In addition, groundwater analytical results from wells installed underlying the facility indicated that groundwater impacts existed directly beneath the three (3) primary source areas indentified within the unsaturated soil zone.

 A vapor intrusion evaluation was conducted, which incorporated analytical results from four (4) sub-slab vapor samples, eight (8) indoor air samples, two (2) ambient air samples, and groundwater samples collected from June to July 2009 at the site. This evaluation identified that although elevated chlorinated solvent concentrations were observed in sub-slab vapors and groundwater, the slab provided high levels of attenuation and no active mitigation was necessary for indoor air. However, additional monitoring was recommended during the heating season (i.e., winter experienced between mid-December and mid-February) to confirm the results from the Phase I RI.

 Sediment impacts were identified within the most downstream portion of the unnamed creek running along the eastern site boundary. Specifically, copper and zinc were detected at concentrations greater than US EPA Region IV Ecological Risk Standards, and are believed to stem from former plant outfalls.

1.3 Scope of Phase II Remedial Investigation Work Plan

Moen has contracted Groundwater & Environmental Services, Inc. (GES) as the REC to conduct the Phase II RI at the site. In accordance with Section 0.0306(g) of the Registered Environmental Consultant Implementation Guidance dated October 2009, the purposes of the Phase II RI will be to delineate the areal and vertical extent of soil and groundwater impacts to below the preliminary remediation goals, to collect sufficient sampling data to support a cleanup-level determination, and to sufficiently characterize the site conditions in order to conduct a feasibility study of applicable remedial alternatives and to support a proposed remedy.

This Phase II RI Work Plan has been prepared and is being submitted in accordance with:

 The voluntary remedial action program Rules 15A NCAC 13C .0300;

3 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

 Section .0306(g) of the Registered Environmental Consultant Program Implementation Guidance dated October 2009; and

 Section 2.3 of the Inactive Hazardous Sites Branch Guidelines for Assessment and Cleanup dated October 2009, where appropriate. The proposed methods of investigation are described within the following sections, which include site characterization procedures, soil and groundwater sample collection methods, laboratory analytical methods, field and laboratory Quality Assurance/Quality Control (QA/QC), and waste management and decontamination procedures.

As described in Section 9.3 of the Phase I RI Report, GES submitted a letter in September 2009 to the REC Program in accordance with Section D.2.2.1 of the Registered Environmental Consultant Program Guidance dated October 2009, which documented the exceedances observed in downstream sediments within the unnamed creek. At the time of the submittal of this Work Plan, no response has been received from the REC Program regarding the contents of this letter. As such, no scope or methodologies related to the sediment and/or surface water have been included herein. Once a response is received from the REC Program, GES shall incorporate any requirements into a Phase II RI Work Plan Addendum.

1.4 Certification of Document

As required by Section.0306(b) of the Registered Environmental Consultant Implementation Guidance dated October 2009, this Phase II RI Work Plan has been certified by the Remediating Party (Moen) and the REC (see Attachment B) and submitted to the Branch prior to implementation. As described in Table 1, Mr. Montgomery S. Bennett of GES will serve as the Registered Site Manager (RSM). Resumes and qualifications for the GES investigation team are included within Attachment C and Section 7.0, respectively.

4 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

2.0 PROPOSED METHODS OF INVESTIGATION - SOIL

2.1 Scope of Work

The objectives of the additional soil assessment shall include:

 Lateral and vertical delineation of volatile organic compound (VOC) and metal impacts exceeding their respective Protection of Groundwater SRGs within the three (3) primary source areas identified within the Facility; and

 Site-specific evaluation of leachability for isolated VOC and metal Protection of Groundwater SRG exceedances, which are not believed to be primary source areas; and

 Calculation of more-representative background concentrations for metals.

Further information is provided in the following subsections.

2.1.1 Delineation of VOC and Metal Impacts

In accordance with Section A.2.2 of Appendix A of the Registered Environmental Consultant Implementation Guidance dated October 2009, a semi-quantitative field screening method (e.g., membrane interface probe [MIP]) will be used to help pinpoint the locations of the source areas and evaluate the lateral and vertical extent of contamination. The MIP survey will be conducted in accordance with the Standard Operating Procedures (SOP) included as Attachment D. The survey locations coincide with the following AOCs located within the Facility and investigated during the Phase I RI:

 AOC-13 (Former Brite Dip Pit), which was characterized by Protection of Groundwater SRG exceedances for trichloroethane (TCA) daughter products including 1,1-DCA and 1,1-DCE, methylene chloride, and mercury;

 AOC-16C (Former Parts Degreaser) within the former Tool Room (Cafeteria), which was characterized by Protection of Groundwater SRG exceedances for 1,2-DCA, 1,1-DCE, 1,4-dioxane, arsenic, and cadmium (neighboring soil boring AOC19-SB01 was also characterized by 1,1-DCE in exceedance of the Protection of Groundwater SRG); and

 AOC-21 (Former Cast Bar Department) currently located in the Finishing Department just northwest of AOC-17 (Molding Department), which was characterized by exceedances for chlorinated ethenes (i.e., TCE and vinyl chloride).

5 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

As currently envisioned, the MIP soil borings will be installed using a grid pattern (i.e., 20 feet by 20 feet) within the three (3) primary source areas as shown on Figure 1. The initial survey points in each source area will be situated adjacent to previous soil borings where exceedances of the either or both of the Branch’s SRGs were observed during the Phase I RI. Any subsequent locations will be determined based on the MIP response in the initial borings. Based upon MIP results, confirmation soil borings will be advanced in the various areas and soil samples shall be collected from borings where the MIP response was the highest and at the expected vertical and lateral boundaries of each of the three (3) source areas. The purpose of confirmation soil samples will be to confirm and delineate the lateral and vertical extent of contamination to concentrations less than or equal to the Branch Remediation Goals (health based and protection of groundwater SRGs). Further description of the proposed scope of work is detailed in the following bullets.

 The MIP investigation will be conducted at AOC-13 (Former Brite Dip Pit) within the rectangular area shown in Figure 1 to evaluate the extent of VOC impacts associated with former Brite Dip operations. Specifically, the MIP soil borings will be installed on an approximate 20-foot by 20- foot sampling grid around Phase I RI soil borings AOC13-SB01 and AOC13-SB02, where exceedances of Protection of Groundwater SRGs were detected for 1,1-DCA, 1,1-DCE, and methylene chloride (see Table 26 of the Phase I RI Report). Up to six (6) confirmation soil borings (i.e., AOC13-SB03 through AOC13-SB08) are proposed to be installed within the Brite Dip Pit source area. The confirmation samples will be collected at the location of the highest MIP response and at the boundaries of the impacts. Each boring will be advanced to the water table (at around 9 feet bls), and sampled for VOCs (see Table 2). Confirmation soil samples will also be analyzed for mercury, which exceeded the Protection of Groundwater SRG in soil boring AOC13-SB01, and metals by US EPA methods 6200/6010B/7471 as specific metals (e.g., copper, lead, zinc, cadmium, and nickel) were detected in shallow groundwater at concentrations exceeding groundwater remediation goals (see results for wells IW-2 and MW-26S in Table 27 of the Phase I RI Report).

 The MIP investigation will be conducted at AOC-16C (Former Parts Washer) within the rectangular area shown in Figure 1 to evaluate the extent of VOC impacts in the former Tool Room ( Cafeteria). Specifically, the MIP soil borings will be installed on an approximate 20- foot by 20-foot sampling grid around Phase I RI soil borings AOC16C- SB01 and AOC16C-SB02, where exceedances of Protection of Groundwater SRGs were detected for 1,2-DCA, 1,1-DCE, and 1,4- dioxane (see Table 26 of the Phase I RI Report). Up to eight (8) confirmation soil borings (i.e., AOC16C-SB03 through AOC16C-SB10) will be collected at the location of the highest MIP response and at the

6 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

boundaries of the impacts. The borings will be advanced to the water table (between 7 to 9 feet bls), and sampled for VOCs (see Table 2). Confirmation soil samples will also be analyzed for metals including arsenic and cadmium, which exceeded the Protection of Groundwater SRG in soil boring AOC16C-SB01, and cadmium and manganese detected in shallow groundwater above groundwater remediation goals (see results for wells MW-22S and MW-22I in Table 27 of the Phase I RI Report) by US EPA methods 6200/6010B.

 The MIP investigation will be conducted at AOC-21 (Former Cast Bar Department) within the rectangular area shown in Figure 1 to evaluate the extent of VOC impacts. Specifically, the MIP soil borings will be installed on an approximate 20-foot by 20-foot sampling grid around Phase I RI soil boring AOC21-SB01, where exceedances of Protection of Groundwater SRGs were detected for TCE and vinyl chloride (see Table 26 of the Phase I RI Report). Up to five (5) confirmation soil borings (i.e., AOC21-SB02 through AOC21-SB06) will be collected at the location of the highest MIP response and at the boundaries of the impacts. The borings will be advanced to the water table (at around 9 feet bls), and sampled for VOCs (see Table 2). Confirmation soil samples will also be analyzed for metals by US EPA method 6200/6010B, as specific metals (e.g., antimony, beryllium, lead, and manganese) were detected in groundwater at concentrations exceeding their respective groundwater remediation goals (see results for wells MW-28S and MW-28I in Table 27 of the Phase I RI Report).

Further description regarding soil boring installation and sample collection/analytical methodologies is provided in Sections 2.2 and 2.3, respectively.

2.1.2 Leachability Evaluation

In accordance with Section D.2.1.2.1 of Appendix D of the Registered Environmental Consultant Implementation Guidance dated October 2009, Synthetic Precipitation Leaching Procedure (SPLP) analysis will be utilized to evaluate the leachability of isolated VOC and metal exceedances of Protection of Groundwater SRGs. Specifically, four (4) new soil borings will be installed adjacent to Phase I RI soil boring locations where isolated VOCs or metals were observed to exceed Protection of Groundwater SRGs including:

 AOC2-SB01, which exhibited vinyl chloride at a concentration of 0.0019 mg/kg from 5- to 6-feet bls;

 AOC17-SB02, which exhibited methylene chloride at a concentration of 0.0544 mg/kg from 0.5- to 1-foot bls;

7 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

 AOC22-SB01, which exhibited methylene chloride at a concentration of 0.162 mg/kg from 0.5- to 1-foot bls; and

 AOC23-SB01, which exhibited arsenic exceedances from 0- to 0.5-feet beneath land surface (bls) and 2- to 4-feet bls, and a cadmium exceedance from 10- to 11-feet bls.

As described in Table 2, the new soil borings will be advanced to the depth of the observed Phase I RI exceedance and sampled at that depth for SPLP analysis. The SPLP sample will be analyzed for the specific VOC or metal that exceeded the Protection of Groundwater SRG (see Table 2). Further description regarding soil boring installation and sample collection/analytical methodologies is provided in Sections 2.2 and 2.3, respectively.

2.1.3 Background Metal Concentration Calculation

In accordance with Section A.5.1.3 of Appendix A of the Registered Environmental Consultant Implementation Guidance dated October 2009, ten (10) additional background soil samples will be collected from an area on-site where, based on historical operational knowledge, no manufacturing or waste management activities occurred (i.e., not influenced by the releases at the site).

As described in Section 2.3.1 of the Phase I RI Report, five (5) soil samples (i.e., background-SB01 through background-SB05) were collected upgradient of the Facility for analysis of site-specific background metal concentrations (see Figure 1). These soil samples were collected from shallow soil at a depth of 0- to 0.5- foot bls. At locations adjacent to the five (5) Phase I RI background soil borings, five (5) additional soil borings (i.e., background-SB06 through background-SB10) are proposed herein to be advanced to water table (at around 9 feet bls) and sampled at deeper intervals (i.e., 5- to 6-feet bls and at the water table) for analysis of metals (see Table 2). Should different lithologies be encountered during soil boring installation, additional samples and/or soil borings may be necessary to provide sufficient background data.

The new background analytical data will be combined with the data obtained during the Phase I RI, and evaluated statistically to calculate a more- representative average background concentration. The more-representative background concentrations will then be compared to the arsenic, cadmium, manganese, and mercury detections from the Phase I RI, which exceeded Preliminary Health-Based PSRGs and/or Protection of Groundwater SRGs.

Further description regarding soil boring installation and sample collection/analytical methodologies is provided in Sections 2.2 and 2.3, respectively.

8 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

2.1.4 Collection of Site-Specific Geotechnical Samples

Site-specific geotechnical samples are proposed to be collected from four (4) of the five (5) background soil boring locations (i.e., background-SB06 through background-SB10), as identified in the field. The purpose of these samples will be to provide representative geotechnical data for incorporation into any future modeling used to support the Remedial Action Plan.

As shown in Table 2, two (2) grab soil samples will be collected from the intermediate interval (i.e., 5- to 6-feet bls) and two (2) will be collected at the water table. Geotechnical samples will be shipped to PTS Laboratories in Santa Fe Springs, California and analyzed for the following parameters:

 The fraction of organic carbon (foc) in soil by the Walkley-Black method;

 Dry bulk density by ASTM method D2937;

 Total porosity by method API RP40; and

 Moisture content by ASTM method D2216.

Further description regarding soil boring installation and geotechnical sample collection/analytical methodologies is provided in Sections 2.2 and 2.3, respectively.

2.2 MIP Investigation

As detailed in Section 2.1.1, the objective of the MIP investigation will be to define the vertical and lateral extent of VOC impacts within the three (3) primary source areas via field screening. The MIP is a direct-push logging tool that measures soil conductivity and total VOC concentrations via three (3) analytical instruments: a photoionization detector (PID), an electron-capture detector (ECD), and a flame-ionization detector (FID). These measurements allow for a semi-quantitative (e.g., impacted soils/GW or non-impacted soils/GW) evaluation to be conducted in near “real-time”, which guides the delineation activities based on data collected in the field.

Prior to conducting the MIP screening, GES will mobilize to the site and mark out all anticipated grid locations to ensure that all areas are accessible for the MIP investigation. Additionally, GES will utilize Taylor Wiseman & Taylor (TWT), a private utility locator, to identify any underground utilities and/or sub-surface anomalies. The proposed MIP borings will be concrete-cored to an appropriate diameter.

MIP points will be advanced by Columbia Technologies, Inc. utilizing a Geoprobe® direct-push rig to a depth of between 10- to 15-feet bls. As shown on Figure 1, the boundaries for each of the three (3) primary source areas provide a guide for the MIP

9 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

investigation. However, if chlorinated solvent impacts are observed (e.g., elevated ECD results) during the MIP investigation, the characterization profile and depth will be noted before moving to the surrounding grid points. If the surrounding grid points do not encounter impacts, the investigation may be refocused in an attempt to refine the nature and (vertical and lateral) extent of the impacted area.

In accordance with the US EPA Region 4 Logbooks Operating Procedure (SESDPROC- 010-R3), the date and time of observation, MIP boring identification, and advancement depth will be recorded within dedicated, bound logbooks for continuous soil samples collected during boring advancement.

No confirmation soil samples will be collected during the MIP investigation. Following completion of each MIP boring, the boring shall be properly abandoned in accordance with the US EPA Region 4 Design and Installation of Monitoring Wells Guidance (SESDGUID-101-R0) and sealed at the surface to match the surrounding flooring. Each MIP boring location will be surveyed by a NC-registered land surveyor following completion of the MIP investigation.

Decontamination of the MIP unit and Geoprobe® 54DT will be conducted between borings in accordance with requirements detailed in Section 5.0.

2.3 Soil Boring Installation

All proposed new soil boring locations (e.g., background soil borings, confirmation soil borings, and “leachability evaluation” soil borings) will first be cleared by TWT prior to installation. Next, all of the proposed soil boring locations inside of the facility will be concrete-cored to an appropriate diameter. Following utility clearance and concrete coring; soil borings shall be advanced to 5 feet bls in accordance with GES subsurface clearance protocols. In accordance with Section A.2.1.2 of Appendix A to the Registered Environmental Consultant Implementation Guidance dated October 2009, the boring will be advanced to the water table using either a 4-inch diameter, stainless steel hand auger and/or direct-push methods.

In accordance with the US EPA Region 4 Logbooks Operating Procedure (SESDPROC- 010-R3), the date and time of observation, soil boring identification, advancement depth, and soil description will be recorded within dedicated, bound logbooks for continuous soil samples collected during boring advancement. The physical description of the soil within each soil boring will be conducted visually in accordance with the Modified Unified Soil Classification System (USCS) for Field Classification of Soil. Each soil sample will be visually described within the dedicated logbook(s) as follows:

 The main soil type’s name;

 Gradation (coarse-grained soils) and plasticity (fine-grained soils);

10 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

 Density or Consistency;

 Water content or depth at which saturated soils are encountered;

 Color description;

 Minor soil type;

 Structure;

 Presence of inclusions (if observed);

 Geological name (if known);

 Appropriate USCS group name and symbol; and

 Results of screening with a hand-held photoionization detector (PID).

Following soil boring installation and sampling (see Section 2.3), each soil boring shall be properly abandoned in accordance with the US EPA Region 4 Design and Installation of Monitoring Wells Guidance (SESDGUID-101-R0) and sealed at the surface to match the surrounding flooring. A stake or flag will be placed at the soil boring location until surveying by a NC-registered land surveyor is conducted.

2.4 Soil Sample Collection and Analysis

During boring advancement, soil samples will be collected in accordance with US EPA Region 4 Soil Sampling Operating Procedure (SESDPROC-300-R1) from:

 0 – to 1-foot bls, at 5-foot intervals to the water table, and at the water table in accordance with Section A.2.1.2 of Appendix A to the Registered Environmental Consultant Implementation Guidance dated October 2009 (see Table 2); or

 For SPLP samples, at the depth at which an exceedance was detected within the Phase I RI (see Table 2).

In accordance with analytical reporting requirements provided in Section A.7.2. of Appendix A to the Registered Environmental Consultant Program Implementation Guidance dated October 2009; soil samples shall be collected and analyzed as follows (see Table 2).

 Samples for US EPA Target Compound List (TCL) VOCs and site-specific tentatively-identified compounds (TICs) shall be collected within a method 5035 compatible container (ex., Terra-Core sampler) and analyzed using US EPA SW846 method 8260B.

11 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

 Samples for total hazardous substance list metals shall be prepared by EPA 3050B and analyzed with US EPA method 6020/6010B/7471.

 Grab samples for SPLP analysis shall be prepared by US EPA method 1312 and analyzed for the specific VOC or metal, which exceeded the Protection of Groundwater SRG, via US EPA methods 8260B and/or 6020/6010B/7471.

As described in Section 2.3.21 of the Phase I RI Report, in accordance with Section A.7.1.1 of the Registered Environmental Consultant Implementation Guidance dated October 2009, the following TICs shall be included in the suite for VOC analysis: 1- methyl-3-(1-methylethyl)-benzene; 2-methyl butane; butyl-cyclohexane; 1,3-dimethyl- cyclohexane; propyl-cyclohexane; cyclopentane; decane; 4-methyl-decane; dodecane; 1,1-difluoroethane; hexane; 2,3-dihydro-1,6-dimethyl-1H-indene; decahydro-2-methyl- naphthalene; trans-decahydronaphthalene; nonane; propene; sulfur dioxide; and undecane.

As discussed in Section 8.1.2 of the Phase I RI Report, no SVOCs were detected in soil at concentrations exceeding Preliminary Health-Based PSRGs or Protection of Groundwater SRGs. Although at a number of soil boring locations, the laboratory MDL and/or RL were greater than these criteria; the laboratory indicated that the MDLs and RLs were the lowest achievable using US EPA methodologies and instrumentation. As such, SVOCs in soil are not considered constituents of concern (COCs) at the Moen site and will not be analyzed during the Phase II RI. Similarly, no PCBs were detected at concentrations exceeding the Preliminary Health-Based PSRGs (see Section 8.1.4 of the Phase I RI Report) and will not be analyzed during the Phase II RI.

QA/QC samples shall be collected in accordance with Section A.6 of Appendix A to the Registered Environmental Consultant Program Implementation Guidance dated October 2009. Specifically, the following QA/QC samples will be collected (see Table 2) during the proposed soil sample collection activities:

 A minimum of one (1) field duplicate per medium and container type shall be collected each day of field activities;

 One (1) equipment rinsate blank will be collected per week and analyzed for US EPA TCL VOCs and total hazardous substance list metals via US EPA SW846 methods 8260B and 6020/6010B/7470A, respectively;

 One (1) ambient blank will be collected per week and analyzed for US EPA TCL VOCs via US EPA SW846 method 8260B;

 Soil samples will be collected and submitted to the laboratory for Matrix Spike/Matrix Spike Duplicate (MS/MSD) analysis on a frequency of one (1) per twenty (20) samples collected per media; and

12 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

 A trip blank will be submitted within each cooler containing bottleware for VOC analysis and analyzed for US EPA TCL VOCs via US EPA SW846 method 8260B.

13 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

3.0 PROPOSED METHODS OF INVESTIGATION - GROUNDWATER

3.1 Scope of Work

The objectives of additional groundwater assessment include:

 Well installation and groundwater sample collection along the southern property line to evaluate the lateral and vertical extent of groundwater impacts;

 Refinement of the lateral and vertical distribution of the on-site VOC plume; and

 Confirmation of marginal exceedances of groundwater remediation goals detected during the Phase I RI within deep hydrostratigraphic units (e.g., saprolite) underlying the Facility.

Further information is provided in the following subsections.

3.1.1 Well Installation and Sample Collection along Southwestern Property Line

As discussed in Section 8.2 of the Phase I RI Report, the following constituents were detected within the shallow upper intervals of well nest MW-22 at concentrations exceeding groundwater remediation goals (i.e., 2L standards and/or US EPA MCLs):

 Parent compounds 1,1,1- and 1,1,2-TCA, and daughter products 1,1-DCA, 1,1-DCE, and 1,2-DCA;

 Parent compound TCE and daughter product vinyl chloride;

 1,4-Dioxane; and

 Cadmium and manganese.

As shown on Figure 2, well nest MW-22 is positioned approximately 100 feet from the southwestern site boundary. As such, new well nest MW-31 is proposed to be installed along the southwestern property boundary just downgradient of MW-22 (see Figure 2) in order to confirm the groundwater flow direction and evaluate whether shallow groundwater impacts underlying the former Tool Room (cafeteria) have migrated to the south-southwest within shallow and/or deep groundwater flow systems.

Similarly, TCA daughter product 1,1-DCE was detected at a concentration greater than the groundwater remediation goal in well MW-10, which is around 125 feet

14 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

from the southwestern property line. Well nest MW-32 is proposed to be installed to the south of well MW-10 at the southern corner of the property (see Figure 2). This well will be utilized to evaluate whether 1,1-DCE impacts extend past (horizontally) or below (vertically) well MW-10 and have the potential to migrate towards the property line.

Further description regarding well construction and groundwater sample collection methodologies is provided within Sections 3.2 and 3.3.

3.1.2 Volumetric Delineation of Groundwater Plume

In accordance with Section A.3.2 of Appendix A of the Registered Environmental Consultant Implementation Guidance dated October 2009, additional well nests are proposed to gain a better understanding of the horizontal and vertical distribution of the on-site contaminant plume. Specifically, six (6) additional wells will be installed to address groundwater data gaps upgradient, within, and downgradient of the facility as follows. The proposed well locations are depicted on Figure 2.

 Well nest MW-30 is proposed to evaluate the northwestern boundary of solvent and metal impacts detected in well nest MW-22 within the former Tool Room (Cafeteria).

 Well nest MW-33 is proposed to characterize shallow and intermediate impacts downgradient of the solvent and metal impacts detected in well nest MW-22 within the former Tool Room (Cafeteria).

 Well nest MW-34 is proposed to characterize shallow and deep impacts downgradient of the chlorinated ethene source area identified near AOC- 21 (Former Cast Bar Department). In addition, well MW-34 will be utilized to detail the subsurface lithology directly downgradient of well nest MW-28, where groundwater impacts are believed to “dive” into deeper hydrostratigraphic zones (as isolated by well MW-21D).

 Well MW-35 is intended to provide information on the vertical extent of impacts downgradient of well MW-21D and adjacent to well MW-4D. The new well will be installed adjacent to well MW-4D, and advanced to a minimum of 50-feet deeper than well MW-4D, which is screened from 28- to 38-feet bls (see Table 6 of the Phase I RI Work Plan).

 Well nest MW-36 is proposed to evaluate whether a contaminant migration pathway (i.e., relict sand channel) exists between well nest MW-28 and downgradient well nest MW-13, which are both impacted by chlorinated ethanes (e.g., 1,1-DCE and 1,2-DCA), chlorinated ethenes (e.g., TCE), methylene chloride, and benzene.

15 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

 Well nest MW-37 is proposed to evaluate groundwater underlying AOC- 21 (former Cast Bar Department), which is believed to be the primary source of chlorinated ethene (e.g., TCE and daughter products) impacts at the site.

Further details are provided within Sections 3.2 and 3.3 regarding well construction and groundwater sample collection methodologies.

3.1.3 Background Metal Concentration Calculation

During the Phase I RI; four (4) metals (i.e., antimony, beryllium, manganese, and thallium), which are not believed to be associated with past or current facility operations, were detected at concentrations above groundwater remediation goals in various hydrostratigraphic units. A well nest is proposed to be installed at an on-site location where, based on historical operational knowledge, no manufacturing or waste management activities occurred (i.e., not influenced by the releases at the site). Specifically, well nest MW-38 shall be installed at the furthest upgradient location at the site adjacent to existing shallow well MW-5. The screened intervals within well MW-38 are proposed to target the deeper water-bearing units where the metals were observed.

As part of the Phase II RI, groundwater samples are proposed to be collected from MW-5 and nested well MW-38 for analysis of metals. This analytical data will be combined with analytical data obtained from upgradient well MW-1 during the Phase I RI, and evaluated statistically to calculate a representative average background concentration for metals collectively or for individual hydrostratigraphic units. The background concentrations will then be compared to the antimony, beryllium, manganese, and thallium detections from the Phase I RI, which exceeded Groundwater Remediation Goals.

Further description regarding groundwater sample collection and analysis is provided in Section 3.3.

3.1.4 Confirmation of 2L Exceedances

As discussed within Section 8.2 of the Phase I RI Report, benzene was detected within deep wells MW-22D and MW-24D at concentrations slightly exceeding the 2L standard of 1 µg/L. Both wells are screened within low-yielding hydrostratigraphic zone 4 (i.e., saprolite). As such, a confirmation groundwater sample will be collected via bailer, small-diameter bladder pump, or discrete sampler (e.g., Hydrosleeve sampler) from both wells to confirm the presence of a 2L exceedance (see Table 3) prior to further delineation efforts.

During the Phase RI, groundwater samples were not collected for metal analysis from the following low-yielding deep wells: MW-22D; MW-23D; MW-24D;

16 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

MW-25D; MW-26D; MW-27D; and MW-29D. Further attempts will be made during the Phase II RI to collect representative groundwater samples using either a bailer, small-diameter bladder pump, or a discrete sampler (e.g., Hydrosleeve sampler) from deep wells characterized by metal exceedances within the overlying intermediate interval. These wells include MW-22D, MW-23D, MW- 24D, MW-25D, MW-26D, and MW-27D. As shown on Table 27 of the Phase I RI Report, no metal exceedance was observed within well MW-29I and thus no sample will be collected from MW-29D.

Further description regarding groundwater sample collection and analysis is provided in Section 3.3.

3.2 Well Construction

As detailed in the prior section, nine (9) well nests (i.e., MW-30 through MW-38) are proposed to be installed upgradient, within, and downgradient of the facility (see Figure 2). Each monitoring well will be designed and installed in accordance with the US EPA Region 4 Design and Installation of Monitoring Wells Guidance dated 18 February 2008 (SESDQUID-101-R0). A NC-Certified Well Driller and a Certified Well Contractor shall be on-site at all times during well installation.

Each well nest will consist of three (3) wells each, which will be used to evaluate groundwater quality underlying the facility within different isolated hydrostratigraphic zones. The well nests shall be installed with each well in an individual borehole (minimum of 2.25 inch diameter) or within a single borehole (minimum of 8 inch diameter). At each proposed well nest location, at least one (1) soil boring will be extended to terminal depth for geologic characterization. Soil sampling shall be continuous to the terminal depth of the deepest soil boring at each location (to be identified in the field by GES). For wells MW-30 through MW-34 and MW-36 through MW-38:

 The shallow well is to be installed in the uppermost hydrostratigraphic zones including the channel sand (Zone 1A) and/or mottled clay (Zone 2);

 The intermediate well is proposed to be screened within the quartz gravel layer (Zone 3) from around 25 to 35 feet bls; and

 The deepest well is proposed to be installed within the saprolite (Zone 4), which is around 40 to 50 feet below grade.

As detailed in Section 3.1.2, well MW-35 will be utilized to evaluate the vertical extent of impacts beneath the screened intervals of wells MW-21D and MW-4D. The screened locations within well MW-35, which is to be advanced a minimum of 50 feet deeper than well MW-4D, will be selected in the field following boring advancement.

17 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

Monitoring wells installed within the Facility shall be a minimum of 2-inch in diameter, and constructed with Schedule (Sch) 40 PVC riser and 5- to 10-feet of Sch40 PVC 10- slot screen. The screen shall be packed with commercially-available washed siliceous Morie no.0 (DSI no.1) sand (or similar). Well nests installed outside of the Facility shall be a minimum of 2-inch in diameter, and constructed with Sch40 PVC riser and 5- to 10- feet of Sch40 PVC 10-slot screen. A minimum 2 foot thick bentonite (i.e., untreated, high-yielding Wyoming bentonite pellets) seal will be placed above each sand filter pack. Bentonite- grout will be placed above the uppermost bentonite seal to around 1- to 2-feet bls.

Monitoring wells installed within the Facility (i.e., MW-33, MW-34, and MW-37) shall be constructed flush-mount and completed with watertight lockable caps. Similarly, those wells installed adjacent to the building (i.e., MW-30, MW-31, MW-32, and MW- 36) will be constructed flush-mount. Well vaults for flush mount construction will be equipped with a water-resistant cast-iron flange and lid with Buna N Gaskets. The well pads shall be completed such that they are flush with the surrounding floor or land surface.

Monitoring wells MW-38 and MW-35, which shall be installed upgradient and downgradient of the Facility, respectively, shall be constructed with a 3-foot tall protective casing and completed with a watertight lockable cap. A 2-foot by 2-foot concrete pad shall be installed at the base of each well.

Following well construction, each installed well will be developed in accordance with the US EPA Region 4 guidance document titled Design and Installation of Monitoring Wells and dated 18 February 2008. In addition, the appropriate well construction record (Form GW-1b) will be completed for each new well and submitted to the REC Program as an Attachment to the Phase II RI Report.

3.3 Groundwater Sample Collection and Analysis

Prior to groundwater sample collection, the “free” water surface (i.e., potentiometric surface) will be measured within each well using an electronic water level indicator in accordance with the US EPA Region 4 Groundwater level and Well Depth Measurement Operating Procedure (SESDPROC-105-R1). Specifically, for each new well, the following information will be entered into the bound logbook:

 The water level to the nearest 0.01 foot relative to a surveyed reference point on the well casing; and

 The serial number of the electronic water level indicator.

Groundwater samples will be collected from well locations described in Table 3 via an environmental pump (e.g., peristaltic or electronic submersible pump) using the general low-flow/low-stress methodology in accordance with the US EPA Region 4 Groundwater

18 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

Sampling Operating Procedure (SESDPROC-301-R1). Should isolated zones not yield enough groundwater for low-flow sampling, a decontaminated bailer or Hydrosleeve sampler will be utilized to purge and collect the groundwater sample.

In accordance with analytical reporting requirements contained within Section A.7.2 of Appendix A to the Registered Environmental Consultant Program Implementation Guidance dated October 2009, groundwater samples shall be collected from all wells identified within Table 3 as follows.

 Samples for US EPA TCL VOCs and site-specific TICs shall be collected within three (3) 40-mL, HCl-preserved VOA glass vials with Teflon septa and analyzed using US EPA SW846 method 8260B.

 Samples for total hazardous substances list metals will be collected within HNO3- preserved, 500-mL polyethylene or glass jars, prepared by SM 3030C, and analyzed via US EPA method 6200/6010B/7470A.

As described in Section 3.5 of the Phase I RI Report, in accordance with Section A.7.1.1 of the Registered Environmental Consultant Implementation Guidance dated October 2009, the TIC propene shall be included in the suite for VOC analysis. Based on field measurements of , a filtered sample for metals analysis may be collected.

As detailed in Section 8.2.2 of the Phase I RI Report, no SVOCs were detected at concentrations exceeding groundwater remediation goals. Although at a number of wells, the laboratory MDL and/or RL were greater than the preliminary remediation goal; the laboratory indicated that the MDLs and RLs were the lowest achievable using US EPA methodologies and instrumentation. As such, SVOCs in groundwater are not considered COCs at the Moen site and will not be analyzed during the Phase II RI. Similarly, PCBs were not detected in any sample at concentrations groundwater remediation goals (see Section 8.2.4 of the Phase I RI Report) and will not be analyzed during the Phase II RI.

QA/QC samples shall be collected in accordance with Section A.6 of Appendix A to the Registered Environmental Consultant Program Implementation Guidance dated October 2009. Specifically, the following QA/QC samples will be collected during groundwater sample collection (see Table 3).

 A minimum of one (1) field duplicate per medium and container type shall be collected each day of field activities.

 One (1) equipment rinsate blank will be collected per week and analyzed for US EPA TCL VOCs and total hazardous substance list metals via US EPA SW846 methods 8260B and 6020/6010B/7470A, respectively.

19 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

 One (1) ambient blank will be collected per week and analyzed for US EPA TCL VOCs via US EPA SW846 method 8260B.

 Two (2) samples will be collected and submitted to the laboratory for MS/MSD analysis on a frequency of one (1) per twenty (20) samples collected per media.

 A trip blank will be submitted within each cooler containing bottleware for VOC analysis and analyzed for US EPA TCL VOCs via US EPA SW846 method 8260B.

20 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

4.0 PROPOSED METHODS OF INVESTIGATION – STRUCTURAL VAPOR INTRUSION

In accordance with Section D.4 of Appendix D to the Registered Environmental Consultant Implementation Guidance dated October 2009 and the Supplemental Guidelines for the Evaluation of Structural Vapor Intrusion Potential for Site Assessments and Remedial Actions Under the Inactive Hazardous Sites Branch dated 05 November 2009, additional sub-slab vapor, indoor air, and QA/QC samples will be collected within the Facility during the heating season (i.e., mid-December through mid-February). These data will be compared to the previous vapor data in order to confirm the findings of the included as part of the Phase I RI Report. Specifically, as described in Table 4:

 Four (4) sub-slab vapor samples will be collected from existing vapor implants installed during the Phase I RI (see Figure 3) including VI-01SS at AOC-16C (Former Parts Degreaser) located in the former Tool Room (Cafeteria), VI-02SS at AOC-13 (Former Brite Dip Pit), VI-03SS at AOC-20 (Former Miscellaneous Machining Department), and VI-04SS at AOC-17 (Molding Department);

 Seven (7) indoor air samples will be collected at locations shown on Figure 3 including samples IA-01 and IA-02 within the former Tool Room (Cafeteria), sample IA-03 within the meeting room adjacent to the former Tool Room (Cafeteria), sample IA-04 from AOC-13 (Former Brite Dip Pit), sample IA-05 from AOC-20 (Former Miscellaneous Machining Department), sample IA-06 from AOC-17 (Molding Department), and sample IA-07 from the break room (i.e., snack shack) overlying AOC-12 (Former Equalization Pit); and

 Four (4) QA/QC samples will be collected including one (1) “side-by-side” field duplicate, two (2) ambient air samples outside of the Facility to evaluate whether outside interferences affect indoor air quality, and one (1) trip blank.

In accordance with the Supplemental Guidelines for the Evaluation of Structural Vapor Intrusion Potential for Site Assessments and Remedial Actions Under the Inactive Hazardous Sites Branch dated 05 November 2009, items that induce short term changes (e.g., exhaust fans) will not be used during sampling. In addition, the following monitoring conditions shall be established to the extent practicable in the sampling area to provide reliable analytical results:

 Ensuring windows and doors are shut 12- to 24-hours before measurements begin, and maintained shut during sampling; and

 Placing sampling units for indoor and ambient air samples within the normal zone, 2- to 5-feet above the floor, in the lowest inhabited area.

At each location detailed in Table 4, samples will be collected in accordance with the US EPA Region 4 Soil Gas Sampling Operating Procedure (SESDPROC-307-R1), US EPA Region 4

21 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

Ambient Air Sampling Operating Procedure (SESDPROC-303-R1), and the Supplemental Guidelines for the Evaluation of Structural Vapor Intrusion Potential for Site Assessments and Remedial Actions Under the Inactive Hazardous Sites Branch dated 05 November 2009. 24- hour time-weighted-average (TWA) samples will be collected within either “100% certified” or “batch certified”, evacuated, stainless-steel SUMMA® canisters (1-liter size) with pressure gauges and Swagelok® stainless steel fittings and connections. The Laboratory, Centek Laboratories, LLC. (see Section 9.0), will provide appropriate flow controllers and Swagelok® connections for the collection of a 24 hour composite sample.

During collection of sub-slab samples, laboratory-grade helium will be utilized to demonstrate that no leaks are occurring with the SUMMA® canister. For all vapor samples collected, at a minimum, the canister serial number, sample number, location, date, and pre- and post-sample vacuum readings will be recorded on the canister tag and within the dedicated logbook(s). Also, conditions under which the samples are collected, which might affect the interpretation of the results, will be recorded within the dedicated logbook(s). These conditions include, but are not limited to, unusual weather conditions, air , current building ventilation status, and the presence of petroleum related products on site.

Following sampling, SUMMA® canisters will be shipped to the laboratory (i.e., Centek Laboratories, LLC) for VOC analysis using method TO-15 or TO-15 SIM in accordance with testing requirements provided within the Supplemental Guidelines for the Evaluation of Structural Vapor Intrusion Potential for Site Assessments and Remedial Actions Under the Inactive Hazardous Sites Branch dated 05 November 2009 (see Table 4).

22 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

5.0 PROPOSED METHODS OF INVESTIGATION – DECONTAMINATION ACTIVITIES AND WASTE MANAGEMENT

5.1 Decontamination

Decontamination activities will be conducted in accordance with the US EPA Region 4 Field Equipment Cleaning and Decontamination Operating Procedure (SESDPROC- 205-R1). A decontamination area will be established outside of the work area, in a surface-contamination-free area designated by Moen, for any equipment coming in contact with subsurface materials, including:

 Down-hole drilling equipment (ex., augers);

 Split-spoon samplers;

 Equipment utilized to collect environmental samples (e.g., submersible pumps);

 Electronic water level indicators; and

 Tools exposed to contaminated media.

The decontamination area shall be constructed on a level surface of impervious and compatible materials, shall be free of cracks and other potential leakage routes, and managed in accordance with the US EPA Region 4 Field Equipment Cleaning and Decontamination Operating Procedure (SESDPROC-205-R1). The decontamination area shall be designed, through size or other means, to collect all liquid and semi-liquid material generated or collected during decontamination activities.

All drilling equipment shall be decontaminated prior to drilling and between soil borings and wells. In addition, all sampling equipment will be decontaminated with tap water, detergent (e.g., Luminox soap), and deionized water between sampling events. Further equipment-specific requirements are provided in the US EPA Region 4 Field Equipment Cleaning and Decontamination Operating Procedure (SESDPROC-205-R1). All wash and residues will be collected, containerized, and characterized for proper disposal.

5.2 Waste Management

Wastes generated shall be managed in accordance with Section A.6.2.g. of Appendix A to the Registered Environmental Consultant Implementation Guidance dated October 2009 and the US EPA Region 4 Management of Investigation Derived Waste Operating Procedure (SESDPROC-202-R1). More specifically, DOT-approved fifty-five (55)- gallon steel drums will be utilized to containerize all investigation-derived waste (IDW) including:

23 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

 Soil cuttings generated from soil boring installation, well installation and construction, and soil sample collection;

 Drilling and purge water generated during concrete coring, well installation and construction, well development, and groundwater sample collection;

 Decontamination fluids generated during decontamination of drilling equipment (between the installation of soil borings and wells) and sampling equipment (between sampling events); and

 Disposable equipment and personal protective equipment (PPE) containerized with the appropriate waste.

Containerized waste accumulated during the Phase II RI will be stored within a proper storage area as identified by Moen. Once containerized, each individual waste stream listed above will be sampled for characterization and profiling purposes in accordance with Section 4.3 of the US EPA Region 4 Waste Sampling Operating Procedure (SESDPROC-302-R1). Specifically,

 Representative liquid samples will be collected from each individual liquid waste stream and analyzed for RCRA VOCs, SVOCs, and metals via US EPA methods 8260B, 8270D, and 6020/6010B/7470A; and

 A discrete, representative, grab soil sample will be collected from drill cuttings and analyzed for RCRA VOCs, SVOCs, and metals via US EPA method 1311, the Toxicity Characteristic Leaching Procedure (TCLP).

All analytical results will be directly compared against TCLP regulatory levels for profiling as either non-hazardous or RCRA characteristic hazardous waste. PPE will be disposed of in accordance with the characterization of the source material.

Trash generated during implementation of the Phase II RI Work Plan shall be containerized and properly disposed of off-site in accordance with Federal, State, and Local permits, rules, and regulations.

24 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

6.0 REPORTING

Following the implementation of the Phase II RI Work Plan detailed herein; a Phase II RI Report shall be prepared in accordance with:

 Section .0306(h) of the Registered Environmental Consultant Program Implementation Guidance dated October 2009; and

 Section 3.0 of the Inactive Hazardous Sites Program Guidelines for Assessment and Cleanup dated October 2009, where applicable.

At a minimum, the Phase II RI Report shall include the following:

 A remedial investigation completion statement (Form G-II) should no further investigation be necessary;

 Clearly-written and well-organized documentation of the findings of the Phase II RI;

 Copies of laboratory data including the laboratory summary sheet, laboratory results, QA/QC results, and chain of custody documentation; and/or

 A Work Plan for Phase III Remedial Investigation (if necessary).

Once finalized, the Phase II RI Report will be submitted to the Division of Waste Management within 30 days of certification by the Registered Site Manager (RSM).

25 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

7.0 CONSULTANT INFORMATION

7.1 Contact Name

The Consultant’s contact name is: Groundwater & Environmental Services, Inc. (GES).

7.2 Address

The Consultant is located at:

23 South 13th Street, Suite 201 Exchange Alley Building Richmond, VA 23219

7.3 Telephone Number

The Consultant can be contacted at: (866) 222-7786.

7.4 Qualifications and Certifications

7.4.1 Registered Site Manager (RSM)

Montgomery S. Bennett, PG, is a Principal Hydrogeologist with 20 years of environmental consulting experience. Monty provides senior evaluation and oversight of site assessment projects, risk assessments, remediation system designs, and regulatory negotiations. His diverse experience includes developing remediation strategies, managing soil and groundwater remediation projects, providing litigation support, and performing indoor air quality monitoring.

Monty graduated from West Virginia University with a BS in geology. He is registered as a professional geologist in Georgia, North Carolina, South Carolina, and Virginia. He is a Registered Site Manager (RSM) in North Carolina and a certified professional in Ohio and serves as a member of the Association of Ground Water Scientists and Engineers.

7.4.2 Project Manager

Jonathan Waddell is a Project Manager with nearly ten (10) years of experience in characterization and remediation of chlorinated solvent contamination at federal and industrial sites underlain by fractured crystalline and fractured porous rock. Jonathan graduated from Georgia Institute of Technology with a BS and MS in Civil Engineering. His career began with the United States Geological Survey (USGS) in 2000. With the USGS, he focused primarily on characterization of deep bedrock contamination underlying a federal installation. He joined GES in

26 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

September 2006. With GES, he has been involved with the characterization and remediation of industrial sites underlain by complex media (e.g., glacial tills, fractured crystalline or sedimentary rocks, heterogeneous alluvial deposits, etc.) and impacted by various contaminants of concern (e.g., solvents, petroleum, PCBs, metals, polycyclic aromatic hydrocarbons (PAHs), etc).

27 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

8.0 LABORATORY INFORMATION – SOIL AND GROUNDWATER

8.1 Contact Name

The N.C. Division of Water Quality – certified Laboratory’s contact name is Pace Analytical Services, Inc. The Project Manager will be Kevin Godwin.

8.2 Address

The Laboratory is located at:

9800 Kincey Avenue, Suite 100 Huntersville, NC 28078-7929

8.3 Telephone Number

The Laboratory can be contacted at (704) 875-9092.

8.4 Qualifications and Certifications

The Laboratory has in-state Certification No. 12 under the North Carolina Division of Water Quality. Should samples be sent from Pace Analytical Services, Inc. in Huntersville (NC) to Asheville (NC), the Asheville Laboratory has in-state Certification No. 40.

28 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

9.0 LABORATORY INFORMATION – SUB-SLAB VAPOR AND INDOOR AIR

9.1 Contact Name

The Laboratory’s contact name is Centek Laboratories, LLC. The Project Manager will be David Linda.

9.2 Address

The Laboratory is located at:

143 Midler Park Drive Syracuse, New York 13206

9.3 Telephone Number

The Laboratory can be contacted at (315) 431 – 9730.

9.4 Qualifications and Certifications

At the time of this work plan, no certification has been provided from NCDENR for sub- slab vapor and indoor air analyses.

29 Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

TABLES

Phase II Remedial Investigation Work Plan Table 1 GES Investigation Team Moen Incorporated Sanford, North Carolina

Project Professional Position General Duties Senior project management, REC Program Mr. Montgomery S. supervision, direction, and technical Registered Site Bennett guidance; Phase II RI Work Plan Manager (RSM) review and certification Phase II RI Work Plan preparation; Mr. Jonathan P. management and supervision of Phase Project Manager Waddell II RI Work Plan implementation; Primary laboratory contact

GES – February 2010 1 of 1 Moen – Sanford, NC Table 2 Soil Collection and Analytical Matrix Moen Incorporated Sanford, North Carolina

2 3 1 Number Sampling Depth Required Laboratory Analyses Area of Descriptive Type of of Soil Soil Boring ID Soil Sample ID 0 - 0.5 feet 0.5 - 1 feet 5 - 6 feet Depth of Concern Name Release 4VOCs 5Metals 6Geotech 7SPLP Borings bls bls bls Water Table Soil Background-SB06 (5-6) - - X - - 1 1 - Background-SB06 Background-SB06 (Depth) - - - X - 1 - - Background-SB07 (5-6) - - X - - 1 - - Background-SB07 Background-SB07 (Depth) - - - X - 1 1 - Site-Specific Background-SB08 (5-6) - - X - - 1 1 - NA Background Soil NA 5 Background-SB08 Background-SB08 (Depth) - - - X - 1 - - Samples Background-SB09 (5-6) - - X - - 1 - - Background-SB09 Background-SB09 (Depth) - - - X - 1 1 - Background-SB10 (5-6) - - X - - 1 - - Background-SB10 Background-SB10 (Depth) - - - X - 1 - - Former Empty 1 (vinyl chloride AOC-2 Drum and Pallet Surface 2 AOC2-SB05 AOC2-SB05 (5-6) - - X - - - - only) Storage Area AOC13-SB03 (0-0.5) X - - - 1 - - AOC13-SB03 (0.5-1) - X - - 1 - - - AOC13-SB03 AOC13-SB03 (5-6) - - X - 1 1 - - AOC13-SB03 (Depth) - - - X 1 1 - - AOC13-SB04 (0-0.5) X - - - - 1 - - AOC13-SB04 (0.5-1) - X - - 1 - - - AOC13-SB04 AOC13-SB04 (5-6) - - X - 1 1 - - AOC13-SB04 (Depth) - - - X 1 1 - - AOC13-SB05 (0-0.5) X - - - - 1 - - AOC13-SB05 (0.5-1) - X - - 1 - - - AOC13-SB05 AOC13-SB05 (5-6) - - X - 1 1 - - Former Brite Dip Sub- AOC13-SB05 (Depth) - - - X 1 1 - - AOC-13 6 Pit surface AOC13-SB06 (0-0.5) X - - - - 1 - - AOC13-SB06 (0.5-1) - X - - 1 - - - AOC13-SB06 AOC13-SB06 (5-6) - - X - 1 1 - - AOC13-SB06 (Depth) - - - X 1 1 - - AOC13-SB07 (0-0.5) X - - - - 1 - - AOC13-SB07 (0.5-1) - X - - 1 - - - AOC13-SB07 AOC13-SB07 (5-6) - - X - 1 1 - - AOC13-SB07 (Depth) - - - X 1 1 - - AOC13-SB08 (0-0.5) X - - - - 1 - - AOC13-SB08 (0.5-1) - X - - 1 - - - AOC13-SB08 AOC13-SB08 (5-6) - - X - 1 1 - - AOC13-SB08 (Depth) - - - X 1 1 - -

GES - February 2010 Page 1 of 3 Moen - Sanford, NC Table 2 Soil Collection and Analytical Matrix Moen Incorporated Sanford, North Carolina

2 3 1 Number Sampling Depth Required Laboratory Analyses Area of Descriptive Type of of Soil Soil Boring ID Soil Sample ID 0 - 0.5 feet 0.5 - 1 feet 5 - 6 feet Depth of Concern Name Release 4VOCs 5Metals 6Geotech 7SPLP Borings bls bls bls Water Table AOC16C-SB03 (0-0.5) X - - - - 1 - - AOC16C-SB03 (0.5-1) - X - - 1 - - - AOC16C-SB03 AOC16C-SB03 (5-6) - - X - 1 1 - - AOC16C-SB03 (Depth) - - - X 1 1 - - AOC16C-SB04 (0-0.5) X - - - - 1 - - AOC16C-SB04 (0.5-1) - X - - 1 - - - AOC16C-SB04 AOC16C-SB04 (5-6) - - X - 1 1 - - AOC16C-SB04 (Depth) - - - X 1 1 - - AOC16C-SB05 (0-0.5) X - - - - 1 - - AOC16C-SB05 (0.5-1) - X - - 1 - - - AOC16C-SB05 AOC16C-SB05 (5-6) - - X - 1 1 - - AOC16C-SB05 (Depth) - - - X 1 1 - - AOC16C-SB06 (0-0.5) X - - - - 1 - - AOC16C-SB06 (0.5-1) - X - - 1 - - - AOC16C-SB06 Former Parts AOC16C-SB06 (5-6) - - X - 1 1 - - Degreaser in AOC16C-SB06 (Depth) - - - X 1 1 - - AOC-16C Surface 8 Former Tool AOC16C-SB07 (0-0.5) X - - - - 1 - - Room AOC16C-SB07 (0.5-1) - X - - 1 - - - AOC16C-SB07 AOC16C-SB07 (5-6) - - X - 1 1 - - AOC16C-SB07 (Depth) - - - X 1 1 - - AOC16C-SB08 (0-0.5) X - - - - 1 - - AOC16C-SB08 (0.5-1) - X - - 1 - - - AOC16C-SB08 AOC16C-SB08 (5-6) - - X - 1 1 - - AOC16C-SB08 (Depth) - - - X 1 1 - - AOC16C-SB09 (0-0.5) X - - - - 1 - - AOC16C-SB09 (0.5-1) - X - - 1 - - - AOC16C-SB09 AOC16C-SB09 (5-6) - - X - 1 1 - - AOC16C-SB09 (Depth) - - - X 1 1 - - AOC16C-SB10 (0-0.5) X - - - - 1 - - AOC16C-SB10 (0.5-1) - X - - 1 - - - AOC16C-SB10 AOC16C-SB10 (5-6) - - X - 1 1 - - AOC16C-SB10 (Depth) - - - X 1 1 - - Molding 1 (methylene AOC-17 Surface 1 AOC17-SB03 AOC17-SB03 (0.5-1) - X - - - - - Department chloride only)

GES - February 2010 Page 2 of 3 Moen - Sanford, NC Table 2 Soil Collection and Analytical Matrix Moen Incorporated Sanford, North Carolina

2 3 1 Number Sampling Depth Required Laboratory Analyses Area of Descriptive Type of of Soil Soil Boring ID Soil Sample ID 0 - 0.5 feet 0.5 - 1 feet 5 - 6 feet Depth of Concern Name Release 4VOCs 5Metals 6Geotech 7SPLP Borings bls bls bls Water Table AOC21-SB02 (0-0.5) X - - - - 1 - - AOC21-SB02 (0.5-1) - X - - 1 - - - AOC21-SB02 AOC21-SB02 (5-6) - - X - 1 1 - - AOC21-SB02 (Depth) - - - X 1 1 - - AOC21-SB03 (0-0.5) X - - - - 1 - - AOC21-SB03 (0.5-1) - X - - 1 - - - AOC21-SB03 AOC21-SB03 (5-6) - - X - 1 1 - - AOC21-SB03 (Depth) - - - X 1 1 - - AOC21-SB04 (0-0.5) X - - - - 1 - - Former Cast Bar AOC21-SB04 (0.5-1) - X - - 1 - - - AOC-21 Surface 5 AOC21-SB04 Department AOC21-SB04 (5-6) - - X - 1 1 - - AOC21-SB04 (Depth) - - - X 1 1 - - AOC21-SB05 (0-0.5) X - - - - 1 - - AOC21-SB05 (0.5-1) - X - - 1 - - - AOC21-SB05 AOC21-SB05 (5-6) - - X - 1 1 - - AOC21-SB05 (Depth) - - - X 1 1 - - AOC21-SB06 (0-0.5) X - - - - 1 - - AOC21-SB06 (0.5-1) - X - - 1 - - - AOC21-SB06 AOC21-SB06 (5-6) - - X - 1 1 - - AOC21-SB06 (Depth) - - - X 1 1 - - Former Zinc Die 1 (methylene AOC-22 Surface 1 AOC22-SB02 AOC22-SB02 (0.5-1) - X - - - - - Cast Department chloride only) AOC23-SB02 (0-0.5) X ------1 (arsenic only) Undocumented AOC-23 Surface 1 AOC23-SB02 AOC23-SB02 (2-4) ------1 (arsenic only) Release AOC23-SB02 (10-11) - - - X - - - 1 (cadmium only) QA/QC Field Duplicate X - - - 5 5 - - Quality Equipment Rinsate Blank --X - 11- - Assurance/ NA NA NA NA Ambient Blank --- X 10- - Quality Control MS/MSD --- - 33- - (QA/QC) Samples Trip Blank X - - - 10 0 - - Totals 29 NA NA NA NA NA NA 77 76 4 6

Notes:

ID, identification; bls, beneath land surface; NA, not applicable; MS/MSD, matrix spike/matrix spike duplicate 1 - See Table 9 of Phase I Remedial Investigation Work Plan for description of Areas of Concern (AOCs). 2 - Soil boring shall be advanced to water table and sampled at 5-foot intervals from 1 feet bls to the water table, and at the water table. 3 - Analytical method requirements provided in Section A.7.1.2. of Appendix A to the Registered Environmental Consultant Program Implementation Guidance dated October 2009. 4 - US EPA Target Compound List (TCL) volatile organic compounds (VOCs) and tentatively identified compounds (TICs) shall be analyzed using US EPA SW846 method 8260B. 5 - Total hazardous substance list metals shall be prepared by EPA 3050B and analyzed with US EPA method 6020/6010B/7470A.

6 - Geotechnical samples to be analyzed for foc in soil (Walkley-Black), dry bulk density (ASTM D2937), total porosity (API RP40), and moisture content (ASTM D2216) 7 - Sample shall be prepared by the Synthetic Precipitation Leaching Procedures (SPLP, US EPA Method 1312), and analyzed for specific VOCs or metals via US EPA methods 8260B and 6020, respectively.

GES - February 2010 Page 3 of 3 Moen - Sanford, NC Table 3 Groundwater Collection and Analytical Matrix Moen Incorporated Sanford, North Carolina

1Laboratory Analyses Groundwater Sample ID 2VOCs 3Metals Existing Monitoring Wells MW-5 - 1 MW-18 1 1 MW-22D 1 1 MW-23D - 1 MW-24D 1 1 MW-25D - 1 MW-26D - 1 MW-27D - 1 Proposed Monitoring Wells MW-30S 1 1 MW-30I 1 1 MW-30D 1 1 MW-31S 1 1 MW-31I 1 1 MW-31D 1 1 MW-32S 1 1 MW-32I 1 1 MW-32D 1 1 MW-33S 1 1 MW-33I 1 1 MW-33D 1 1 MW-34S 1 1 MW-34I 1 1 MW-34D 1 1 MW-35S 1 1 MW-35I 1 1 MW-35D 1 1 MW-36S 1 1 MW-36I 1 1 MW-36D 1 1 MW-37S 1 1 MW-37I 1 1 MW-37D 1 1 MW-38S - 1 MW-38I - 1 MW-38D - 1

GES - February 2010 Page 1 of 2 Moen - Sanford, NC Table 3 Groundwater Collection and Analytical Matrix Moen Incorporated Sanford, North Carolina

1Laboratory Analyses Groundwater Sample ID 2VOCs 3Metals QA/QC Field Duplicate 5 5 Equipment Rinsate Blank 11 Ambient Blank 1- Matrix Spike/ Matrix Spike Duplicate 22 Trip Blank 5 - Total Sample Count 41 43

Notes:

1 - Groundwater samples to be collected and analyzed in accordance with analytical method requirements provided in Section A.7.2. of Appendix A to the REC Program Implementation Guidance dated October 2009 2 - Target Compound List (TCL) volatile organic compound (VOCs) and tentatively-identified compounds (TICs) to be analyzed via US EPA method 8260B. 3 - Total hazardous substances list metals to be prepared by method 3030C and analyzed via method 6020/6010B/7470A.

GES - February 2010 Page 2 of 2 Moen - Sanford, NC Table 4 Sub-Slab Vapor and Indoor Air Collection and Analytical Matrix Moen Incorporated Sanford, North Carolina

Location Sample ID Area of 2VOCs 1Descriptive Name Concern Sub-Slab Former Parts Degreaser within VI-01SS AOC-16C 1 Tool Room (Cafeteria) VI-02SS AOC-13 Former Brite Dip Pit 1 Former Miscallaneous Machining VI-03SS AOC-20 1 Department VI-04SS AOC-17 Molding Department 1 Indoor Air IA-01Former Parts Degreaser within 1 AOC-16C IA-02Tool Room (Cafeteria) 1 Meeting Room adjacent to IA-03 - 1 Former Tool Room (Cafeteria) IA-04 AOC-13 Former Brite Dip Pit 1 Former Miscallaneous Machining IA-05 AOC-20 1 Department IA-06 AOC-17 Molding Department 1 IA-07 AOC-12 Former Equalization Pit 1 3 QA/QC Former Parts Degreaser within Duplicate AOC-16C 1 Tool Room (Cafeteria) Upwind of Facility, Outside of OA-01 - 1 Former Tool Room (Cafeteria) HVAC Intake for Cafeteria, OA-02 - 1 located on Roof Trip Blank - - 1 Total Sample Count 15

Notes:

VI, vapor implant; SS, sub-slab; IA, indoor air; OA, outdoor air 1 - See Table 9 of Phase I Remedial Investigation Work Plan for description of Areas of Concern (AOCs). 2 - Volatile organic compounds (VOCs) to be analyzed via US EPA method TO-15 or TO-15 SIM. 3 - Tubing to be dedicated and not reused. As such, no equipment blank will be collected.

GES - February 2010 Page 1 of 1 Moen - Sanford, NC Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

FIGURES

Phase II Remedial Investigation Work Plan

Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

ATTACHMENTS

Phase II Remedial Investigation Work Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

ATTACHMENT A – SITE-SPECIFIC HEALTH AND SAFETY PLAN

Phase II Remedial Investigation Work Plan GROUNDWATER & ENVIRONMENTAL SERVICES, INC. SITE-SPECIFIC HEALTH AND SAFETY PLAN FOR

Moen Incorporated 2609 Cox Mill Road Sanford, NC 27330

EMERGENCY PHONE NUMBERS

Local Police 911

Local Fire 911

Local Rescue 911

Local Hospital Name, Number & Address: Central Carolina Hospital 1135 Carthage Street Sanford, NC 27330

Directions to Hospital (map attached): Start NW on Cox Mill Road 0.3 miles Turn left at Avents Ferry Road 2.1 miles Turn right at S Horner Blvd 2.6 miles Turn right at 1/15/501 Carthage Street 0.7 miles End at Central Carolina Hospital

National Response Center (NRC): 1-800-424-8802 The NRC should be contacted in the event of a significant chemical release. Once notified, the NRC will activate a federal response to the spill. Please confirm with the client and project manager to determine if the spill should be reported.

Poison Control Center: 1-800-682-9211 The Poison Control Center should be contacted in the event of accidental poisoning. They will provide information on immediate treatment for the poisoning.

Nearest Telephone: On-site cell phone

GROUNDWATER & ENVIRONMENTAL SERVICES, INC. 1-866-222-7786

Sam Nicolai Telephone: 1-866-222-7786 ext. 3767 Site Operations Manager Cell Phone: 1-804-869-0192

Monty Bennett Telephone: 1-866-222-7786 ext. 3771 Senior Project Manager Cell Phone: 1-804-467-8572

Thomas Baylis Pager: 1-800-458-1077, Ext. 124 Director of Corporate Health and Safety Cell phone: 1-610-587-1124

Mark Renick Telephone: 1-(919) 258-4203 Client Representative Cell Phone: 1-(919) 356-7382

DO NOT TRANSPORT SERIOUSLY INJURED CALL LOCAL RESCUE

ATTACHMENT I

HOSPITAL ROUTE MAPS

TABLE OF CONTENTS

Section Page No.

1.0 INTRODUCTION ...... 1 1.1 APPROVALS...... 1 1.2 SITE BACKGROUND...... 1 1.3 SCOPE OF WORK ...... 1

2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES...... 2

3.0 OSHA TRAINING REQUIREMENTS...... 2 3.1 GENERAL TRAINING REQUIREMENTS ...... 2 3.2 PRE-ENTRY MEETING...... 2 3.3 /CPR TRAINING...... 2

4.0 MEDICAL SURVEILLANCE REQUIREMENTS...... 3 4.1 GENERAL MEDICAL SURVEILLANCE REQUIREMENTS ...... 3 4.2 DRUG AND ALCOHOL COMPLIANCE...... 3 4.3 ACCIDENT/INCIDENT MEDICAL SURVEILLANCE ...... 3

5.0 ASSESSMENT...... 3 5.1 CHEMICAL ...... 3 5.1.1 Contaminant Characterization and Potential Routes of Exposure...... 3 5.1.2 General Chemical Data...... 4 5.2 PHYSICAL HAZARDS...... 4 5.2.1 Slipping/Tripping Hazards...... 4 5.2.2 Excessive Noise...... 4 5.2.3 Airborne Particulates...... 4 5.2.4 On-site Traffic...... 4 5.2.5 Ladder Safety...... 5 5.2.6 Air Compressor...... 5 5.2.7 Electrical...... 5 5.2.8 Power Tools...... 5 5.2.9 Back Strain...... 5 5.2.10 Site Security...... 6 5.2.11 Biological Hazards...... 6 5.2.12 Heat Stress...... 6 5.2.13 Cold Stress...... 6 5.2.14 Confined Space Entry...... 7 5.2.15 Fall Hazards...... 7 5.2.16 Hot Work...... 7 5.3 RADIOLOGICAL HAZARDS...... 7

6.0 SITE CONTROL MEASURES ...... 7 6.1 SITE ZONES...... 7 6.1.1 SPECIFIC CONTROL MESURES ...... 8 6.2 COMMUNICATIONS...... 8

7.0 PERSONAL PROTECTIVE EQUIPMENT...... 8 7.1 GENERAL ...... 8 7.2 LEVEL D PROTECTION ...... 8 7.3 MODIFIED LEVEL C PROTECTION ...... 9 7.4 LEVEL C PROTECTION...... 9 7.5 LEVEL A AND B PROTECTION ...... 9

8.0 DECONTAMINATION ...... 9 8.1 GENERAL ...... 9

9.0 EMERGENCY ACTION PLAN ...... 10 9.1 PERSONAL INJURY WITHIN THE EXCLUSION ZONE ...... 10 9.2 PERSONAL INJURY WITHIN THE DECONTAMINATION ZONE...... 11 9.3 PERSONAL INJURY WITHIN THE SUPPORT ZONE ...... 11 9.4 FIRE/EXPLOSION...... 11 9.5 PERSONAL PROTECTIVE EQUIPMENT FAILURE...... 12 9.6 EQUIPMENT FAILURE...... 12

10.0 STANDARD OPERATING SAFETY PROCEDURES, AND WORK PRACTICES...... 12 10.1 WORK PERMITS...... 12 10.2 GENERAL SITE RULES...... 12 10.3 ADDITIONAL STANDARD OPERATING SAFETY PROCEDURES...... 14

FIGURES

FIGURE 1 Route to Local Hospital Map

LIST OF ATTACHMENTS

ATTACHMENT A Site Map ATTACHMENT B Exposure Monitoring Program for the Contaminants of Concern ATTACHMENT C Material Safety Data Sheets ATTACHMENT D Sheets, Standard Operating Procedures and Daily Site Safety ATTACHMENT E Pre-Entry Meeting Notes ATTACHMENT F Sign-Off Sheets

1.0 INTRODUCTION

1.1 APPROVALS

Prepared By: Date: February 2010 (Kara Ford, Project Remediation Scientist)

Reviewed by: Date: February 2010 (Jonathan Waddell, Project Manager)

Approved By: Date: February 2010 (Melissa Orndorff, Local Health and Safety Officer)

1.2 SITE BACKGROUND

Project Name: Moen Incorporated Site Address: 2609 Cox Mill Road, Sanford, North Carolina Nearest Intersection: Cox Mill Road and Avents Ferry Road Township/Municipality: Sanford County: Lee Additional Site Information: Must sign in as visitor at guardhouse and at Main Facility prior to entry

1.3 SCOPE OF WORK

Task 1 – Utility Markout

Task 2 – Surveying

Task 3 - Soil boring installation and sampling

Task 4 - Groundwater monitoring well installation and sampling

Task 5 - Sediment/surface water sampling

Task 6 - Vapor implant installation and sampling

Task 7 -

Task 8 -

1

2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES

Responsibility Name Task Description

Project Manager Jonathan Waddell Oversee and coordinate all budget and technical aspects for the project

Local Health & Safety Melissa Orndorff Oversee and coordinate all health and Officer safety operations for the project site

Site Supervisor GES Personnel Oversee and coordinate all health and safety aspects from the project site

3.0 OSHA TRAINING REQUIREMENTS

3.1 GENERAL TRAINING REQUIREMENTS

All personnel performing activities covered by this plan must be trained in accordance with the requirements of 29 CFR 1910.120(e). The Project Manager will verify and document that all GES personnel meet the applicable training requirements prior to the start of site work, including:

 OSHA 1910.120 initial 40-hour training  OSHA annual eight-hour refresher training within the last year  OSHA eight-hour supervisory training for on-site managers and supervisors and GES requirements  At least one GES personnel will have American Red Cross (or equivalent) first aid and CPR training, and will be present on-site at all times

Documentation for training certification will be maintained by the Local HSO.

Subcontractors chosen to perform well drilling, excavation, materials disposal, utility installation in trenches, and any other site activities where the potential exists for contact with contaminants must provide written documentation of HAZWOPER training, for each of his employees who will be involved in activities at this site, before the start of work.

3.2 PRE-ENTRY MEETING

A Pre-entry meeting reviewing the Site Specific Health and Safety Plan for all proposed work location personnel shall be held and documented in this HASP and in the site log. This meeting shall be prior to the commencement of any on-site work activities.

3.3 FIRST AID/CPR TRAINING

At least one member of the GES staff assigned to the project will have American Red Cross (or equivalent) first aid and cardiopulmonary resuscitation (CPR) training. At least one trained individual will be present on-site at all times. The Local HSO will maintain all training documentation.

2

4.0 MEDICAL SURVEILLANCE REQUIREMENTS

4.1 GENERAL MEDICAL SURVEILLANCE REQUIREMENTS

All personnel performing activities covered by this plan must be active participants in an ongoing medical monitoring program in accordance with the requirements of 29 CFR 1910.120(f). Subcontractors chosen to perform selected site activities must provide written documentation of such, for each employee who will be involved in activities at this site, before the start of work.

4.2 DRUG AND ALCOHOL COMPLIANCE

All personnel performing activities covered by this plan must have had a negative drug and alcohol screen performed within the last 12 months.

4.3 ACCIDENT / INCIDENT MEDICAL SURVEILLANCE

As a follow-up to a work-related injury, all employees are entitled and encouraged to seek medical attention. All accidents and potential exposures must be reported immediately to the Local HSO, who will coordinate with the CHS to arrange for appropriate medical attention. Depending on the type of incident, it may be critical to perform tests within 24 to 48 hours. Failure to report an injury or incident immediately will result in disciplinary action.

Events surrounding near-miss accidents/injuries will be recorded in the daily log and documented in accordance with the GES Incident Reporting Procedures.

5.0 HAZARD ASSESSMENT

5.1 CHEMICAL HAZARDS

5.1.1 Contaminant Characterization and Potential Routes of Exposure

The main routes of exposure for field personnel include:

. Inhalation of contaminant vapors; . Inhalation of contaminated particulate matter; . Ingestion of contaminated material; or . Dermal absorption of contaminated material. . Injection of contaminated material

Site personnel can reduce their exposure potential by:

. Using the proper PPE; . Practicing contamination avoidance; . Following proper decontamination procedures; and . Observing good personnel hygiene.

3

5.1.2 General Chemical Data

In order to protect site personnel from the hazards associated with site contaminants of concern typically found during projects at Industrial Sites, an Exposure Monitoring Program will be implemented to control potential chemical exposures. Attachment B contains this program along with data tables on the contaminants of concern. These tables provide information on each contaminant’s characteristics, such as routes of exposure, health hazards, ionization potentials, exposure limits, etc. All hazardous chemicals brought on-site by GES personnel or its subcontractors will be managed in accordance with 29 CFR 1910.1200 and the GES Hazard Communication Program. This will include: proper labeling, an inventory list of all hazardous materials brought onsite, and a copy of each chemical’s Material (MSDS) will be maintained on-site. Attachment C contains MSDSs of hazardous substances generally used by GES personnel.

5.2 PHYSICAL HAZARDS

A variety of physical hazards may be present, but these hazards are similar to those associated with any field project.

5.2.1 Slip/Trip/Fall/Cuts

* Utilize proper housekeeping practices, such as removal of debris and tools from the work area to keep the area clear of trip hazards. * Use caution tape or barricade fencing where warranted to keep unauthorized personnel from entering the work area. * Replace manhole covers securely to prevent tripping and vehicle accidents. * Use hose cutters when cutting piping. * Walkways and work spaces will be kept clear of cords, hoses, pipes, etc. that cause trip hazards. * If trip hazards cannot be removed from the work area, they shall be taped down and cones shall be placed to identify the hazard.

5.2.2 Excessive Noise

* Use hearing protection during loud mechanical operations such as drilling, Geoprobing and excavating operations. * Use hearing protection inside a remedial shed when equipment is operating loudly.

5.2.3 Airborne Particulate (ears, eyes, nose, mouth, inhalation)

* Eye protection is to be worn at all times on site. * Respiratory protection is to be worn when site activities cause excessive particulates, such as performing carbon changeouts.

5.2.4 On-site Traffic

* Safety vest shall be worn and safety cones placed around the work site as specified in the "GES Traffic Control Procedures.” * Use caution tape or barricade fencing where warranted to keep unauthorized personnel from entering the work area.

4

5.2.5 Ladder Safety

* Ladders must be inspected prior to use. Any damaged ladder will be discarded immediately. * Painted ladders are forbidden. * Never stand on the top step of the ladder. * Extension ladders must extend 36" beyond work area. * Pitch ladders at a 4:1 ratio. * Extension and straight ladders must be tied off. * Fall protection must be worn when working at heights six (6) feet or more above ground.

5.2.6 Air Compressor

* Eye protection is to be worn at all times on site. * Hot steam will burn skin upon contact. * Use proper pressure relief valves before performing O&M on an air compressor.

5.2.7 Electrical

* Inspect all electrical equipment and extension cords prior to use. * All electrical circuits and equipment must be grounded in accordance with the NEC regulations. * Equipment producing sparks are not to be used in operating remedial system sheds. * Lockout/Tagout procedures will be in effect if equipment is to be repaired. * Use three-pronged plugs and heavy-duty extension cords. * A GFCI is required when using an extension cord. * Workers must not have wet hands or be standing in water while plugging/unplugging energized equipment. * Plugs and receptacles will be kept out of water (unless they are approved for submersion).

5.2.8 Power Tools

* Equipment will be inspected for defects prior to use. * Eye protection is to be worn at all times on site. * Employees using tools that may subject their hands to an injury, such as cuts, abrasions, punctures, or burns will wear protective gloves. * Loose or frayed clothing, dangling jewelry, or loose long hair will not be worn when working with power tools. * A GFCI will be used with all power tool operations. * Shielding or guarding will be in effect if applicable.

5.2.9 Back Strain

* Utilize proper lifting procedures when loading and unloading heavy equipment. * Bend down at the knees rather than bending the back. * Use a mechanical lifting device or a lifting aid such as hand carts, drum dolly’s or lift gates when lifting heavy objects.

5

5.2.10 Site Security

* Do not permit anyone who is not properly trained and outfitted with the appropriate PPE to enter the Exclusion or Contamination Reduction Zones (this includes GES personnel, clients, etc.) * Use caution tape or barricade fencing where warranted to keep unauthorized personnel from entering the work area.

5.2.11 Biological Hazards (insects, snakes, poisonous plants and animals)

* Do not touch or contact poisonous plants, such as poison ivy and poison oak. * If available, apply an over-the-counter barrier cream, such as Ivy Block® to prevent contact with plant oils. * Wash hands and arms immediately with soap and water if skin contacts the plants. * Wear long pants with socks pulled over legs to prevent skin contact with plants and insects. * Inspect yourself carefully for insects or ticks after being outdoors. * Spray any wasp/hornet nests with an insect repellant from a safe distance recommended by the product’s manufacturer. * Do not antagonize snakes or wild animals.

5.2.12 Heat Stress

 Know and recognize the signs and symptoms of heat-related illnesses, as follows: Heat cramps Heat exhaustion: Cool, moist, pale, or flushed skin Headache Nausea Dizziness, weakness and exhaustion Heat stroke: Red, hot, dry, skin Changes in consciousness Rapid, weak pulse Rapid, shallow breathing * Adjust work schedules to provide time intervals for intake of juices, juice products and water in an area free from contamination.

5.2.13 Cold Stress

* Know and recognize the signs and symptoms of cold-related illnesses, as follows: Frostbite: Lack of feeling in the affected area Skin that appears waxy, is cold to the touch or is discolored (flushed, white, yellow or blue) * : Shivering Numbness Glassy stare Apathy Loss of consciousness * Have appropriate clothing available and dress in layers to protect against cold weather.

6

* Adjust work schedules to provide sufficient rest periods in a heated area for warming up during operations conducted in cold weather.

5.2.14 Confined Space (CS) Entry

* Confined space entry is prohibited unless authorized by the project manager or local health and safety officer. * All Confined Space Entry procedures must be followed, including and not limited to air monitoring, presence of attendant and permit completion.

5.2.15 Fall Hazards

* OSHA-approved man-lifts and ladders will be used for access to elevated locations. * Employees must wear a safety belt with a lanyard attached to the boom or basket when working from a man-lift. * If the elevated location is inaccessible by a man-lift, the CHS shall be contacted to determine the appropriate fall protection.

5.2.15 Hot Work

* A hot work permit will be completed prior to the start of the work. * The Site Supervisor will conduct a safety briefing on hot work rules and procedures, and all hot work participants will sign the permit. * Hot work will not be performed if there is a possibility of an explosive atmosphere or an -enriched atmosphere. * The Site Supervisor will designate a person for fire watch duty, who will have access to a properly rated fire extinguisher and will remain on-duty for one-half hour after the hot work is complete. * All hot work equipment will be inspected daily, prior to use. If the equipment is found to be defective, it will be removed from the site, or tagged with a "Do Not Use" sign until it is repaired. * All welding and cutting personnel will be trained in the safe operation of their equipment.

5.3 RADIOLOGICAL HAZARDS

Based on available site historical information, there are no radiological contaminants of concern at this site. If site-specific potential radiological information becomes available, the hazards will be addressed in an addendum to the HASP.

6.0 SITE CONTROL MEASURES

6.1 SITE ZONES

A controlled work area should be established in the immediate vicinity of the site activities covered by this plan. Only those persons who can comply with the requirements of this plan should be allowed into this area during any work activities, which may result in exposure to the hazards associated with the specific

7 task being performed. The work site should be marked off with at least the following items from the GES Traffic Control Procedures: Four (4) traffic cones with flags 50 inches high, caution tape, two (2) work area signs or barricades at the site entrances and a flashing amber light on the company vehicle. When activities involve invasive activities on sites in which the Project Manager, Local HSO or the CHS have determined the area to be highly-contaminated, a three-zone system will be used to control the potential spread of contamination. For the purpose of this plan, the following definition of terms is provided:

Exclusion Zone - The immediate area of the work activity to be performed or an area fully enclosing the hazards present.

Contamination Reduction Zone - The transition area between the contaminated area and the uncontaminated area. Decontamination procedures take place within this zone.

Support Zone - The uncontaminated area where exposure to hazardous conditions, is not anticipated.

6.1.1 SPECIFIC CONTROL MEASURES

A fence surrounding the Site as well a full-time, on-site police office will ensure that the health and safety of nearby residential and business communities as they will not be adversely affected by the activities related to the remedial investigation.

6.2 COMMUNICATIONS

Emergency numbers are listed on cover of this HASP. Work will not be conducted on-site without access to a telephone, and site personnel will be informed of the nearest available telephone. If a telephone is not available on site, a cellular phone will be made available for emergency use.

7.0 PERSONAL PROTECTIVE EQUIPMENT

7.1 GENERAL

The level of protection worn by site personnel will be enforced by the Site Supervisor. Levels of protection may be upgraded or downgraded at the discretion of the Local HSO, or CHS, based on real-time air monitoring data and prior site experience. Any changes in the level of protection will be documented. Levels of protection less than those designated in this HASP must first be approved by the CHS.

8

7.2 LEVEL D PROTECTION

Level D PPE provides minimal protection against chemical hazards. A respirator is not required. Level D PPE includes:

. Cotton coveralls or long pants and a shirt with sleeves . Reflective safety vest . Safety glasses . Steel-toe/steel-shank work boots . Work gloves . Hearing protection (as required by task) . Hard Hat (as required by task) . Chemical resistant gloves (as required by task)

7.3 MODIFIED LEVEL C PROTECTION

Modified Level C PPE includes the items listed in Section 7.2 above, and the following items:

. Full-face APR or Half-face APR respirator equipped with the appropriate chemical cartridges

7.4 LEVEL C PROTECTION

Level C PPE provides a higher level of respiratory and skin protection against chemical hazards than Level D. Level C PPE includes the items listed in Section 7.2 above, and the following items:

. Poly-coated tyvek (yellow) or Saranax (shiny white) . Steel-toe/steel-shank work boots and chemical resistant over-boots, or chemical resistant steel-toe/steel shank boots . Inner chemical resistant gloves . Chemical resistant outer gloves . Seal arm, leg, and zipper joints with tape, as required . Half-face or full-face, air-purifying respirator equipped with appropriate cartridges

7.5 LEVEL A AND B PROTECTION

Level A PPE should be worn when the highest level of respiratory and skin protection is needed, or if the contaminants of concern are unknown. Level B PPE should be worn when the highest level of respiratory protection is required, but a lesser level of skin protection is needed. The tasks covered under this HASP do not require the use of Level A or B PPE.

Separate Health and Safety Plans will be developed for Level A/Level B investigations and for Emergency Responses, which may involve the use of Level A and/or Level B health and safety measures.

8.0 DECONTAMINATION

9

8.1 GENERAL

At a minimum, the procedures outlined below shall be followed for decontamination:

. Remove gross contamination from tools, respirator, monitoring equipment, boots, etc., prior to leaving the “exclusion zone”, using paper towels, handi-wipes, etc. . Completely decontaminate soiled equipment in the Contamination Reduction Zone using detergent and water and dispose of all cleaning materials as follows.

1. Due to the small quantity of waste generated during decontamination, it is allowable in most states to dispose of lightly contaminated materials in the site dumpster. It is important, however, to ensure that there is no chance of vapor generation or fluid leaking from the dumpster. At no time are materials containing free product to be disposed of in this manner. In this case, arrangements must be made for use of labeled drums and proper disposal.

2. All decontamination materials including protective sheeting, rags, sorbents, disposable personal protective equipment, and decontamination fluids should be carefully screened with an OVA/OVM prior to disposal to determine relative levels of contamination.

3. Lightly contaminated decontamination fluids should either be treated via the site treatment system prior to discharge or disposed of via the sanitary sewer system. Highly contaminated decontamination fluids must be stored in labeled drums and proper disposal arrangements must be made.

. Dispose of contaminated gloves, Tyvek suits, used cartridges, paper towels, etc., by placing in a plastic bag and discarding in accordance with applicable standards. . Wash hands and face thoroughly with soap and water before lunch or coffee breaks, and as soon as practical after finishing work for the day. . Particular care should be taken to protect any skin injuries. If open wounds exist on hands or forearms, handling chemicals should be restricted or eliminated. . Shower as soon as possible.

9.0 EMERGENCY ACTION PLAN

9.1 PERSONAL INJURY WITHIN THE EXCLUSION ZONE

Site operations shall be temporarily halted and all site personnel shall assemble in the Contamination Reduction Zone. The Site Supervisor shall evaluate the nature of the injury and, if indicated by the hazards present on site, the injured person shall be decontaminated to the extent possible prior to movement to the Support Zone.

10

Contact shall be made for an ambulance and with the designated medical facility (if required). An individual certified in Standard First Aid and Adult CPR may choose to initiate the appropriate first aid. No persons shall reenter the Exclusion Zone until:

a. The conditions resulting in the emergency have been corrected; b. The hazards have been reassessed; c. The Site Safety Plan has been reviewed; and d. Site personnel have been briefed on any changes in the Site Safety Plan.

9.2 PERSONAL INJURY WITHIN THE DECONTAMINATION ZONE

The Site Supervisor shall evaluate the nature of the injury and, if indicated by the hazards present on site, the injured person shall be decontaminated to the extent possible prior to movement to the Support Zone.

Contact shall be made for an ambulance and with the designated medical facility (if required). An individual certified in Standard First Aid and Adult CPR may choose to initiate the appropriate first aid.

If the injury increases risk to other site workers, all site personnel shall move to the Contamination Reduction Zone and site activities will stop until the risks can be assessed and either removed or minimized.

9.3 PERSONAL INJURY WITHIN THE SUPPORT ZONE

The Site Supervisor will assess the nature of the injury and determine if the cause of injury or loss of the injured person will affect continuation of site operations. If the injury will not affect the safety or performance of other site workers, operations may continue, with the person certified in first aid initiating the appropriate first aid and necessary follow up as stated above.

If the injury increases risk to other site workers, all site personnel shall move to the Contamination Reduction Zone and site activities will stop until the risks can be assessed and either removed or minimized.

9.4 FIRE/EXPLOSION

If a fire is observed in the incipient phase (i.e., when it begins) and if the site personnel witnessing the fire feel secure in attempting to control the fire, the individual can attempt to extinguish the fire by using the onsite fire extinguisher. The fire extinguisher should be a 10 or 20 pound (lb)

11

dry chemical, Class A, B, and C extinguisher and is adequate for paper and wood based products (A), flammable and combustible liquids (B), and electrical (C) type fires.

If there is no fire extinguisher available or if site personnel do not feel secure in attempting to extinguish the fire, site personnel shall perform the following:

 Secure the site, if possible.  Evacuate the area using the nearest safe pathway from the area.  Proceed to the nearest phone and call 911 and provide the emergency operator all required information. This will activate the emergency response system. If more than one individual is on the site team, the individual activating the evacuation plan shall verbally communicate to the other site personnel that there is an emergency condition and that they should evacuate from the work area. If contact cannot be made verbally with the other site personnel, any of the following systems can be used as long as the system is audible above background noise. The system can be the site vehicle horn, a whistle, an air horn, or other acceptable device. The system used for initiating an evacuation from the site shall be discussed during the tailgate meeting with the other site personnel prior to beginning the workday. The system that is decided upon shall be documented in the site logbook.

If an explosion or other unsafe condition occurs that the site supervisor had determined will place the other site personnel at risk, then the evacuation system described above should be activated immediately.

9.5 PERSONAL PROTECTIVE EQUIPMENT FAILURE

If any site worker experiences a failure or alteration of protective equipment that affects the protection factor, that person and his/her buddy, if applicable, shall immediately leave the Exclusion Zone. Reentry shall not be permitted until the equipment has been repaired or replaced.

9.6 EQUIPMENT FAILURE

If any other equipment on site fails to operate properly, the Site Supervisor shall be notified and then determine the effect of this failure on continuing operations. If the failure will affect the safety of personnel, all personnel shall leave the Exclusion Zone until the situation is evaluated and appropriate actions are taken.

10.0 STANDARD OPERATING SAFETY PROCEDURES, ENGINEERING CONTROLS, AND WORK PRACTICES

12

10.1 WORK PERMITS

Work permits will be required for confined space entry, and hot work. These permits must be obtained from the Local Health and Safety Officer prior to site work.

13

10.2 General Site Rules

The following general site rules apply to all personnel while on the site:

 Before daily site operation begins, the daily site safety will be completed, the subcontractor’s training documentation will be reviewed (as required by section 3 of this plan), and a pre-entry briefing will be held to review the site's health and safety plan concerns and emergency procedures. This meeting will be registered in this health and safety plan. Attendance will be documented.

 One site worker will be assigned to keep the daily log for all health- and safety-specific site activities, unless otherwise specified.

 All personnel will wear Steel-toe safety boots. Hard hats will be worn when working near heavy equipment (drill rigs, excavating equipment, etc.), or when individuals are working overhead.

 Eye protection and reflective safety vests will be worn at all times while on site.

 Possession of alcohol or illegal substances on the job site or consumption during hours of site operation is strictly prohibited.

 Food and/or beverages are not permitted in the site's Exclusion or Contamination Reduction Zones. Food and/or beverages will be permitted in the Support Zone, if proper decontamination procedures are being followed.

 Smoking is not permitted on site.

 A change in level of protection will be based on air monitoring equipment readings taken in the breathing zone.

 Field personnel will use air monitoring equipment and not their nose to determine site contamination (i.e., sniffing sampled soils or water in jars, confined spaces, open bore holes or trenches, etc.). Odors detected during the course of standard operating procedures, however, should be noted in the daily log.

 Field personnel should not stand with their head directly over a well when it is being opened.

 First aid kit(s) and a fire extinguisher(s) will be available in all company vehicles and/or within 50 feet of the working area.

14

NOTE: Hotwork activities require that a person onsite shall act as a fire watch with a Class A, B, C dry chemical extinguisher is within 30 feet of the activity, and all required Hotwork requirements are satisfied.

Any revisions to the final Site-Specific Health and Safety Plan must be reviewed by the Project/Case Manager and approved by the Local Health and Safety Officer or a Principal Hydro- geologist, at a minimum.

10.3 ADDITIONAL STANDARD OPERATING SAFETY PROCEDURES

See Attachments.

15

ATTACHMENT A

SITE MAPS

Rev. 5/99

ATTACHMENT B

EXPOSURE MONITORING PROGRAM FOR THE CONTAMINATES OF CONCERN

Rev. 5/99 EXPOSURE MONITORING PROGRAM

REAL-TIME MONITORING Photo-ionization Detector (PID): Real-time monitoring for volatile organic compounds (VOCs) will be conducted using a photo-ionization detector (PID). The PID will be used to monitor employee breathing zones during all invasive activities. Table 1 lists PID action levels and response requirements

Combustible Gas Indicator/Oxygen Level Meter: Real-time monitoring for combustible gases and oxygen levels will be conducted using a Combustible Gas Indicator (CGI)/Oxygen Level Meter. The CGI will test for the presence of combustible gases by continuously monitoring the lower explosive limit (LEL) of organic vapors. The CGI will be used to monitor the LEL prior to, and during, Confined Space (CS) entries and during work near an excavation in contaminated soil. The Oxygen Level Meter will detect an oxygen-deficient or oxygen-enriched atmosphere, and will be used prior to, and during, all CS entry activities. Table 2 lists CGI and Oxygen Level Meter action levels and response requirements.

. Calibration of Real-Time Monitoring Equipment: Monitoring and calibration protocols will be performed in accordance with the manufacturer's guidelines. Calibration will be performed, at a minimum, prior to each day's use.

. Calibration logs will be maintained by the Local HSO.

ACTION LEVELS

Tables 1 and 2 list the action levels and response requirements for a PID and CGI/Oxygen Level Meter. Leaving the work area, changing levels of protection, upgrading respiratory protection, or changing work practices is based on maintaining the upper limit of the action level for approximately 10 minutes sustained in the breathing zone (i.e., a non-transient reading) or at the discretion of the Site Supervisor. If changes in protection levels are required, the HSO will notify the Local HSO or the CHS.

TABLE 1 OVM ACTION LEVELS Meter Response Action Required PID response <5 units above No respiratory protection required (i.e., Level D) background PID response >5 units above Leave work area. Work activities shall only continue background (Bkgd) and < 50 once levels have decreased to or below 5 units above units above Bkgd. background. If levels continue above 5 units, only individuals who are medically qualified to wear respiratory protection are permitted to continue work activities. Modified Level C, half-face respiratory protection must be worn; investigate the cause of elevated VOC measurements PID response >50 units and < Respirator Qualified individuals must upgrade to 250 units above Bkgd. Level C, full-face respiratory protection; investigate the cause of elevated VOC measurements PID response > 250 above All staff must retreat from site* Bdgd.

*Note 1: If a retreat becomes necessary, the Local HSO or CHS must be consulted in regard to adding mechanical ventilation or possible changes in work practices. Work will not resume until appropriate corrective measures are implemented.

*Note 2: Because direct reading instruments can not indicate or are not compound specific, concentrations shown on the instruments shall be related to units above background and not parts per million (ppm).

TABLE 2 CGI/OXYGEN LEVEL METER ACTION LEVELS Meter Response Action CGI response < 10 % LEL Continue normal operations. CGI response > 10 % and Eliminate all sources of ignition from the work area; <20 % LEL implement continuous monitoring. However if work is being done in a confined space, retreat from work area.* CGI response > 20 % LEL Discontinue operations; allow to vent; retreat from work area.* Oxygen level < 19.5% Retreat from work area.* Oxygen level > 23.5%

TABLE 3 MATERIALS OF CONCERN FOR RETAIL SITES OSHA TWA ACGIH TLV Contaminant (ppm) (ppm) Hazards Entry Routes IP

Benzene 1 10 1,2,4,5,6,9 Inh, Abs, Ing, Con 9.24 Xylene 100 100 1,2,3,4,5,6,7,10Inh, Abs, Ing, Con 8.56 Ethylbenzene 100 100 1,2,3,10 Inh, Ing, Con 8.76 Toluene 200 50 1,2,3,4,5,7,10 Inh, Abs, Ing, Con 8.82

TWA = Time Weighted Average in parts per million (ppm) C = Ceiling IP = Ionization Potential

1 = irritant to skin 6 = may cause nausea and vomiting 2 = irritant to eyes 7 = may cause liver and kidney damage 3 = irritant to 8 = irritant to GI tract 4 = may cause headache 9 = carcinogen/possible carcinogen 5 = may cause dizziness, lightheadedness 10 = may cause damage to CNS *Note: If a retreat becomes necessary, the Local HSO or CHS will be consulted about adding mechanical ventilation, or possible changes in work practices.

TABLE 4 – ADDITIONAL GENERAL HAZARD EVALUATION

Materials of Concern

Substance Primary Hazards

Trichloroethene - Dizziness, headaches, confusion, nausea, unconsciousness

Trichloroethane - Hypotension, diarrhea and vomiting - Central nervous system depression - Skin, nose, throat irritation

Metheylene Chloride - Dizziness, nausea, numbness in fingers, toes

Lead - Affects central nervous system

Copper - Nose, throat irritation - Exposure to high levels, induces nausea and vomiting

Cyanide - Shortness of breath - Seizures - Affects brain and heart

Chromium - Skin, nose, throat irritation - Stomach ulcers

Non-UST Petroleum - Irritant to Skin - If ingested, induces nausea and vomiting - Flammable - Combustible

PCB’s -Liver and skin damage

Additional Substances: Primary Hazards

ATTACHMENT C

SITE MATERIAL SAFETY DATA SHEETS (MSDS)

Rev. 5/99 Material Safety Data Sheet 1,1-Dichloroethane MSDS

Section 1: Chemical Product and Company Identification Product Name: 1,1-Dichloroethane Contact Information:

Catalog Codes: SLD3280 Sciencelab.com, Inc. 14025 Smith Rd. CAS#: 75-34-3 Houston, Texas 77396 US Sales: 1-800-901-7247 RTECS: KI0175000 International Sales: 1-281-441-4400 TSCA: TSCA 8(b) inventory: 1,1-Dichloroethane Order Online: ScienceLab.com

CI#: Not available. CHEMTREC (24HR Emergency Telephone), call: 1-800-424-9300 Synonym: International CHEMTREC, call: 1-703-527-3887 Chemical Name: 1,1-Dichloroethane For non-emergency assistance, call: 1-281-441-4400 Chemical Formula: C2-H4-Cl2

Section 2: Composition and Information on Ingredients Composition: Name CAS # % by {1,1-}Dichloroethane 75-34-3 100

Toxicological Data on Ingredients: 1,1-Dichloroethane: ORAL (LD50): Acute: 725 mg/kg [Rat].

Section 3: Hazards Identification Potential Acute Health Effects: Hazardous in case of skin contact (irritant), of eye contact (irritant), of ingestion, of inhalation.

Potential Chronic Health Effects: CARCINOGENIC EFFECTS: Classified 2 (Reasonably anticipated.) by NTP. A4 (Not classifiable for human or animal.) by ACGIH. MUTAGENIC EFFECTS: Not available. TERATOGENIC EFFECTS: Not available. DEVELOPMENTAL TOXICITY: Classified Development toxin [POSSIBLE]. The substance is toxic to kidneys, lungs, liver, central nervous system (CNS). Repeated or prolonged exposure to the substance can produce target organs damage.

Section 4: First Aid Measures Eye Contact: Check for and remove any contact lenses. Do not use an eye ointment. Seek medical attention.

p. 1 Skin Contact: After contact with skin, wash immediately with plenty of water. Gently and thoroughly wash the contaminated skin with running water and non-abrasive soap. Be particularly careful to clean folds, crevices, creases and groin. Cover the irritated skin with an emollient. If irritation persists, seek medical attention. Wash contaminated clothing before reusing.

Serious Skin Contact: Wash with a disinfectant soap and cover the contaminated skin with an anti-bacterial cream. Seek immediate medical attention.

Inhalation: Allow the victim to rest in a well ventilated area. Seek immediate medical attention.

Serious Inhalation: Evacuate the victim to a safe area as soon as possible. Loosen tight clothing such as a collar, tie, belt or waistband. If breathing is difficult, administer oxygen. If the victim is not breathing, perform mouth-to-mouth resuscitation. Seek medical attention.

Ingestion: Do not induce vomiting. Examine the lips and mouth to ascertain whether the tissues are damaged, a possible indication that the toxic material was ingested; the absence of such signs, however, is not conclusive. Loosen tight clothing such as a collar, tie, belt or waistband. If the victim is not breathing, perform mouth-to-mouth resuscitation. Seek immediate medical attention.

Serious Ingestion: Not available.

Section 5: Fire and Explosion Data Flammability of the Product: Flammable.

Auto-Ignition Temperature: 458°C (856.4°F)

Flash Points: CLOSED CUP: -17°C (1.4°F). OPEN CUP: -6°C (21.2°F).

Flammable Limits: LOWER: 5.6% UPPER: 11.4%

Products of Combustion: These products are carbon oxides (CO, CO2), halogenated compounds.

Fire Hazards in Presence of Various Substances: Not available.

Explosion Hazards in Presence of Various Substances: Risks of explosion of the product in presence of mechanical impact: Not available. Risks of explosion of the product in presence of static discharge: Not available.

Fire Fighting Media and Instructions: Flammable liquid. SMALL FIRE: Use DRY chemical powder. LARGE FIRE: Use alcohol foam, water spray or fog.

Special Remarks on Fire Hazards: Not available.

Special Remarks on Explosion Hazards: Not available.

Section 6: Accidental Release Measures Small Spill: Absorb with an inert material and put the spilled material in an appropriate waste disposal.

Large Spill: Flammable liquid. Keep away from heat. Keep away from sources of ignition. Stop leak if without risk. Absorb with DRY earth,

p. 2 sand or other non-combustible material. Do not touch spilled material. Prevent entry into sewers, basements or confined areas; dike if needed. Eliminate all ignition sources. Be careful that the product is not present at a concentration level above TLV. Check TLV on the MSDS and with local authorities.

Section 7: Handling and Storage Precautions: Keep locked up Keep away from heat. Keep away from sources of ignition. Ground all equipment containing material. Do not ingest. Do not breathe gas/fumes/ vapour/spray. Wear suitable protective clothing In case of insufficient ventilation, wear suitable respiratory equipment If ingested, seek medical advice immediately and show the container or the label. Avoid contact with skin and eyes Keep away from incompatibles such as oxidizing agents, alkalis.

Storage: Flammable materials should be stored in a separate safety storage cabinet or room. Keep away from heat. Keep away from sources of ignition. Keep container tightly closed. Keep in a cool, well-ventilated place. Ground all equipment containing material. A refrigerated room would be preferable for materials with a flash point lower than 37.8°C (100°F).

Section 8: Exposure Controls/Personal Protection Engineering Controls: Provide exhaust ventilation or other engineering controls to keep the airborne concentrations of vapors below their respective threshold limit value. Ensure that eyewash stations and safety showers are proximal to the work-station location.

Personal Protection: Splash goggles. Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent. Gloves.

Personal Protection in Case of a Large Spill: Splash goggles. Full suit. Vapor respirator. Boots. Gloves. A self contained breathing apparatus should be used to avoid inhalation of the product. Suggested protective clothing might not be sufficient; consult a specialist BEFORE handling this product.

Exposure Limits: TWA: 100 STEL: 250 (ppm) from ACGIH (TLV) [1999] TWA: 100 (ppm) from OSHA (PEL) Australia: TWA: 200 (ppm) Consult local authorities for acceptable exposure limits.

Section 9: Physical and Chemical Properties Physical state and appearance: Liquid. (Oily liquid.)

Odor: Chloroform like odor (Slight.)

Taste: Not available.

Molecular Weight: 98.96 g/mole

Color: Colorless. pH (1% soln/water): Not available.

Boiling Point: 57.3°C (135.1°F)

Melting Point: -96.9°C (-142.4°F)

p. 3 Critical Temperature: 261.5°C (502.7°F)

Specific Gravity: 1.175 (Water = 1)

Vapor Pressure: 180 mm of Hg (@ 20°C)

Vapor Density: 3.44 (Air = 1)

Volatility: Not available.

Odor Threshold: 120 ppm

Water/Oil Dist. Coeff.: Not available.

Ionicity (in Water): Not available.

Dispersion Properties: Partially dispersed in diethyl ether. See in water, diethyl ether.

Solubility: Partially soluble in diethyl ether.

Section 10: Stability and Reactivity Data Stability: The product is stable.

Instability Temperature: Not available.

Conditions of Instability: Not available.

Incompatibility with various substances: Reactive with oxidizing agents, alkalis.

Corrosivity: Corrosive in presence of aluminum.

Special Remarks on Reactivity: Not available.

Special Remarks on Corrosivity: Will attack some forms of plastic and rubber

Polymerization: No.

Section 11: Toxicological Information Routes of Entry: Absorbed through skin. Eye contact. Inhalation. Ingestion.

Toxicity to Animals: Acute oral toxicity (LD50): 725 mg/kg [Rat].

Chronic Effects on Humans: CARCINOGENIC EFFECTS: Classified 2 (Reasonably anticipated.) by NTP. A4 (Not classifiable for human or animal.) by ACGIH. DEVELOPMENTAL TOXICITY: Classified Development toxin [POSSIBLE]. The substance is toxic to kidneys, lungs, liver, central nervous system (CNS).

Other Toxic Effects on Humans: Hazardous in case of skin contact (irritant), of ingestion, of inhalation.

Special Remarks on Toxicity to Animals: Not available.

Special Remarks on Chronic Effects on Humans: Not available.

Special Remarks on other Toxic Effects on Humans: Not available.

p. 4 Section 12: Ecological Information Ecotoxicity: Not available.

BOD5 and COD: Not available.

Products of Biodegradation: Possibly hazardous short term degradation products are not likely. However, long term degradation products may arise.

Toxicity of the Products of Biodegradation: The products of degradation are as toxic as the product itself.

Special Remarks on the Products of Biodegradation: Not available.

Section 13: Disposal Considerations Waste Disposal:

Section 14: Transport Information DOT Classification: CLASS 3: Combustible liquid with a flash point greater than 37.8C (100F). Marine pollutant

Identification: : 1,1-Dichloroethane : UN2362 PG: II

Special Provisions for Transport: Not available.

Section 15: Other Regulatory Information Federal and State Regulations: California prop. 65 (no significant risk level): 1,1-Dichloroethane California prop. 65: This product contains the following ingredients for which the State of California has found to cause cancer which would require a warning under the statute: 1,1-Dichloroethane Rhode Island RTK hazardous substances: 1,1-Dichloroethane Pennsylvania RTK: 1,1-Dichloroethane Florida: 1,1-Dichloroethane Minnesota: 1,1-Dichloroethane Massachusetts RTK: 1,1-Dichloroethane New Jersey: 1,1-Dichloroethane New Jersey spill list: 1,1-Dichloroethane TSCA 8(b) inventory: 1,1-Dichloroethane TSCA 8(a) PAIR: 1,1-Dichloroethane TSCA 8(d) H and S data reporting: 1,1-Dichloroethane: June 1999 TSCA 12(b) one time export: 1,1-Dichloroethane SARA 313 toxic chemical notification and release reporting: 1,1-Dichloroethane: 1% CERCLA: Hazardous substances.: 1,1-Dichloroethane: 1000 lbs. (453.6 kg)

Other Regulations: OSHA: Hazardous by definition of Hazard Communication Standard (29 CFR 1910.1200). EINECS: This product is on the European Inventory of Existing Commercial Chemical Substances.

Other Classifications:

WHMIS (Canada): CLASS B-2: Flammable liquid with a flash point lower than 37.8°C (100°F). CLASS D-2B: Material causing other toxic effects (TOXIC).

DSCL (EEC):

p. 5 R11- Highly flammable. R22- Harmful if swallowed. R37/38- Irritating to respiratory system and skin. R41- Risk of serious damage to eyes. R52- Harmful to aquatic organisms.

HMIS (U.S.A.):

Health Hazard: 2

Fire Hazard: 3

Reactivity: 0

Personal Protection: h

National Fire Protection Association (U.S.A.):

Health: 2

Flammability: 3

Reactivity: 0

Specific hazard:

Protective Equipment: Gloves. Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent. Wear appropriate respirator when ventilation is inadequate. Splash goggles.

Section 16: Other Information References: Not available.

Other Special Considerations: Not available.

Created: 10/09/2005 05:07 PM

Last Updated: 11/06/2008 12:00 PM

The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their particular purposes. In no event shall ScienceLab.com be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if ScienceLab.com has been advised of the possibility of such damages.

p. 6 Page 1 of 8 MATERIAL SAFETY DATA SHEET

1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION

MATHESON TRI-GAS, INC. Emergency Contact: 150 Allen Road Suite 302 CHEMTREC 1-800-424-9300 Basking Ridge, New Jersey 07920 Calls Originating Outside the US: Information: 1-800-416-2505 703-527-3887 (Collect Calls Accepted)

SUBSTANCE: VINYLIDENE CHLORIDE

TRADE NAMES/SYNONYMS: MTG MSDS 239; 1,1-DICHLOROETHENE; 1,1-DICHLOROETHYLENE; VDC; VINYLIDENE CHLORIDE MONOMER; VINYLIDENE DICHLORIDE; VINYLIDENE CHLORIDE, INHIBITED; RCRA U078; UN 1303; C2H2CL2; MAT25070; RTECS KV9275000

CHEMICAL FAMILY: halogens

CREATION DATE: Jan 24 1989 REVISION DATE: Dec 11 2008

2. COMPOSITION, INFORMATION ON INGREDIENTS

COMPONENT: VINYLIDENE CHLORIDE CAS NUMBER: 75-35-4 PERCENTAGE: >99.9

COMPONENT: 4-METHOXYPHENOL CAS NUMBER: 150-76-5 PERCENTAGE: 0.02000

3. HAZARDS IDENTIFICATION

NFPA RATINGS (SCALE 0-4): HEALTH=2 FIRE=4 REACTIVITY=2

EMERGENCY OVERVIEW: COLOR: colorless PHYSICAL FORM: volatile liquid ODOR: faint odor, sweet odor MAJOR HEALTH HAZARDS: harmful if swallowed, respiratory tract irritation, skin irritation, eye irritation, central nervous system depression Page 2 of 8 PHYSICAL HAZARDS: Flammable liquid and vapor. Vapor may cause flash fire. May polymerize. Containers may rupture or explode. May form peroxides during prolonged storage.

POTENTIAL HEALTH EFFECTS: INHALATION: SHORT TERM EXPOSURE: irritation, symptoms of drunkenness, lung congestion, liver damage, convulsions LONG TERM EXPOSURE: kidney damage, tumors SKIN CONTACT: SHORT TERM EXPOSURE: irritation (possibly severe) LONG TERM EXPOSURE: same as effects reported in short term exposure EYE CONTACT: SHORT TERM EXPOSURE: irritation (possibly severe), eye damage LONG TERM EXPOSURE: same as effects reported in short term exposure INGESTION: SHORT TERM EXPOSURE: symptoms of drunkenness, liver damage LONG TERM EXPOSURE: same as effects reported in short term exposure

4. FIRST AID MEASURES

INHALATION: If adverse effects occur, remove to uncontaminated area. Give artificial if not breathing. Get immediate medical attention.

SKIN CONTACT: Wash skin with soap and water for at least 15 minutes while removing contaminated clothing and shoes. Get medical attention, if needed. Thoroughly clean and dry contaminated clothing and shoes before reuse.

EYE CONTACT: Flush eyes with plenty of water for at least 15 minutes. Then get immediate medical attention.

INGESTION: If a large amount is swallowed, get medical attention.

5. FIRE FIGHTING MEASURES

FIRE AND EXPLOSION HAZARDS: Severe fire hazard. The vapor is heavier than air. Vapors or gases may ignite at distant ignition sources and flash back. Vapor/air mixtures are explosive above flash point. Containers may rupture or explode if exposed to heat.

EXTINGUISHING MEDIA: alcohol-resistant foam, carbon dioxide, regular dry chemical, water

Large fires: Use alcohol-resistant foam or flood with fine water spray.

FIRE FIGHTING: Move container from fire area if it can be done without risk. Cool containers with water spray until well after the fire is out. Stay away from the ends of tanks. For fires in cargo or storage area: Cool Page 3 of 8 containers with water from unmanned hose holder or monitor nozzles until well after fire is out. If this is impossible then take the following precautions: Keep unnecessary people away, isolate hazard area and deny entry. Let the fire burn. Withdraw immediately in case of rising sound from venting safety device or any discoloration of tanks due to fire. For tank, rail car or tank truck: Evacuation radius: 800 meters (1/2 mile). Do not attempt to extinguish fire unless flow of material can be stopped first. Flood with fine water spray. Do not scatter spilled material with high-pressure water streams. Cool containers with water spray until well after the fire is out. Apply water from a protected location or from a safe distance. Avoid inhalation of material or combustion by-products. Stay upwind and keep out of low areas. Water may be ineffective.

FLASH POINT: 14 F (-10 C) LOWER FLAMMABLE LIMIT: 5.6% UPPER FLAMMABLE LIMIT: 11.4% AUTOIGNITION: 855 F (457 C) FLAMMABILITY CLASS (OSHA): IA

6. ACCIDENTAL RELEASE MEASURES

AIR RELEASE: Reduce vapors with water spray. Stay upwind and keep out of low areas.

SOIL RELEASE: Dig holding area such as lagoon, pond or pit for containment. Dike for later disposal. Absorb with sand or other non-combustible material.

WATER RELEASE: Collect with absorbent into suitable container. Collect spilled material using mechanical equipment.

OCCUPATIONAL RELEASE: Avoid heat, flames, sparks and other sources of ignition. Remove sources of ignition. Stop leak if possible without personal risk. Reduce vapors with water spray. Small spills: Absorb with sand or other non- combustible material. Collect spilled material in appropriate container for disposal. Large spills: Dike for later disposal. Keep unnecessary people away, isolate hazard area and deny entry. Stay upwind and keep out of low areas. Notify Local Emergency Planning Committee and State Emergency Response Commission for release greater than or equal to RQ (U.S. SARA Section 304). If release occurs in the U.S. and is reportable under CERCLA Section 103, notify the National Response Center at (800)424-8802 (USA) or (202)426- 2675 (USA).

7. HANDLING AND STORAGE

STORAGE: Store and handle in accordance with all current regulations and standards. Subject to storage regulations: U.S. OSHA 29 CFR 1910.106. Grounding and bonding required. Store in a cool, dry place. Store in a well-ventilated area. Keep in the dark. Keep separated from incompatible substances. Store outside or in a detached building. Store with flammable liquids. Store in a tightly closed container. Containers must have overpressure release device. Avoid heat, flames, sparks and other sources of ignition. Keep separated Page 4 of 8 from incompatible substances. Monitor inhibitor content. Avoid exposure to low temperatures or freezing. May form explosive peroxides. Store in a tightly closed container. Avoid contact with light. Store in a cool, dry place. Monitor inhibitor content. Do not evaporate or distill to dryness. Keep separated from incompatible substances.

8. EXPOSURE CONTROLS, PERSONAL PROTECTION

EXPOSURE LIMITS: VINYLIDENE CHLORIDE: 1 ppm (4 mg/m3) OSHA TWA (vacated by 58 FR 35338, June 30, 1993) 5 ppm ACGIH TWA NIOSH TWA (lowest feasible concentration)

VENTILATION: Provide local exhaust ventilation system. Ventilation equipment should be explosion- resistant if explosive concentrations of material are present. Ensure compliance with applicable exposure limits.

EYE PROTECTION: Wear splash resistant safety goggles. Provide an emergency eye wash fountain and quick drench shower in the immediate work area.

CLOTHING: Wear appropriate chemical resistant clothing.

GLOVES: Wear appropriate chemical resistant gloves.

RESPIRATOR: The following respirators and maximum use concentrations are drawn from NIOSH and/or OSHA. At any detectable concentration - Any self-contained breathing apparatus that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode. Any supplied-air respirator with a full facepiece that is operated in a pressure-demand or other positive- pressure mode in combination with an auxiliary self-contained breathing apparatus operated in pressure- demand or other positive-pressure mode. Escape - Any air-purifying full-facepiece respirator (gas mask) with a chin-style, front-mounted or back-mounted organic vapor canister. Any appropriate escape-type, self-contained breathing apparatus. For Unknown Concentrations or Immediately Dangerous to Life or Health - Any supplied-air respirator with a full facepiece that is operated in a pressure-demand or other positive- pressure mode in combination with an auxiliary self-contained breathing apparatus operated in pressure- demand or other positive-pressure mode. Any self-contained breathing apparatus that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode. Page 5 of 8

9. PHYSICAL AND CHEMICAL PROPERTIES

PHYSICAL STATE: liquid COLOR: colorless PHYSICAL FORM: volatile liquid ODOR: faint odor, sweet odor MOLECULAR WEIGHT: 96.64 MOLECULAR FORMULA: C2-H2-CL2 BOILING POINT: 86-90 F (30-32 C) FREEZING POINT: -188 F (-122 C) VAPOR PRESSURE: 400 mmHg @ 14.8 C VAPOR DENSITY (air=1): 3.4 SPECIFIC GRAVITY (water=1): 1.213 WATER SOLUBILITY: 0.04% @ 20 C PH: Not available VOLATILITY: Not available ODOR THRESHOLD: 500 ppm EVAPORATION RATE: Not available COEFFICIENT OF WATER/OIL DISTRIBUTION: Not available SOLVENT SOLUBILITY: Soluble: organic solvents

10. STABILITY AND REACTIVITY

REACTIVITY: May form explosive peroxides. Avoid contact with temperatures above -40 C. Avoid contact with heat, air, light or moisture and monitor inhibitor content. May polymerize. Closed containers may rupture violently.

CONDITIONS TO AVOID: Avoid heat, flames, sparks and other sources of ignition. Containers may rupture or explode if exposed to heat.

INCOMPATIBILITIES: metals, acids, oxidizing materials

HAZARDOUS DECOMPOSITION: Thermal decomposition products: phosgene, halogenated compounds, oxides of carbon

POLYMERIZATION: May polymerize. Avoid contact with heat or light and monitor inhibitor content.

11. TOXICOLOGICAL INFORMATION

VINYLIDENE CHLORIDE: TOXICITY DATA: 10000 mg/m3 inhalation-rat LC50; 200 mg/kg oral-rat LD50 CARCINOGEN STATUS: IARC: Human Inadequate Evidence, Animal Limited Evidence, Group 3; Page 6 of 8 ACGIH: A4 -Not Classifiable as a Human Carcinogen LOCAL EFFECTS: Irritant: inhalation, skin, eye ACUTE TOXICITY LEVEL: Toxic: inhalation, ingestion TARGET ORGANS: central nervous system, liver TUMORIGENIC DATA: Available. MUTAGENIC DATA: Available. REPRODUCTIVE EFFECTS DATA: Available.

12. ECOLOGICAL INFORMATION

ECOTOXICITY DATA: FISH TOXICITY: 74000 ug/L 96 hour(s) LC50 (Mortality) Bluegill (Lepomis macrochirus)

INVERTEBRATE TOXICITY: 224000 ug/L 96 hour(s) LC50 (Mortality) Opossum shrimp (Mysidopsis bahia)

ALGAL TOXICITY: >712000 ug/L 96 hour(s) EC50 (Photosynthesis) Diatom (Skeletonema costatum)

ENVIRONMENTAL SUMMARY: Moderately toxic to aquatic life.

13. DISPOSAL CONSIDERATIONS

Subject to disposal regulations: U.S. EPA 40 CFR 262. Hazardous Waste Number(s): U078. Hazardous Waste Number(s): D029. Dispose of in accordance with U.S. EPA 40 CFR 262 for concentrations at or above the Regulatory level. Regulatory level- 0.7 mg/L. Dispose in accordance with all applicable regulations.

14. TRANSPORT INFORMATION

U.S. DOT 49 CFR 172.101: PROPER SHIPPING NAME: Vinylidene chloride, stabilized ID NUMBER: UN1303 HAZARD CLASS OR DIVISION: 3 PACKING GROUP: I LABELING REQUIREMENTS: 3

CANADIAN TRANSPORTATION OF DANGEROUS GOODS: SHIPPING NAME: Vinylidene chloride, stabilized UN NUMBER: UN1303 CLASS: 3 PACKING GROUP/CATEGORY: I Page 7 of 8

15. REGULATORY INFORMATION

U.S. REGULATIONS: CERCLA SECTIONS 102a/103 HAZARDOUS SUBSTANCES (40 CFR 302.4): VINYLIDINE CHLORIDE: 100 LBS RQ

SARA TITLE III SECTION 302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355 Subpart B): Not regulated.

SARA TITLE III SECTION 304 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355 Subpart C): Not regulated.

SARA TITLE III SARA SECTIONS 311/312 HAZARDOUS CATEGORIES (40 CFR 370 Subparts B and C): ACUTE: Yes CHRONIC: Yes FIRE: Yes REACTIVE: Yes SUDDEN RELEASE: Yes

SARA TITLE III SECTION 313 (40 CFR 372.65): VINYLIDINE CHLORIDE

OSHA PROCESS SAFETY (29 CFR 1910.119): Not regulated.

STATE REGULATIONS: California Proposition 65: Not regulated.

CANADIAN REGULATIONS: WHMIS CLASSIFICATION: BD2

NATIONAL INVENTORY STATUS: U.S. INVENTORY (TSCA): Listed on inventory.

TSCA 12(b) EXPORT NOTIFICATION: VINYLIDENE CHLORIDE CAS NUMBER: 75-35-4 SECTION 4

CANADA INVENTORY (DSL/NDSL): Not determined.

16. OTHER INFORMATION

Page 8 of 8 MSDS SUMMARY OF CHANGES 5. FIRE FIGHTING MEASURES 15. REGULATORY INFORMATION

“RTECS®” is a United States trademark owned and licensed under authority of the U.S. Government, by and through Symyx Software, Inc. Portions ©Copyright 2001, U.S. Government. All rights reserved.

©Copyright 1984-2008 ChemADVISOR, Inc. All rights reserved.

MATHESON TRI-GAS, INC. MAKES NO EXPRESS OR IMPLIED WARRANTIES, GUARANTEES OR REPRESENTATIONS REGARDING THE PRODUCT OR THE INFORMATION HEREIN, INCLUDING BUT NOT LIMITED TO ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR USE. MATHESON TRI-GAS, INC. SHALL NOT BE LIABLE FOR ANY PERSONAL INJURY, PROPERTY OR OTHER DAMAGES OF ANY NATURE, WHETHER COMPENSATORY, CONSEQUENTIAL, EXEMPLARY, OR OTHERWISE, RESULTING FROM ANY PUBLICATION, USE OR RELIANCE UPON THE INFORMATION HEREIN.

Material Safety Data Sheet 1,2-Dichloroethane MSDS

Section 1: Chemical Product and Company Identification Product Name: 1,2-Dichloroethane Contact Information:

Catalog Codes: SLD2521, SLD3721 Sciencelab.com, Inc. 14025 Smith Rd. CAS#: 107-06-2 Houston, Texas 77396 US Sales: 1-800-901-7247 RTECS: KH9800000 International Sales: 1-281-441-4400 TSCA: TSCA 8(b) inventory: 1,2-Dichloroethane Order Online: ScienceLab.com

CI#: Not available. CHEMTREC (24HR Emergency Telephone), call: 1-800-424-9300 Synonym: Ethylene dichloride International CHEMTREC, call: 1-703-527-3887 Chemical Formula: C2H4CL2 For non-emergency assistance, call: 1-281-441-4400

Section 2: Composition and Information on Ingredients Composition: Name CAS # % by Weight {1,2-}Dichloroethane 107-06-2 100

Toxicological Data on Ingredients: 1,2-Dichloroethane: ORAL (LD50): Acute: 670 mg/kg [Rat]. 413 mg/kg [Mouse]. DERMAL (LD50): Acute: 2800 mg/kg [Rabbit]. VAPOR (LC50): Acute: 1414.2 ppm 4 hour(s) [Rat].

Section 3: Hazards Identification Potential Acute Health Effects: Extremely hazardous in case of ingestion. Very hazardous in case of eye contact (irritant), of inhalation. Hazardous in case of skin contact (irritant). Corrosive to skin and eyes on contact. Liquid or spray mist may produce tissue damage particularly on mucous membranes of eyes, mouth and respiratory tract. Skin contact may produce burns. Inhalation of the spray mist may produce severe irritation of respiratory tract, characterized by coughing, choking, or shortness of breath. Inflammation of the eye is characterized by redness, watering, and itching.

Potential Chronic Health Effects: Very hazardous in case of ingestion, of inhalation. CARCINOGENIC EFFECTS: Classified + (PROVEN) by OSHA. Classified 2B (Possible for human.) by IARC. Classified 2 (Reasonably anticipated.) by NTP. MUTAGENIC EFFECTS: Not available. TERATOGENIC EFFECTS: Not available. DEVELOPMENTAL TOXICITY: Not available.

p. 1 The substance is toxic to lungs, the nervous system, liver, mucous membranes. Repeated or prolonged exposure to the substance can produce target organs damage. Repeated or prolonged contact with spray mist may produce chronic eye irritation and severe skin irritation. Repeated or prolonged exposure to spray mist may produce respiratory tract irritation leading to frequent attacks of bronchial infection.

Section 4: First Aid Measures Eye Contact: Check for and remove any contact lenses. Immediately flush eyes with running water for at least 15 minutes, keeping eyelids open. Cold water may be used. Do not use an eye ointment. Seek medical attention.

Skin Contact: If the chemical got onto the clothed portion of the body, remove the contaminated clothes as quickly as possible, protecting your own hands and body. Place the victim under a deluge shower. If the chemical got on the victim's exposed skin, such as the hands : Gently and thoroughly wash the contaminated skin with running water and non-abrasive soap. Be particularly careful to clean folds, crevices, creases and groin. If irritation persists, seek medical attention. Wash contaminated clothing before reusing.

Serious Skin Contact: Wash with a disinfectant soap and cover the contaminated skin with an anti-bacterial cream. Seek immediate medical attention.

Inhalation: Allow the victim to rest in a well ventilated area. Seek immediate medical attention.

Serious Inhalation: Evacuate the victim to a safe area as soon as possible. Loosen tight clothing such as a collar, tie, belt or waistband. If breathing is difficult, administer oxygen. If the victim is not breathing, perform mouth-to-mouth resuscitation. WARNING: It may be hazardous to the person providing aid to give mouth-to-mouth resuscitation when the inhaled material is toxic, infectious or corrosive. Seek immediate medical attention.

Ingestion: Do not induce vomiting. Examine the lips and mouth to ascertain whether the tissues are damaged, a possible indication that the toxic material was ingested; the absence of such signs, however, is not conclusive. Loosen tight clothing such as a collar, tie, belt or waistband. If the victim is not breathing, perform mouth-to-mouth resuscitation. Seek immediate medical attention.

Serious Ingestion: Not available.

Section 5: Fire and Explosion Data Flammability of the Product: Flammable.

Auto-Ignition Temperature: 413°C (775.4°F)

Flash Points: CLOSED CUP: 13°C (55.4°F). OPEN CUP: 18°C (64.4°F).

Flammable Limits: LOWER: 6.2% UPPER: 15.6%

Products of Combustion: These products are carbon oxides (CO, CO2).

Fire Hazards in Presence of Various Substances: Flammable in presence of open flames and sparks. Slightly flammable to flammable in presence of oxidizing materials.

Explosion Hazards in Presence of Various Substances: Risks of explosion of the product in presence of mechanical impact: Not available. Risks of explosion of the product in presence of static discharge: Not available. Slightly explosive to explosive in presence of oxidizing materials.

Fire Fighting Media and Instructions:

p. 2 Flammable liquid, soluble or dispersed in water. SMALL FIRE: Use DRY chemical powder. LARGE FIRE: Use alcohol foam, water spray or fog.

Special Remarks on Fire Hazards: Not available.

Special Remarks on Explosion Hazards: Not available.

Section 6: Accidental Release Measures Small Spill: Absorb with an inert material and put the spilled material in an appropriate waste disposal.

Large Spill: Flammable liquid. Corrosive liquid. Keep away from heat. Keep away from sources of ignition. Stop leak if without risk. Absorb with DRY earth, sand or other non-combustible material. Do not get water inside container. Do not touch spilled material. Use water spray curtain to divert vapor drift. Prevent entry into sewers, basements or confined areas; dike if needed. Eliminate all ignition sources. Call for assistance on disposal. Be careful that the product is not present at a concentration level above TLV. Check TLV on the MSDS and with local authorities.

Section 7: Handling and Storage Precautions: Keep locked up Keep container dry. Keep away from heat. Keep away from sources of ignition. Ground all equipment containing material. Do not ingest. Do not breathe gas/fumes/ vapour/spray. Never add water to this product In case of insufficient ventilation, wear suitable respiratory equipment If ingested, seek medical advice immediately and show the container or the label. Avoid contact with skin and eyes

Storage: Flammable materials should be stored in a separate safety storage cabinet or room. Keep away from heat. Keep away from sources of ignition. Keep container tightly closed. Keep in a cool, well-ventilated place. Ground all equipment containing material. A refrigerated room would be preferable for materials with a flash point lower than 37.8°C (100°F).

Section 8: Exposure Controls/Personal Protection Engineering Controls: Provide exhaust ventilation or other engineering controls to keep the airborne concentrations of vapors below their respective threshold limit value. Ensure that eyewash stations and safety showers are proximal to the work-station location.

Personal Protection: Splash goggles. Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent. Gloves.

Personal Protection in Case of a Large Spill: Splash goggles. Full suit. Vapor respirator. Boots. Gloves. A self contained breathing apparatus should be used to avoid inhalation of the product. Suggested protective clothing might not be sufficient; consult a specialist BEFORE handling this product.

Exposure Limits: TWA: 10 CEIL: 75 (ppm) from ACGIH (TLV) TWA: 40 CEIL: 300 (mg/m3) from ACGIHConsult local authorities for acceptable exposure limits.

Section 9: Physical and Chemical Properties Physical state and appearance: Liquid.

p. 3 Odor: Not available.

Taste: Not available.

Molecular Weight: 98.96 g/mole

Color: Not available. pH (1% soln/water): Not available.

Boiling Point: 83.5°C (182.3°F)

Melting Point: -35.3°C (-31.5°F)

Critical Temperature: Not available.

Specific Gravity: 1.2351 (Water = 1)

Vapor Pressure: 61 mm of Hg (@ 20°C)

Vapor Density: 3.42 (Air = 1)

Volatility: Not available.

Odor Threshold: 26 ppm

Water/Oil Dist. Coeff.: The product is equally soluble in oil and water; log(oil/water) = 0

Ionicity (in Water): Not available.

Dispersion Properties: See solubility in water, methanol, diethyl ether, n-octanol, acetone.

Solubility: Easily soluble in methanol, diethyl ether, n-octanol, acetone. Very slightly soluble in cold water.

Section 10: Stability and Reactivity Data Stability: The product is stable.

Instability Temperature: Not available.

Conditions of Instability: Not available.

Incompatibility with various substances: Not available.

Corrosivity: Non-corrosive in presence of glass.

Special Remarks on Reactivity: Not available.

Special Remarks on Corrosivity: Not available.

Polymerization: No.

Section 11: Toxicological Information Routes of Entry: Eye contact. Inhalation. Ingestion.

Toxicity to Animals:

p. 4 WARNING: THE LC50 VALUES HEREUNDER ARE ESTIMATED ON THE BASIS OF A 4-HOUR EXPOSURE. Acute oral toxicity (LD50): 413 mg/kg [Mouse]. Acute dermal toxicity (LD50): 2800 mg/kg [Rabbit]. Acute toxicity of the vapor (LC50): 1414.2 ppm 4 hour(s) [Rat].

Chronic Effects on Humans: CARCINOGENIC EFFECTS: Classified + (PROVEN) by OSHA. Classified 2B (Possible for human.) by IARC. Classified 2 (Reasonably anticipated.) by NTP. The substance is toxic to lungs, the nervous system, liver, mucous membranes.

Other Toxic Effects on Humans: Extremely hazardous in case of ingestion. Very hazardous in case of inhalation. Hazardous in case of skin contact (irritant).

Special Remarks on Toxicity to Animals: Not available.

Special Remarks on Chronic Effects on Humans: Passes through the placental barrier in animal. Excreted in maternal milk in human.

Special Remarks on other Toxic Effects on Humans: Not available.

Section 12: Ecological Information Ecotoxicity: Not available.

BOD5 and COD: Not available.

Products of Biodegradation: Possibly hazardous short term degradation products are not likely. However, long term degradation products may arise.

Toxicity of the Products of Biodegradation: The products of degradation are more toxic.

Special Remarks on the Products of Biodegradation: Not available.

Section 13: Disposal Considerations Waste Disposal:

Section 14: Transport Information DOT Classification: Class 3: Flammable liquid.

Identification: : Ethylene dichloride : UN1184 PG: II

Special Provisions for Transport: Marine Pollutant

Section 15: Other Regulatory Information Federal and State Regulations: California prop. 65: This product contains the following ingredients for which the State of California has found to cause cancer, birth defects or other reproductive harm, which would require a warning under the statute: 1,2-Dichloroethane California prop. 65: This product contains the following ingredients for which the State of California has found to cause cancer which would require a warning under the statute: 1,2-Dichloroethane Pennsylvania RTK: 1,2-Dichloroethane

p. 5 Massachusetts RTK: 1,2-Dichloroethane TSCA 8(b) inventory: 1,2-Dichloroethane CERCLA: Hazardous substances.: 1,2-Dichloroethane

Other Regulations: OSHA: Hazardous by definition of Hazard Communication Standard (29 CFR 1910.1200).

Other Classifications:

WHMIS (Canada): CLASS B-2: Flammable liquid with a flash point lower than 37.8°C (100°F). CLASS D-1A: Material causing immediate and serious toxic effects (VERY TOXIC). CLASS D-2A: Material causing other toxic effects (VERY TOXIC). CLASS E: Corrosive liquid.

DSCL (EEC): R11- Highly flammable. R20/22- Harmful by inhalation and if swallowed. R38- Irritating to skin. R41- Risk of serious damage to eyes. R45- May cause cancer.

HMIS (U.S.A.):

Health Hazard: 2

Fire Hazard: 3

Reactivity: 0

Personal Protection: h

National Fire Protection Association (U.S.A.):

Health: 2

Flammability: 3

Reactivity: 0

Specific hazard:

Protective Equipment: Gloves. Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent. Wear appropriate respirator when ventilation is inadequate. Splash goggles.

Section 16: Other Information References: Not available.

Other Special Considerations: Not available.

Created: 10/10/2005 08:17 PM

Last Updated: 11/06/2008 12:00 PM

p. 6 The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their particular purposes. In no event shall ScienceLab.com be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if ScienceLab.com has been advised of the possibility of such damages.

p. 7 MATERIAL SAFETY DATA SHEETS

MSDS No: 156-59-2 Date: 03/09/2001 SUPPLIER 6141 Easton Road, Bldg. 1 EMERGENCY PHONE (215) 766-8861 ADDRESS: PO Box 310 NUMBER: Plumsteadville, PA 18949-0310 1. CHEMICAL PRODUCT PRODUCT 1,2-DICHLOROETHYLENE SYNONYMS:cis-Dichloroethylene NAME: (CIS) 2. COMPOSITION, INFORMATION ON INGREDIENTS Exposure Limits (PPM) ACGIH OSHA Other Ingredient Name Formula CAS # Concentration MAC TLV PEL STEL 1,2- C2H2CL2 156- 99+% 200 NE NE NE DICHLOROETHYLENE (CIS) 59-2

Note: NE = NONE ESTABLISHED S/A = SIMPLE ASPHYXIANT 3. HAZARD INDENTIFICATION * * * EMERGENCY OVERVIEW * * * Flammable liquid and vapor. Can form explosive mixtures with air. Can cause irritation to eyes, skin and respiratory tract.

POTENTIAL HEALTH EFFECTS

ROUTES OF ENTRY: Inhalation , Ingestion

ACUTE EFFECTS: Vapor or mist is irritating to the eyes, skin, mucous membrane, and upper respiratory tract. Skin and eye irritation may occur. High concentrations may have a narcotic effect.

CHRONIC EFFECTS: Kidney and liver damage.

MEDICAL CONDITIONS AGGRAVATED BY OVEREXPOSURE: None known

OTHER EFFECTS OF OVEREXPORSURE: None

CARCINOGENICITY (US ONLY): NTP - No IARC MONOGRAPHS - No OSHA REGULATED - No 4. FIRST AID MEASURES

INHALATION: Immediately remove victim to fresh air. If breathing has stopped, give artificial respiration. If breathing is difficult, give oxygen.

EYE CONTACT: Immediately flush with copious amounts of water for at least 15 minutes.

SKIN CONTACT: Immediately flush with copious amounts of water for at least 15 minutes while removing contaminated clothing.

INGESTION: Never give anything by mouth to an unconscious person. Have conscious and alert person drink 1 to 2 glasses of water. Induce vomiting after victim drinks water.

IN EVENT OF EXPOSURE, CONSULT A PHYSICIAN

NOTE TO PHYSICIAN: None

5. FIRE FIGHTING MEASURES

FLASH POINT: 2 deg.C

AUTOIGNITION TEMPERATURE: 460 deg. C

FLAMMABLE LIMITS: Vol.% LOWER: 5.6 UPPER: 12.80

EXTINGUISHING MEDIA: Carbon dioxide, foam, or dry chemical.

SPECIAL FIRE FIGHTING INSTRUCTION AND EQUIPMENT: Wear self-contained breathing apparatus and full protective clothing. Keep fire exposed cylinders cool with water spray.

HAZARDOUS COMBUSTION PRODUCTS: Toxic carbon monoxide, hydrogen chloride and phosgene.

UNUSUAL FIRE AND EXPLOSION HAZARDS: Cylinder rupture may occur under fire conditions. Emits toxic fumes under fire conditions. Vapors may travel a considerable distance to the source of ignition and flash back.

6. ACCIDENTAL RELEASE MEASURES

CLEAN UP PROCEDURES: Evacuate and ventilate area. Remove leaking cylinder to exhaust hood or safe outdoor area. Shut off source if possible and remove source of heat. Absorb with sand or vermiculite and place in closed containers for disposal.

SPECIALIZED EQUIPMENT: None

7. HANDLING AND STORAGE

PRECAUTIONS TO BE TAKEN IN HANDLING: Secure cylinder when using to protect from falling. Use suitable hand truck to move cylinders. Use only in a well-ventilated area.

PRECAUTIONS TO BE TAKEN IN STORAGE: Store in well ventilated areas. Keep valve protection cap on cylinders when not in use. Store away from oxidizers, combustible materials, and source of ignition or heat.

8. EXPOSURE CONTROLS / PERSONAL PROTECTION

ENGINEERING CONTROLS: Provide adequate general and local exhaust ventilation to maintain concentrations below exposure and flammable limits.

EYE / FACE PROTECTION: Goggles. A safety shower and eyewash station should be readily available.

SKIN PROTECTION: Wear suitable protective clothing.

RESPIRATORY PROTECTION: Use a self-contained breathing apparatus in case of emergency or non-routine use.

OTHER PROTECTIVE EQUIPMENT: Safety shoes when handling cylinders.

9. PHYSICAL AND CHEMICAL PROPERTIES

APPEARANCE: Colorless

ODOR: Pleasant aromatic odor

PHYSICAL PRESSURE: Liquid

VAPOR PRESSURE: @41 deg.C: 400 mm Hg

VAPOR DENSITY (AIR=1): 3.34

BOILING POINT (C): 59

SOLUBILITY IN WATER: Insoluble

SPECIFIC GRAVITY (H2O=1): @20 deg.C: 1.284

EVAPORATION RATE: N/Av

ODOR THRESHOLD: N/Av

10. STABILITY AND REACTIVITY

STABILITY: Stable under normal storage conditions.

CONDITIONS TO AVOID: Storage in poorly ventilated areas. Storage near a heat source.

MATERIALS TO AVOID: Oxidizing agents, air and moisture. Nitrogen dioxide, sodium, potassium hydroxide.

HAZARDOUS POLYMERIZATION: Will not occur.

HAZARDOUS DECOMPOSITION: HCl gas, phosgene gas, CO and oxides of chlorine.

11. TOXICOLOGICAL INFORMATION

LETHAL CONCENTRATION (LC50): None established

LETHAL DOSE 50 (LD50): N/Ap

TERATOGENICITY: N/Ap

REPRODUCTIVE EFFECTS: N/Ap

MUTAGENICITY: N/Ap

12. ECOLOGICAL INFORMATION No adverse ecological effects are expected.

13. DISPOSAL CONSIDERATIONS

WASTE DISPOSAL METHOD: Dispose of non-refillable cylinders in accordance with federal, state and local regulations. Allow gas to vent slowly to atmosphere in an unconfined area or exhaust hood. If the cylinders are the refillable type, return cylinders to supplier with any valve outlet plugs or caps secured and valve protection caps in place. Waste can be burned in an approved incinerator equipped with an afterburner and scrubber.

14. TRANSPORT INFORMATION

CONCENTRATION: 99+%

DOT DESCRIPTION (US ONLY):

PROPER SHIPPING NAME: Flammable liquids, n.o.s. HAZARD CLASS: 3 (flammable), Packing Group I INDENTIFICATION NUMBER: UN1993 REPORTABLE QUANTITIES: 1000 lb. LABELING: FLAMMABLE LIQUID

ADR / RID (EU Only): Class 3, 3(b)

SPECIAL PRECAUTIONS: Cylinders should be transported in a secure upright position in a well ventilated truck.

15. REGULATORY INFORMATION

OSHA: Process Safety Management: Material is not listed in appendix A of 29 CFR 1910.119 as highly hazardous chemical.

TSCA: Material is listed in TSCA inventory.

SARA: The threshold planning quantity for material is 10,000 lbs.

EU NUMBER: N/Av

NUMBER IN ANNEX 1 OF DIR 67/548: Material is listed in annex 1.

EU CLASSIFICATION: N/Av

R: 22-33-35-64

S: 15-22-23-27-36-65-71-76-104

16. OTHER INFORMATION

OTHER PRECAUTIONS: Protect containers from physical damage. Do not deface cylinders or labels. Cylinders should be refilled by qualified producers of compressed gas. Shipment of a compressed which has not been filled by the owner or with his written consent is a violation of federal law (49 CFR).

ABBREVIATIONS: N/Ap - Not Applicable N/Av - Not Available SA - Simple Asphyxiant NE - None Established

DISCLAIMER: Information included in this document is given to the best of our knowledge, however, no warranty is made that the information is accurate or complete. We do not accept any responsibility for damages by the use of the document. Material Safety Data Sheet 1,1,1-Trichloroethane

ACC# 14370 Section 1 - Chemical Product and Company Identification

MSDS Name: 1,1,1-Trichloroethane Catalog Numbers: AC294930000, AC294930250, AC294932500, AC327940000, AC327940010, AC327942500, S80231, T391-20, T391-4, T398-4 Synonyms: Methyl chloroform; Methyltrichloromethane; Trichloroethane; Trichloromethylmethane; 1,1,1-TCE. Company Identification: Fisher Scientific 1 Reagent Lane Fair Lawn, NJ 07410 For information, call: 201-796-7100 Emergency Number: 201-796-7100 For CHEMTREC assistance, call: 800-424-9300 For International CHEMTREC assistance, call: 703-527-3887

Section 2 - Composition, Information on Ingredients

CAS# Chemical Name Percent EINECS/ELINCS 71-55-6 1,1,1-Trichloroethane >96 200-756-3 123-91-1 1,4-Dioxane 2.5 204-661-8 106-88-7 1,2-Butylene oxide 0.47 203-438-2 75-52-5 Nitromethane 0.34 200-876-6

Section 3 - Hazards Identification

EMERGENCY OVERVIEW

Appearance: colorless liquid. Warning! Causes eye, skin, and respiratory tract irritation. May be harmful if inhaled. May cause central nervous system depression. This is a CFC substance which destroys in the upper atmosphere. Destruction of the ozone layer can lead to increased ultraviolet radiation which, with excess exposure to sunlight, can lead to an increase in skin cancer and eye cataracts. Target Organs: Central nervous system, respiratory system, eyes, skin.

Potential Health Effects Eye: Causes mild eye irritation. Vapors may cause eye irritation. Skin: Causes skin irritation. Prolonged or repeated contact may dry/defat the skin and cause irritation. 1,4-Dioxane may cause an allergic skin reaction, and absorption of this substance may cause systemic toxicty. Methyl chloroform is an acknowledged skin irritant in guinea pigs, where a single topical application of 1 ml or repeated contact over 3 days causes edema, erythema, inflammation, and cellular degeneration. There is one case report of allergic contact dermatitis in a worker exposed to 1,1,1-trichloroethane. It is not possible to draw any conclusions from this single report. Ingestion: Causes gastrointestinal irritation with nausea, vomiting and diarrhea. Low hazard for usual industrial handling. Although there are no case reports of aspiration, it was induced in rats in one study. In addition, based on its physical properties (viscosity and ), it seems likely that 1,1,1-trichloroethane can be aspirated. Inhalation: Inhalation of high concentrations may cause central nervous system effects characterized by nausea, headache, dizziness, unconsciousness and coma. May cause narcotic effects in high concentration. Causes irritation of the mucous membrane and upper respiratory tract. Numerous deaths due to depression of CNS control of respiration and fatal cardiac arrhythmia have been reported from methyl chloroform inhalation (accidental or intentional) in poorly ventilated rooms, pits, tanks, and other small areas (Documentation of the TLV). Cases of intentional abuse of 1,1,1-trichloroethane in substances such as typewriter correction fluid for euphoric symptoms have been documented. Chronic: Prolonged or repeated skin contact may cause defatting and dermatitis. Exposure to high concentrations may cause central nervous system depression. Studies with solvent abusers have established that severe cardiac arrhythmias may result from cardiac sensitization, where the heart has an increased response to circulating epinephrine. In these cases, exposures by far exceeded occupational relevant levels. Liver effects have been observed in some animal studies at high

Section 4 - First Aid Measures

Eyes: In case of contact, immediately flush eyes with plenty of water for a t least 15 minutes. Get medical aid. Skin: In case of contact, flush skin with plenty of water. Remove contaminated clothing and shoes. Get medical aid if irritation develops and persists. Wash clothing before reuse. Ingestion: Potential for aspiration if swallowed. Get medical aid immediately. Do not induce vomiting unless directed to do so by medical personnel. Never give anything by mouth to an unconscious person. If vomiting occurs naturally, have victim lean forward. Inhalation: If inhaled, remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get medical aid. Notes to Physician: Alcoholic beverage consumption may enhance the toxic effects of this substance.

Section 5 - Fire Fighting Measures

General Information: As in any fire, wear a self-contained breathing apparatus in pressure- demand, MSHA/NIOSH (approved or equivalent), and full protective gear. During a fire, irritating and highly toxic gases may be generated by thermal decomposition or combustion. Use water spray to keep fire-exposed containers cool. Substance is nonflammable. Vapors may accumulate in confined spaces Methyl chloroform burns only in excess oxygen or in air if a strong source of ignition is present. No flash point in conventional closed tester; however, vapors in containers can explode if subjected to high energy source. Extinguishing Media: Use extinguishing media most appropriate for the surrounding fire. Flash Point: Not applicable. Autoignition Temperature: 500 deg C ( 932.00 deg F) Explosion Limits, Lower:7.0 vol % Upper: 16 vol % NFPA Rating: (estimated) Health: 2; Flammability: 1; Instability: 0 Section 6 - Accidental Release Measures

General Information: Use proper personal protective equipment as indicated in Section 8. Spills/Leaks: Absorb spill with inert material (e.g. vermiculite, sand or earth), then place in suitable container. Clean up spills immediately, observing precautions in the Protective Equipment section. Provide ventilation. Approach spill from upwind.

Section 7 - Handling and Storage

Handling: Wash thoroughly after handling. Remove contaminated clothing and wash before reuse. Use with adequate ventilation. Avoid contact with eyes, skin, and clothing. Keep container tightly closed. Avoid breathing vapor. Storage: Store in a cool, dry, well-ventilated area away from incompatible substances. Do not store in aluminum containers.

Section 8 - Exposure Controls, Personal Protection

Engineering Controls: Facilities storing or utilizing this material should be equipped with an eyewash facility and a safety shower. Use adequate general or local exhaust ventilation to keep airborne concentrations below the permissible exposure limits. Exposure Limits Chemical Name ACGIH NIOSH OSHA - Final PELs 350 ppm TWA; 450 ppm 350 ppm TWA; 1900 1,1,1-Trichloroethane 700 ppm IDLH STEL mg/m3 TWA 20 ppm TWA; Skin - potential significant 100 ppm TWA; 360 1,4-Dioxane contribution to overall 500 ppm IDLH mg/m3 TWA exposure by the cutaneous r oute 1,2-Butylene oxide none listed none listed none listed 100 ppm TWA; 250 Nitromethane 20 ppm TWA 750 ppm IDLH mg/m3 TWA

OSHA Vacated PELs: 1,1,1-Trichloroethane: 350 ppm TWA; 1900 mg/m3 TWA 1,4-Dioxane: 25 ppm TWA; 90 mg/m3 TWA 1,2-Butylene oxide: No OSHA Vacated PELs are listed for this chemical. Nitromethane: 100 ppm TWA; 250 mg/m3 TWA Personal Protective Equipment Eyes: Wear chemical splash goggles. Skin: Wear appropriate protective gloves to prevent skin exposure. Clothing: Wear appropriate protective clothing to minimize contact with skin. Respirators: A respiratory protection program that meets OSHA's 29 CFR 1910.134 and ANSI Z88.2 requirements or European Standard EN 149 must be followed whenever workplace conditions warrant respirator use.

Section 9 - Physical and Chemical Properties

Physical State: Liquid Appearance: colorless Odor: Sweet, mild chloroform-like. pH: Not applicable. Vapor Pressure: 100 mm Hg @ 20 deg C Vapor Density: 4.55 (air=1) Evaporation Rate:1.0 (carbon tetrachloride=1) Viscosity: 0.86 cP @ 20 deg C Boiling Point: 74 deg C Freezing/Melting Point:-33 deg C Decomposition Temperature:> 260 deg C Solubility: Insoluble. Specific Gravity/Density:1.338 (water=1) Molecular Formula:C2H3Cl3 Molecular Weight:133.38

Section 10 - Stability and Reactivity

Chemical Stability: Because of 1,1,1-TCE's reactivity with magnesium, aluminum, & their alloys, inhibitors (like 1,4-dioxane, 1,3-dioxolane, isobutyl alcohol, or nitroethane) are often added to increase the stability of the solvent & prevent corrosion of metal parts. 1,1,1-Trichloroethane reacts slowly with water to produce hydrochloric acid. Conditions to Avoid: High temperatures, ignition sources, moisture, confined spaces. Incompatibilities with Other Materials: Strong oxidizing agents, strong bases, aluminum, magnesium, chemically active metals. Hazardous Decomposition Products: Hydrogen chloride, chlorine, phosgene, carbon monoxide, carbon dioxide. Hazardous Polymerization: Will not occur.

Section 11 - Toxicological Information

RTECS#: CAS# 71-55-6: KJ2975000 CAS# 123-91-1: JG8225000 CAS# 106-88-7: EK3675000 CAS# 75-52-5: PA9800000 LD50/LC50: CAS# 71-55-6: Draize test, rabbit, eye: 100 mg Mild; Draize test, rabbit, eye: 2 mg/24H Severe; Draize test, rabbit, skin: 5 gm/12D (Intermittent) Mild; Draize test, rabbit, skin: 20 mg/24H Moderate; Inhalation, mouse: LC50 = 3911 ppm/2H; Inhalation, mouse: LC50 = 29492 ppm/10M; Inhalation, rat: LC50 = 17000 ppm/4H; Inhalation, rat: LC50 = 14250 ppm/7H; Inhalation, rat: LC50 = 20000 ppm/2H; Oral, mouse: LD50 = 6 gm/kg; Oral, rabbit: LD50 = 5660 mg/kg; Oral, rat: LD50 = 9600 CAS# 123-91-1: Draize test, rabbit, eye: 100 mg Severe; Draize test, rabbit, eye: 100 mg/24H Moderate; Inhalation, mouse: LC50 = 37 gm/m3/2H; Inhalation, rat: LC50 = 46 gm/m3/2H; Oral, mouse: LD50 = 5300 mg/kg; Oral, rabbit: LD50 = 2 gm/kg; Oral, rat: LD50 = 4200 mg/kg; Skin, rabbit: LD50 = 7600 uL/kg; .

CAS# 106-88-7: Draize test, rabbit, eye: 100 mg/24H Moderate; Draize test, rabbit, skin: 500 mg/24H Mild; Inhalation, rat: LC50 = 6300 mg/m3/4H; Oral, rat: LD50 = 500 mg/kg; Skin, rabbit: LD50 = 2100 uL/kg; .

CAS# 75-52-5: Oral, mouse: LD50 = 950 mg/kg; Oral, rat: LD50 = 940 mg/kg; .

Carcinogenicity: CAS# 71-55-6: Not listed by ACGIH, IARC, NTP, or CA Prop 65. CAS# 123-91-1:

z ACGIH: A3 - Confirmed animal carcinogen with unknown relevance to humans z California: carcinogen, initial date 1/1/88 z NTP: Suspect carcinogen z IARC: Group 2B carcinogen

CAS# 106-88-7:

z ACGIH: Not listed. z California: Not listed. z NTP: Not listed. z IARC: Group 2B carcinogen

CAS# 75-52-5:

z ACGIH: A3 - Confirmed animal carcinogen with unknown relevance to humans z California: carcinogen, initial date 5/1/97 z NTP: Suspect carcinogen z IARC: Group 2B carcinogen

Epidemiology: No information found Teratogenicity: Animal evidence suggests that 1,1,1-TCE is not teratogenic at exposures which are not maternally toxic. Slight fetotoxicity (for example, reduced fetal weight) has been reported at doses which were not maternally toxic. Reproductive Effects: Animal evidence suggests that 1,1,1-TCE does not cause reproductive effects. Mutagenicity: Evidence from studies using live animals suggests that 1,1,1-trichloroethane is not mutagenic. Neurotoxicity: Some studies using sensitive neurobehavioural tests have shown altered scores for exposed workers. However, whether or not these results indicate nervous system damage is not clear. Other studies with 1,1,1-TCE have not shown any changes. Other Studies:

Section 12 - Ecological Information

Ecotoxicity: Fish: Fathead Minnow: EC50 = 52.9 mg/L; 96 Hr; Flow-through at 25.5°CFish: Bluegill/Sunfish: LC50 = 72 mg/L; 96 Hr; Static bioassayFish: Fathead Minnow: LC50 = 52.9 mg/L; 96 Hr; Flow-through at 25.5°CFish: Sheepshead minnow: LC50 = 53-72 mg/L; 96 Hr; UnspecifiedWater flea Daphnia: EC50 > 530 mg/L; 48 Hr; Unspecified Releases to surface water will decrease in concn almost entirely due to evaporation. Spills on land will decrease in concentration almost entirely due to volatilization and leaching. Environmental: Releases to air may be transported long distances and partially return to earth in rain. In the troposphere, 1,1,1-trichloroethane will degrade very slowly by photooxidation and also slowly diffuse to the stratosphere where photodegradation will be rapid. This substance has a high potential for oxone depletion. Physical: No information available. Other: No information available.

Section 13 - Disposal Considerations

Chemical waste generators must determine whether a discarded chemical is classified as a hazardous waste. US EPA guidelines for the classification determination are listed in 40 CFR Parts 261.3. Additionally, waste generators must consult state and local hazardous waste regulations to ensure complete and accurate classification. RCRA P-Series: None listed. RCRA U-Series: CAS# 71-55-6: waste number U226. CAS# 123-91-1: waste number U108.

Section 14 - Transport Information

US DOT Canada TDG Shipping Name: 1,1,1-TRICHLOROETHANE 1,1,1-TRICHLOROETHANE Hazard Class: 6.1 6.1 UN Number: UN2831 UN2831 Packing Group: III III

Section 15 - Regulatory Information

US FEDERAL

TSCA CAS# 71-55-6 is listed on the TSCA inventory. CAS# 123-91-1 is listed on the TSCA inventory. CAS# 106-88-7 is listed on the TSCA inventory. CAS# 75-52-5 is listed on the TSCA inventory. Health & Safety Reporting List CAS# 71-55-6: Effective 10/4/82, Sunset 10/4/92 CAS# 106-88-7: Effective 10/4/82, Sunset 10/4/92 CAS# 75-52-5: Effective 4/13/89, Sunset 12/19/95 Chemical Test Rules CAS# 71-55-6: 40 CFR 799.5000 Section 12b None of the chemicals are listed under TSCA Section 12b. TSCA Significant New Use Rule None of the chemicals in this material have a SNUR under TSCA. CERCLA Hazardous Substances and corresponding RQs CAS# 71-55-6: 1000 lb final RQ; 454 kg final RQ CAS# 123-91-1: 100 lb final RQ; 45.4 kg final RQ CAS# 106-88-7: 100 lb final RQ; 45.4 kg final RQ SARA Section 302 Extremely Hazardous Substances None of the chemicals in this product have a TPQ. SARA Codes CAS # 71-55-6: immediate. CAS # 123-91-1: delayed, fire. CAS # 106-88-7: immediate. CAS # 75-52-5: immediate, delayed, fire, reactive. Section 313 This material contains 1,1,1-Trichloroethane (CAS# 71-55-6, >96%),which is subject to the reporting requirements of Section 313 of SARA Title III and 40 CFR This material contains 1,4-Dioxane (CAS# 123-91-1, 2.5%),which is subject to the reporting requirements of Section 313 of SARA Title III and 40 CFR Part 373. This material contains 1,2-Butylene oxide (CAS# 106-88-7, 0.47%),which is subject to the reporting requirements of Section 313 of SARA Title III and 40 CFR Part 373. Clean Air Act: CAS# 71-55-6 is listed as a hazardous air pollutant (HAP). CAS# 123-91-1 is listed as a hazardous air pollutant (HAP). CAS# 106-88-7 is listed as a hazardous air pollutant (HAP). CAS# 71-55-6 is listed as a Class 1 ozone depletor with an 0.1 ODP; 110 GWP This material does not contain any Class 2 Ozone depletors. Clean Water Act: None of the chemicals in this product are listed as Hazardous Substances under the CWA. CAS# 71-55-6 is listed as a Priority Pollutant under the Clean Water Act. CAS# 71-55-6 is listed as a Toxic Pollutant under the Clean Water Act. OSHA: CAS# 75-52-5 is considered highly hazardous by OSHA. STATE CAS# 71-55-6 can be found on the following state right to know lists: California, New Jersey, Pennsylvania, Minnesota, Massachusetts. CAS# 123-91-1 can be found on the following state right to know lists: California, New Jersey, Pennsylvania, Minnesota, Massachusetts. CAS# 106-88-7 can be found on the following state right to know lists: New Jersey, Pennsylvania, Minnesota, Massachusetts. CAS# 75-52-5 can be found on the following state right to know lists: California, New Jersey, Pennsylvania, Minnesota, Massachusetts.

California Prop 65 WARNING: This product contains 1,4-Dioxane, a chemical known to the state of California to cause cancer. WARNING: This product contains Nitromethane, a chemical known to the state of California to cause cancer. California No Significant Risk Level: CAS# 123-91-1: 30 æg/day NSRL

European/International Regulations European Labeling in Accordance with EC Directives Hazard Symbols: XN N Risk Phrases: R 20 Harmful by inhalation. R 59 Dangerous for the ozone layer.

Safety Phrases: S 24/25 Avoid contact with skin and eyes. S 59 Refer to manufacturer/supplier for information on recovery/recy cling. S 61 Avoid release to the environment. Refer to special instructions /safety data sheets.

WGK (Water Danger/Protection) CAS# 71-55-6: 3 CAS# 123-91-1: 2 CAS# 106-88-7: 3 CAS# 75-52-5: 2 Canada - DSL/NDSL CAS# 71-55-6 is listed on Canada's DSL List. CAS# 123-91-1 is listed on Canada's DSL List. CAS# 106-88-7 is listed on Canada's DSL List. CAS# 75-52-5 is listed on Canada's DSL List. Canada - WHMIS This product has a WHMIS classification of D1B, D2B. This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations and the MSDS contains all of the information required by those regulations. Canadian Ingredient Disclosure List CAS# 71-55-6 is listed on the Canadian Ingredient Disclosure List. CAS# 123-91-1 is listed on the Canadian Ingredient Disclosure List. CAS# 75-52-5 is listed on the Canadian Ingredient Disclosure List.

Section 16 - Additional Information

MSDS Creation Date: 6/11/1999 Revision #5 Date: 3/16/2007

The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their particular purposes. In no event shall Fisher be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if Fisher has been advised of the possibility of such damages.

Material Safety Data Sheet Trichloroethylene ACC# 23850 Section 1 - Chemical Product and Company Identification

MSDS Name: Trichloroethylene Catalog Numbers: AC158310000, AC158310025, AC421520000, AC421520040, AC421520200, AC421525000, 15831-0010, S80327ACS-1, S80327ACS-2, T340-4, T341-20, T341-4, T341-500, T341J4, T403-4 Synonyms: Ethylene trichloride; 1,1,2-Trichloroethylene; TCE. Company Identification: Fisher Scientific 1 Reagent Lane Fair Lawn, NJ 07410 For information, call: 201-796-7100 Emergency Number: 201-796-7100 For CHEMTREC assistance, call: 800-424-9300 For International CHEMTREC assistance, call: 703-527-3887

Section 2 - Composition, Information on Ingredients

CAS# Chemical Name Percent EINECS/ELINCS 79-01-6 Trichloroethylene 99+ 201-167-4

Section 3 - Hazards Identification

EMERGENCY OVERVIEW

Appearance: APHA: 15 max liquid. Warning! Harmful to aquatic organisms; may cause long-term adverse effects in the aquatic environment. Breathing vapors may cause drowsiness and dizziness. Possible risks of irreversible effects. Cancer hazard. Causes eye and skin irritation. May cause respiratory tract irritation. May cause liver and kidney damage. May cause central nervous system effects. Target Organs: Kidneys, central nervous system, liver, spleen, respiratory system, eyes, skin.

Potential Health Effects Eye: Causes eye irritation. Contact with trichloroethylene causes pain but no permanent injury to the eyes. (Doc of TLV) Skin: Causes skin irritation. May be harmful if absorbed through the skin. Ingestion: May cause irritation of the digestive tract. May be harmful if swallowed. May cause central nervous system effects. Inhalation: May cause respiratory tract irritation. May cause liver and kidney damage. May be harmful if inhaled. May cause central nervous system effects. The chief symptoms of TCE exposure were found to be abnormal fatigue, irritability, headache, gastric disturbances, and intolerance to alcohol. (Doc to TLV) Chronic: Prolonged or repeated skin contact may cause defatting and dermatitis. May cause liver and kidney damage. May cause cancer in humans. Repeated exposure may cause damage to the spleen. Adverse reproductive effects have been reported in animals. Laboratory experiments have resulted in mutagenic effects. Possible risk of irreversible effects.

Section 4 - First Aid Measures

Eyes: Immediately flush eyes with plenty of water for at least 15 minutes, occasionally lifting the upper and lower eyelids. Get medical aid. Skin: Get medical aid. Immediately flush skin with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. Ingestion: Do not induce vomiting. Get medical aid. Inhalation: Remove from exposure and move to fresh air immediately. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get medical aid. Notes to Physician: Treat symptomatically and supportively.

Section 5 - Fire Fighting Measures

General Information: As in any fire, wear a self-contained breathing apparatus in pressure-demand, MSHA/NIOSH (approved or equivalent), and full protective gear. Extinguishing Media: Use water spray, dry chemical, carbon dioxide, or chemical foam. Flash Point: Not applicable. Autoignition Temperature: 410 deg C ( 770.00 deg F) Explosion Limits, Lower:7.9 Vol % Upper: 90 Vol % NFPA Rating: (estimated) Health: 2; Flammability: 1; Instability: 1

Section 6 - Accidental Release Measures

General Information: Use proper personal protective equipment as indicated in Section 8. Spills/Leaks: Absorb spill with inert material (e.g. vermiculite, sand or earth), then place in suitable container. Wear a self contained breathing apparatus and appropriate personal protection. (See Exposure Controls, Personal Protection section). Remove all sources of ignition. Use a spark-proof tool. Do not let this chemical enter the environment.

Section 7 - Handling and Storage

Handling: Do not get in eyes, on skin, or on clothing. Keep away from heat, sparks and flame. Do not ingest or inhale. Use only in a chemical fume hood. Storage: Keep away from sources of ignition. Store in a cool, dry place. Store in a tightly closed container. Store protected from light.

Section 8 - Exposure Controls, Personal Protection

Engineering Controls: Facilities storing or utilizing this material should be equipped with an eyewash facility and a safety shower. Use only under a chemical fume hood. Exposure Limits

Chemical Name ACGIH NIOSH OSHA - Final PELs 10 ppm TWA; 25 ppm 100 ppm TWA; 200 Trichloroethylene 1000 ppm IDLH STEL ppm Ceiling

OSHA Vacated PELs: Trichloroethylene: 50 ppm TWA; 270 mg/m3 TWA Personal Protective Equipment Eyes: Wear appropriate protective eyeglasses or chemical safety goggles as described by OSHA's eye and face protection regulations in 29 CFR 1910.133 or European Standard EN166. Skin: Wear appropriate protective gloves to prevent skin exposure. Clothing: Wear appropriate protective clothing to prevent skin exposure. Respirators: Follow the OSHA respirator regulations found in 29 CFR 1910.134 or European Standard EN 149. Use a NIOSH/MSHA or European Standard EN 149 approved respirator if exposure limits are exceeded or if irritation or other symptoms are experienced.

Section 9 - Physical and Chemical Properties

Physical State: Liquid Appearance: clear, colorless - APHA: 15 max Odor: chloroform-like pH: Not available. Vapor Pressure: 77.3 mbar @ 20 deg C Vapor Density: 4.5 (air=1) Evaporation Rate:Not available. Viscosity: Not available. Boiling Point: 87 deg C @ 760 mmHg Freezing/Melting Point:-86 deg C Decomposition Temperature:Not available. Solubility: Insoluble. Specific Gravity/Density:1.460 Molecular Formula:C2HCl3 Molecular Weight:131.39

Section 10 - Stability and Reactivity

Chemical Stability: Moisture sensitive. Light sensitive. Conditions to Avoid: Incompatible materials, light, ignition sources, excess heat, exposure to moist air or water. Incompatibilities with Other Materials: Strong oxidizing agents, strong reducing agents, bases, active metals, metals and metal compounds (toxic, e.g. beryllium, lead acetate, nickel carbonyl, tetraethyl lead). Hazardous Decomposition Products: Hydrogen chloride, carbon monoxide, carbon dioxide. Hazardous Polymerization: Will not occur.

Section 11 - Toxicological Information

RTECS#: CAS# 79-01-6: KX4550000 LD50/LC50: CAS# 79-01-6: Draize test, rabbit, eye: 20 mg/24H Moderate; Draize test, rabbit, skin: 2 mg/24H Severe; Inhalation, mouse: LC50 = 8450 ppm/4H; Inhalation, mouse: LC50 = 220000 mg/m3/20M; Inhalation, mouse: LC50 = 262000 mg/m3/30M; Inhalation, mouse: LC50 = 40000 mg/m3/4H; Inhalation, rat: LC50 = 140700 mg/m3/1H; Oral, mouse: LD50 = 2402 mg/kg; Oral, mouse: LD50 = 2400 mg/kg; Oral, rat: LD50 = 4920 mg/kg; Skin, rabbit: LD50 = >20 gm/kg; Skin, rabbit: LD50 = 20 mL/kg; .

Carcinogenicity: CAS# 79-01-6:

• ACGIH: A2 - Suspected Human Carcinogen • California: carcinogen, initial date 4/1/88 • NTP: Suspect carcinogen • IARC: Group 2A carcinogen

Epidemiology: Tumorigenic effects have been reported in experimental animals. Teratogenicity: Teratogenic effects have occurred in experimental animals. Reproductive Effects: Adverse reproductive effects have occurred in experimental animals. Mutagenicity: Mutagenic effects have occurred in humans. Neurotoxicity: No information available. Other Studies: Section 12 - Ecological Information

Ecotoxicity: Fish: Fathead Minnow: 41-67 mg/L; 96 hrs.; LC50Daphnia: Daphnia: 2.2-100 mg/L; 48 hrs.; LC50Mollusk Shrimp: 2 mg/L; 96 hrs.; LC50 Bluegill sunfish, LD50= 44,700 ug/L/96Hr. Fathead minnow, LC50=40.7 mg/L/96Hr. Environmental: In air, substance is photooxidized and is reported to form phosgene, dichloroacetyl chloride, and formyl chloride. In water, it evaporates rapidly. Potential for mobility in soil is high. Physical: No information available. Other: Bioconcentration potential is low (BCF less than 100).

Section 13 - Disposal Considerations

Chemical waste generators must determine whether a discarded chemical is classified as a hazardous waste. US EPA guidelines for the classification determination are listed in 40 CFR Parts 261.3. Additionally, waste generators must consult state and local hazardous waste regulations to ensure complete and accurate classification. RCRA P-Series: None listed. RCRA U-Series: CAS# 79-01-6: waste number U228.

Section 14 - Transport Information

US DOT Canada TDG Shipping Name: TRICHLOROETHYLENE TRICHLOROETHYLENE Hazard Class: 6.1 6.1 UN Number: UN1710 UN1710 Packing Group: III III

Section 15 - Regulatory Information

US FEDERAL

TSCA CAS# 79-01-6 is listed on the TSCA inventory. Health & Safety Reporting List None of the chemicals are on the Health & Safety Reporting List. Chemical Test Rules None of the chemicals in this product are under a Chemical Test Rule. Section 12b None of the chemicals are listed under TSCA Section 12b. TSCA Significant New Use Rule None of the chemicals in this material have a SNUR under TSCA. CERCLA Hazardous Substances and corresponding RQs CAS# 79-01-6: 100 lb final RQ; 45.4 kg final RQ SARA Section 302 Extremely Hazardous Substances None of the chemicals in this product have a TPQ. SARA Codes CAS # 79-01-6: immediate, delayed, reactive. Section 313 This material contains Trichloroethylene (CAS# 79-01-6, 99+%),which is subject to the reporting requirements of Section 313 of SARA Title III and 40 CFR Clean Air Act: CAS# 79-01-6 is listed as a hazardous air pollutant (HAP). This material does not contain any Class 1 Ozone depletors. This material does not contain any Class 2 Ozone depletors. Clean Water Act: CAS# 79-01-6 is listed as a Hazardous Substance under the CWA. CAS# 79-01-6 is listed as a Priority Pollutant under the Clean Water Act. CAS# 79-01-6 is listed as a Toxic Pollutant under the Clean Water Act. OSHA: None of the chemicals in this product are considered highly hazardous by OSHA. STATE CAS# 79-01-6 can be found on the following state right to know lists: California, New Jersey, Pennsylvania, Minnesota, Massachusetts.

California Prop 65 The following statement(s) is(are) made in order to comply with the California Safe Drinking Water Act: WARNING: This product contains Trichloroethylene, a chemical known to the state of California to cause cancer. California No Significant Risk Level: CAS# 79-01-6: 50 æg/day NSRL (oral); 80 æg/day NSRL (inhalation)

European/International Regulations European Labeling in Accordance with EC Directives Hazard Symbols: T Risk Phrases: R 36/38 Irritating to eyes and skin. R 45 May cause cancer. R 52/53 Harmful to aquatic organisms, may cause long-term adverse effects in the aquatic environment. R 67 Vapours may cause drowsiness and dizziness. R 68 Possible risk of irreversible effects.

Safety Phrases: S 45 In case of accident or if you feel unwell, seek medical advice immediately (show the label where possible). S 53 Avoid exposure - obtain special instructions before use. S 61 Avoid release to the environment. Refer to special instructions /safety data sheets.

WGK (Water Danger/Protection) CAS# 79-01-6: 3 Canada - DSL/NDSL CAS# 79-01-6 is listed on Canada's DSL List. Canada - WHMIS This product has a WHMIS classification of D1B, D2B. This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations and the MSDS contains all of the information required by those regulations. Canadian Ingredient Disclosure List CAS# 79-01-6 is listed on the Canadian Ingredient Disclosure List.

Section 16 - Additional Information

MSDS Creation Date: 2/01/1999 Revision #9 Date: 6/03/2008

The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their particular purposes. In no event shall Fisher be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if Fisher has been advised of the possibility of such damages.

Page 1 of 8 MATERIAL SAFETY DATA SHEET

1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION

MATHESON TRI-GAS, INC. Emergency Contact: 150 Allen Road Suite 302 CHEMTREC 1-800-424-9300 Basking Ridge, New Jersey 07920 Calls Originating Outside the US: Information: 1-800-416-2505 703-527-3887 (Collect Calls Accepted)

SUBSTANCE: VINYL CHLORIDE

TRADE NAMES/SYNONYMS: MTG MSDS 97; 1-CHLOROETHYLENE; 1-CHLOROETHENE; CHLOROETHYLENE; CHLOROETHENE; CHLORETHENE; CHLORETHYLENE; ETHYLENE MONOCHLORIDE; MONOCHLOROETHYLENE; MONOCHLORO ETHENE; MONOCHLOROETHENE; VINYL CHLORIDE MONOMER; VINYL CHLORIDE, INHIBITED; VINYL C MONOMER; RCRA U043; UN 1086; C2H3Cl; MAT24940; RTECS KU9625000

CHEMICAL FAMILY: halogenated, aliphatic

CREATION DATE: Jan 24 1989 REVISION DATE: Dec 11 2008

2. COMPOSITION, INFORMATION ON INGREDIENTS

COMPONENT: VINYL CHLORIDE CAS NUMBER: 75-01-4 PERCENTAGE: >99.9

COMPONENT: PHENOL CAS NUMBER: 108-95-2 PERCENTAGE: <0.1

COMPONENT: INHIBITORS CAS NUMBER: Not assigned. PERCENTAGE: <0.1

3. HAZARDS IDENTIFICATION

NFPA RATINGS (SCALE 0-4): HEALTH=2 FIRE=4 REACTIVITY=1

Page 2 of 8 EMERGENCY OVERVIEW: COLOR: colorless PHYSICAL FORM: gas ODOR: faint odor, sweet odor MAJOR HEALTH HAZARDS: harmful if swallowed, skin irritation, eye irritation, central nervous system depression, cancer hazard (in humans) PHYSICAL HAZARDS: Flammable gas. May cause flash fire. May polymerize. Containers may rupture or explode.

POTENTIAL HEALTH EFFECTS: INHALATION: SHORT TERM EXPOSURE: irritation, nausea, difficulty breathing, irregular heartbeat, headache, drowsiness, dizziness, disorientation, joint pain, loss of coordination, hearing loss, lung congestion LONG TERM EXPOSURE: impotence, bluish skin color, blood disorders, liver damage, cancer SKIN CONTACT: SHORT TERM EXPOSURE: irritation, blisters LONG TERM EXPOSURE: irritation, blisters EYE CONTACT: SHORT TERM EXPOSURE: irritation, eye damage LONG TERM EXPOSURE: irritation, eye damage INGESTION: SHORT TERM EXPOSURE: frostbite LONG TERM EXPOSURE: cancer

4. FIRST AID MEASURES

INHALATION: If adverse effects occur, remove to uncontaminated area. Give artificial respiration if not breathing. If breathing is difficult, oxygen should be administered by qualified personnel. Get immediate medical attention.

SKIN CONTACT: If frostbite or freezing occur, immediately flush with plenty of lukewarm water (105- 115 F; 41-46 C). DO NOT USE HOT WATER. If warm water is not available, gently wrap affected parts in blankets. Get immediate medical attention.

EYE CONTACT: Wash eyes immediately with large amounts of water, occasionally lifting upper and lower lids, until no evidence of chemical remains. Get medical attention immediately.

INGESTION: If a large amount is swallowed, get medical attention.

NOTE TO PHYSICIAN: For inhalation, consider oxygen.

5. FIRE FIGHTING MEASURES

Page 3 of 8 FIRE AND EXPLOSION HAZARDS: Severe fire hazard. Severe explosion hazard. The vapor is heavier than air. Vapors or gases may ignite at distant ignition sources and flash back. Vapor/air mixtures are explosive. Electrostatic discharges may be generated by flow or agitation resulting in ignition or explosion.

EXTINGUISHING MEDIA: carbon dioxide, regular dry chemical

Large fires: Use regular foam or flood with fine water spray.

FIRE FIGHTING: Move container from fire area if it can be done without risk. For fires in cargo or storage area: Cool containers with water from unmanned hose holder or monitor nozzles until well after fire is out. If this is impossible then take the following precautions: Keep unnecessary people away, isolate hazard area and deny entry. Let the fire burn. Withdraw immediately in case of rising sound from venting safety device or any discoloration of tanks due to fire. For tank, rail car or tank truck: Stop leak if possible without personal risk. Let burn unless leak can be stopped immediately. For smaller tanks or cylinders, extinguish and isolate from other flammables. Evacuation radius: 800 meters (1/2 mile). Do not attempt to extinguish fire unless flow of material can be stopped first. Flood with fine water spray. Cool containers with water spray until well after the fire is out. Apply water from a protected location or from a safe distance. Avoid inhalation of material or combustion by-products. Stay upwind and keep out of low areas. Evacuate if fire gets out of control or containers are directly exposed to fire. Evacuation radius: 500 meters (1/3 mile). Consider downwind evacuation if material is leaking.

FLASH POINT: -108 F (-78 C) (CC) LOWER FLAMMABLE LIMIT: 3.6% UPPER FLAMMABLE LIMIT: 33% AUTOIGNITION: 882 F (472 C)

6. ACCIDENTAL RELEASE MEASURES

WATER RELEASE: Subject to California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). Keep out of water supplies and sewers.

OCCUPATIONAL RELEASE: Avoid heat, flames, sparks and other sources of ignition. Stop leak if possible without personal risk. Reduce vapors with water spray. Keep unnecessary people away, isolate hazard area and deny entry. Remove sources of ignition. Ventilate closed spaces before entering. Notify Local Emergency Planning Committee and State Emergency Response Commission for release greater than or equal to RQ (U.S. SARA Section 304). If release occurs in the U.S. and is reportable under CERCLA Section 103, notify the National Response Center at (800)424-8802 (USA) or (202)426-2675 (USA).

7. HANDLING AND STORAGE

STORAGE: Store and handle in accordance with all current regulations and standards. Protect from physical damage. Store outside or in a detached building. Inside storage: Store in a cool, dry place. Store in a Page 4 of 8 well-ventilated area. Avoid heat, flames, sparks and other sources of ignition. Grounding and bonding required. Subject to storage regulations: U.S. OSHA 29 CFR 1910.101. See original container for storage recommendations. Keep separated from incompatible substances.

8. EXPOSURE CONTROLS, PERSONAL PROTECTION

EXPOSURE LIMITS: VINYL CHLORIDE: 1.0 ppm OSHA TWA 5 ppm OSHA STEL 15 minute(s) 0.5 ppm OSHA action level 8 hour(s) 1 ppm ACGIH TWA NIOSH TWA (lowest feasible concentration)

VENTILATION: Ventilation equipment should be explosion-resistant if explosive concentrations of material are present. Provide local exhaust or process enclosure ventilation system. Ensure compliance with applicable exposure limits.

EYE PROTECTION: Wear splash resistant safety goggles with a faceshield. Provide an emergency eye wash fountain and quick drench shower in the immediate work area.

CLOTHING: Wear appropriate chemical resistant clothing.

GLOVES: For the gas: Wear appropriate chemical resistant gloves. For the liquid: Wear insulated gloves. OSHA REGULATED SUBSTANCES: U.S. OSHA 29 CFR 1910.1017.

RESPIRATOR: The following respirators and maximum use concentrations are drawn from NIOSH and/or OSHA. OSHA Standard: Respirator selection should comply with 29 CFR 1910.134, 29 CFR 1910.1017, and the final rule published in the Federal Register on August 24, 2006. NIOSH Recommendations: At any detectable concentration - Any self-contained breathing apparatus that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode. Any supplied-air respirator with a full facepiece that is operated in a pressure-demand or other positive- pressure mode in combination with an auxiliary self-contained breathing apparatus operated in pressure- demand or other positive-pressure mode. Escape - Any air-purifying full-facepiece respirator (gas mask) with a chin-style, front-mounted or back-mounted canister providing protection against the compound of concern. Any appropriate escape-type, self-contained breathing apparatus. Page 5 of 8

9. PHYSICAL AND CHEMICAL PROPERTIES

PHYSICAL STATE: gas COLOR: colorless ODOR: faint odor, sweet odor MOLECULAR WEIGHT: 62.50 MOLECULAR FORMULA: C-H2-C-H-Cl BOILING POINT: 9 F (-13 C) FREEZING POINT: -245 F (-154 C) VAPOR PRESSURE: 2515.6 mmHg @ 21.1 C VAPOR DENSITY (air=1): 2.2 SPECIFIC GRAVITY (water=1): 0.9106 WATER SOLUBILITY: 0.25% PH: Not applicable VOLATILITY: Not applicable ODOR THRESHOLD: 260 ppm EVAPORATION RATE: Not applicable VISCOSITY: 0.01072 cP @ 20 C COEFFICIENT OF WATER/OIL DISTRIBUTION: Not applicable SOLVENT SOLUBILITY: Soluble: alcohol, ether, carbon tetrachloride, benzene

10. STABILITY AND REACTIVITY

REACTIVITY: May polymerize. Avoid contact with light or storage and use above room temperature.

CONDITIONS TO AVOID: Avoid heat, flames, sparks and other sources of ignition. Containers may rupture or explode if exposed to heat.

INCOMPATIBILITIES: metal carbide, metals, oxidizing materials, peroxides

HAZARDOUS DECOMPOSITION: Thermal decomposition products: halogenated compounds, oxides of carbon, phosgene

POLYMERIZATION: May polymerize. Avoid contact with heat, light, air, water or incompatible materials. Closed containers may rupture violently.

11. TOXICOLOGICAL INFORMATION

VINYL CHLORIDE: TOXICITY DATA: 18 pph/15 minute(s) inhalation-rat LC50; 500 mg/kg oral-rat LD50 CARCINOGEN STATUS: OSHA: Carcinogen; NTP: Known Human Carcinogen; IARC: Human Sufficient Evidence, Animal Sufficient Evidence, Group 1; ACGIH: A1 -Confirmed Human Carcinogen; Page 6 of 8 EC: Category 1 LOCAL EFFECTS: Irritant: skin, eye ACUTE TOXICITY LEVEL: Toxic: ingestion Relatively Non-toxic: inhalation TARGET ORGANS: central nervous system TUMORIGENIC DATA: Available. MUTAGENIC DATA: Available. REPRODUCTIVE EFFECTS DATA: Available. ADDITIONAL DATA: Stimulants such as epinephrine may induce ventricular fibrillation. May cause birth defects.

12. ECOLOGICAL INFORMATION

ECOTOXICITY DATA: FISH TOXICITY: 388000 ug/L 10 month(s) LETH (Mortality) Northern pike (Esox lucius)

INVERTEBRATE TOXICITY: 41.74 ug/L 72 day(s) (Residue) Mosquito (Culex pipiens quinquefasciata)

ALGAL TOXICITY: 41.74 ug/L 72 day(s) (Residue) Green algae (Oedogonium cardiacum)

13. DISPOSAL CONSIDERATIONS

Dispose in accordance with all applicable regulations. Hazardous Waste Number(s): D043. Dispose of in accordance with U.S. EPA 40 CFR 262 for concentrations at or above the Regulatory level. Regulatory level- 0.2 mg/L. U043.

14. TRANSPORT INFORMATION

U.S. DOT 49 CFR 172.101: PROPER SHIPPING NAME: Vinyl chloride, stabilized ID NUMBER: UN1086 HAZARD CLASS OR DIVISION: 2.1 LABELING REQUIREMENTS: 2.1 QUANTITY LIMITATIONS: PASSENGER AIRCRAFT OR RAILCAR: Forbidden CARGO AIRCRAFT ONLY: 150 kg

CANADIAN TRANSPORTATION OF DANGEROUS GOODS: SHIPPING NAME: Vinyl chloride, stabilized UN NUMBER: UN1086 CLASS: 2.1 Page 7 of 8

15. REGULATORY INFORMATION

U.S. REGULATIONS: CERCLA SECTIONS 102a/103 HAZARDOUS SUBSTANCES (40 CFR 302.4): Vinyl chloride: 1 LBS RQ PHENOL: 1000 LBS RQ

SARA TITLE III SECTION 302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355 Subpart B): Not regulated.

SARA TITLE III SECTION 304 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355 Subpart C): Not regulated.

SARA TITLE III SARA SECTIONS 311/312 HAZARDOUS CATEGORIES (40 CFR 370 Subparts B and C): ACUTE: Yes CHRONIC: Yes FIRE: Yes REACTIVE: Yes SUDDEN RELEASE: Yes

SARA TITLE III SECTION 313 (40 CFR 372.65): Vinyl chloride

OSHA PROCESS SAFETY (29 CFR 1910.119): Not regulated.

STATE REGULATIONS: California Proposition 65: Known to the state of California to cause the following: Vinyl chloride Cancer (Feb 27, 1987)

CANADIAN REGULATIONS: WHMIS CLASSIFICATION: ABD2

NATIONAL INVENTORY STATUS: U.S. INVENTORY (TSCA): Listed on inventory.

TSCA 12(b) EXPORT NOTIFICATION: Not listed.

CANADA INVENTORY (DSL/NDSL): Not determined.

16. OTHER INFORMATION

Page 8 of 8 MSDS SUMMARY OF CHANGES 15. REGULATORY INFORMATION

“RTECS®” is a United States trademark owned and licensed under authority of the U.S. Government, by and through Symyx Software, Inc. Portions ©Copyright 2001, U.S. Government. All rights reserved.

©Copyright 1984-2008 ChemADVISOR, Inc. All rights reserved.

MATHESON TRI-GAS, INC. MAKES NO EXPRESS OR IMPLIED WARRANTIES, GUARANTEES OR REPRESENTATIONS REGARDING THE PRODUCT OR THE INFORMATION HEREIN, INCLUDING BUT NOT LIMITED TO ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR USE. MATHESON TRI-GAS, INC. SHALL NOT BE LIABLE FOR ANY PERSONAL INJURY, PROPERTY OR OTHER DAMAGES OF ANY NATURE, WHETHER COMPENSATORY, CONSEQUENTIAL, EXEMPLARY, OR OTHERWISE, RESULTING FROM ANY PUBLICATION, USE OR RELIANCE UPON THE INFORMATION HEREIN.

ATTACHMENT D

JOB SAFETY ANALYSIS SHEETS, STANDARD OPERATING PROCEDURES AND DAILY SITE SAFETY CHECKLISTS

Rev. 5/99

JOB SAFETY ANALYSIS DATE 2/22/05, 4/13/06, 5/5/06 NEW PAGE 1 of 1 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Sampling Absorbed/Adsorbed Phase Soil Sampling 001

INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Thomas Baylis, CIH Dir, HSSE Eric Munz, ASP Reg HSSE Spec - NE

REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. X AIR PURIFYING RESPIRATOR if levels HEARING PROTECTION X SAFETY SHOES steel-toed exceed those set by the HASP LIFELINE / HARNESS SUPPLIED RESPIRATOR FACE SHIELD X PPE CLOTHING highly visible clothing such OTHER X GLOVES leather; nitrile as orange coveralls, reflective safety vest; GOGGLES Saranex-coated Tyvek for whole body X HARD HAT protection X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. PID 2. LEL meter 3. Sample bottles/jars 4. Small shovel 5.

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Review “Skid Loading Operations” JSA #058 for Operation of a Bobcat or Similar Vehicle C. Review “Bailing and Gauging of Free Product Wells” JSA #009 for Sampling Impacted Liquid D. Review “Hand Auger Use” JSA #035 for Sampling Impacted Soils E. Handling and Treatment of Impacted Soils 1. Don necessary PPE 1a. Contact with contaminated 1a. Wear appropriate PPE (i.e., safety glasses, nitrile gloves, soils steel-toe shoes, highly visible clothing, and Level D attire).  Review and understand action levels noted in the HASP.  Monitor (evaluate) breathing zone of workers with PID.  Monitor (evaluate) any enclosure with a PID.  If action levels are met, either Level C PPE must be donned or the space must be ventilated below the action level. 2. Start ventilation equipment 2a. Overexposure to vapors 2a. All ventilation equipment utilized near impacted soils must be explosion-proof to minimize the chance of fire/explosion resulting from this equipment.  Personnel must stay at least 3 feet away from the exit exhaust of this ventilation equipment. 2b. Explosion, fire 2b. A PID and LEL must be utilized to scan the atmosphere ensuring that the site conditions are properly documented. Note: If air monitoring equipment begins to alarm because of an unsafe condition the site activities must stop immediately until additional PPE is used or the space is properly ventilated restoring a safe atmosphere. 3. Sample and classify 3a. Contact with contaminated 3a. Wear appropriate PPE to prevent contact with the skin impacted soil soils including nitrile gloves and safety glasses. 3b. Cut/puncture from fill 3b. Wear cut-resistant gloves (i.e.., nitrile coated knit gloves) material/soil when sampling soil containing sharp debris.  A small shovel can be used to loosen compacted soil containing shart debris. 3c. Cut/puncture from broken 3c. Wear cut-resistant gloves (i.e., leather work gloves or nitrile glass coated knit gloves) when handling broken sampling glassware.

JOB SAFETY ANALYSIS DATE 2/23/05, 9/16/09 NEW PAGE 1 of 2 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Well Management Air Jetting of Wells — Use of 004 Compressed Air to Cleanout/Remove Sediment, Develop Wells

OVERSIGHT CRITERIA INITIATED / CHANGED BY POSITION / TITLE Thomas Baylis, CIH Dir, HSSE APPROVED BY POSITION / TITLE RISK LEVEL: MEDIUM Julius Pachy Reg HSSE Spec - MW

REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. AIR PURIFYING RESPIRATOR X HEARING PROTECTION X SAFETY SHOES steel-toed; booties X FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES leather; nitrile X PPE CLOTHING highly visible clothing such X OTHER RESPIRATORS - may be required if GOGGLES as orange coveralls; Tyvek; reflective safety conditions or work area air quality exceeds X HARD HAT vest applicable HASP action levels X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. J - Hook to open 2. 3. 4. 5. roadbox covers ¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Tow-Behind Compressor 1. Position tow-behind 1a. Traffic, blind spots 1a. Utilize a spotter prior to backing and/or positioning the compressor compressor near obstructions.  Once compressor is in correct location at well, place traffic controls around work zone per GES’ Traffic Control Procedure. 1b. Contact 1b. Utilize wheel chocks behind tires of compressor. Note: Never stand in the area between a moving vehicle and a fixed object (i.e., a building or other parked vehicle). C. Air Jetting of Wells 1. Inspect and open wells 1a. Pinch points/abrasions 1a. Properly remove and replace roadbox covers so that they do not pinch fingers.  Don appropriate PPE (Leather gloves, safety glass, high visible clothing, hard hat and steel toe boots)  Use proper tools (i.e., J - Hook) to prevent injuries to hands.  While opening wells keep your fingers away from the pinch point. 1b. Shoulder strain resulting 1b. Always keep your wrist straight when using a wrench. from using a socket wrench to  Be sure that the opening of the socket is in full contact with loosen and remove bolts from the bolt before you apply pressure. well lid  Pull, don’t push, and use a slow, steady motion. If the bolt can not be loosened with normal , use the correct breaking bar and do not place a piece of pipe on the end of the wrench to improve leverage.  Protect yourself from losing your balance if the wrench slips or a bolt breaks. Kneel (use knee pads) on a solid surface with one foot planted firmly on the ground and don’t lean into the work. Note: Never use hand sockets with power or impact wrenches. Replace sockets showing cracks or wear. 2. Air jetting activity 2a. Contact w/air compressor 2a. Keep hands and clothing 3 feet away from rotating components machinery, inlet, and discharge openings. 2b. Excessive noise 2b. Wear hearing protection. 2c. Burns 2c. Avoid contact with compressor casing and associated piping; may cause major skin burns on contact. 2d. Pinch points 2d. Do not reach into any opening in the compressor while it is operating; ensure that any guards are in place on external

JOB SAFETY ANALYSIS JSA # - 004 PAGE 2 of 2

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS moving parts.  All hoses and fittings should be inspected prior to use. Defective equipment must be repaired or replaced prior to use.  Inspect emergency shut-off switches. Note: Chicago-style hose fittings and whip checks must be properly secured with locking pins to prevent the coupling from becoming separated while under pressure. Note: The compressor should be secured during operation to prevent the unit from moving while in operation (i.e., chock the wheels and secure the hitch). 2e. Exposure to site 2e. Wear appropriate PPE (i.e., eye protection-glasses and a contaminants face shield, hearing protection, long pants, nitrile sampling gloves, leather work gloves, shirt with sleeves, steel-toed shoes).  Review and understand action levels noted in the HASP. Note: Wear outer boot covers if water is splashed during the air jetting of wells. Note: A face shield must be worn in addition to safety glasses to prevent water from splashing onto the face of the operator. 2f. Overhead lines 2f. Maintain a working distance of at least 10 feet from an energized overhead power line.  A spotter shall be used to observe equipment clearance during relocation.  For other overhead lines such as telephone or cable lines, if there is a potential of contacting and/or damaging the lines, the appropriate service company should be contacted so that the lines can be relocated or protected.

JOB SAFETY ANALYSIS DATE 2/23/05, 3/7/05, 3/11/05, 4/18/06, 5/5/06, NEW PAGE 1 of 2 7/10/06, 12/22/06, 3/4/08, 3/19/08 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Cutting Tool Use 015 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Thomas Baylis, CIH Dir, HSSE Thomas Baylis, CIH Dir, HSSE Dan Germann Local HSO - NJ-C Jim Leonard REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR X HEARING PROTECTION if noise level X SAFETY SHOES steel-toed FACE SHIELD exceeds 90 dB SUPPLIED RESPIRATOR X GLOVES leather/Kevlar/nitrile LIFELINE / HARNESS & OTHER HEPA MASK - if dust is generated GOGGLES X PPE CLOTHING highly visible clothing such during cutting activities X HARD HAT as orange coveralls, reflective safety vest X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Lockout/tagout kit 2. Extra blades (if 3. Hotwork Permit 4. 5. applicable) ¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA - #028 B. Hand Tool Use 1. Use of hand tools (i.e., 1a. Cuts to the skin from tool 1a. Wear appropriate PPE (i.e., eye protection, long pants, Geoprobe cutter, hand saw, blade nitrile sampling gloves (inner), Kevlar or leather cut resistant poly line cutter, etc.) gloves (outer), shirt with sleeves, steel-toed boots). ¾ Inspect the cutting equipment prior to start of cut. NOTE: The use of utility ¾ Make sure blades are sharp and any guards are in place. knives and pocket knives ¾ Cut away from your body and keep hands out of the path of (i.e., stanley knives, box cutting tools. cutters) are STRICTLY ¾ Have bystanders maintain a 3 foot distance from the PROHIBITED. operation at all times. ¾ Use the proper cutting tool for the job (i.e., pipe cutters for cutting poly pipe). ¾ The material being cut must not interfere with the operator’s vision. Note: Extreme caution must be taken while handling and using sharp hand tools. Always cut away from your body. Never walk with blades in the engaged position. C. Power Tool Use 1. Power equipment, cutters 1a. Cuts to the skin from tool 1a. Wear appropriate PPE (i.e., hard hat, long pants, steel-toed blade boots, hearing protection). ¾ Wear a face shield in addition to safety glasses when flying particles have the chance to strike the operator in the face. ¾ Have bystanders maintain a 3 foot distance from the operation at all times. ¾ The material being cut must not interfere with the operator’s vision. ¾ Equipment must be turned off and allowed to cool prior to refueling. 1b. Spark/dust reduction 1b. When possible perform wet cuts to reduce the explosion and dust hazard. Note: Extreme caution must be taken while handling and using sharp hand tools. Always cut away from your body. Never walk with blades in the engaged position. Never rest any object that is being cut on your leg or any other part of your body. Place object onto a proper cutting surface or work platform. 1c. Excessive noise 1c. Wear proper hearing protection (i.e., ear muffs or foam inserts). 2. Contact with damage to 2a. Electrocution/contact with 2a. Obtain up-to-date as-built plan to identify any subsurface utilities energized equipment utilities or obstructions. ¾ Identify all aboveground utilities and obstructions prior to commencing work.

JOB SAFETY ANALYSIS Page 2 of 2

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS ¾ Use LO/TO when sources of energy can be de-energized. 3. Sample atmosphere 3a. Elevated levels of organic 3a. Utilize a PID to test the atmosphere prior to entering a vapors system enclosure. ¾ Organic vapor limit for entry is <5 ppm. ¾ If the PID reads 5 ppm or greater, explosion-proof ventilation equipment can be used to clear the atmosphere. 3b. Oxygen deficient/enriched 3b. Oxygen level limits for entry are >19.5% and <23.5% atmospheres ¾ If the LEL reads greater than 23.5% or less than 19.5% oxygen, ventilation equipment can be used to clear the atmosphere. 4. Hotwork Permit 4a. Fire/explosion 4a. If sparks are generated within 35 feet of a vapor source (i.e., an operating pump island) a Hotwork Permit must be furnished and air monitoring must take place.

WORK ACTIVITY (Description) — Cutting Tool Use - #015

JOB SAFETY ANALYSIS DATE 2/23/05, 2/5/10 NEW PAGE 1 of 2 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Various Deliveries and Pick-ups 016

INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Julius Pachy Reg HSSE Spec - MW Thomas Baylis, CIH Dir, HSSE

REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. AIR PURIFYING RESPIRATOR HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES leather; nitrile X PPE CLOTHING highly visible clothing such OTHER GOGGLES as orange coveralls, reflective safety vest X HARD HAT client-specific when overhead X SAFETY GLASSES hazards are present/heavy equip is in use REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Material handling device 2. 3. 4. 5. (i.e., hand truck)

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Delivery of Materials/ Equipment 1. Delivery or pick-up of 1a. Improper lifting technique, 1a. Utilize proper lifting procedure when loading and unloading supplies or materials to the site back strain, exertion, muscle vehicle. by an outside source (manual injuries  Determine that object is within safe weight limit. lifting heavy objects)  Do not lift any object weighting more then 50Lbs Note: Recommended safe  Use 2 people if packages are heavy, large, or awkward. lifting for an average  Check that there is ample room to squat, lift, turn or man or woman are 50 and 35 maneuver without twisting the back or other muscles or pounds respectively. joints.  Bend down at the knees and lift with your legs rather than Note: Mechanical equipment bending and lifting with your back. or assistance such as dollies,  Place one foot slightly in front of the other. carts, come-alongs, or rollers  Squat as close to the object as possible. are to be used whenever  Grasp one of the top corners away from the body and the possible. opposite bottom corner closest to the body.  Tilt the object slightly away from the body, tilt forward at the Note: Stop immediately if you hips, keep the back straight and tuck in the chin. feel any pain, muscle pulls, or  Pull the object into the body and stand up slowly and evenly limited range of motion. without jerking or twisting. Contact LHSO, project  To set an object down, reverse the sequence, being sure not manager, and/or site to trap the bottom hand between the object and the surface operations manager. on which the object is set. Do not carry objects in a manner that obstruct vision in line of travel.  When 2 or more persons are lifting, have a plan and a set of signals so lifting occurs simultaneously. 1b. Cuts, pinching, and 1b. Check each object before lifting for presence of splinters, crushing slivers, sharp edges, and loose joints; signs of biological hazards; or chemical contamination.  Check for pinch points (i.e., other objects close by). 1c. Slips, trips, falls 1c. Check route to be traveled if lifting involves carrying.  Check walking and working surfaces for slip/trip/fall hazards. Note ramps, changes on level of elevation, and ladders or stairways than need to be negotiated. 2. Deliveries of remediation 2a. Contact with heavy 2a. Make sure all operators have seat belts and safety bars in equipment requiring heavy equipment use. equipment to unload or move  All equipment should be inspected prior to use by the operator for hydraulic leaks, broken glass, safety devices, NOTE: If moving remediation etc. equipment with heavy 2b. Pinch points 2b. Never stand in equipment pinch points (i.e., between tracks

JOB SAFETY ANALYSIS JSA # - 016 Page 2 of 2

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS equipment make sure the load and counter weight of excavators, between back of backhoe is balanced and secured. and bucket arm, etc.). 2c. Blind spots 2c. Never let anyone stand in the swing radius.  Never assume operator can see you.  Never approach equipment in a blind spot.  Always approach equipment from the front where the operator can see you and stop the activities. 2d. Caught or stuck by 2d. Never let anyone stand under an elevated load.  Never let anyone ride on the side or in a bucket of equipment.  Make sure cabs are clean and no loose objects are on the floor that could block control pedals.

JOB SAFETY ANALYSIS DATE 2/23/05, 3/11/05, 5/27/05, 6/20/05, NEW PAGE 1 of 4 7/11/05, 8/26/05, 6/8/07, 8/17/07, X REVISED 6/9/2008, 8/14/08, 8/26/08, 9/15/08, 6/24/09, 6/30/09, 7/8/09, 10/26/09 JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Drilling Drilling/Soil Boring/Monitoring Well Installation 019

INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Tonya McGowen Staff Environmental Scientist Thomas Baylis, CIH Dir, HSSE Brenda Anderson Assoc Environmental Scientist

REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. X AIR PURIFYING RESPIRATOR respirators X HEARING PROTECTION if noise levels X SAFETY SHOES steel-toed; non-slip soles may be required if conditions or work area air exceed 85 dB SUPPLIED RESPIRATOR quality exceeds applicable HASP action LIFELINE / HARNESS OTHER levels; don a DUST MASK for comfort if X PPE CLOTHING highly visible clothing such inhalation of concrete dust is unavoidable as orange coveralls, reflective safety vest X FACE SHIELD if flying particles are X SAFETY GLASSES generated X GLOVES leather; nitrile; cut resistant (Kevlar) GOGGLES X HARD HAT REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. PID 2. CGI/O2 or LEL meter 3. Sample bottles/jars 4. Lockout/tagout kit 5. Spill response kit/spill 6. Hotwork Permit 7. Driller's tools - inspect 8. Sand and/pr salt for ice 9. PVC casing (6-10" pad - used under hydraulic condition of diameter) equipment when work activities occur on a permeable surface such as grass or gravel ¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Prepare for Soil Boring and Well Installation 1. Review, inspect and locate 1a. Trip, slips, falls 1a. Maintain all equipment and tools in designated areas and safety equipment including fire out of pathways. extinguisher, first aid kit, insect  Identify and protect all air lines, water lines, electrical cords, repellant, ice melt, PPE, etc. and cables.  Inspect work area for uneven ground and terrain. Note: Show subcontractors  Watch for the formation of snow covered ice during cold location of first aid kit and eye weather. wash; check fire extinguisher 1b. Exertion 1b. Use proper lifting techniques; bend at the legs and keep on drill rig. back straight. Hold item close to body. Items heavier than 50 lbs or items that are awkward to handle, use mechanical devices or ask for help. 2. Ensure that appropriate 2a. Contact 2a. Identify appropriate safety equipment and PPE. equipment and materials are  Time savings to reduce trips for forgotten items. available for sampling  Ensure proper gloves are worn for the appropriate task and client-specific protocols. . Leather gloves shall be worn at all times while operating the drill rig, handling augers, operating equipment, handling heavy loads, and whenever else deemed appropriate. . Kevlar gloves shall be worn while handling cutting tools or any other sharp objects. . Nitrile gloves shall be worn over Kevlar gloves when there is a potential to contact any contaminated solids or fluids.  Ensure the appropriate layering of gloves (i.e., nitrile gloves 2b. Cuts, burns, acid contact are worn under leather gloves while handling augers). 2b. Watch for broken bottles (i.e., when removing from cooler, be careful while filling sample vials/jars, and when placing on ice in cooler). 3. Load required equipment on 3a. Exertion 3a. Use proper lifting techniques; this consists of bending your support truck and drill rig knees and lifting with your back straight.

JOB SAFETY ANALYSIS JSA # - 019 Page 2 of 4

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS  While carrying, hold objects close to your body.  Items heavier than 50 lbs or items that are awkward to handle, use mechanical devices or ask for help. 3b. Slips, trips, falls 3b. Continuously check ground for uneven and slippery terrain. 3c. Caught, pinch points 3c. Position hands 6 inches away from pinch points on lift gate latches and utility boxes.  Use established handles and/or latches while opening and closing. 4. Drill rig positioning at drilling 4a. Contact with rig supports/ 4a. All staff accept those individuals who are responsible for location levelers positioning and leveling the rig must remain at least 20 feet away from the rig. Note: If the rig is positioned on soft ground or there is any evidence of the levelers or jacks sinking into the soil or other surfaces, all activities must stopped and all site staff alerted. The GES oversight person must call into the office, the client notified, and a near loss report must be completed regarding the issue. Prior to restarting activities, approved cribbing and other supports must be placed under each leveler (jack). If there is still evidence of sinking or if the rig appears to be unstable in any way, all work must stop, site staff alerted, and the local GES office and corporate HSSE notified. Work should not begin until all issues have been resolved. 4b. Electrocution contact with 4b. Locate all sources of electricity to site features. underground energized  To the extent possible, LO/TO all sources of electricity in the electrical lines vicinity of the drilling location.  Position boom a minimum of 10 feet from overhead power lines.  Have an observer watch the raising of mast.  Notify all affected employees on-site of the de-energized condition. 5. Drilling area containment 5a. Exertion 5a. See B.3a for guidance when carrying and placing bails of construction straw or other material for containment. 5b. Pinch points with tools 5b. Use appropriate PPE including safety glasses and nitrile (hammer) and equipment coated or regular workgloves. (stakes or other material Note: Containment construction must comply with the guidance provided in Attachment 3 of the GES Drilling Protocol. C. Drilling 1. Begin drilling soil boring/ 1a. Clearing 1a. Ensure that the use of soft dig protocol creates a borehole monitor well clearance that is at least 2 inches wider than the widest drilling tool. Always clear to at least 5 feet depth outside the exclusion Note: When using an air zone and to 8’ depth in the exclusion zone. rotary to drill the borehole  If soils are collapsing during the soft dig process, insert the ensure that the protective skirt appropriate sized PVC casing to keep the hole open to at is firmly secured to the drill rig least 2 inches wider than the widest drilling tool. in order to prevent sudden 1b. Contact and caught 1b. Ensure locations have been cleared. Stay 2 feet away from expulsions of potentially moving rotating parts (i.e., augers, drill drive shaft, etc.). impacted groundwater/mud  Recommended to keep at least 10 feet away from borehole from the open borehole, rapid while drilling is in progress. propulsion of the skirt, and/or  Confer with drillers to make sure you are in a good spot (i.e., potential exposures to on-site safe distance and out of their work zone) personnel. Note: If a jackhammer is used to break concrete or asphalt, wear leather or vibration-absorbing gloves, eye protection, hearing protection, and a hard hat.  Use shovels to push debris out of way.  Follow manufacturer’s operating procedures for equipment.  Have a stable stance; feet shoulder width apart, hold jackhammer lightly and balanced.  Do not wear excessively loose, baggy clothing, or jewelry.  Take breaks (a 10 minute break every hour of operation) during operation of equipment (i.e., jack hammer) to prevent vibration/repetitive motion injuries. 1c. Exertion 1c. Bend down at the knees and lift with your legs rather than

JOB SAFETY ANALYSIS JSA # - 019 Page 3 of 4

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS bending and lifting with your back. Drink plenty of water and Gatorade. 1d. Exposure 1d. Use nitrile gloves while handling soil samples. Scan with PID. Monitor air in work area for elevated vapors during drilling activities. 1e. Noise 1e. Wear hearing protection (i.e., ear muffs or foam inserts). Note: If any drums are filled with soil or any material, the drum can only be filled a maximum of two-thirds (2/3) full. 2. Collecting soil samples if 2a. Exposure 2a. Proper PPE nitrile gloves for handling soil samples (all PPE necessary safety glasses, hard hat, nitrile gloves, Level D clothing). Handle sample jars safely, if a jar is broken make sure leather work gloves are used during clean up. 2b. Contact 2b. While logging soil samples, continuously observe all drilling activities and maintain a safe distance from the active drilling. 2c. Slips, trips, falls 2c. Maintain work area, keep walk ways clean, pick up tools, and soil in drums. Watch for ice formation while drilling in winter. 3. Auger removal 3a. Contact and caught 3a. Use proper auger removal tools; NO J-hooks.  Leather work gloves must be used while handling winch cables.  Only Shackles properly secured to the auger flight should be used for lift augers. The shackles should be certified by the manufacturer and are appropriately labeled/stamped with model number or other documentation confirming load rating.  The augers should be lifted hydraulically with the drive cap bolted on the auger string. If permitted, the use of a clevace or chain wrap device should be wrapped around the augers so that the augers can be lifted and placed in the proper location safely. 3b. Exertion 3b. Utilize proper lifting procedures. See B.3a. 4. Install well (riser, screen, 4a. Exertion 4a. Utilize proper lifting procedures while carrying bentonite and sand pack, and bentonite) sand bags. 4b. Slips, trips, falls 4b. Make sure work area is clean, pick up all tools, sweep up all soil, and maintain walk ways. Fall protection is required whenever individuals are working 6 feet or more above ground level. 4c. Exposure, inhalation 4c. Monitor vapor levels in work area and wear nitrile gloves hazard from nuisance dust when cleaning up soil.  Position yourself up wind from concrete dust generated while mixing. Don a dust mask for comfort if inhalation is unavoidable. 4d. Striking and laceration 4d. Wear cut resistant (Kevlar or similar) gloves during this from hand saw while cutting activity. PVC well to finished length 5. Pressure grout the steel 1a. Back injury that can result 1a. Utilize proper lifting procedures to add materials to the mixer casing (if open rock well) or from exertion and while installing or removing the tremie pipe. See B.3a. PVC riser in place using a 1b. Respiratory irritation from 1b. Avoid breathing dust generated when opening bags or tremie pipe nuisance dust, inhalation mixing the grout. Stay upwind of the dust or wear a dust mask hazard for comfort. 1c. Wear appropriate PPE (i.e., eye protection, long pants, 1c. Injury from the contact with nitrile gloves or nitrile coated work gloves, shirt with sleeves, materials or equipment steel-toed boots). 1d. Avoid contact with grout; grout may cause skin irritation and 1d. Skin irritation from the burns. exposure to grout 1e. Do not reach into the mixer while operating. 1e. Injury from exposure to  Make sure all guards are in place on the mixer prior to pinch points operating. 1f. Wear proper hearing protection (i.e., ear muffs or foam 1f. Potential hearing loss from inserts) if noise levels exceed 85 dB. exposure to elevated noise levels.

JOB SAFETY ANALYSIS JSA # - 019 Page 4 of 4

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS 6. Install manway and concrete 5a. Exertion 5a. Utilize proper lifting procedures while carrying concrete pad bags. While mixing concrete use a balanced stance and mix slowly to avoid splashing concrete. 5b. Slips, trips, falls 5b. Make sure work area is clean, pick up all tools, sweep up all soil, and maintain walk ways. 5c. Spark/dust reduction 5c. When possible, perform wet cuts to reduce the explosion and dust hazard. 5d. Fire/explosion 5d. If sparks are generated within 35 feet of a vapor source (i.e., an operating pump island) a Hotwork Permit must be furnished and air monitoring must take place. 5e. Personal injury from 5e. A "spotter" should be used when manually hauling or contact with vehicles moving any loads such as using a wheel barrow that could deviate their attention from surrounding hazards. D. Decontamination Procedures 1. Decontamination of augers 1a. Contact 1a. Proper PPE safety glasses, hard hat, ear muffs, work and drilling tools. (use for gloves, Level D clothing. guideline while drilling and 1b. Exertion 1b. Utilize proper lifting procedures. See B.3a if augers need to decontaminating split spoons) be carried to decon area or manually loaded into a truck; use 2 people. 1c. Slips, trips, falls 1c. Make sure work area is clean, pick up all tools, sweep up all soil, and maintain walk ways. 2. Soak/spray durable 2a. Contact 2a. Wear appropriate PPE (i.e., eye protection, long pants, equipment to prevent cross- nitrile sampling gloves, shirt with sleeves, hard hat, steel-toed contamination between boots, rain suit or coated Saranex). Comply with monitoring and multiple well locations; properly action level requirements in HASP. store disposable equipment 2b. Exposure 2b. Avoid contact with all decontamination chemicals including Liquinox and any other soaps or solvents used on drilling equipment. Use of face shield during high to avoid splashing face. 2c. Exertion 2c. Utilize proper lifting procedures. See B.3a E. Mobilization 1. Preparation to mob to next 1a. Contact and caught 1a. Ensure an observer is watching the raising and lowering of drilling location or leave site the drill rig mast so no lines or overhead obstacles are contacted.  Use proper PPE (i.e., hard hat, safety glasses, hearing protection (while rig is operational), steel-toed boots, and leather work gloves.  Prior to lowering rig off of outriggers make sure all tools and personnel are clear of the drill rig. Prior to driving to next location make sure auger racks are in.  While rig is moving on site have spotters verify clearance so no overhead obstacles are contacted and no obstacles are hit while backing up. 1b. Exertion 1b. Utilize proper lifting procedures.  See B.3a and drink plenty of water and Gatorade.

JOB SAFETY ANALYSIS DATE 9/15/08 x NEW PAGE 1 of 2 REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Driving - To and From a Site 112 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Brenda Anderson Local HSO - FL-W Thomas Baylis Dir, HSSE Julius Pachy Reg HSSE Spec - MW Cris Altman Reg HSSE Spec - NE

REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR HEARING PROTECTION SAFETY SHOES FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR GLOVES PPE CLOTHING X OTHER Sealtbelts and Air bags GOGGLES SAFETY GLASSES HARD HAT REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Fire extinguisher 2. First aid kit 3. Yellow flashing light 4. Roadside emergency kit 5.

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Pre-mobilization 1. Inspect vehicle prior to 1a. Inadequate operation of 1a. Inspect exterior and interior of vehicle. departure vehicle ¾ Exterior: o Check condition of windshield wipers (wear and Note: cracking). ¾ Drive with low beams on at o Check tires for proper inflation rate and tread condition. all times o Check for body damage/overall condition. o Check under vehicle for fluid leaks (i.e., oil, brakes, ¾ Cell phone usage is not transmission, etc.). permitted while driving o Check all lights (i.e., hi/low beams, turn signals, ¾ Smoking is not permitted in emergency flashers). GES vehicles ¾ Interior: o Adjust seat to your height and visibility. o Adjust mirrors to eliminate blind spots. o Fasten safety belt (passengers too). o Secure all lose items in appropriate container, glove box. o Verifying critical equipment is working (i.e., defogger, wipers, air bags, lights, turn signals). 1b. Hazards caused by 1b. Prepare vehicle for weather conditions prior to departure environmental conditions ¾ Snow/Ice (inclement weather) o Scrape snow/ice from entire vehicle (i.e., hood, roof, windows, etc.). o Add extra weight to back of trucks to increase traction. o Maintain appropriate speed for conditions. o Maintain hand position at 9 and 3. ¾ Fog o Turn on fog lights. o Maintain appropriate speed for conditions. o Maintain hand position at 9 and 3. ¾ Rain o Ensure windows are defogged prior to mobilization. o Utilize windshield wipers as appropriate. o Consider alternative routes based on flooding potential of roadway. o Maintain appropriate speed for conditions. B. Driving 1. During mobilization, practice 1a. Accident caused by traffic 1a. Mitigate potential for an accident by practicing the following proper techniques to avoid conditions or other vehicles techniques: accidents (struck by, contact with) ¾ Look ahead a minimum of 15 seconds to identify potential oncoming hazards. ¾ Maintain 4-second minimum following distance (increase distance due to weather conditions). ¾ Avoid focusing on any one object for more than 2 seconds. ¾ Scan the road, area around vehicle, and mirrors every 3-5

JOB SAFETY ANALYSIS Page 2 of 2

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS seconds. ¾ Stay out of other vehicles blind spots. ¾ Do not drive in clusters of traffic (i.e., adjust speed to give cushion between your vehicle and others). ¾ Engage in eye contact with other drivers and ensure they see you ¾ Utilize turn signals at appropriate times 1b. Accident caused by road 1b. Mitigate the potential for an accident by practicing the surface condition (i.e., struck following techniques: by, contact with) ¾ Maintain appropriate speed; slower depending on (i.e., dirt, concrete, asphalt, gravel, etc.). ¾ Drive posted speed limits (i.e., city, country roads, and highway). ¾ Do not tailgate vehicles in front of you. ¾ Pay attention for pedestrians. ¾ Check for and yield to emergency vehicles. ¾ Place two hands on steering wheel at 9 and 3 position. ¾ Obey traffic signals. ¾ Use particular caution in construction zones. ¾ Look ahead a minimum of 15 seconds. Scan the road, area around vehicle, and mirrors every 3-5 seconds. C. Preparing to Park 1. Parking 1a. Injury/vehicle impairment 1a. Mitigate the potential for an accident by practicing the caused by contact with other following techniques: vehicles ¾ Maneuver vehicle slowly within parking lot. ¾ Ensure vehicle is legally parked. ¾ Back into space if appropriate (required on terminal sites) ¾ Ensure nothing is located at rear of vehicle prior to mobilization. ¾ Get out and inspect space and vehicle if unsure of potential or unseen hazards. D. Post Trip Inspections 1. Inspecting vehicle 1a. Inadequate operation of 1a. Identify problems that have occurred or may occur. Report vehicle any issues/problems to management to include: ¾ Maintenance needs. ¾ Malfunctions. ¾ Supply needs. 1b. Operational breakdown 1b. Perform the necessary maintenance in order to ensure vehicle use proper vehicle operation ¾ Report all activated indicator lights (i.e., check engine, oil, breaks, etc.). ¾ Perform monthly inspections. ¾ Follow manufactures recommendations for maintenance. ¾ Maintain cleanliness of interior.

WORK ACTIVITY (Description) — Driving – To and From a Site - #112

JOB SAFETY ANALYSIS DATE 2/23/05, 3/31/06, 8/17/07, 6/9/08, 4/24/09 NEW PAGE 1 of 2 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Drum Sampling/Evaluation 022 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Thomas Baylis, CIH Dir, HSSE Eric Munz, CSP Reg HSSE Spec - NE Eric Munz, CSP Reg HSSE Spec - NE

REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) X AIR PURIFYING RESPIRATOR X HEARING PROTECTION X SAFETY SHOES steel-toed and booties FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES nitrile exam gloves, nitirile 11-mil X PPE CLOTHING highly visible clothing such OTHER outer gloves, leather as orange coveralls, Tyvek, reflective safety X GOGGLES vest X HARD HAT X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. PID 2. LEL 3. Eyewash kit 4. Flashlight 5.

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Protective Equipment 1. Don proper PPE 1a. Exposure to contaminants 1a. Wear appropriate PPE (eye protection-goggles, long pants, nitrile exam gloves, nitrile over-gloves (11-mil, long wrist), Tyvek Note: This JSA is only coveralls, shirt with sleeves, steel-toed shoes with boot covers, intended for sampling drums half-face air purifying respirator fitted with an organic vapor, that contain waste oil or similar acid, HEPA filter combination cartridge). material. Drums that contain  Evaluate (monitor work area with a CGI/O2 (LEL). If levels an unknown material are not to exceed 10% LEL, leave the area and contact GES Corporate be opened and may only be H&S. handled and sampled under  Review action levels noted in the HASP. the direct supervision of  When approaching or sampling drum(s), monitor breathing Corporate H&S. zone with a PID. If levels exceed 50 ppm in breathing zone, leave area and contact GES Corporate H&S.  Restrict any contact with bailed/recovered waste samples. C. Inspect the Drum 1. Drum(s) condition 1a. Spill prevention and 1a. Evaluate drum(s) condition, if drums are distended or containment bulging, leave the area and contact GES Corporate H&S. To prevent contamination of clean or non-impacted surfaces, place absorbent material (i.e., pads, absorbent pillows, etc.) around the perimeter of the drum(s) and parts cleaner. Note: If any drums are filled with soil or any material, the drum can only be filled a maximum of two-thirds (2/3) full. 1b. Slips/trips/falls 1b. Keep all equipment and tools in designated areas within working (exclusion) zone.  Secure and protect all air lines, water lines, electrical cords, and cables. 1c. Cuts to the skin/PPE 1c. Handle all sample collection containers and tools with protective gloves (e.g., nitrile knit or leather) to prevent cuts.  Be cautious of your surroundings; do not kneel on broken glass or sharp objects. 1d. Fire, explosion 1d. Use the proper tool for the job. Use non-sparking tools for opening and sampling drums. 1e. Inadequate lighting 1e. Ensure that there is enough light to complete the necessary activities. If sufficient lighting can not be obtained, two GES personnel must be onsite to complete the necessary task. 2. Release pressure in the 2a. Pressurized vessel 2a. Loosen the vent port slowly to release any pressure that drum might have built up in the container. 3. Open the drum or securing 3a. Pinch point 3a. Use the proper type of gloves – thick enough to prevent the drum collar pinch points and cuts (i.e., leather, nitrile coated knit, etc.). 4. Moving/relocating drums 4a. Back strain 4a. If drums must be moved utilize a drum dolly.  DO NOT ATTEMPT TO “WALK” or “ROCK” DRUMS TO

JOB SAFETY ANALYSIS Page 2 of 2

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS MOVE THEM. Drums can become unstable and easily tip- over causing possible damage and personal injury as well as releasing the material contained.

WORK ACTIVITY (Description) — Drum Handling - #022

JOB SAFETY ANALYSIS DATE 2/28/05, 10/31/05, 7/29/09 NEW PAGE 1 of 1 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Gauging Liquid Levels in 027 Remediation Groundwater Monitoring Wells DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Thomas Baylis, CIH Dir, HSSE Julius Pachy Reg HSSE Spec - MW Eric Munz, ASP NE Corporate H&S Spec

REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR X HEARING PROTECTION X SAFETY SHOES steel-toed; booties FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES leather; nitrile X PPE CLOTHING highly visible clothing such & OTHER RESPIRATORS - may be required if GOGGLES as orange coveralls; reflective vest conditions or work area air quality exceeds HARD HAT X SAFETY GLASSES applicable HASP action levels REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. 2. 3. 4. 5.

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA - #028 B. Locate and Open Onsite Wells 1. Traverse site to wells 1a. Slips, trips, and falls 1a. Maintain all equipment and tools in designated areas and out of pathways.  Be alert for uneven terrain. 2. Inspect and open wells, 2a. Pinch points/abrasion 2a. Remove and replace manhole covers so that they do not replace well cap, and cover pinch fingers.  Wear leather work gloves to protect your fingers and hand.  Use kneeling pads when kneeling on hard surfaces. 2b. Contact with, struck by well 2b. Release any stored air pressure in the well casing by slowly cap removing well cap. C. Conduct Liquid Gauging 1. Insert interface probe into 1a. Exposure to site 1a. Wear appropriate PPE (i.e., eye protection, long pants, well contaminants nitrile sampling gloves, shirt with sleeves, steel-toed shoes). Note: Be aware that there may be elevated levels of gasoline or product vapors in product recovery wells. Note: If organic vapors are believed to be present, replace the well cap and do not proceed until a PID is obtained to scan the atmosphere ensuring that concentrations are below 5 ppm. 1b. Exposure to 1b. Avoid skin/eye/mouth contact with contamination chemicals decontamination chemicals and decon waste water.  Wear nitrile gloves and eye protection. 1c. Electrical shock or 1c. If there is an electrical powered pump installed in the well, electrocution the pump must be de-energized and locked and tagged out prior to inserting the interface probe into the well.

JOB SAFETY ANALYSIS DATE 4/11/05, 12/7/05, 5/8/06, 6/1/06, NEW PAGE 1 of 4 10/23/06, 2/21/07, 5/16/07, 6/4/07, X REVISED 10/24/07, 3/19/08, 9/16/08, 10/14/08, 12/23/08, 3/23/09, 4/9/09, 8/10/09 JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and General Site Activities (Night and 029 Remediation Dusk Work) — Health & Safety DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Lee Felski Thomas Baylis, CIH Dir, HSSE Sue Cameron

REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES leather; nitrile X PPE CLOTHING reflective safety vest OTHER GOGGLES X SAFETY GLASSES X HARD HAT if overhead hazards or areas of low overhead clearance are present REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Floodlights, light tower 2. Flashing traffic 3. Cones/flags 4. Miner head lamps 5. Wheel chocks barricades/beacon ¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Travel To and Arrive Onsite Complete JSA/HASP/safety 1a. Workers being struck/ 1a. Park in a secure area where vehicle is out of traffic pattern checklist/tailgate meeting injured and work vehicles/ so that tailgate safety meeting can be performed safely. Be property damage being caused extra cautious when parked near active roadways do to flying Note: Two individuals will be by traffic debris or other material flying off of roadway. required to be onsite for all 1b. Potential to cause a fire/ 1b. All personal electronic devices (i.e., cell phones) are not to activities that occur during the explosion by use of cell be used in the vicinity of tank systems, remediation systems, night unless an alternative phones and other electronic vehicular traffic areas, or any area where the potential for an approach is implemented that equipment explosive environment exists or where cell phone use can is approved by the director distract from surrounding hazards. Ensure that 10 lb fire HSSE and the regional extinguisher is brought to and available for site personnel. operations manager. 1c. Overhead hazards 1c. Inspect work area for any overhead hazards including overhead utilities and overhead trees and vegetation. Note: Please remember to  A visual inspection of overhead tree branches and complete each applicable vegetation should be conducted prior to starting a job task. client required checklist prior to  Suspicious or dead braches will need to be removed prior to performing on site activities. performing the job task.  Working in a wooded area during high winds should be Note: Identify and locate the avoided and re-evaluate conditions after a storm. Emergency Stop switch for the fuel delivery system at all active retail sites. 2. Establish/set up site control 2a. Personal injury from 2a. Wear highly visible clothing and REFLECTIVE traffic vests (traffic control) contact with vehicles; property must be worn. damage caused by being hit  Utilize cones/barricades/safety fence to establish work zones with a vehicle as indicated in the “Traffic Control Program” posted in the HASP. Flashing traffic barricades shall be placed around the work area perimeter.  Cone/flag height must be at least 50” tall. 2b. Personal injury to 2b. Establish access points in the work zone to keep pedestrians if hit by (contact pedestrians and unintentional traffic out. by) vehicles  Inform facility personnel of work (restricted) area and do not permit unauthorized individuals (those not properly trained or wearing appropriate PPE) access to the exclusion zone. 2c. Electrocution and/or 2c. A spotter must be utilized when vehicles, including property damage by contacting construction vehicles, are backing or moving onsite to ensure a overhead wires or structures. safe pathway. Prior to any vehicle movement, a discussion must be held with each designated spotter so that they are Note: If electrical utilities must aware of their responsibilities, hand signals that must be used be de-energized and locked for directing equipment operators and ensure that they are

JOB SAFETY ANALYSIS Page 2 of 4

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS and tagged out of service, a aware of any unique site conditions or concerns. thorough evaluation must be  Prior to moving any vehicle, all racks, doors, and toolboxes conducted of the work area to must be closed to prevent contact with objects and to ensure that all electrical prevent items from falling out in transport. service that is required to be  If there is no spotter, the driver must get out and walk around de-energized has been de- the vehicle prior to backing. energized and that no one  Spotters must look up to ensure that there are no overhead remains exposed to hazardous wires or structures such as canopies that can be struck and electrical energy. ensure that they can be safely cleared by the operating equipment.  Look down to identify unusual depressions, holes, or debris that may interfere with backing.  Observe fixed objects or parked, unoccupied vehicles.  Back slowly using rear view mirrors frequently.  If backing vision is obscured, stop the vehicle every few feet to exit and recheck the backing route.  Remain constantly alert at all times while backing a vehicle for the potential for other vehicles or pedestrians to appear unexpectedly in the path of travel.  Vehicle tail gate must be in up/closed position when vehicle 2d. Parked vehicles/ is in motion. equipment may roll and cause 2d. When parked and unhooked from a vehicle, trailers must injury and/or property damage have a wheel chock placed in front of and behind each rear wheel.  Wheel chocks must also be used for large vehicles when parked or positioned on uneven surfaces (terrain). In addition, wheel chocks must be used for vehicles or machinery that include but are not limited to all IRSP trucks (DAPL, HypeAir#1, #2, trailer, skid mounted F-250, F-350, dewatering truck, and PRSP trailers), aerial manlifts (cherrypickers), geoprobes as appropriate, airknife units, VR units, and all vehicles with manual transmissions when 2e. Personal injury due to parked on sloped surfaces. working at dusk work and 2e. One or more flood lights (at least 4 feet high) with an output limited lighting within the of 500 watt minimum shall be positioned so sufficient lighting is vicinity of the area covered by maintained over the work area. The lighting should be sufficient operating permanent lights to perform work safely and that personnel and machinery is (i.e., service station) visible by all motorist.  A flashing beacon light shall be used and placed on the top of GES vehicle, parked in the vicinity of the working area.  The GES vehicle should have the warning lights on.  The beacon light and working sign should be placed so that the most visibility can be provided to motorists or other 2f. Personal injury due to night traffic. work/improper lighting and 2f. A tower light (30 feet in height) with an output of 50,000 work area visibility lumens shall be positioned so that an average illuminance of 20 footcandles is maintained over the work area. The lighting should be sufficient so that personnel and machinery is visible by all motorists.  Machine lights shall be operated throughout the work period.  Two illuminated work area signs shall be used and placed at the entrance to and exit from the work area. The signs should be placed so that the most visibility can be provided to motorists or other traffic. 3. Remove/load equipment 3a. Personal injury due to back 3a. Utilize proper lifting procedure (keep your back straight) from vehicle or other strains when loading coolers and/or equipment back into truck. Bend down at the knees and lift with your legs rather than bending Note: If equipment is to be and/or lifting with your back. placed within an area that has  To avoid lifting heavy/awkward coolers, leave cooler on an overhead/garage door tailgate to load samples and ice into. which has not been in use or  Utilize material handling devices when possible to move appears to be in poor or equipment (i.e., lift gates, pallet jacks, dollies, etc.). suspect condition, the door  If necessary, utilize a ramp for loading and unloading

JOB SAFETY ANALYSIS Page 3 of 4

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS and operating system (springs/ wheeled devices, ensuring the ramp is properly supported pulleys and wires) must be prior to use. inspected by a qualified  Use mechanical means or assistance for items weighing >50 overhead/garage door repair lbs. service. The qualified 3b. Personal injury due to falls 3b. Maintain three points of contact when exiting vehicle cab or individual must ensure that the while exiting vehicles when exiting truck beds. door can be operated safely  Position cooler/equipment in a location that is nearest to exit and that the door and its point of vehicle (i.e., cab door, truck bed tailgate) to eliminate operating system do not the need to carry items while exiting vehicle. present any hazards to the 3c. Personal injury due 3c. Ensure all equipment is properly secured and stored (i.e., tie individuals occupying the area. equipment shift downs, adjustable straps, tool box, tool cabinet, etc.) during non- use and transportation.  Don appropriate gloves (leather) when securing or removing equipment.  During removal of equipment be cautious of pinch points that may have been created due to shifting equipment or equipment that may be secured or stored together. 4. Exposure 4a. Weather related issues 4a. Staff should understand and be able to recognize the signs and/or symptoms of cold and hot weather related illnesses.  Personnel should dress appropriately for ambient temperatures which would include the use of dry layered clothing. 4b. Cold stress related injury 4b. For cold weather, work schedules should be adjusted to provide sufficient break periods in a heated area. 4c. Heat stress related injury 4c. For hot weather, work schedules may need to be adjusted to provide time intervals for replenishing fluids and which is free of contamination. 4d. Severe weather 4d. Avoid exposure to severe weather.  Pay attention to severe weather alerts and take appropriate precautions to secure life and property when severe weather occurs in work area.  Take precautions with approaching thunderstorms and lighting. Discontinue all work until 30 minutes after severe weather has passed.  In case severe weather such as tornados, hailstorms, or strong winds, take cover and make every effort to protect life. Note: When operating equipment or machinery indoors that is fueled by gasoline, propane, or other hydrocarbon fuels, the emissions must be exhausted to the outside and carbon monoxide (CO) levels must be monitored during indoor activities. Levels of CO that exceeds 35 ppm will require operations to cease and staff to evacuate from the work area. 4e. Personal injury or illness 4e. Review and understand action levels noted in the HASP. due to exposure to site  Monitor (evaluate) breathing zone of workers with PID. contaminants  Monitor (evaluate) any enclosure with a PID.  Ensure that Level C PPE is available for potential upgrade. Note: GES and/or subcontractor personnel are required to wear fire retardant clothing or protection when operating cutting tools that may generate sparks or generate conditions that act as ignition sources. B. Biological Hazards 1. Exposure 1a. Injury or illness caused by 1a. Wear appropriate PPE (i.e., eye protection, long pants, exposure to bio-hazards nitrile sampling gloves, shirt with sleeves, steel-toed shoes). 1b. Personal injury or illness 1b. Do not touch or contact poisonous plants, such as poison caused by exposure to ivy and poison oak. poisonous plants  If available, apply an over-the-counter barrier cream, such as Ivy Block® to prevent contact with plant oils.  Wash hands and arms immediately with soap and water if skin contacts the plants.  Wear long pants with socks pulled over legs to prevent skin contact with plants and insects. 1c. Personal injury or illness 1c. Spray any wasp/hornet nests with an insect repellant from a

JOB SAFETY ANALYSIS Page 4 of 4

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS due to exposure to insects safe distance recommended by the product’s manufacturer.  Inspect yourself carefully for insects or ticks after being outdoors.  Visually inspect and carefully open any outside enclosures that insects and small animals could potentially enter. 1d. Personal injury or illness 1d. Do not antagonize snakes or wild animals. due to encounters with animals C. Traverse Site 1. Traversing site 1a. Personal injury due to 1a. Maintain all equipment and tools in designated areas and slips, trips, and falls out of pathways.  Look for changes in elevation and grade when walking on uneven terrain.  If applicable, replace manhole covers securely to prevent tripping and vehicle accidents.  If ice and slick conditions are present, use salt or sand to add traction to prevent slips.  Snow can be moved away from walk ways if it poses a slip hazard.

WORK ACTIVITY (Description) — General Site Activities (Night and Dusk Work) - #029

JOB SAFETY ANALYSIS DATE 11/1/04, 1/19/05, 2/8/05, 3/7/05, 4/11/05, NEW PAGE 1 of 3 11/2/05, 6/6/05, 5/8/06, 6/1/06, 10/23/06, X REVISED 2/21/07, 5/16/07, 6/4/07, 10/24/07, 3/19/08, 4/11/08, 5/12/08, 6/20/08, 9/16/08, 10/14/08, 12/23/08, 3/23/09, 8/10/09 JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and General Site Activities — Health & 028 Remediation Safety Contingency Plan DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Jim Leonard Thomas Baylis, CIH Dir, HSSE Nick Kowalczyk Dawn Vought Sr Project Manager REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) & AIR PURIFYING RESPIRATOR half-mask & HEARING PROTECTION X SAFETY SHOES steel-toed respirator LIFELINE / HARNESS SUPPLIED RESPIRATOR & FACE SHIELD X PPE CLOTHING reflective safety vest or OTHER X GLOVES leather; nitrile orange outerwear GOGGLES X SAFETY GLASSES X HARD HAT if overhead hazards or areas of low overhead clearance are present REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Insect repellent with 2. Sunscreen 3. Wheel chocks 4. 5. DEET (recommended) (recommended) ¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Travel To and Arrive Onsite 1. Complete JSA/HASP/safety 1a. Workers being struck/ 1a. Park in a secure area where vehicle is out of traffic pattern so checklist/tailgate meeting injured and work vehicles/ that tailgate safety meeting can be performed safely. Be extra property damage being caused cautious when parked near active roadways do to flying debris or Note: Please remember to by traffic other material flying off of roadway. complete each applicable client 1b. Potential to cause a fire/ 1b. All personal electronic devices (i.e., cell phones) are not to be required checklist prior to explosion by use of cell phones used in the vicinity of tank systems, remediation systems, vehicular performing on site activities. and other electronic equipment traffic areas, or any area where the potential for an explosive environment exists or where cell phone use can distract from. Note: Identify and locate the Ensure that a 10 lb fire extinguisher is brought to and made Emergency Stop switch for the available to site personnel surrounding hazards. fuel delivery system at all active 1c. Overhead hazards 1c. Inspect work area for any overhead hazards including overhead retail sites. utilities and overhead trees and vegetation.  A visual inspection of overhead tree branches and vegetation should be conducted prior to starting a job task.  Suspicious or dead braches will need to be removed prior to performing the job task.  Working in a wooded area during high winds should be avoided and re-evaluate conditions after a storm. 2. Establish/set up site control 2a. Personal injury from contact 2a. Wear highly visible clothing such as orange reflective traffic (traffic control) with vehicles; property damage vests or clothing. caused by being hit with a  Utilize cones/barricades/safety fence to establish work zones as vehicle indicated in the “Traffic Control Program” posted in the HASP.  Cone/flag height must be at least 50” tall. 2b. Personal injury to 2b. Establish access points in the work zone to keep pedestrians pedestrians if hit by (contact by) and unintentional traffic out. vehicles  Inform facility personnel of work (restricted) area and do not permit unauthorized individuals (i.e., those not properly trained or wearing appropriate PPE) access to the exclusion zone. 2c. Electrocution and/ or 2c. A spotter must be utilized when vehicles, including construction property damage by contacting vehicles, are backing or moving onsite to ensure a safe pathway. overhead wires or structures. Prior to any vehicle movement, a discussion must be held with each designated spotter so that they are aware of their responsibilities, Note: If electrical utilities must hand signals that must be used for directing equipment operators, be de-energized and locked and and ensure that they are aware of any unique site conditions or tagged out of service, a concerns. thorough evaluation must be  Prior to moving any vehicle, all racks, doors, and toolboxes must conducted of the work area to be closed to prevent contact with objects and to prevent items ensure that all electrical service from falling out in transport. that is required to be de-  If there is no spotter, the driver must get out and walk around energized has been de- the vehicle prior to backing.

JOB SAFETY ANALYSIS Page 2 of 3

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS energized and that no one  Spotters must look up to ensure that there are no overhead remains exposed to hazardous wires or structures such as canopies that can be struck and electrical energy. ensure that they can be safely cleared by the operating equipment.  Look down to identify unusual depressions, holes, or debris that may interfere with backing.  Observe fixed objects or parked, unoccupied vehicles.  Back slowly using rear view mirrors frequently.  If backing vision is obscured, stop the vehicle every few feet to exit and recheck the backing route.  Remain constantly alert at all times while backing a vehicle for the potential for other vehicles or pedestrians to appear unexpectedly in the path of travel.  Vehicle tailgate must be in up/closed position when vehicle is in motion. 2d. When parked and unhooked from a vehicle, trailers must have 2d. Parked vehicles/equipment a wheel chock placed in front of and behind each rear wheel. may roll and cause injury and/or  Wheel chocks must also be used for large vehicles when parked property damage or positioned on uneven surfaces (terrain).  Wheel chocks must be used for vehicles or machinery that include but are not limited to all IRSP trucks (i.e., DAPL, HypeAir #1, #2, trailer, skid mounted F-250, F-350, dewatering truck, and PRSP trailers), aerial manlifts (i.e., cherrypickers), geoprobes as appropriate, airknife units, VR units, and all vehicles with manual transmissions when parked on sloped surfaces. 3. Remove/load equipment from 3a. Personal injury due to back 3a. Utilize proper lifting procedure (keep your back straight) when vehicle or other strains loading coolers and/or equipment back into truck. Bend down at the knees and lift with your legs rather than bending and/or lifting Note: If equipment is to be with your back. placed within an area that has  To avoid lifting heavy/awkward coolers, leave cooler on tailgate an overhead/garage door which to load samples and ice into. has not been in use or appears  Utilize material handling devices when possible to move to be in poor or suspect equipment (i.e., lift gates, pallet jacks, dollies, etc.). condition, the door and  If necessary, utilize a ramp for loading and unloading wheeled operating system (springs/ devices, ensuring the ramp is properly supported prior to use. pulleys and wires) must be  Use mechanical means or assistance for items weighing >50 inspected by a qualified lbs. overhead/garage door repair 3b. Personal injury due to falls 3b. Maintain three points of contact when exiting vehicle cab or service. The qualified individual while exiting vehicles when exiting truck beds. must ensure that the door can  Position cooler/equipment in a location that is nearest to exit be operated safely and that the point of vehicle (i.e., cab door, truck bed tailgate) to eliminate door and its operating system do the need to carry items while exiting vehicle. not present any hazards to the 3c. Personal injury due to 3c. Ensure all equipment is properly secured and stored (i.e., tie individuals occupying the area. equipment shift downs, adjustable straps, tool box, tool cabinet, etc.) during non- use and transportation.  Don appropriate gloves (leather) when securing or removing equipment.  During removal of equipment be cautious of pinch points that may have been created due to shifting equipment or equipment that may be secured or stored together. 4. Exposure 4a. Weather related issues 4a. Staff should understand and be able to recognize the signs and/or symptoms of cold and hot weather related illnesses.  Personnel should dress appropriately for ambient temperatures which would include but not be limited to dry layered clothing.  Applying sunscreen to exposed skin is strongly recommended during sunny weather conditions (all seasons) to mitigate sun exposure. 4b. Cold stress related injury 4b. For cold weather, work schedules should be adjusted to provide sufficient break periods in a heated area. 4c. Heat stress related injury 4c. For hot weather, work schedules may need to be adjusted to provide time intervals for replenishing fluids and which is free of contamination. 4d. Severe weather 4d. Avoid exposure to severe weather.  Pay attention to severe weather alerts and take appropriate precautions to secure life and property when severe weather

JOB SAFETY ANALYSIS Page 3 of 3

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS occurs in work area.  Take precautions with approaching thunderstorms and lighting. Discontinue all work until 30 minutes after severe weather has passed.  In case severe weather such as tornados, hailstorms, or strong winds, take cover and make every effort to protect life. Note: When operating equipment or machinery indoors that is fueled by gasoline, propane, or other hydrocarbon fuels, the emissions must be exhausted to the outside and carbon monoxide (CO) levels must be monitored during indoor activities. Levels of CO that exceeds 35 ppm will require operations to cease and staff to evacuate from the work area. 4e. Personal injury or illness due 4e. Review and understand action levels noted in the HASP. to exposure to site contaminants  Monitor (evaluate) breathing zone of workers with PID.  Monitor (evaluate) any enclosure with a PID.  Ensure that Level C PPE is available for potential upgrade. Note: GES and/or subcontractor personnel are required to wear fire retardant clothing or protection when operating cutting tools that may generate sparks or generate conditions that act as ignition sources. B. Biological Hazards 1. Exposure 1a. Injury or illness caused by 1a. Wear appropriate PPE (i.e., eye protection, long pants, nitrile exposure to bio-hazards sampling gloves, shirt with sleeves, steel-toed boots). 1b. Personal injury or illness 1b. Do not touch or contact poisonous plants, such as poison ivy caused by exposure to and poison oak. poisonous plants  If available, apply an over-the-counter barrier cream, such as Ivy Block® to prevent contact with plant oils.  Wash hands and arms immediately with soap and water if skin contacts the plants.  Wear long pants with socks pulled over legs to prevent skin contact with plants and insects. 1c. Personal injury or illness due 1c. Spray any wasp/hornet nests with an insect repellent from a to exposure to insects safe distance recommended by the product’s manufacturer.  Ensure that long sleeve shirts and pants are worn at all times to prevent contact with ticks. Using insect repellent with DEET is strongly recommended. Do not spray your skin directly. If conditions warrant, don a Tyvek suit.  Visually inspect and carefully open any outside enclosures that insects and small animals could potentially enter. 1d. Personal injury or illness due 1d. Do not antagonize snakes or wild animals. to encounters with animals C. Traverse Site 1. Walking service 1a. Personal injury due to slips, 1a. Maintain all equipment and tools in designated areas and out of trips, and falls pathways.  Look for changes in elevation and grade when walking on uneven terrain.  If applicable, replace manhole covers securely to prevent tripping and vehicle accidents.  If ice and slick conditions are present, use salt or sand to add traction to prevent slips.  Snow can be moved away from walkways if it poses a slip hazard.  Place temporary ramps over hoses or cords leading from water source or power source to designated work zone.

WORK ACTIVITY (Description) — General Site Activities - #028

JOB SAFETY ANALYSIS DATE 2/7/05, 3/8/05, 5/20/05, 5/24/06, 7/10/06, NEW PAGE 1 of 2 8/22/06, 6/8/07, 5/12/08, 5/16/08, X REVISED 11/11/08, 8/4/09 JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Geoprobing/Soil Sampling 030 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Dan Germann Local HSO - NJ Thomas Baylis, CIH Dir, HSSE

REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR X HEARING PROTECTION X SAFETY SHOES FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES Nitrile, surgical, Kevlar X PPE CLOTHING OTHER GOGGLES X SAFETY GLASSES X HARD HAT REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Lockout/tagout kit 2. Spill response 3. 4. 5. kit/spillpad - used under hydraulic equipment when work activities occur on a permeable surface such as grass or gravel ¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA - #028 B. Review “Cutting Tool Note: Nitrile or other surgical gloves must always be worn over Use” JSA - #015 cut resistant gloves (Kevlar) or other workgloves. C. Lockout/Tagout 1. Lockout all possible 1a. Electrocution/contact with 1a. Locate all sources of electricity to site parking lights, air electrical lines on-site energized electrical lines compressor, vacuum, car wash, ID sign, and de-energize lines by using locks and tags or a tag a minimum.  Notify all affected employees on-site of the de-energized condition. D. Mobilize to Sampling Location 1. Geoprobe set up, set up 1a. Contact with obstructions 1a. Check well locations for underground and overhead utilities decon area for augers follow GES subsurface protocol.  Observe mast set up so no contact is made with overhead obstacles. 1b. Vehicle stability 1b. The geoprobe must be leveled prior to beginning advancement activities. 1c. Pinch points 1c. Remind everyone never to leave hand tools on rig. The rig can move and cause their hand/arm/tools to become pinched. 1d. Contact with high pressure 1d. Set up decon area/pad for augers (if decon on site) water  Do not spray your face/body with water.  If using a hot water pressure washer be aware of high temperature water. 2. Open/cut concrete, asphalt, 2a. Eye injury, cuts to skin 2a. Proper use of equipment (i.e., concrete saw, core drill, etc.). or soil at soil sampling location  Make sure all kill switches and blade guards are functioning properly and correctly positioned per manufacturer’s instruction.  Refer to the “Cutting Tool Use” JSA #015 for more information. 3. Hand clear soil boring 3a. Damage to underground 3a. Hand clear slowly, do not force through soil. You may location to assure no improvements contact/break underground lines (“soft dig” technologies are underground improvements strongly recommended).  Ensure that the use of non destructive methods such as hand augering or vacuum digging creates a borehole clearance that is at least 2 inches wider than the widest drilling tool.  Always clear to at least 5’ depth outside the exclusion zone and to 8’ depth in the exclusion zone.

JOB SAFETY ANALYSIS Page 2 of 2

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS  If soils are collapsing during the soft dig process, insert the appropriate sized PVC casing to keep the hole open at least 2 inches wider than the widest drilling tool. 3b. Bodily injury 3b. Wear proper PPE (i.e., safety glasses, hard hat, Level D clothing, hard hat, and work gloves) during hand clearing activities. 3c. Muscle/joint strain 3c. Keep your feet shoulder width apart to improve stability and to avoid back, neck, and wrist strain injuries. E. Soil Sampling 1. Begin drilling, soil boring 1a. Caught on rotating parts 1a. Stay an arms length away from moving/rotating parts (i.e., augers, drill drive shaft). 1b. Contact to contaminants 1b. Use nitrile gloves while handling soil samples. Scan with a PID. 1c. Inhalation of organic 1c. Monitor the air in the work area with a PID for elevated vapors vapors during the drilling activities.  Discontinue activities if the PID reads >5 ppm sustained for 10 minutes. 1d. Cut/abrasion to the skin 1d. If tightening rods, wear work gloves to prevent injury to the hand. 2. Collecting soil samples/ 2a. Housekeeping 2a. Stay alert while logging soil samples for all drilling activities. removal of acetate sleeve from  Maintain your work area, keep walkways clean, tools picked direct-push sampler up, and soil in drums should be placed out of walkways and traffic areas. 2b. Improper drum storage 2b. For petroleum only contamination from a UST release or petroleum only contamination that is going to be recycled, the drum must be labeled non-hazardous. For all other sites, check with the project manager or industrial program manager. 2c. Slip on ice formations 2c. If ice forms while drilling in colder months, apply sand or salt to the work area to increase traction. 2d. Cuts to the skin from 2d. If a sample jar breaks, wear leather work gloves during the broken glass cleanup to prevent cuts to the skin. 2e. Cuts to the skin from tool 2e. If an acetate sleeve needs to be cut, DO NOT not use a blade utility knife (i.e., Stanley knife, box cutter) to cut the plastic liner.  A cutting tool with a self retracting blade is acceptable.  Cut away from your body and keep hands out of the path of cutting tools. 2f. Muscle/joint strain 2f. If the acetate sleeve can not be removed by normal means, then the truck deck extruder will be used or the direct-push sampling device will be taken back to the shop for proper removal of the sleeve after the soil sample is removed. Note: Never attempt to remove the sleeve by using a pulling or jerking motion. This action could possibly cause a strain to occur. 3. Preparation to mob to next 3a. Contact with overhead 3a. Insure an observer is watching the lowering of the drill rig drilling location or leave site obstructions and equipment mast so no lines or overhead obstacles are contacted.  Prior to lowering rig off of outriggers make sure all tools and personnel are clear of the drill rig.  Prior to driving to next location make sure auger racks are secured and the drilling mast is completed lowered. Note: While rig is moving on site, have spotters verify clearance so no overhead obstacles are contacted and no obstacles are hit while backing.

WORK ACTIVITY (Description) — Geoprobing/Soil Sampling - #030

JOB SAFETY ANALYSIS DATE 2/8/05, 3/8/05, 6/9/05, 9/16/05, 12/21/05, NEW PAGE 1 of 3 12/28/06, 6/4/07, 12/4/07, 6/11/08, X REVISED 10/16/08, 12/23/08, 3/20/09, 8/3/09, 12/21/09, 1/26/10 JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Sampling Groundwater Sampling 032

INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Maurice Baron Reg HSSE Spec - SE & Intern Thomas Baylis, CIH Dir, HSSE

REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. AIR PURIFYING RESPIRATOR X HEARING PROTECTION if site activities X SAFETY SHOES steel-toed FACE SHIELD raise the noise level to 85 dB SUPPLIED RESPIRATOR X GLOVES nitrile; Kevlar; leather LIFELINE / HARNESS OTHER GOGGLES X PPE CLOTHING highly visible clothing such X HARD HAT if working in an area with low as orange coveralls, reflective safety vest overhead clearance X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. LEL (to be used if within 2. PID (if organic vapors 3. 4. 5. 35 feet of an ignition are probable) source)

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Locate and Open Onsite Note: The GES SOP for “Groundwater Sampling” must be reviewed. Please note that it is Wells important that the GES vehicle is shut-off or the vehicle positioned so that the vehicle exhaust does not present an exposure concern for staff members or impact sample integrity. 1. Inspect and open wells 1a. Pinch points/abrasion 1a. Remove and replace manhole covers so that they do not pinch fingers.  Use a screwdriver or crowbar as appropriate and wear work gloves to prevent injuries to hands.  Use kneeling pads when kneeling on hard surfaces. 1b. Back strain 1b. Utilize proper lifting procedure when removing covers. Bend down at the knees and lift with your legs rather than bending and/or lifting with your back. 1c. Shoulder strain resulting 1c. Always keep your wrist straight when using a wrench. from using a socket wrench to  Be sure that the opening of the socket is in full contact with loosen and remove bolts from the bolt before you apply pressure. the lid  Pull, don't push, and use a slow, steady motion. If the bolt can not be loosened with normal force, use the correct breaking bar and do not place a piece of pipe on the end of the wrench to improve leverage.  Protect yourself from losing your balance if the wrench slips or a bolt breaks. Kneel on a solid surface with one foot planted firmly on the floor and don't lean into the work. Note: Never use hand sockets with power or impact wrenches. Replace sockets showing cracks or wear. C. Conduct Liquid Gauging 1. Insert interface probe into 1a. Exposure to site 1a. Wear appropriate PPE (i.e., eye protection, long pants, well and record liquid level contaminants nitrile sampling gloves, shirt with sleeves, steel-toed boots). reading in site log book 1b. Inhalation of organic 1b. If organic vapors are present, replace the well cap and do vapors not proceed until a PID is obtained to scan the atmosphere ensuring that concentrations are below 5 ppm. Note: Be aware that there may be elevated levels of gasoline or product vapors in the wells. D. Purge Monitoring Well 1. Set up of equipment; insert 1a. Exposure to site 1a. Refer to PPE required for C.1a. bailer/pump into monitoring contaminants  Do not splash purged water on clothing or skin. well and purge water into 1b. Exposure to acid from 1b. Prior to lifting and carrying battery from GES vehicle to appropriate container at battery that is used to power sample location, inspect the battery to ensure that there is no surface purge pump visible sign of leaking acid.  It is recommended that the battery is placed and carried to

JOB SAFETY ANALYSIS JSA # - 032 Page 2 of 3

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS location in a carrying container that would prevent acid from Note: When using non- contacting sampling personnel and equipment. intrinsically safe pumps within 1c. Cuts, punctures 1c. Don leather gloves during the connection of the battery 35 feet of a vapor source, converter to the car battery. within the critical zone as 1d. Hand injuries from cutting 1d. Use cut resistant gloves when cutting polyethylene tubing to defined by client-specific polyethylene tubing and bailing prevent hand injuries. protocols, or when there are string  Use a proper tool, a tubing cutter. noticeable gasoline vapor  When cutting bailing string to attach to bailer, cut away from odors, the atmosphere must the body, not towards. be tested with a combustible  Wear Kevlar or similar cut resistant gloves. gas indicator so that it can be  Use appropriate cutting tool, i.e. scissors, safety knife, etc. determined if the atmosphere 1e. Repetitive motion from 1e. Take frequent breaks as needed to prevent fatigue to contains less than 10% of the bailing purge water shoulder and arm muscles caused by bailing water. LEL.  Be aware of the signs and symptoms of repetitive stress injuries and report all symptoms immediately. 1f. Spill or release of impacted 1f. Take care to minimize the splash/release of purged water. water prior to treatment (if  If purging activity causes splashing, slow the bailing process required by local regulations) to prevent the loss of water. 1g. Electrical shock hazard 1g. If using an energy source to power and electric pump, refer to the owner’s manual for correct setup procedures.  When using a battery, make sure that the polarity is correct (i.e., positive to positive contact, etc.).  If the connection is loose, repair or replace the cord. 1h. Slip, trip, fall on 1h. Set up the work area so that all of the cords and piping are cords/piping in one area. This will help to minimize the possibility of tripping. 1i. Back injuries 1i. Utilize proper lifting procedure (i.e., keep your back straight) when loading coolers and/or equipment back into truck. Bend down at the knees and lift with your legs rather than bending and lifting with your back.  To avoid lifting heavy/awkward coolers, leave cooler on tailgate to load samples and ice into.  Utilize material handling devices when possible to move equipment (i.e., lift gates, pallet jacks, dollies, etc.).  If necessary, utilize a ramp for loading and unloading wheeled devices, ensuring the ramp is properly supported prior to use. Note: Tie a rope or line to the pump that can be used to raise and lower pump from the well. Do not lower or raise the pump by pulling on the electrical feeds. Note: No one should ever attempt to lift an object that weighs greater than 50 lbs. E. Conduct Groundwater Sampling 1. Insert disposable 1a. Exposure to site 1a. Refer to PPE required for C.1a. bailer/peristaltic pump into contaminants monitoring well to collect water for sampling 2. Collect groundwater in 2a. Pull out bailer/tubing from 2a. Refer to PPE required for C.1a. sampling container monitoring well  Do not splash purged water on clothing or skin.  Pull out tubing carefully to avoid hitting the body or face. 2b. Burns to the skin/eyes 2b. Avoid contact with preservatives. These are commonly corrosive and can burn the skin/eyes on contact.  Kevlar and nitrile surgical gloves should be worn when opening a cooler and retrieving sample collection containers. Sample preservative may have leaked from a container or multiple containers. Sample preservatives consist of various types of acids that include HCL, HNO3, and H2SO4 – hand and skin protection is necessary.  Flush skin/eyes with water if contact is made.  Refer to the MSDS for more information. 2c. Cuts to the skin 2c. Wear Kevlar gloves under nitrile-surgical gloves when sampling and especially when handling broken glassware.

JOB SAFETY ANALYSIS JSA # - 032 Page 3 of 3

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS  Wear Kevlar gloves when using a blade to cut bailer twine.  Cut away from the body, not towards. 2d. Contact with skin or 2d. Place bailer back into well when filling multiple collection clothing containers.  Do not hold bailer under arm or between knees when switching to a new container. F. Decontamination 1. Soak/spray durable 1a. Exposure to 1a. Refer to PPE required for C.1a. equipment to prevent cross- decontamination chemicals  Avoid contact with all decontamination chemicals including contamination between Liquinox, Simple Green, Methanol, and any other solvents multiple well locations; properly used on sampling equipment. store disposable equipment G. Replace Well Cap and Cover 1. Replace well cap and cover 1a. Pinch points 1a. Refer to B.1a above.

JOB SAFETY ANALYSIS DATE 5/31/06, 1/29/07 NEW PAGE 1 of 1 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Monitoring Well Development 088 Remediation (Utilizing Dry Penetrating Agent (DPA)) DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Thomas Baylis, CIH Dir, HSSE Dan Germann Local HSSE - NJ

REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR & HEARING PROTECTION if noise levels X SAFETY SHOES steel-toed shoes & FACE SHIELD during the mixing of the DPA exceed 90 dB SUPPLIED RESPIRATOR X GLOVES leather/nitrile LIFELINE / HARNESS X OTHER HALF FACE RESPIRATOR - with GOGGLES X PPE CLOTHING highly visible clothing such HEPA filters & HARD HAT if overhead hazards are present as orange coveralls, reflective safety vest; or working in an area with low overhead Tyvek suit may be necessary if whole body clearance contact is unavoidable X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Sorbent sock or pillow 2. 3. 4. 5.

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA - #028 B. Locate and Open Onsite Wells 1. Inspect and open wells 1a. Pinch points, abrasion 1a. Remove and replace manhole covers so that they do not pinch fingers. Wear leather gloves for this task. 1b. Back strain 1b. Utilize proper lifting procedure when removing covers. ¾ Bend down at the knees and lift with your legs rather than bending and lifting with your back. C. Mix DPA 1a. Contact or exposure to DPA 1a. Wear half face respirator with HEPA filters for particulate, a face shield with safety glasses underneath, nitrile or latex surgical gloves, long sleave shirts, and pants. Note: Comply with the requirements found in the MSDS for DPA. D. Add DPA to Well 1a. Contact or exposure to 1a. Wear a face shield with safety glasses underneath and nitrile diluted DPA chemical gloves (only). Comply with the requirements presented in the MSDS for DPA as well as the Technical Data provided for DPA. E. Well Water Agitation and Purging 1. Setup pump and check valve, 1a. Exposure to site 1a. Wear appropriate PPE (i.e., eye protection, long pants, leather tubing, ring, and generator contaminants palm gloves, shirt with sleeves, steel-toed boots). 1b. Slip, trip, fall 1b. Setup work area to minimize the amount of hoses and equipment positioned in walkways. 2. Operate generator, pump and 2a. Repetitive motion operating 2a. Take frequent breaks as needed to prevent fatigue to shoulder or agitate well water pump and arm muscles caused by water agitation with bailer. ¾ Be aware of the signs and symptoms of repetitive stress injuries and report all symptoms immediately. 2b. Exposure from splashes 2b. Wear additional PPE (i.e., Tyvek) and pace bailing actions. during agitation activities and purging 2c. Spill or release of impacted 2c. Have spill pillows or socks available to contain any release or water impacted water spill. 3. Remove pump and tubing 3a. Exposure to contaminants 3a. Refer to C.1 above. from well 3b. Back/muscle strain 3b. Refer to B.1b above. F. Decontamination 1. Soak/spray durable 1a. Exposure to 1a. Wear appropriate PPE (i.e., eye protection, long pants, nitrile equipment to prevent cross- decontamination chemicals sampling gloves, shirt with sleeves, steel-toed boots). contamination between multiple ¾ Avoid contact with all decontamination chemicals including well locations; properly store Liquinox, Simple Green, Methanol, and any other solvents used disposable equipment on sampling equipment. 2. Replace well cap and cover 2a. Pinch points 2a. Refer to B.1 above.

JOB SAFETY ANALYSIS DATE 2/9/05, 3/10/05, 5/5/06, 2/5/10 NEW PAGE 1 of 2 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Equipment Operation Portable Generator Use 053

INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Julius Pachy Reg HSSE Spec - MW Thomas Baylis, CIH Dir, HSSE

REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. AIR PURIFYING RESPIRATOR X HEARING PROTECTION if noise levels X SAFETY SHOES steel-toed FACE SHIELD exceed 85 dB SUPPLIED RESPIRATOR X GLOVES leather; nitrile LIFELINE / HARNESS OTHER GOGGLES X PPE CLOTHING highly visible clothing such X HARD HAT if overhead hazards are present as orange coveralls, reflective safety vest X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Sorbent pads 2. Funnel 3. Ground fault circuit 4. 5. interruptor (GFCI)

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Transporting Generator 1. Place the generator into 1a. Damage to the generator 1a. Ensure that individuals read and understand the vehicle which could result in improper manufacturer’s specifications and and operation understand the requirements for proper transportation and handling.  Never transport the generator in the passenger area of a vehicle. 1b. Muscle/back strain 1b. Lift with your legs and not your back while handling the equipment.  Wear PPE including leather gloves when handling the generator. C. Using the Generator 1. Remove the generator from 1a. Muscle/back strain 1a. Lift with your legs and not your back while handling the the vehicle equipment.  Wear PPE including leather gloves when handling the generator. 2. Set up generator 2a. Shock/electrocution 2a. Insure the portable generator is located on the ground. Note: Portable generator can not stay or be mounted within the truck unless proper grounding and bounding are performed.  Verify that the grounding wire between the generator and generator frame is intact and secure if not removing generator from the truck.  Place the generator in a well vented area away from flammable objects.  Have a fire extinguisher readily available within 10 feet of the portable generator. 3. Plugging tools/ equipment 3a. Shock/electrocution 3a. Start the generator and allow it to warm up. into the generator  When using hand operated tools and using the 120 volt, 15 or 20 amp receptacles, a GFCI is required to be in line.  Other electric operated equipment using greater than 120 volt receptacles do not require GFCI, but need to be grounded. D. Fueling Generator 1. Prepare area for fueling 1a. Fire/explosion 1a. Keep operation area well-vented (i.e., outdoors). process  Keep generator at least 3 feet away from any object.  Do not place flammable objects near generator.  Do not use generator in an environment where flammable vapors are present. Note: Check location/inspect all fire extinguishers. Have fire extinguisher readily available within 10 feet.

JOB SAFETY ANALYSIS JSA # - 053 Page 2 of 2

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS 2. Remove gas tank cap on 2a. Exposure to fuel and 2a. Don appropriate PPE (i.e., nitrile gloves). the generator; carry refueling vapors  Store fuel in approved container (i.e., metal can with self- container to refueling area closing spring lid).  Store fuel in a well vented area free of open flames or sparks. 3. Fill generator fuel tank 3a. Exposure to fuel and 3a. Don appropriate PPE (nitrile gloves). vapors  Use a funnel to minimize the chance of spilling fuel.  Fill fuel tank in well ventilated areas. 3b. Exertion from lifting 3b. Lift with your legs not your back while refueling the refueling container generator. 3c. Fire/explosion 3c. Ensure all ignition sources are removed form the refueling area.  Never refuel a “hot” generator; let it cool first.  Refuel in a well vented area (i.e., outdoors).  Do not refuel while engine is running.  Unhook all electrical loads.  Do not overfill tank. Fuel can overflow causing a release of product onto the ground and increase the chance of a fire or explosion.  If fuel spills, use sorbent pads to wipe the area and make sure area is dry before starting engine.

JOB SAFETY ANALYSIS DATE 9/30/05, 3/24/06, 4/14/06, 8/13/07, NEW PAGE 1 of 2 3/4/08, 10/24/08 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Investigation and Private Markout/Site Survey 049 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Bob Peterson Probe Technician Thomas Baylis, CIH Dir, HSSE Dan Germann Local HSO - NJ

REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES nitrile, leather, or equivalent X PPE CLOTHING highly visible clothing such OTHER GOGGLES as orange reflective safety vest & HARD HAT when overhead hazards are X SAFETY GLASSES present REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Flagging tape 2. Traffic control 3. Lockout/tagout kit 4. Paint spray and wand 5. (barricades, cones, flags, caution tape) ¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Markout/Survey 1. Drive to site and park 1a. Contact with traffic, 1a. Drive defensively following GES safe driving policy; obey all vehicle. pedestrians, and obstacles traffic laws. 1b. Contact, parking vehicles, 1b. Park in designated parking area. traffic flow/ control 2. Check in with property 2a. Contact with site traffic 2a. Don traffic safety gear immediately. owner/station manager and ¾ Inform property owner/station manager of your presence on conduct tailgate safety meeting site. 3. Site walk and evaluation of 3a. Contact with site traffic 3a. Don PPE (listed above). conditions/site features, locate points to be marked out 4. Set up site control and 4a. Contact with traffic while 4a. Set up traffic control (cones/barricades) as needed. control points setting up control points 4b. Exertion carrying 4b. Utilize proper lifting techniques when loading and unloading equipment vehicle. ¾ Bend down at the knees and lift with your legs rather than bending and lifting with your back. 4c Pinch point when placing 4c. Wear leather or equivalent gloves when handling barricades barricades and avoid pinch point area 4d. Exposure to the elements 4d. Dress appropriately for ambient temperatures, drink plenty of fluids. Note: Do not twist while lifting. This can cause a severe back injury. 5. Open roadbox to prepare for 5a. Skin abrasion 5a. Don leather (or similar) gloves to prevent a skin injury while TOC reading handling tools and opening the roadbox. 6. Markout points 6a. Contact with traffic 6a. Constantly scan for vehicles. ¾ Set up traffic control (i.e., cones, barricades) as needed. ¾ Limit time spent in areas where lines of sight for oncoming traffic are limited. ¾ Use a spotter in high traffic areas. 6b. Slip, trip, and fall when 6b. Check thick vegetation for tripping hazards and debris. moving through thick ¾ Look for the safest route to a point before proceeding and vegetation proceed with caution. 7. Direct connect method or 7a. Electrocution 7a. Locate source of electricity of line being located and de- induction method using clamp; contact with energized lines energize lines by using lockout/tagout procedures. induction method using drop 7b. Traffic which includes 7b. Wear highly visible clothing such as orange reflective traffic box technique; tracing utilities; being struck by pedestrian or vests or clothing. marking lines on ground to other vehicles indicate utilities 7c. Paint overspray 7c. Use paint wand to apply paint.

JOB SAFETY ANALYSIS Page 2 of 2

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS 8. If needed, expose metal 8a. Electrocution 8a. Comply with requirements indicated in 7a above. wiring. 8b. Potential cut or abrasion 8b. Leather or equivalent work gloves must be worn to provide from the tool used to expose hand protection. Sand paper or similar tool should be used. If a wire cutting tool is used, the “Cutting Tool Use” JSA # 015 must be reviewed. NOTE: The use of utility knives and pocket knives (i.e., stanley knives, box cutters) are STRICTLY PROHIBITED.

WORK ACTIVITY (Description) — Private Markout/Site Survey - #049

JOB SAFETY ANALYSIS DATE 9/22/04, 5/18/06, 8/8/07, 4/8/09, 7/29/09 NEW PAGE 1 of 1 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Investigation and Site Survey 057 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Edwin Fox Case Mgr/LHSO Julius Pachy Reg HSSE Spec - MW J. Kohnen & J. Gould Surveyors (Gateway) J. Brethauer Asst Dir of Surveyors (Gateway) REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES nitrile; leather X PPE CLOTHING highly visible clothing such OTHER GOGGLES as orange reflective safety vest HARD HAT X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Transit 2. Stadia rod 3. Plumb-bob 4. Flagging tape 5. Traffic control 6. Hammer and nails 7. Socket wrench 8. Screw driver (barricades, cones, flags, caution tape) ¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA - #028 B. Review “Groundwater Sampling” JSA - #032 C. Mobilize to Site 1. Drive to site and park vehicle 1a. Contact with traffic, 1a. Drive defensively following GES safe driving policy. Obey all pedestrians, and obstacles traffic laws. 1b. Contact with parking 1b. Park in designated parking area. vehicles, traffic flow/control D. Arrive On-site 1. Check in with property 1a. Contact with site traffic 1a. Don traffic safety gear immediately. owner/station manager  Inform property owner/station manager of your presence on site.  Don PPE (listed above).  Determine location(s) for transit where the maximum number of points can be surveyed with out moving the transit.  Select locations outside of main traffic patterns. 2. Set up control points 2a. Contact with traffic while 2a. Set up traffic control (cones/barricades) work zone, per GES’ setting up control points Traffic Control Program. 2b. Contact while driving nails 2b. Check hand tools for wear and tear. for the control points 2c. Exertion carrying equipment 2c. Utilize proper lifting techniques when loading and unloading vehicle.  Bend down at the knees and lift with your legs. Note: Do not twist while lifting. This can cause a severe back injury. 2d. Exposure to the elements 2d. Dress appropriately for ambient temperatures; drink plenty of fluids. E. Roadbox 1. Open roadbox to prepare for 1a. Skin abrasion 1a. Don leather gloves to prevent a skin injury while handling tools TOC reading and opening the roadbox. F. Survey Points 1. Surveying 1a. Contact with traffic 1a. Constantly scan for vehicles.  Set up traffic control (i.e., cones/barricades) work zone.  Limit time spent in areas where lines of sight for oncoming traffic are limited. 1b. Fall, slip/trip when moving 1b. Check thick vegetation for tripping hazards and debris. through thick vegetation  Look for the safest route to a point before proceeding; then proceed with caution. Consult “Offsite and Onsite Clearing of Overgrowth (Vegetation)” JSA #111. 1c. Exposure to poisonous 1c. Don leather gloves before accessing monitor wells. plants, insects, animals 1d. Injurious contact (i.e., pinch 1d. Consult Job step B.1 of “Groundwater Sampling” JSA #032 if points or strains) accessing monitoring wells to survey casing elevations.

JOB SAFETY ANALYSIS DATE 2/9/05, 3/10/05, 5/24/06, 4/15/08 NEW PAGE 1 of 2 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Soil Vapor Point Screening 061 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Thomas Baylis, CIH Dir, HSSE Eric Munz, CSP Reg HSSE Spec - NE

REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR X HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES leather/nitrile, Kevlar X PPE CLOTHING highly visible clothing such X OTHER RESPIRATORS - may be required if GOGGLES as orange coveralls or reflective safety vest conditions or work area air quality exceeds X HARD HAT when overhead hazards are X SAFETY GLASSES applicable HASP action levels present or in areas of low overhead clearance REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. PID 2. Sample container 3. 4. 5.

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA - #028 B. Prepare Well for Sampling Event 1. Inspect and open wells/ 1a. Pinch points 1a. Remove and replace manhole covers so that they do not replace well cap and cover pinch fingers. Wear leather gloves during this process. ¾ Note any damaged lids, bolts, caps, or locks and record in field book. 1b. Exposure to site 1b. Wear appropriate PPE (i.e., eye protection, hearing contaminants protection, long pants, nitrile sampling gloves, leather work gloves, shirt with sleeves, steel-toed shoes). ¾ Review and understand Action Levels noted in the HASP. ¾ Monitor (evaluate) breathing zone of workers with PID. ¾ Monitor (evaluate) any enclosure with a PID. ¾ Ensure that Level C PPE is available for potential upgrade. Note: Be aware that there may be elevated levels of gasoline or product vapors exhausted from the vacuum. 2. Purging well with hand or 2a. Repetitive trauma (hand 2a. Take sufficient breaks; at least 2 minutes for every 15 battery operated pump pump) minutes of work (hand pump). 2b. Fire or explosion resulting 2b. Ensure equipment is properly maintained (no frayed wires) from a spark or other ignition and ensure that all connections have been properly connected source (battery operated and secured (battery operated pump). pump) C. Connect Well Cap to Monitoring Well or Sampling Container to Vapor Point 1. Apply vacuum to monitoring 1a. High vacuum 1a. Eye protection must be worn when dealing with vacuum. well ¾ All hose connections must be secure. ¾ The hose should have pressure rated well seals. ¾ Develop mechanism for depressurizing lines in the event of an emergency such as someone caught by the vacuum (i.e., switch off the power to the generator). 1b. Electrocution 1b. All power tools and electrical cords will be inspected prior to use. ¾ Keep electrical cords away from water. ¾ Electrical extension cords must be grounded and used with ground fault circuit interrupters (GFCI). 2. Collection of vapor sample 2a. Exposure to site 2a. Ensure sample collection tubing, etc., are identified by contaminants, vapor placing cones, flags, and caution tape to increase the visibility and reduce the tripping hazard. Note: If the sampling event calls for the use of tedlar bags to collect vapor for analysis, refer to the instruction below: ¾ Connect vapor sampling assembly (inlet and outlet tubing,

JOB SAFETY ANALYSIS Page 2 of 2

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS vacuum pump) to the vapor sampling collection port. ¾ Withdraw vapor sample from vapor stream and collect in sample container. ¾ Secure container by closing the sample intake valve. ¾ Preserve gas sample in chilled cooler for transport to analytical lab for analysis. ¾ Secure vapor sampling collection port (lock and seal). 2b. Pinch points 2b. When attaching tubing to the collection port keep fingers from areas that could be caught. ¾ Wear nitrile over Kevlar protective gloves.

WORK ACTIVITY (Description) — Soil Vapor Point Screening - #061

JOB SAFETY ANALYSIS DATE 10/25/07 X NEW PAGE 1 of 1 REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Sub-Slab Soil Gas Sampling 102 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE William Dougherty Project Manager Thomas Baylis, CIH Dir, HSSE

REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR X HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES leather/nitrile X PPE CLOTHING highly visible clothing such X OTHER RESPIRATORS - may be required if GOGGLES as orange coveralls or reflective safety vest conditions or work area air quality exceeds X HARD HAT when overhead hazards are X SAFETY GLASSES applicable HASP action levels present or in areas of low overhead clearance REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Hammer drill 2. PID 3. Summa canister 4. 5.

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA - #028 B. Prepare for Sub-Slab Sampling Event 1. Evaluate drilling location and 1a. Damage to utilities during 1a. Evaluate utilities connections to the building. the “Pre-Drilling Protocol” drilling ¾ Obtain as builts where possible to indicate whether utilities are present beneath or imbedded in the slab. ¾ Call in public utility markout. ¾ Identify all utilities servicing building prior to drilling. ¾ Discuss proposed drilling locations with project manager and local health and safety officer prior to drilling. C. Drilling Through Flooring 1. Use of hammer drill 1a. Contact with the drill bit 1a. Eye and hand protection must be worn when hand drilling. ¾ Inspect drill bits for wear. Replace old or worn drill bits prior to drilling. ¾ Inspect hammer drill to make sure it is in good working condition. 1b. Electrocution 1b. All power tools (hammer drill) and electrical cords will be inspected prior to use. ¾ Keep electrical cords away from water. ¾ Electrical extension cords must be grounded and used with ground fault circuit interrupters (GFCI). 1c. Back strain 1c. Utilize proper lifting procedure when handling the hammer drill. ¾ Bend down at the knees to lift and operate the drill rather than lifting and bending and lifting with your back. 2. Collection of vapor sample 2a. Exposure to site 2a. Wear appropriate PPE (i.e., eye protection, hearing contaminants, vapor protection, long pants, nitrile sampling gloves, leather work gloves, shirt with sleeves, steel-toed shoes). ¾ Review and understand action levels noted in the HASP. ¾ Monitor (evaluate) breathing zone of workers with PID if vapors are present. ¾ Ensure that Level C PPE is available for potential upgrade. ¾ Wear dusk mask while drilling through concrete flooring.

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

1.0 TITLE: DRILLING PROTOCOL

2.0 PURPOSE / SCOPE The objective of this procedure is to prevent damage to subsurface structures (including tanks, product lines, water lines, gas lines, electrical service, etc.) during drilling, Geoprobing/direct push sampling, augering, sampling, or other advancement operations. This protocol establishes the requirements for on-site drilling operations, addressing the key issues and activities associated with safe drilling and boring operations.

3.0 REFERENCE

ASTM PS 89 Guide for expedited site characterization of hazardous waste contaminated sites

ASTM D5434 Guide for field logging of subsurface explorations of soil and rock

ASTM D5781 Guide for use of dual-wall reverse-circulation drilling for geoenvironmental exploration and the installation of subsurface water-quality monitoring devices

ASTM D5782 Guide for use of direct air-rotary drilling for geoenvironmental exploration and the installation of subsurface water-quality monitoring devices

ASTM D5783 Guide for use of direct rotary drilling with water-based drilling fluid for geoenvironmental exploration and the installation of subsurface water-quality monitoring devices

ASTM D5784 Guide for use of hollow-stem augers for geoenvironmental exploration and the installation of subsurface water-quality monitoring devices

ASTM D5872 Guide for use of casing advancement drilling methods for geoenvironmental exploration and installation of subsurface water-quality monitoring devices

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 1 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

ASTM D5875 Guide for use of cable-tool drilling and sampling methods for geoenvironmental exploration and installation of subsurface water-quality monitoring devices

ASTM D5876 Guide for use of direct rotary wireline casing advancement drilling methods for geoenvironmental exploration and installation of subsurface water-quality monitoring devices

ASTM D2113 Practice for diamond core drilling for site investigation

ASTM D4700 Guide for soil sampling from the vadose zone

ASTM D1586 Test method for penetration test and split-barrel sampling of soils

ASTM D1587 Practice for thin-walled tube geotechnical sampling of soils

ASTM D4220 Practices for preserving and transporting soil samples

ASTM D6001 Guide for direct-push water sampling for geoenvironmental investigations

4.0 RESPONSIBILITIES

4.1 Project Manager (PM) • The PM will be responsible for fulfilling the objectives of this protocol by ensuring that this procedure is carried out by all of the employees, sub- contractors, and any other person acting on behalf of Groundwater & Environmental Services, Inc. (GES). The PM will also ensure that LPS is implemented during the drilling project that will include but not limited to ensuring staff understand the need to conduct Safe Performance Self Assessments, review and understand activity specific Job Safety Analyses and schedule Loss Prevention Observations as necessary. • The PM will ensure that all individuals working on drilling projects are adequately trained and supervised.

4.2 Site Supervisor • The Site Supervisor will practice sound investigation and drilling practices and employ all necessary measures to avoid damage to subsurface product systems and structures. The supervisor will also be responsible for ensuring

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 2 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

that each appropriate JSA is reviewed by the project staff prior to project activities each day and immediately following the lunch time break. • A Loss Prevention Observation (LPO) must be conducted by the Project Manager on the individual who is providing oversight for the first time during the first or second day of the project. Depending on the outcome of the LPO, additional LPOs may be necessary. • The PM will be the point of contact for the Site Supervisor in the event an exception to this protocol is requested.

4.3 Case Manager • The Case Manager (CM) is responsible for providing Field Personnel with a sampling or work plan/schedule. In addition, the PM or CM will provide field personnel with enough information to perform the work safely and correctly. This information should include the operational and safety procedures that are applicable to the work being performed.

5.0 EQUIPMENT / MATERIALS • Drilling rig appropriate to investigation goals and site conditions. • Drilling tools required to complete borehole of required depth and diameter. • Pavement saw or jackhammer to cut asphalt or concrete, if required. • Hand tools required to clear drilling location. • Air knife and air compressor to hand clear drilling location, if applicable. • Minimum PPE: Steel-toed safety shoes, safety glasses, hard hat, reflective vest or safety orange or yellow clothing, gloves (leather work gloves, Kevlar gloves, latex or nitrile gloves). • Plastic sheeting or steel drums to stage drill cuttings. • Plastic trash bags for refuse. • Cones, flags, caution tape, and signage appropriate for site control . • Apparatus and materials required for the completion of split-spoon soil sampling (see SOP FM-9.2). • Decontamination equipment (potable water, pressure washer, steam cleaner, scrub brushes, detergent, wash buckets) as appropriate • Sand, bentonite, grout, or materials appropriate for borehole abandonment

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 3 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

• Cold patch asphalt, concrete, or materials appropriate for pavement restoration, if required. • Materials required for proper soil sample management (see SOP FM-13.5).

6.0 PREPARATION • Review site specific Work Plan and iTracker ticket with Project Manager. • Obtain client approval of selected soil boring locations, if applicable. • Notify One-Call system or appropriate agency to mark-out utilities a minimum of 72 hours in advance. • Conduct site visit, if appropriate, to check proposed drilling locations, map utilities, establish traffic control plan, and notify site personnel of upcoming work. • Notify property owner, site manager, or appropriate site personnel at least 24- hours in advance of completing field activity. • Locate all subsurface utilities according to GES’ Subsurface Clearance Protocol. • Locate all overhead utilities. • Workers shall wear appropriate PPE as specified in the site specific Work Plan. Additional PPE may be required based on air monitoring results, contaminants of concern, or site-specific conditions. • The work area shall be appropriately secured according to the practices outlined in SOP FM-1.3. • The Site Supervisor shall conduct air monitoring in accordance with the site Health and Safety Plan. • If drill cuttings are expected to be generated, set up a staging area for drums or build a containment pad for a cuttings pile with plastic sheeting. All soil piles shall be covered with plastic sheeting at the end of each work day. Refer to SOP FM-14.1.

7.0 PROCEDURE

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 4 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

7.1 Pre-Drilling Procedure

7.1.1 Preparation tasks The Site Supervisor is responsible for reviewing the site specific Work Plan and accuracy of iTracker ticket with the PM.

7.1.2 Obtain Permits The PM is responsible for following all local, state and federal laws, obtaining all necessary permits and utility clearances, and securing site access permission.

7.1.3 Obtain Site Plans

The PM or CM shall obtain as built drawings and/or site plans as available.

NOTE: As-built drawings may not accurately depict the locations of improvements and subsurface features should therefore not be solely relied upon to determine drilling locations. Visually check positions when drilling near sewers. Personnel should also be alert to the presence of additional piping if the plans are outdated.

7.1.4 Mark-outs The PM is responsible to ensure the One-Call system or appropriate agency is notified to mark-out utilities a minimum of 72 hours in advance. The Site Supervisor must conduct a walkthrough of the site to locate all main electrical, gas, telephone and all other subsurface utilities. A Site Walkthrough Utility and Service Line Determination Record (Attachment A) was developed to assist the Site Supervisor in identifying above ground and subsurface utilities. On third party sites, close coordination with the site owner's representatives for mark outs, review of as-builts, and other information reviews should be conducted prior to work. A private utility mark-out company should be contracted prior to performing subsurface activities so that the approximate location of any potential subsurface utility line is identified near the areas to be drilled. For any utility line which is identified, a “soft-dig” contractor should be utilized to verify the location and depth of the lines as well as the size and type of line.

Note: If subsurface improvements are identified within an area, the method utilized during the private utility mark-out must be adequate to identify the utility prior to any subsurface activities (e.g., GPR survey).

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 5 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

7.1.5 Pre-drilling meeting Prior to the start of the project, a pre-drilling meeting must be held onsite that includes the local Site Operations Manager or their designee (i.e., PM), the local office Health and Safety Officer, designated site supervisor, and the subcontractor(s) procured to perform the work. The property owner, site manager, or appropriate site personnel is to be notified at least 24-hours in advance of completing any field activity. The pre-drilling meeting activities shall include but not limited to a sight walk to delineate and determine all above ground utility and service lines, review project health and safety requirements, review planned drilling or boring locations, discuss the anticipated project schedule and other pertinent project information.

7.1.6 Utilities The locations of the following should be determined: • Electrical Lines, control boxes, and appliances • Electrical breaker boxes • Gas lines • Pipelines • Fiber Optic lines • Steam lines, water lines • Sanitary and storm-water sewer lines • Pressurized airlines • Underground storage tanks and associated vent and dispensing lines • Cable lines

NOTE: Drill Rigs and vehicle super structures shall be a minimum of 10 feet from overhead electrical lines for lines rated 50 kV or below. For lines over 50 kV the clearance must be 10 feet PLUS 0.4-inches for each 1 kV over 50 kV (1926.550(a)(15)(i & ii) Subpart N).

7.1.7 Product Systems If possible, speak with someone with historical site knowledge to gain information about the site (locations of former tanks, lines, etc.).

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 6 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

7.1.8 For UST systems • When possible, inspect for the presence of a dispenser pan and determine whether piping is rigid or flexible. • Visually inspect the location of the tank field, observation wells (if present), dispensers and vent stack(s). • Document the orientation, arrangement, location, sizes, etc. of the tanks and manholes. Determine the burial depth of the tank field. • Observe paving scars (i.e. fresh asphalt/concrete patches, scored asphalt/concrete). NOTE: This may indicate the location of product piping or other utilities. • Document the location of the emergency shut off switch to the dispensers and become familiar with its use.

7.1.9 Existing Remediation Systems • Visually inspect the location of above ground components. • Document the location of well manholes, sparge points, etc.

7.2 Selection of Drilling Locations Document, communicate and review the selected drilling locations.

7.2.1 Define Critical Zones A critical zone is defined as an area within: • 10 feet of the perimeter of the UST area, • 10 feet of the drip line of the dispenser/rack canopy, • 10 feet of product/vent/instrument lines, gas lines, electrical conduits, sewer lines, water supply lines, telecommunications lines, • All areas between the UST and the dispensers, between the dispensers/rack and the store/office building and within street utility corridors (typically within a right-of-way easement).

7.2.2 The Site Supervisor shall establish the following drilling critical zones • 10 feet from the furthest edge of any operating tank • 10 feet surrounding operating dispenser islands

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 7 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

• 10 feet surrounding marked or know utility locations • At active service station sites, the entire area between the tank field and the dispenser islands and the area between two or more dispenser islands

The Site Supervisor should utilize the information collected to this point in combination with regulatory requirements and investigation objectives to select drilling locations. If possible, the Site Supervisor should avoid selecting locations within the critical zone. Review Selected Locations with the Client and with the Project Manager.

NOTE: The Site Supervisor must not proceed with the investigation until the plan has been discussed with the client and approval to proceed has been granted. If relocation of a boring is necessary at any time and for any reason outside approved limits, the Site Supervisor must contact the client and GES PM prior to proceeding.

7.2.3 Required Notifications Notify affected parties of planned work and avoid scheduling conflicts with other remediation or facility activities at the site. The Site Supervisor will notify the following persons as applicable: • Project Manager • Site Manager/Operator for active locations • Property Owner for private properties, when possible

7.3 Procedure for On-Site Drilling Identify to the fullest extent possible any improvements present in the sub-surface prior to advancing drilling tools in order to prevent damage to the improvements.

7.3.1 Safety • A Health and Safety Plan (HASP) must be available onsite at all times and all employees and subcontractors must be familiar with attached JSAs and other information. • All work areas shall be secured with safety cones, safety tape, construction fence, other barriers, or signs as appropriate. Construction of the drilling

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 8 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

water containment if necessary must be completed in accordance with guidance provided in Attachment C. • The Site Supervisor should locate the emergency shut off switch for the dispensers and shall ensure all site personnel are familiar with their use. • A fire extinguisher and "No Smoking" signs must be present at all times. • The Site Supervisor shall complete the Drilling Protocol Checklist (Attachment B) prior to commencing drilling operations.

7.3.2 Supervision • The Site Supervisor will be responsible for drilling operations and must have a copy of the Drilling Protocol on-site. • All surface removal, hand auger digging and drilling will be performed; observed or supervised by the Site Supervisor at all times. • The Site Supervisor will ensure that the work is performed with due caution and will be alert for warning signs that could indicate the presence of underground lines or other subsurface structures (i.e., tanks). • If any such indications arise, the work should immediately cease in the area and the PM shall be contacted.

7.3.3 Warning Signs The following warning signs may indicate the presence of a sub-surface structures (i.e., tanks/lines): • Pea Gravel/Sand/ other fill material. • The absence of soil recovery in the hand auger. This could indicate pea gravel that has spilled out of the auger. • Any unexpected departure from the native soil conditions as established in other onsite excavation/trenching digging. • If any of the above warning signs or a suspicious condition is encountered, drilling in this area should immediately cease and the PM shall be contacted.

7.3.4 Drill Boring Sequence • If possible, the boring sequence should be planned such that the boring furthest from any suspected underground improvements is carried out first. This is done to determine the natural subsurface conditions and to allow the Site Supervisor to recognize fill conditions.

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 9 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

• Least impacted locations should be done first if possible to prevent possible cross contamination.

7.3.5 Surface Removal for Paved Areas - Paving Removal • Sufficient paving or surface improvement should be removed to allow clear visibility of the subsurface conditions during hand augering and/or air knifing. • Drilling in an area of high risk may warrant a larger pavement opening. • Monitoring Well Installations: 2ft x2ft minimum removal is suggested. • Soil Borings/Push Type Samplers: 8 inches minimum removal is suggested.

7.3.6 Surface Removal Technique The technique used should not pose a threat to subsurface structures. The only approved methods for completing holes within a paved area shall be to neatly saw-cut or core unless otherwise directed by the Client.

7.3.7 Subsurface Evaluation Ensure that no subsurface improvements exist where drill or auger will penetrate. • In critical zones, a minimum evaluation to a depth of 8 feet utilizing a non- destructive method such as hand clearing or vacuum digging is required. • In non-critical zones, a minimum evaluation to a depth of 5 feet utilizing a non-destructive method such as hand clearing or vacuum digging is required. • Areas where utility or service lines have been identified or within site critical zones, a minimum evaluation to a depth of 8 feet shall be completed utilizing a non-destructive method such as hand clearing or vacuum digging.

NOTE: Client specific specifications must always be satisfied with regard to hand clearing requirements. Therefore, the most conservative approach either GES or our client’s requirement must be implemented.

7.3.8 Approach The method used to identify the subsurface should be compatible with the inherent risk associated with the type of facility / property, and the location of the drilling. Only tools approved shall be used for probing, and digging.

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 10 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

NOTE: The Site Supervisor should discuss tool requirements with the Client. Also, no subsurface activities are permitted within a critical zone until the client and the GES client Program Manager is notified of the planned activity.

• Vacuum Digging: Vacuum digging has proven to be a very effective and safe means of digging and should be used unless the soil or other material prevents the use of a vacuum digging device. • Probing: If probing is necessary, it should occur by using a blunt or rounded tip and should be advanced by hand without excessive force. Digging bars, pry bars or other digging tool that may result in damage to subsurface utilities are not permitted. • Hand Digging: Should be performed with a small spade shovel. • Hand Augering: The auger is to be turned slowly and not forced through the soil. It is recommended that an auger without sharp points (some augers have rounded edges) be used. • Post Hole Digging: Can be used for soil removal only in soil that has been probed and cannot be used to advance the hole beyond the depth or width of probing.

NOTE: In the event a drilling location is selected where it’s apparent that additional soil or other fill material has been placed/added to the original ground surface level where utility or service lines have been identified (i.e., sloped area next to an existing building, landscaped area, etc.), the depth of the added soil will need to be taken into account or added to the required hand clearing depth.

Approval to deviate from this work scope may be granted on an exception basis for specific situations, such as undeveloped land. In addition, the GES Site Supervisor (oversight person) must stop all project activities and discuss the situation with the GES PM or senior office manager when client or GES requirements cannot be implemented or when site conditions result that are not consistent with normal conditions. Evaluation of the subsurface should ideally be accomplished by probing followed by soil removal using critical and non-critical zone guidelines as a minimum. Additional exploratory methods (e.g., water drilling, electronic screening), which will achieve at least the same level of precautionary investigation and/ or drilling safety, should be reviewed with the PM prior to implementation.

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 11 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

The First 5 Feet: The area to be evaluated shall not exceed the diameter of the largest tool (hand auger, drill auger, sampling tube, etc.) to be advanced and sufficiently large to allow for visual inspection of any obstructions encountered. • The first 1–2 feet can be cleared by hand digging to remove the soil. • Next, probe throughout the area to ensure that no obstructions exist anywhere near the potential path of the drill auger or push type sampler. • Probing shall extend as far laterally as possible. Hand auger or vacuum digging can then proceed but only to the depth that has been probed. • The soil in the area shall be fully removed during this step. Alternate probing with soil removal until the first 5 feet has been evaluated. If subsurface characteristics prohibit effective probing; a hand auger may be carefully advanced past the point of probing. • In this event, sufficient soil borings must be placed to ensure that the soil in the area is fully removed.

The Last 3 Feet: • For boring locations outside the critical zone, probing an additional 3 feet is recommended. • For boring locations inside the critical zone, probing an additional 3 feet is required. • If probing is met with refusal, then trained personnel should advance a hand auger without excessive force.

7.3.9 Refusal Where natural subsurface conditions (e.g. cobbles/rocks, fill material, and/or bedrock) may prevent adequate probing and augering, a practical and sensible evaluation by the Site Supervisor will be the basis for determining if continuation of probing and augering is feasible. In all cases the Site Supervisor must employ all means necessary to prevent damaging subsurface product lines and tanks. When conventional means of probing and augering cannot be utilized or the Site Supervisor feels that additional probing/augering is not feasible, they must cease work in that specific area and contact the PM to discuss the matter.

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 12 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

7.3.10 Event Notification If any portion of a utility or other subsurface structures is encountered or if there is suspicion that one has been encountered, all work shall be halted, emergency conditions secured, and the client notified immediately. If there is suspicion that the structure has been damaged, the emergency shut-off switch should be activated if applicable, and the PM should be notified immediately. The client should decide if additional hand clearing is required. If it is confirmed that utilities have been encountered, the client should be consulted to determine what actions should be taken, such as performing a tightness test(s).

NOTE: Under no circumstance is the area to be backfilled without notifying the client and receiving an approval to proceed.

7.3.11 Scheduling Since evaluating the subsurface may be time-consuming, it may be appropriate to perform it prior to the drill rig's arrival on-site. If these activities are conducted prior to the actual drilling day, the augered holes must be adequately covered with road plates and/or backfilled. Care must be taken to prevent settlement of the material used to cover the holes. In remote, idled, or access controlled sites, augered/probed holes can be left open during fieldwork. A red hazard cone shall be placed over each penetration that will not be drilled the same day.

8.0 DISPOSAL OF CONTAMINATED MATERIALS All materials and equipment used for decontamination must be disposed of properly as outlined in the Sampling and Analysis Plan (SAP). Clothing (PPE), tools, buckets, brushes, and all other equipment that cannot be reused will be disposed of as discussed in the SAP.

9.0 RECORDS

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 13 of 20

STANDARD

OPERATING Section: FM-4.0 Revision #: 001 PROCEDURES Date: Nov-08

9.1 Field Notes The field notes must document all the events, equipment used, and measurements collected during the activities. The field notes must be legible and concise so that the entire sample event can be reconstructed later for future reference. Record field notes in a standard bound survey-type field book issued for general note taking/field records and available from all GES equipment administrators. Make all field book entries black ink and make any changes/corrections with a single strikethrough line. Initial and date to indicate who made the change/ correction and when it was made.

10.0 FOLLOW-UP ACTIVITIES Perform the following once field activities are complete. • Clean and return equipment to the equipment administrator and sign and date the appropriate form. • Complete purge water and cleaning fluid disposal requirements per the Work Plan. • Complete the appropriate forms and data sheets. Send a copy to file, along with any field notes. • Return site/well keys.

ATTACHMENTS

Attachment A Site Walkthrough—Utility and Service Line Determination Record Attachment B Drilling Protocol Checklist Attachment C Containment Construction

STANDARD OPERATING PROCEDURE: Drilling Protocol Page 14 of 20

STANDARD

OPERATING Section: FM-4.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

1.0 TITLE: SOIL BORING ADVANCEMENT

2.0 PURPOSE / SCOPE This SOP provides detailed instructions to serve as guidance during site investigations involving soil borings. This procedure is not intended to satisfy or replace regulatory or client-specific requirements.

3.0 REFERENCE

ASTM D1452-80(2000) — Standard Practice for Soil Investigation and Sampling by Auger Borings ASTM D5784-95(2000) — Standard Guide for Use of Hollow Stem Augers for Geoenvironmental Exploration and the Installation of Subsurface Water-Quality Monitoring Devices GES SOP FM-1.3 Controlling the Work Area GES SOP FM-2.1 Field Logging of Subsurface Investigations GES SOP FM-2.3 Field Screening Methods GES SOP FM-5.7 Well and Borehole Decommissioning GES SOP FM-9.1 Soil Sampling for Analysis GES SOP FM-9.2 Collection of Soil Samples Using a Split-Spoon Sampler GES SOP FM-13.5 Sample Management GES SOP FM-13.1 Decontamination of Non-dedicated Sampling Equipment GES SOP FM-13.2 Decontamination of Heavy Equipment GES SOP FM-14.1 Containerization and Removal of Remedial Investigation- Derived Waste

4.0 RESPONSIBILITIES

4.1 Project Manager

STANDARD OPERATING PROCEDURE: Soil Boring Advancement Page 1 of 6 STANDARD

OPERATING Section: FM-4.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

The responsibility of the Project Manager (PM) is to ensure that all activities performed by site personnel are performed: safely; in compliance with all pertinent regulations and procedures; and with the necessary equipment and resources to accomplish the tasks described in the Work Plan.

4.2 Local Health and Safety Officer (LHSO) The Local Health and Safety Officer (LHSO), in consultation with the Corporate HSO and State project representatives, will designate the appropriate level of personnel protective equipment (PPE) for field personnel to safely accomplish their work.

4.3 Case Manager The Case Manager (CM) is responsible for providing Field Personnel with a sampling or work plan/schedule. In addition, the PM or CM will provide field personnel with enough information to perform the work safely and correctly. This information should include the operational and safety procedures that are applicable to the work being performed.

4.4 Field Personnel Field personnel are responsible for the safe completion of assigned tasks as described in the SOPs, Health and Safety Plan (HASP) and appropriate site- specific work plans and procedures. They are required to document the work performed and to alert their immediate supervisors of any variances from procedures established in the above documents.

5.0 EQUIPMENT / MATERIALS

• Drilling rig appropriate to investigation goals and site conditions • Drilling tools required to complete borehole of required depth and diameter • Pavement saw or jackhammer to cut asphalt or concrete, if required • Hand tools required to clear drilling location, including shovel, hard bar, fence post digger • Air knife and air compressor to hand clear drilling location, if applicable • Minimum PPE: Steel-toed safety shoes, safety glasses, hard hat, reflective vest or safety orange or yellow clothing, gloves (leather work gloves, Kevlar gloves, latex or nitrile gloves)

STANDARD OPERATING PROCEDURE: Soil Boring Advancement Page 2 of 6 STANDARD

OPERATING Section: FM-4.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

• Air monitoring equipment, including soil headspace scanning instrument (PID or FID). See SOP FM-2.3 • Plastic sheeting or steel drums to stage drill cuttings • Plastic trash bags for refuse • Cones, flags, caution tape, and signage appropriate for site control (see GES SOP FM-1.3) • Apparatus and materials required for the completion of split-spoon soil sampling (see SOP FM-9.2) • Decontamination equipment (potable water, pressure washer, steam cleaner, scrub brushes, detergent, wash buckets) as appropriate to SOP FM-13.1 and 13.2 • Sand, bentonite, grout, or materials appropriate for borehole abandonment • Cold patch asphalt, concrete, or materials appropriate for pavement restoration, if required • Apparatus and materials required for field logging of subsurface investigations (see SOP FM-5.3) • Materials required for proper soil sample management (see SOP FM-13.5)

6.0 PREPARATION

• Review investigation Work Plan with Project Manager. • Obtain client approval of selected soil boring locations, if applicable. • Notify Underground Facilities Protection Organization (UFPO) or appropriate agency of intended subsurface work. • Conduct site visit, if appropriate, to check proposed drilling locations, map utilities, establish traffic control plan, and notify site personnel of upcoming work. • Locate all subsurface utilities according to GES’ Subsurface Clearance Protocol. • Locate all overhead utilities. • Workers shall wear appropriate PPE as specified in Section 5 above. Additional PPE may be required based on air monitoring results, contaminants of concern, or site-specific conditions. • The work area shall be appropriately secured according to the practices outlined in SOP FM-1.3.

STANDARD OPERATING PROCEDURE: Soil Boring Advancement Page 3 of 6 STANDARD

OPERATING Section: FM-4.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

• The Site Supervisor shall conduct air monitoring in accordance with the site Health and Safety Plan. • If drill cuttings are expected to be generated, set up a staging area for drums or build a containment pad for a cuttings pile with plastic sheeting. All soil piles shall be covered with plastic sheeting at the end of each work day. Refer to SOP FM-14.1.

7.0 PROCEDURE

1. Select first soil boring location. In general, this boring should be the location expected to be the least impacted by contaminants of concern and most representative of native soil conditions (i.e., away from areas where fill materials are suspected). 2. Saw cut or jackhammer existing pavement at soil boring location, if required. Make pavement cut large enough to account for the required hand cleared width and depth. Once pavement thickness is known, do not cut deeper than the bottom of the pavement. Remove pavement materials. 3. Hand clear boring location at a minimum according to GES’ Subsurface Clearance Protocol. Additional client or site-specific requirements should be followed while completing this task. No drilling tools shall be advanced without hand clearing unless the requirements have been waived by the client, GES Corporate Health and Safety, GES Local Health and Safety, and the GES Project Manager. 4. Collect soil samples, as appropriate, during hand clearing activities. Follow SOPs FM-9.1 and FM-9.8. 5. After boring location is hand cleared, work can proceed with the appropriate drilling tools—either direct-push, or hollow stem auger / split-spoon sampler methods. 6. Advance drilling tools to appropriate depth and collect soil samples according to the project Work Plan. Complete field logging activities in accordance with SOP FM-2.1. Collect all drill cuttings that will not be used as backfill and stage for future disposal. 7. Conduct soil sampling activities in accordance with SOP FM-9.1, -9.2, and -9.3. Handle all soil samples in accordance with SOP FM-13.5. 8. General information to collect during advancement of the soil boring includes, but is not limited to: soil moisture content, first occurrence of groundwater, lithology description, lithology changes, presence of confining layers, visual

STANDARD OPERATING PROCEDURE: Soil Boring Advancement Page 4 of 6 STANDARD

OPERATING Section: FM-4.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

and/or olfactory evidence of contamination, split-spoon blow counts (if applicable). 9. Continue advancing drilling tools and collecting soil samples until the termination depth of the soil boring is reached, bedrock is encountered, or drilling tools are refused. 10. Remove drilling tools from boring. Decontaminate tools as appropriate upon removal. 11. If no monitoring well is to be installed at the soil boring location, abandon borehole according to regulations and/or client requirements and the Work Plan. Drill cuttings, sand, bentonite, or cement/bentonite grout are all acceptable materials. Refer to SOP FM-5.7. 12. If a monitor well is to be installed, refer to SOP FM-5.4. 13. Decontaminate all drilling and sampling tools per SOP FM-13.2. 14. Move to next location, if applicable, and repeat procedure 8.2 through 8.13.

8.0 RECORDS

Field Notes The field notes must document all the events, equipment used, and measurements collected during the sampling activities. The field notes must be legible and concise so that the entire sample event can be reconstructed later for future reference.

Record field notes in a standard bound survey-type field book issued for general note taking/field records and available from all GES equipment administrators. Make all field book entries black ink and make any changes/corrections with a single strikethrough line. Initial and date to indicate who made the change/ correction and when it was made.

The logbook should document the following for each boring sampled:

• Soil Boring ID • Boring depth • Static water level depth and measurement technique, if applicable • Sounded well depth • Presence of immiscible layers and detection/collection method • Sampling sequence • Sample appearance

STANDARD OPERATING PROCEDURE: Soil Boring Advancement Page 5 of 6 STANDARD

OPERATING Section: FM-4.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

• Sample odors (if respiratory protection is not required) • Types of sample containers and sample identification numbers • Preservative(s) used • Parameters requested for analysis • Field analysis data and method(s) • Sample distribution and transporter • Laboratory performing analysis • Chain-of-custody number • Field observations on sampling event • Name of collector(s) • Climatic conditions including air temperature • Problems encountered and any deviations made from the established sampling protocol.

Measure temperature, specific conductance, pH, and turbidity each time a well is sampled. Stabilization of these parameters is measured during the purging process to insure that samples accurately represent the groundwater formation. Record parameter measurements prior to sampling in the field records for that well. If you did not perform these parameters during purging you must do so prior to sampling.

9.0 FOLLOW-UP ACTIVITIES

Perform the following once field activities are complete.

• Double check Work Plan to ensure all samples have been collected and confirm this with Project Coordinator. • Clean and return equipment to the equipment administrator and sign and date the appropriate form. • Complete decon water and cleaning fluid disposal requirements per the Work Plan. • Notify the contract laboratory as to when to expect the samples. Enclose the chain-of-custody and covering letter, indicating the parameters and number of samples, in the sample cooler. • Complete the appropriate forms and data sheets. Send a copy to file, along with any field notes. • Return site keys.

STANDARD OPERATING PROCEDURE: Soil Boring Advancement Page 6 of 6

ATTACHMENT A

Site Walkthrough—Utility and Service Line Determination Record

ATTACHMENT A

Site Walkthrough Utility and Service Line Determination Record Project/ Site Location: ______

Name of person performing walkthrough: ______Date: ______

Utility Description of Location found onsite Approximate depth below Method used to determine ground surface location Electrical lines

Gas lines

Pipelines

Steam lines

Water lines

Sanitary and Storm- water Sewer lines Pressured air-lines

Tank vent lines

Optical fiber lines

Underground Storage Tanks Other

ATTACHMENT B

Drilling Protocol Checklist

ATTACHMENT B

Drilling Protocol Checklist Site Supervisor:______Date: ______

CHECKLIST

Prior To Site Visit: YES NO N/A Obtained necessary permits Obtained Site Plans (If plans are unavailable and subsurface Visually inspected location of above ground components Note location well manholes, sparge points, etc. Document selection of drilling locations Define the “Critical Zones” Review selected locations with PM Conduct Utility Mark Out Site Visit: Note location of utility mark-outs and above ground utilities (Complete Walkthrough Record) Compared Site Plan to actual conditions Updated Site Plan, if necessary UST Systems: Inspected for presence of dispenser pan Inspected location of tank field Noted orientation, arrangement, location of tanks, manholes Noted location of Emergency Shut Off Switch Determined burial depth of tank field Noted paving scars Existing Remediation Systems: Visually inspected location of above ground components Note location well manholes, sparge points, etc. Document selection of drilling locations DEFINE THE “CRITICAL ZONES”

Notified all affected parties of planned work Copy of Pre-Drilling Protocol available for site Health and Safety Plan (HASP) available for site Fire extinguisher and First Aid Kit available for site “No Smoking” signs available for site Safety Cones, Safety Tape, Construction Fence, other barriers available for site Developed Scope of Work and reviewed with all concerned

ATTACHMENT C

Containment Construction

JOB SAFETY ANALYSIS DATE 7-22-05 NEW REVISED PAGE 1 of JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) Monitoring well drilling Well Construction CONTAINMENT CELL CONSTRUCTION Preparation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY: POSITION / TITLE D. Demko Project Coordinator T. Baylis Director of Health & Safety

REQUIRED AND / OR RECOMMENDED PERSONAL PROTECTIVE EQUIPMENT LIFE VEST GOGGLES AIR PURIFYING GLOVES HARD HAT FACE SHIELD RESPIRATOR OTHER LIFELINE / BODY HARNESS HEARING PROTECTION SUPPLIED RESPIRATOR SAFETY GLASSES SAFETY SHOES PPE CLOTHING

¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS Determine type of drilling to None Review with drilling contractor type, method and needs of occur at job site (ie: air rotary, drilling technique to be used. auger etc.)

Review background geology and None Collection of accurate data on site specific hydrogeology and anticipated contaminant to be contaminants for analysis. encountered at job site. Inspect job site location. Define the management and None Set up containment, transportation and storage logistics for disposal process for collection and management of drilling returns. removal of drilling returns

Assess site specific location for Hazards relative to the proposed Assess topographic slope and land surface features; assess containment cell construction drilling location potential receptors in area of activity

Design containment cell to hold Hazards associated with Must design the containment cell to hold sufficient volume of the desired volume of drilling handling materials, working with fluids for rate of drilling fluids return/collection; must select fluids; select appropriate materials building tools. the proper materials for cell construction based on cell volume to maintain cell integrety and and cell location. install containment cell Ready the components of fluid Hazards associated with Proper assessment and inspection of the contaiment cell removal from the cell, transport equipment movement and construction and reiew of transport/storage elements for fluids and storge/disposal locations to handling of drilling return management prior to drilling startup. ensure adequate capacity materials Preparation of a contingency and Loss of cell contents may pose Assess risk to personnel and the environment based on cell response plan based on hazard to personnel working location and potential migration of contents from a loss containment cell failure near the cell structure senario.

Develop a commuication protocol Hazards associated with Must determine an appropriate level for cell volume liquid between the driller and site monitoring well construction and containment/storage based on cell construction characteristics geologist to cease drilling when a operation around a drilling rig. and placement location. pre-determined level of fluids in containment cell is reached. ¹ Each Job or Operation consists of a set of tasks / steps. Be sure to list all the steps needed to perform job.

² A hazard is a potential danger. Break hazards into five types: Contact - victim is struck by or strikes an object; Caught - victim is caught on, caught in or caught between objects; Fall - victim falls to ground or lower level (includes slips and trips); Exertion - excessive strain or stress / ergonomics / lifting techniques; Exposure - inhalation/skin hazards.

³ Using the first two columns as a guide, decide what actions or procedures are necessary to eliminate or minimize the risk. List the recommended safe operating procedures. Say exactly what needs to be done - such as "use two persons to lift". Avoid general statements such as, "be careful".

STANDARD

OPERATING Section: FM-4.4 Revision #: 001 PROCEDURES Date: 01-Aug-07

1.0 TITLE: SOIL BORING LOG COMPLETION

2.0 PURPOSE / SCOPE This SOP provides the procedures for completing soil boring and well construction logs.

Note: The importance of proper and consistent field sampling methods, as well as proper documentation, CANNOT BE OVER-EMPHASIZED.

This SOP shall be used in conjunction with an approved Health and Safety Plan (HASP). Also, consult the HASP for information on the selection and use of PPE.

3.0 REFERENCE Site plan with soil boring and/or monitor well locations shown Health and Safety Plan SOP FM-2.2

4.0 RESPONSIBILITIES

4.1 Project Manager The responsibility of the Project Manager (PM) is to ensure that all activities performed by site personnel are performed safely; in compliance with all pertinent regulations and procedures; and with the necessary equipment and resources to accomplish the tasks described in the Work Plan.

4.2 Local Health and Safety Officer (LHSO) The LHSO, in consultation with the Corporate HSO and State project representatives, will designate the appropriate level of personnel protective equipment (PPE) for field personnel to safely accomplish their work.

4.3 Case Manager The Case Manager (CM) is responsible for providing field personnel with a sampling or work plan/schedule. In addition, the PM or CM will provide field

STANDARD OPERATING PROCEDURE: Soil Boring Log Completion Page 1 of 5

STANDARD

OPERATING Section: FM-4.4 Revision #: 001 PROCEDURES Date: 01-Aug-07

personnel with enough information to perform the work safely and correctly. This information should include the operational and safety procedures that are applicable to the work being performed.

4.4 Field Personnel Field personnel are responsible for the safe completion of assigned tasks as described in the SOPs, HASP, and appropriate site-specific work plans and procedures. They are required to document the work performed and to alert their immediate supervisors of any variances from procedures established in the above documents.

5.0 EQUIPMENT / MATERIALS

A basic checklist of suggested equipment and supplies needed to implement this SOP include, but is not limited to:

Dedicated field log book Soil Boring log sheet Indelible ink pen (black) Field Guide for Soil and Stratigraphic Analyses

6.0 PREPARATION

Ensure that soil borings are completed as appropriate in accordance with other SOPs and applicable federal, state, and local requirements.

7.0 PROCEDURE

7.1 Completing Soil Boring Logs 1. Collect soil samples according to SOPs FM-4.1, -9.1, -9.2, and -9.3. 2. Log soils and record information according to SOPs FM-2.2 and 4.1. 3. For each soil boring log to be completed, include the following information at a minimum:

STANDARD OPERATING PROCEDURE: Soil Boring Log Completion Page 2 of 5

STANDARD

OPERATING Section: FM-4.4 Revision #: 001 PROCEDURES Date: 01-Aug-07

• Soil boring identification • Client • Site name or project reference, including station, facility number, and/or address • Employee name collecting and classifying soil samples • Date and time soil boring was started • Date and time soil boring was completed • Terminal depth of soil boring • Drilling method • Driller’s Name • Driller’s License Number • Drilling Company • Rig Type • Sample collection method • Sample recovery and blow counts • Lithology including stratigraphic Unified Soil Classification System (USCS) symbol • Field screening measurements • Borehole diameter • Any applicable permit numbers • Depth to water table, if encountered • General comments

4. For each sample interval, provide a description of the soils as noted in, and in accordance with SOP FM-4.1. 5. Soil descriptions and classifications should be compliant with the USCS. Refer to attached USCS summary and SOP FM-2.2. 6. Note the depth intervals of any samples collected for chemical, geotechnical, or other analysis and indicate type of analysis for each sample. 7. If monitoring for chemical constituents, note the depth intervals, field screening results, and visual description of sample.

7.2 Completing Monitoring Well Construction Logs 1. Refer to SOP FM-5.4 for monitoring well installations. 2. Obtain lithologic information for boring and complete a lithologic log as described for Soil Boring Logs above.

STANDARD OPERATING PROCEDURE: Soil Boring Log Completion Page 3 of 5

STANDARD

OPERATING Section: FM-4.4 Revision #: 001 PROCEDURES Date: 01-Aug-07

3. The following additional information should be provided on each monitoring well construction log. • Applicable monitoring well permit numbers • Top of casing survey elevation • Ground level survey elevation • Terminal depth of monitor well • Well casing diameter • Screen or open hole length • Riser length • Screen construction material • Riser construction material • Measured static water level in monitoring well 4. Provide details regarding the construction of the monitoring well. The following information shall be specified, at a minimum: • Screen interval in feet below grade • Riser interval in feet below grade • Depth interval of well gravel pack in feet below grade

8.0 RECORDS

Field Notes The field notes must document all the events, equipment used, and measurements collected during the sampling activities. The field notes must be legible and concise so that the entire sample event can be reconstructed later for future reference.

Record field notes in a standard bound, survey-type field book issued for general note taking/field records and available from all GES equipment administrators. Make all field book entries black ink and make any changes/corrections with a single strikethrough line. Initial and date to indicate who made the change/ correction and when it was made.

The logbook should document the following for each well sampled:

• Soil boring ID • Boring depth • Static water level depth and measurement technique, if applicable • Measured field parameters (e.g., volatile organic compounds) • Field observations on boring event

STANDARD OPERATING PROCEDURE: Soil Boring Log Completion Page 4 of 5

STANDARD

OPERATING Section: FM-4.4 Revision #: 001 PROCEDURES Date: 01-Aug-07

• Name of field personnel • Climatic conditions including air temperature • Problems encountered and any deviations made from the established sampling protocol.

9.0 FOLLOW-UP ACTIVITIES Perform the following once field activities are complete.

• Review Work Plan to ensure all work has been done and confirm this with Project Coordinator. • Clean and return equipment to the equipment administrator and sign and date the appropriate form. • Complete purge water and cleaning fluid disposal requirements per the Work Plan. • Complete the appropriate forms and data sheets. Send a copy to file, along with any field notes. • Return site/well keys.

STANDARD OPERATING PROCEDURE: Soil Boring Log Completion Page 5 of 5

STANDARD

OPERATING Section: FM-8.5 Revision #: 001 PROCEDURES Date: 01-Aug-05

1.0 TITLE: LOW FLOW GROUNDWATER SAMPLING

2.0 PURPOSE / SCOPE This SOP describes procedures for sampling groundwater using low-flow purging and sampling techniques. The purpose is to obtain samples that are representative of existing groundwater conditions, or samples that retain the physical and chemical properties of the groundwater within an aquifer. Improper sampling and transport procedures may cause compounds of interest to be removed from or added to the sample prior to analysis.

Note: The importance of proper and consistent field sampling methods, as well as proper documentation, CANNOT BE OVER-EMPHASIZED.

This SOP shall be used in conjunction with an approved Health and Safety Plan (HASP). Also, consult the HASP for information on the selection and use of PPE.

3.0 REFERENCE

ASTM D5903: Guide for Planning and Preparing for a Groundwater Sampling Event ASTM D4448: Standard Guide for Sampling Groundwater Wells ASTM D5979: Guide for Conceptualization and Characterization of Groundwater Systems EPA, Low-Flow (Minimal Drawdown) Ground-Water Sampling Procedures, (ORD/ OSWER, Washington D.C., 1996) (EPA-540/S-95/504). EPA Region III, Recommended Procedure For Low-Flow Purging and Sampling of Groundwater Monitoring Wells. (Waste and Chemicals Management Division, 1997.)

4.0 RESPONSIBILITIES

4.1 Project Manager

STANDARD OPERATING PROCEDURE: Low Flow Groundwater Sampling Page 1 of 10

STANDARD

OPERATING Section: FM-8.5 Revision #: 001 PROCEDURES Date: 01-Aug-05

The responsibility of the Project Manager (PM) is to ensure that all activities performed by site personnel are performed: safely; in compliance with all pertinent regulations and procedures; and with the necessary equipment and resources to accomplish the tasks described in the Work Plan.

4.2 Local Health and Safety Officer (LHSO) The Local Health and Safety Officer (LHSO), in consultation with the Corporate HSO and State project representatives, will designate the appropriate level of personnel protective equipment (PPE) for field personnel to safely accomplish their work.

4.3 Case Manager The Case Manager (CM) is responsible for providing Field Personnel with a sampling or work plan/schedule. In addition, the PM or CM will provide field personnel with enough information to perform the work safely and correctly. This information should include the operational and safety procedures that are applicable to the work being performed.

4.4 Field Personnel Field personnel are responsible for the safe completion of assigned tasks as described in the SOPs, Health and Safety Plan (HASP) and appropriate site- specific work plans and procedures. They are required to document the work performed and to alert their immediate supervisors of any variances from procedures established in the above documents.

5.0 EQUIPMENT / MATERIALS

A basic checklist of suggested equipment and supplies needed to implement this SOP include, but is not limited to:

• Personnel protective equipment as outlined in the site-specific HASP • Adjustable rate, positive displacement pump (low flow-rate stainless steel submersible pump recommended) or pre-cleaned stainless steel bladder pump • Electronic, audible (or visual identification) water level meter (0.01 feet accuracy), or interface probe if needed • Teflon or Teflon-lined polyethylene tubing (3/8 to 1/2 inch, inside diameter) • Flow measurement supplies (graduated cylinder and stop watch). • Properly sized generator to operate pump

STANDARD OPERATING PROCEDURE: Low Flow Groundwater Sampling Page 2 of 10

STANDARD

OPERATING Section: FM-8.5 Revision #: 001 PROCEDURES Date: 01-Aug-05

• In-line flow-through cell capable of measuring pH, specific conductance, and temperature • Nylon cable-ties • Decontamination supplies • Distilled water • Polyethylene sheeting/cloth/paper towels/garbage bags • Transportable, purged water storage container • Well construction log details and historical groundwater gauging data • Photoionization detector (PID) • Secondary containment for the flow-through cell • Field book • Well Purging Record Form

Note: Gas powered equipment at sampling sites require special care to ensure that GES staff handling these units do not contaminate down-hole equipment. Frequent disposable glove changes are required, as well as strict separation of sampling crew tasks (e.g., those handling pumps and hoses do not conduct fueling activities).

6.0 PREPARATION

Note: Pre-plan the schedule of sampling activities so that sample collection progresses from “clean” to “dirty” areas to minimize the potential for cross contamination.

7.0 PROCEDURE

Prior to low-flow purging and sampling activities, all measuring devices must be calibrated daily in accordance with equipment vendor recommendations and recorded on a calibration log sheet. Purging and sampling activities should occur in a progression from the “cleanest” to the “dirtiest” well.

7.1 Well Set-Up Activities The following steps are required to properly set up for sampling:

1. Properly identify and inspect each well. 2. Wear appropriate PPE during set-up activities.

STANDARD OPERATING PROCEDURE: Low Flow Groundwater Sampling Page 3 of 10

STANDARD

OPERATING Section: FM-8.5 Revision #: 001 PROCEDURES Date: 01-Aug-05

3. Place a sheet of polyethylene adjacent to the well to keep sampling and monitoring equipment from touching the ground. 4. Remove the well cap slowly (positive pressure inside may blow cap off). 5. Measure the VOC concentration at the top of the casing and in the breathing zone using a PID—record reading in field book. 6. Measure and record the depth to water using a water level meter or interface probe, if applicable (the water level measurement should be taken from a permanent reference point scribed on top of the well casing). 7. To minimize turbidity in the well, use total well depth information obtained from the well construction logs to calculate one casing volume.1 8. Attach and secure Teflon or Teflon-lined polyethylene tubing to low-flow (0.10 to 0.50 L/min) stainless steel submersible pump. 9. Lower the submersible pump slowly and gently into the monitor well to minimize aquifer agitation and mixing of the stagnant well casing water, then secure the safety drop cable or nylon rope and tubing together with nylon cable-ties. 10. Place the intake of the submersible pump in the middle, or slightly above the middle, of the saturated screen interval or 2 feet above the well bottom/sediment level. The intake of the pump should be placed at an elevation above dense non-aqueous phase liquid (DNAPL), if applicable. 11. Plumb the in-line flow-through cell to the discharge tubing from the well. 12. Plumb a discharge line from the effluent of the flow-through cell to a transportable, purged water storage container. 13. Position a power source (e.g., a generator) for operation of the submersible pump down gradient of the well to be purged. 1 Multiply the total water column thickness (ft) by the cross-sectional area of the well (ft2) and record in field book and on Well Purging Record form. One cubic foot (ft3) is equivalent to 7.48 gallons.

7.2 Low Flow Purging and Sampling Once you have completed the well set up activities above, follow these steps to purge and sample using low-flow techniques: 1. Put on new nitrile gloves. Change nitrile gloves any time the integrity of the glove is compromised during the purging and sampling activities. 2. Activate the low-flow submersible pump and begin extracting groundwater at a rate between 0.10 and 0.50 L/min.

STANDARD OPERATING PROCEDURE: Low Flow Groundwater Sampling Page 4 of 10

STANDARD

OPERATING Section: FM-8.5 Revision #: 001 PROCEDURES Date: 01-Aug-05

3. Measure the water level approximately every 10 seconds and adjust extraction rate to obtain minimal drawdown in the well of 0.2 feet, but no more than 0.3 feet maximum. 4. Once drawdown is stabilized, begin monitoring water quality indicators (pH, specific conductance, and temperature) using the in-line flow-through cell. Record observations in field book and on the attached Well Purging Record form. Note: while purging, the pumping rate and groundwater level are measured and recorded every 10 minutes (or as appropriate). 5. Monitor the water level and extraction rate, in addition to monitoring water quality indicators, and make periodic adjustments to flow rates to ensure steady flow and minimal drawdown. 6. Water quality readings will be monitored every five minutes (or as appropriate) until stabilization criteria are achieved. 7. Stabilization is achieved when three successive readings for each parameter are within the following criteria:

Water Quality Indicator Parameter Stabilization Criteria NpH ±0.1 s.u. o Specific Conductance ±3% t eTemperature ±10% : Oxidation-reaction potential (ORP) ± mV

STu rbidity ±10% Dissolved Oxygen ±10%

Note: Stabilization criteria is achieved when the average value of three readings are within each parameter criteria limits.

8. Collect the necessary samples once purging activities are complete and the groundwater stabilization/clarity is acceptable according to applicable protocol described above. 9. Collect samples directly from the pump or bailer into the appropriate sample container under typical circumstances. Take care to avoid handling the interior of the bottle or cap. Do not place the bottle cap on the ground or in a pocket to avoid contamination. 10. Fill all sampling containers for each well in a manner that minimizes aeration and turbulence. Put on a new pair of nitrile gloves before filling each container.

STANDARD OPERATING PROCEDURE: Low Flow Groundwater Sampling Page 5 of 10

STANDARD

OPERATING Section: FM-8.5 Revision #: 001 PROCEDURES Date: 01-Aug-05

11. Disconnect or bypass the flow-through cell prior to obtaining each sample. The first volume of groundwater in the tubing is to be discarded and treated according to the waste management section described below. Place the discharge line in position at the base of the sample bottle. Fill the sample bottle from the bottom to the top, allowing it to overflow before sealing. Note: do not overflow if the sample bottles contain preservatives. 12. Place samples immediately on ice and store at 4° C. 13. Obtain final water level and flow rate measurements and enter in field book and on the Well Purging Record form.

7.3 Decontamination Procedures Clean all equipment that will enter the well or come into contact with groundwater prior to each low-flow purging and sampling activity with clean tap water in accordance with SOP FM 14.1. All decontamination fluids will be disposed of in accordance with the site’s waste management plan.

7.4 Documentation Document all the events, equipment used, and measurements collected during the sampling activities in the field notes. Make all entries in black indelible ink and strike out any corrections with a single line. Initial and date corrections.

Record all manually-measured data and procedural descriptions in a field notebook and on well purging forms (Attachment 1). Maintain detailed notes regarding field calibration events, purging or PID anomalies, and volumes of extracted groundwater.

7.5 Waste Management Transfer all purged water to the hazardous waste accumulation area were it will be pumped through a 20 and 50 micron filter prior to transfer into 6,000-gallon wastewater storage tank. A record of the total gallons will be maintained in the field book.

Porous materials (PPE, rags, etc.) contaminated with groundwater and non-porous materials that cannot be decontaminated will be managed as hazardous waste. Porous and non-porous materials not contaminated with groundwater will be disposed of as residual waste.

8.0 RECORDS

STANDARD OPERATING PROCEDURE: Low Flow Groundwater Sampling Page 6 of 10

STANDARD

OPERATING Section: FM-8.5 Revision #: 001 PROCEDURES Date: 01-Aug-05

Field Notes The field notes must document all the events, equipment used, and measurements collected during the sampling activities. The field notes must be legible and concise so that the entire sample event can be reconstructed later for future reference.

Record field notes in a standard bound survey-type field book issued for general note taking/field records and available from all GES equipment administrators. Make all field book entries black ink and make any changes/corrections with a single strikethrough line. Initial and date to indicate who made the change/ correction and when it was made.

The logbook should document the following for each well sampled:

• Well ID • Well depth • Static water level depth and measurement technique • Sounded well depth • Presence of immiscible layers and detection/collection method • Well yield (high or low) • Purge volume and pumping rate • Time well purged • Measured field parameters • Purge/sampling device used • Well sampling sequence • Sample appearance • Sample odors (if respiratory protection is not required) • Sample volume • Types of sample containers and sample identification numbers • Preservative(s) used • Parameters requested for analysis • Field analysis data and method(s) • Sample distribution and transporter • Laboratory performing analysis • Chain-of-custody number • Field observations on sampling event • Name of collector(s) • Climatic conditions including air temperature • Problems encountered and any deviations made from the established sampling protocol.

STANDARD OPERATING PROCEDURE: Low Flow Groundwater Sampling Page 7 of 10

STANDARD

OPERATING Section: FM-8.5 Revision #: 001 PROCEDURES Date: 01-Aug-05

Measu r e temperature, specific conductance, pH, and turbidity each time a well is sampled. Stabilization of these parameters is measured during the purging process to insure that samples accurately represent the groundwater formation. Record parameter measurements prior to sampling in the field records for that well. If you did not perform these parameters during purging you must do so prior to sampling.

9.0 FOLLOW-UP ACTIVITIES Perform the following once field activities are complete.

• Review Work Plan to ensure all samples have been collected and confirm this with Project Coordinator. • Clean and return equipment to the equipment administrator and sign and date the appropriate form. • Complete purge water and cleaning fluid disposal requirements per the Work Plan. • Notify the contract laboratory as to when to expect the samples. Enclose the chain-of-custody and covering letter, indicating the parameters and number of samples, in the sample cooler. • Complete the appropriate forms and data sheets. Send a copy to file, along with any field notes. • Return site/well keys.

ATTACHMENTS

Attachment A –Well Purging Record and Low-Flow Sampling Method Form

STANDARD OPERATING PROCEDURE: Low Flow Groundwater Sampling Page 8 of 10

ATTACHMENT A

WELL PURGING RECORD AND LOW-FLOW SAMPLING METHOD FORM

WELL PURGING RECORD LOW-FLOW SAMPLING METHOD

Site: Tubing Diameter (ID): inches Project Number: Depth to Water: ft, TOC Sampling Device: Depth to Bottom of Well: ft, TOC Date: Feet of Water in Well: ft Well ID: Volume of Water in Well: gal Depth to Specific Elapsed Time pH Temperature Purge Rate Water Conductance (min) (s.u.) (°F) (L/min) (ft, TOC) ( / )

Purge Start Time: Purge End Time: Total Volume Purged: gal Approximate Purge Rate: Purged/Sampled by: Weather Conditions: Comments:

STANDARD

OPERATING Section: FM-9.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

1.0 TITLE: SOIL SAMPLING FOR ANALYSIS

2.0 PURPOSE / SCOPE This SOP provides procedures to obtain representative samples of subsurface soil. Subsurface soil samples are usually “grab” samples, used to characterize the soil at a specific depth or depth interval (e.g., 2–4 feet). On occasion, composite samples are collected from a borehole.

3.0 REFERENCE ASTM D 4700 – Standard Guide for Soil Sampling from the Vadose Zone ASTM D 4220 – Practices for Preserving and Transporting Soil Samples ASTM D 1586 – Test Method for Penetration Test and Split Spoon Barrel Sampling of Soils ASTM 5434 – Guide for Field Logging of Subsurface Explorations of Soil and Rock ASTM D50790 – Practices for Preserving and Transporting Rock Core Samples

4.0 RESPONSIBILITIES

4.1 Project Manager The responsibility of the Project Manager (PM) is to ensure that all activities performed by site personnel are performed: safely; in compliance with all pertinent regulations and procedures; and with the necessary equipment and resources to accomplish the tasks described in the Work Plan.

4.2 Local Health and Safety Officer (LHSO) The Local Health and Safety Officer (LHSO), in consultation with the Corporate HSO and State project representatives, will designate the appropriate level of personnel protective equipment (PPE) for field personnel to safely accomplish their work.

STANDARD OPERATING PROCEDURE: Soil Sampling for Analysis Page 1 of 8

STANDARD

OPERATING Section: FM-9.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

4.3 Case Manager The Case Manager (CM) is responsible for providing Field Personnel with a sampling or work plan/schedule. In addition, the PM or CM will provide field personnel with enough information to perform the work safely and correctly. This information should include the operational and safety procedures that are applicable to the work being performed.

4.4 Field Personnel Field personnel are responsible for the safe completion of assigned tasks as described in the SOPs, Health and Safety Plan (HASP) and appropriate site- specific work plans and procedures. They are required to document the work performed and to alert their immediate supervisors of any variances from procedures established in the above documents.

5.0 EQUIPMENT / MATERIALS

A basic checklist of suggested equipment and supplies needed to implement this SOP include, but is not limited to:

• Stainless steel utensils (e.g., spatulas, spoons, knives) • Stainless steel bowls • Aluminum foil • Plastic sheeting • Chain-of-custody form • Shipping cooler • Photoionization detector (PID) • Glassware/sample jars/ziplock bags • PPE: safety shoes, long pants and sleeved shirts, leather gloves, safety glasses, hard hat and hearing protection • Indelible black ink pen • Field notebook • Decontamination water and rinse water storage containers w/brushes • Ice

STANDARD OPERATING PROCEDURE: Soil Sampling for Analysis Page 2 of 8

STANDARD

OPERATING Section: FM-9.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

6.0 PREPARATION

Determine the exact number, location, and depth of samples to be collected for analysis. If the soil sample location is not accessible, contact manager for resolution.

Conduct the following activities prior to undertaking a subsurface soil sampling program: 1. Review the Sampling Plan, Work Program, Project Documents, and the Health and Safety requirements with the Project Manager. 2. Contact the laboratory to arrange/determine the • sample container ordering and shipping details; • receipt of client specific chain of custody forms (if applicable); • start date; • expected duration. 3. Establish sampling locations in field using available landmarks or by surveying methods if necessary. 4. Arrange for clearance of all site utilities. Complete property access/utilities clearance data sheet. 5. Determine notification needs with the Project Manager. Inform the regulatory agencies, client, landowner, GES personnel, and laboratory of the sampling event. 6. Determine the methods for handling and disposal of drill cuttings, wash waters, and spent decontamination fluids. 7. Clean the split-spoon sampling (SSS) equipment, auger and other equipment using the appropriate decontamination SOP. 8. Ensure the field equipment and decontamination stations are operational as necessary

Note: Check the Quality Assurance Project Plan (QAPP) to confirm the cleaning protocol. Using incorrect cleaning protocol could invalidate analytical data.

STANDARD OPERATING PROCEDURE: Soil Sampling for Analysis Page 3 of 8

STANDARD

OPERATING Section: FM-9.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

7.0 PROCEDURE

7.1 Sample Collection Subsurface soil samples are usually “grab” samples, used to characterize the soil at a specific depth or depth interval (e.g., 2 to 4 feet). On occasion, composite samples are collected from a borehole over a greater depth interval such as 5 to 15 feet.

Soil samples are to be collected immediately after removing the material from the sampling device and scanning the core run with a PID. Soil samples are to be collected from the interval having the highest volatile organic compound (VOC) field screen reading, or if no elevated VOC readings are detected, then soil samples are to be collected as follows:

• If fill is present, collect soil sample from fill/native soil interface. • If no fill is present, collect soil sample from native material/bedrock interface. • Collect soil sample from the soil/groundwater interface.

7.2 Soil Sample Examination During soil examination, the sampler shall carefully check and note for the presence of light or dense Non-Aqueous Phase Liquids (NAPL). NAPL may be present in gross amounts or present in minute quantities. The adjectives and corresponding quantities used when describing NAPL within a soil matrix are as follows:

• Fraction of Soil Pore • Visual Description • Volume Containing NAPL • Saturated >0.5 • Some 0.5 - 0.25 • Trace <0.25

A complete description of NAPL must describe the following:

• color • density (compared to water—e.g., light/floats or heavy/sinks) • odor (if observed) • viscosity (e.g., mobile/flowable, non-mobile/highly viscous-tar like)

STANDARD OPERATING PROCEDURE: Soil Sampling for Analysis Page 4 of 8

STANDARD

OPERATING Section: FM-9.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

The presence of an iridescent sheen by itself does not constitute NAPL presence, but may indicate it is close to the area.

Representative portions of the soil sample must be retained for geologic record following description. Place the soil portions into labeled, sealable sample containers (usually mason jars) without destroying any apparent stratification.

7.3 Chemical Sample Preparation and Packaging The following describes the collection of grab samples for chemical analysis (all soil from one split spoon).

Clayey Soils 1. Discard upper and lower ends of sample core (3 inches ±) 2. Use a pre-cleaned stainless steel knife 3. Cut the remaining core longitudinally 4. With a sample spoon remove soil from the center portion of the core and place in a pre-cleaned stainless steel bowl 5. Remove large stones and natural vegetation debris 6. Homogenize the soil and place directly into the sample jars

Note: DO NOT homogenize samples for VOC analysis. Collect soil from the length of the center portion of the core and place in the sample container until it is completely filled.

7.4 Sandy Soils Since sandy soils have less cohesion than clayey soils, it is not easy to cut the core longitudinally to remove the center of the sample. Therefore, scrape away surface soils that have likely contacted the sampler with a stainless steel spoon, and then sample the center portion of the soil core.

Note: Immediately place all soil samples collected for chemical analysis in a cooler with ice.

All soil samples shall be recorded in the sample log book and labeled according to SOPs FM-13.4 and 13.5.

EPA adopted methods for sampling soils for VOC analysis. Method 5035 calls for collecting soil using a coring device (refer to SOP FM-9.3). For analysis of low level VOCs (typically 1 to 200 µg/kg), soil is sealed in a specially prepared vial with a of sodium bisulfate. For higher levels of VOCs, the soil is placed in a vial with a volume of methanol. This method increases the complexity of

STANDARD OPERATING PROCEDURE: Soil Sampling for Analysis Page 5 of 8

STANDARD

OPERATING Section: FM-9.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

collecting soils and makes it imperative that the sampler and laboratory work closely together.

7.5 Geotechnical/Hydrogeologic Sample Preparation and Packaging When a sample is collected for geotechnical or hydrogeologic properties, the sample needs to be prepared and packaged in a manner to maintain its physical properties. Soil samples are usually grab samples, collected from a specific depth or depth interval (e.g., 2 to 4 feet). On occasion, composite samples are collected from the borehole over a greater depth interval (e.g., 5 to 15 feet).

The following describes the collection of grab samples for geotechnical or hydrogeologic purposes for two common samplers, the split spoon and the thin wall samplers.

Split-Spoon Sample Following completion of PID screening, remove and dispose of soil at the top of the sample that is obviously sloughed material not representative of the soil at the sampled depth. Measure the length of the sample and record as the recovered length. If cohesive, perform pocket penetrometer reading and describe soil as discussed above in Soil Sample Examination. Carefully transfer sample onto a sheet of aluminum foil, taking care to maintain structure and bedding of the sample as much as possible. This may not be possible with non-cohesive soils with low silt or clay contents. The sample may need to be packaged in three 6- to 8-inch segments. Roll the sample in the aluminum foil and fold over the ends to seal. Wrap in a second layer of foil. Identify the top, middle, and bottom segments with a T, M, and B using an indelible marker. For each segment record the “up” direction with an arrow. Place the foil-wrapped sample in a plastic bag and write the sample identification on the bag using an indelible marker. Storing the sample in foil, as opposed to a jar, has the advantage of retaining the soil's in-place structure and prevents loss of moisture. If the soils are sandy and it is not possible to retain the soils structure by rolling it in foil, packaging the sample in a jar is also acceptable, provided the jar is filled to eliminate air space which could result in the soil drying out.

Thin Wall (Shelby Tube) Sample Remove any sloughed material from the top of the sample using a knife or similar long-bladed instrument. If it is not possible to distinguish sloughed soil from intact soil, do not remove. Following removal of sloughed material, measure the tube length and the air space in the tube above the sample and record the difference as the sample recovery. (In the unusual circumstance that there is also

STANDARD OPERATING PROCEDURE: Soil Sampling for Analysis Page 6 of 8

STANDARD

OPERATING Section: FM-9.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

air space at the bottom of the sample, subtract this as well and record this latter measurement as a separate entry.)

Seal the top and bottom of the sample with wax (wax is normally provided and prepared by the driller). First, pour the liquefied wax into the top of the sample to a thickness of about 1 inch and let cool sufficiently. Next, remove approximately 1/2 inch of soil from bottom of sample (unless there is already a cavity at bottom of sample) and seal similarly.

Fill the remaining air space above the sample with loose soil to prevent the sample from shifting in the tube, and then close both ends of the sample with plastic caps. Tape on the caps using duct tape, then write the sample identification number on the cap using an indelible marker.

Shelby tubes containing soft clays and wet silts need to be handled with care to avoid damage to the sample. Keep samples in an upright position at all times and transport either in a specifically designed cushioned box or position in your vehicle with cushioning under and around the individual tubes.

8.0 RECORDS

Field Notes The field notes must document all the events and measurements collected during the sampling activities. The field notes must be legible and concise so that the entire soil sampling event can be reconstructed later for future reference.

The field notes will be recorded on the field stratigraphy log or when approved by the Project Coordinator/manager in a standard bound survey-type field book issued for general note taking/field records.

Make all field book and form entries in black ink and strike out any changes/corrections with a single line. Initial and date correction.

The field notes should document the following for each sample:

• sample identification • depth • time started and completed • measured field parameters (e.g., PID readings) • sample appearance • sample odors (if respiratory protection is not required)

STANDARD OPERATING PROCEDURE: Soil Sampling for Analysis Page 7 of 8

STANDARD

OPERATING Section: FM-9.1 Revision #: 001 PROCEDURES Date: 01-Aug-05

• types of sample containers and sample identification numbers • parameters requested for analysis • field analysis data and method(s) • sample distribution and transporter • laboratory shipped to • chain-of-custody number for shipment to laboratory • field observations on sampling event • name of collector(s) • climatic conditions, including air temperature • problems encountered and any deviations made from the established sampling protocol

9.0 FOLLOW-UP ACTIVITIES Perform the following once field activities are complete.

• Review Work Plan to ensure all samples have been collected and confirm this with Project Coordinator. • Clean and return equipment to the equipment administrator and sign and date the appropriate form. • Complete decon water and cleaning fluid disposal requirements per the Work Plan. • Notify the contract laboratory as to when to expect the samples. Enclose the chain-of-custody and covering letter, indicating the parameters and number of samples, in the sample cooler. • Complete the appropriate forms and data sheets. Send a copy to file, along with any field notes. • Return site/well keys.

STANDARD OPERATING PROCEDURE: Soil Sampling for Analysis Page 8 of 8

STANDARD

OPERATING Section: FM-14.3 Revision #: 002 PROCEDURES Date: 01-Nov-08

1.0 TITLE: FIELD PERSONNEL DECONTAMINATION

2.0 PURPOSE / SCOPE

This SOP establishes the materials and procedures necessary to decontaminate personnel who contact (skin, eye, inhale, ingest) environmental media containing residual contaminants, sample chemical preservatives and equipment decontamination .

This SOP shall be used in conjunction with an approved Health and Safety Plan (HASP). Also, consult the HASP for information on the selection and use of PPE.

3.0 REFERENCE

Site Specific Health and Safety Plan

NIOSH Pocket Guide to Chemical Hazards, June 1990

Site Specific Sampling and Analysis Plan

4.0 RESPONSIBILITIES

4.1 Project Manager The Project Manager’s (PM) responsibility is to ensure that all activities performed by GES personnel are performed safely, that the employee complies with all pertinent regulations and procedures, and that the employee has the necessary equipment and resources to accomplish the tasks describe in this procedure.

4.2 Local Health and Safety Officer (LHSO) The Local Health and Safety Officer (LHSO), in consultation with the Corporate HSO will designate the appropriate level of personnel protective equipment (PPE) for field personnel to safely accomplish their work.

STANDARD OPERATING PROCEDURE: Field Personnel Decontamination Page 1 of 5

STANDARD

OPERATING Section: FM-14.3 Revision #: 002 PROCEDURES Date: 01-Nov-08

4.3 Field Personnel Field personnel are responsible for the safe completion of assigned tasks as described in the SOPs, Health and Safety Plan (HASP) and appropriate site- specific work plans and procedures. They are required to document the work performed and to alert their immediate supervisors of any variances from procedures established in the above documents.

5.0 GENERAL • During the various environmental investigations, personnel could contact soil and groundwater that contains one or more chemical contaminants at the parts per million (PPM) or less level. The site specific HASP should be referenced to review all constituents that may be encountered at a site. • Personnel could also contact equipment decontamination solutions. These are a non-phosphate soaps, acid solutions (i.e., nitric), and volatile organic compounds (i.e., methanol, isopropanol). • Contact with chemicals/contaminants is not expected due to the controls in- corporated in the various SOPs. However, contact could occur if personnel fail to wear the specified PPE, improperly remove PPE, use poor work practices or wear inadequate PPE. • Contact could occur through any one of the normal pathways—skin/eye con- tact, ingestion or inhalation. Skin/eye contact and ingestion are not considered likely modes of contact. More likely would be an occasional, brief inhalation of vapors. Drilling operations can volatilize some of the organic components and create a potential for inhalation. Airborne monitoring will be conducted during all drilling operations to warn personnel if such conditions are created.

6.0 EQUIPMENT / MATERIALS • Thermally insulated portable eye wash fountain/support stand • Minimum 2 gallons potable water (containerized to maintain temperature at 70-85°F) • Mild soap water solution (0.5 L) • Cloth diapers, paper towels or equivalent

STANDARD OPERATING PROCEDURE: Field Personnel Decontamination Page 2 of 5

STANDARD

OPERATING Section: FM-14.3 Revision #: 002 PROCEDURES Date: 01-Nov-08

• Coveralls (2 pair)—large enough to fit the largest person who may handle chemicals

7.0 PREPARATION • The personnel decontamination equipment must be staged, ready for use, close to the area where contact with chemical preservatives and decontamination solutions occur. • For non-hazardous waste sites, collection of the personnel decontamination waste water (and soap/water) is not necessary. Cloth diapers or equivalent may be disposed of as nonhazardous solid waste. Waste Management Plans are to be followed for the collection of and disposal of personnel decontamination waste water and related solid waste for regulated substances classified as hazardous. • The temperature of water for flushing should be in the range of 70-85°F (i.e., tepid water). The water may need to be stored in insulated containers to preclude the influence of prolonged storage of the water at ambient tempera- ture outside this range and to preclude the heating effect of direct sunlight. • A minimum of 2 gallons of flush water and 0.20 gallons of a mild soap solution shall be initially established for decontamination. Any use of the water shall be immediately replaced prior to proceeding with work subsequent to decontamination. Replenish soap prior to being depleted by 50%. • An eye wash station shall also be established with its self-contained water source. This water is in addition to that discussed in the above step. The self- contained water in the eye wash fountain may need to be insulated to control the water temperature to 70-85°F.

8.0 PROCEDURE

8.1 Eye Contact • Only water shall be used to flush the eyes, unless administered by emergency personnel. • If any environmental medium as stated in the site specific HASP, equipment decontamination solution, or other material contacts, the eye(s), immediately wash the eye(s) with large amounts of water, occasionally lifting the lower and upper lids. Subsequently report the situation to the GES local health and safety officer (LHSO). If necessary, contact emergency personnel for first aid followed by immediately contacting the GES LHSO to report the occurrence.

STANDARD OPERATING PROCEDURE: Field Personnel Decontamination Page 3 of 5

STANDARD

OPERATING Section: FM-14.3 Revision #: 002 PROCEDURES Date: 01-Nov-08

8.2 Skin Contact • The site specific HASP shall be reviewed prior to conducting site activities so that skin hazardous can be identified and planned for in the event that cleaning of the skin is required. Skin contact with environmental media such as soil or groundwater outside of the areas of concern does not require immediate attention. In the event skin contact is made with a constituent outlined in the site specific HASP, the affected area shall be immediately cleaned as outlined in the site specific HASP. • Notify the GES LHSO of all instances of skin contact with constituent of concern as listed in the site specific HASP.

8.3 Clothing Contact • Personal clothing contacted by the constituents outlined in the site specific HASP should be decontaminated immediately or removed and the skin under the wetted portion of the clothes shall be washed as specified in HASP. The clothes must be washed prior to reuse. • Notify the GES LHSO of all instances of personal clothing contamination.

8.4 Ingestion • Ingestion is not considered a very likely mode of contact. However, should ingestion of environmental media occur, rinse the mouth with water (DO NOT SWALLOW) and immediately report to the incident to the GES LHSO. • Critique any ingestion. Do not resume work until the cause is determined and corrected.

8.5 Inhalation • Inhalation, other than an occasional, brief whiff of vapors is not likely. However, should inhalation occur other than an occasional, brief whiff, move away from the source to fresh air. If breathing has stopped, perform artificial respiration and get medical attention. • Notify the GES Health and Safety Officer of all events which require movement to fresh air and conduct of critique of such events. The Health and Safety Officer shall evaluate the cause and institute appropriate corrective actions.

9.0 DISPOSAL OF CONTAMINATED MATERIALS

STANDARD OPERATING PROCEDURE: Field Personnel Decontamination Page 4 of 5

STANDARD

OPERATING Section: FM-14.3 Revision #: 002 PROCEDURES Date: 01-Nov-08

All materials and equipment used for decontamination must be disposed of properly as outlined in the Sampling and Analysis Plan (SAP). Clothing (PPE), tools, buckets, brushes, and all other equipment that cannot be reused will be disposed of as discussed in the SAP and waste management plan.

10.0 RECORDS

Field Notes

The field notes must document all the events, equipment used, and measurements collected during the activities. The field notes must be legible and concise so that the entire sample event can be reconstructed later for future reference.

Record field notes in a standard bound survey-type field book issued for general note taking/field records and available from all GES equipment administrators. Make all field book entries black ink and make any changes/corrections with a single strikethrough line. Initial and date to indicate who made the change/ correction and when it was made.

11.0 FOLLOW-UP ACTIVITIES

Perform the following once field activities are complete. • Clean and return equipment to the equipment administrator and sign and date the appropriate form. • Complete purge water and cleaning fluid disposal requirements per the Work Plan. • Complete the appropriate forms and data sheets. Send a copy to file, along with any field notes. • Return site/well keys.

STANDARD OPERATING PROCEDURE: Field Personnel Decontamination Page 5 of 5

GES DAILY SITE SAFETY CHECKLIST

Site Name: Address:

Individual’s Name: Date: Task and date of entry:

This checklist is to be completed on a daily basis. The date should be noted in the space provided. The employee completing the checklist should verify that each item is correct and initial in the last space provided.

Date: 1. Proper training certificates have been obtained from subcontractors. 2. The site-specific HASP has been reviewed and signed by GES employees and GES-hired subcontractors. 3. The daily site-safety meeting has been conducted. 4. Applicable JSAs are onsite, reviewed by Staff to ensure all tasks/jobs are covered, and site specific JSA modifications occur when needed. 5. Fire extinguishers are available for use and are fully charged. 6. A fully-stocked first aid kit and eye wash bottle are readily available. 7. Any potential tripping hazards have been removed from site. 8. All vessels containing flammable or corrosive material are properly labeled. 9. Proper personal protective equipment is being used for present conditions. 10. Equipment on-site is checked and in safe working order. 11. Safety cones and flags or barricades have been utilized to mark out work area. 12. No person on-site has the appearance of being under the influence of motor skill altering substances. 13. All workers on-site are clothed in an appropriate manner (highly visible clothing, no tank tops, muscle shirts or shorts). 14. Electrical power operated tools shall be properly grounded and used with a Ground- Fault Circuit Interrupter (GFCI). 15. All required Permits (GES and/or client) are completed by an authorized individual. 16. When working alone, has a phone call been placed to the PM to discuss site conditions, review the Scope of Work, LPS requirements, and coordinate communications for the day. Note: The frequency/ amount of additional calls from the field should be established during the PM’s discussion with the individual. A call must always occur prior to leaving the site. 17. All health and safety concerns have been communicated to the Local Health and Safety Officer and Project Manager I verify and initial that the above information is correct.

Rev. 2/09

ATTACHMENT E

PRE-ENTRY MEETING NOTES

Rev. 5/99 PRE-ENTRY MEETING NOTES/ATTENDANCE (Include date, length of meeting, names of personnel in attendance, topics of discussion, comments and concerns, etc.)

Rev. 5/99

ATTACHMENT F

SIGN OFF SHEET

Rev. 5/99 SITE SAFETY AND HEALTH PLAN COMPLIANCE AGREEMENT

All project personnel, including visitors, must follow the requirements of this Site Safety Plan. In order to document individual agreement with this requirement, all personnel must complete this “Site Safety and Health Plan Compliance Agreement.” These agreements will be kept in this Site Safety Plan and will become part of the permanent project record upon completion of site activities.

By signing below, I have read the Site Health and Safety Plan (HASP), or I have been verbally advised of its contents. I understand, and I agree to comply with all of its provisions. I understand that I could be prohibited from working on the project, and I may be subject to disciplinary actions for violating any of the health and safety requirements specified in the HASP.

NAME SIGNATURE DATE (TIME IN/OUT) 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21.

Rev. 5/99 Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

ATTACHMENT B – CERTIFICATION STATEMENTS

Phase II Remedial Investigation Work Plan

Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

ATTACHMENT C – RESUMES AND QUALIFICATIONS

Phase II Remedial Investigation Work Plan MONTGOMERY S. BENNETT, PG, CP, RSM principal hydrogeologist

Profile Monty Bennett is a principal hydrogeologist with over 20 years of environmental consulting experience. Monty provides senior evaluation and oversight of site assessment projects, risk assessments, remediation system designs, and regulatory negotiations. He is currently serving as senior project manager/principal hydrogeologist for three large industrial projects in Virginia, North Carolina, and Ohio involving the use of enhanced, in-situ bioremediation of chlorinated solvents. Monty has developed facility investigation work plans, site conceptual models, and source-area investigations. He is also overseeing the design and construction of a large-scale source-area interim measures project within fractured bedrock that includes various technologies such as excavation, soil vapor extraction (SVE), and enhanced bioremediation. He has developed and supervised innovative fractured-rock hydrologic tests including pulse interference and tracer tests, and performed site-wide analyses of microbial reductive dechlorination potential, bench tests, and the implementation of full- scale in-situ bioremediation.

Education BS, geology – West Virginia University

Registrations Professional geologist – GA, NC, SC, and VA Registered site manager – NC Certified professional – OH

Professional History GES principal hydrogeologist Environmental Resources Management project manager Resource International, Ltd. Bennett & Williams North American Exploration Froehling & Robertson

Training Loss Prevention System (LPS) Analysis and Design of Aquifer Tests – NGWA short course

Affiliations Association of Ground Water Scientists and Engineers

Presentations and Seminars Bennett, M.S., D. Hintz, and T. Larrieu, “Assessing Sodium Chloride Contamination and Remedial Alternatives: A Case Study.” Paper presented at Focus Conference on Eastern Regional Ground Water Issues, Burlington, VT, September 1993.

Page 1 MONTGOMERY S. BENNETT, PG, CP, RSM principal hydrogeologist

Representative Projects Former Bulk Oil Storage Terminal (Greensboro, NC) – Performed peer review of historical site assessment work for large petrochemical client. Responsible for developing a hydrogeologic conceptual site model, which included the integration of historical data into a project database, a 3-D visualization package, and a groundwater flow and fate-and-transport model. Conducted a site feasibility analysis and performed an Electro-Thermal Dynamic Stripping Process® pilot test. Currently implementing the largest (>6 acres) thermal remediation project in the US. Former Bulk Oil Storage Terminal (Spartanburg, SC) – Performed peer review of historical site assessment work for large petrochemical client. Developed time series animation of historical data to evaluate and locate potential source areas. Conducted a focused site assessment to pinpoint source areas using a GeoProbe® and membrane interface probe. Developed remediation alternative evaluation and conducted soil vapor extraction (SVE) and sparging pilot tests (ambient air and oxygen). Designed and installed an aggressive SVE, dual-phase extraction, and air sparging system to remediate the impacts identified at the site. Bulk Oil Storage Sites (Richmond, Norfolk, Hopewell, Williamsburg, and Petersburg, VA) – Conducted groundwater characterization studies and installed and monitored early release detection systems at various bulk oil storage and industrial facilities across Virginia. “State–Lead” Underground Storage Tank (UST) Sites (throughout VA) – Conducted site investigations, risk assessments, alternate water supply evaluations for numerous “state-lead” UST sites throughout Virginia. Conducted pump tests, SVE, and air sparging tests in support of remediation system design. Former Polystyrene Manufacturing Facility (Windsor, NJ) – Responsible for managing the investigation and remediation of a former polystyrene plant under the auspices of the Industrial Site Recovery Act program. Conducted an investigation to delineate the nature and extent of the environmental impacts and designed a bench-scale treatability study and field pilot test related to the in situ chemical oxidation of the environmental impacts. Developed a classification exception area document for the site. Polyester Manufacturing Facility (Wilmington, NC) – Served as investigation task manager to identify and remediate the impacts associated with a former process waste landfill under the inactive hazardous waste site program. Conducted groundwater sampling to assess the potential for monitored natural attenuation. Also responsible for evaluating 16 deep injection wells historically used to dispose of wastewater into the deep saline aquifer. Virginia Voluntary Remediation Sites (Chantilly, Danville, Chesapeake, Richmond, and Newport News, VA) – Served as project manager responsible for the investigation, risk assessment, and remediation evaluation of two former dry cleaning facilities, a tool manufacturing facility, and an aluminum siding manufacturing facility. These sites are being managed under the auspices of the Virginia voluntary remediation program (VRP). Performed environmental investigations, including the collection of soil, groundwater, and air samples using various sampling methods. Conducted quantitative risk assessments in accordance with the VRP guidance. Designed and implemented several innovative remedial methods including pneumatic fracturing and dual-phase extraction, in-situ anaerobic biological degradation, and in-situ chemical oxidation using potassium permanganate. Former Manufactured Gas Plants (Petersburg, Portsmouth, Lynchburg, and Staunton, VA) – Managed the investigation and remediation of four former manufactured gas plants under the auspices of the VRP. Developed a site investigation program including direct-push sampling, indoor air monitoring, soil gas surveys, geophysics, groundwater modeling, and hydraulic testing. Performed a risk assessment for each of the facilities, which included the evaluation of realistic exposure

Page 2 MONTGOMERY S. BENNETT, PG, CP, RSM principal hydrogeologist

pathways, exposure assumptions, and risk characterization. Evaluated various remedial alternatives for several of the sites. This included the removal of impacted soils, the closure of several large underground holders, the installation of a vapor barrier system, stream-bank stabilization, and the installation of a groundwater recovery trench. Pharmaceutical Manufacturing Facility (Petersburg, VA) – Managed an investigation of a release from a RCRA solid waste management unit (SWMU) underlain by a complex stratigraphic sequence using a cone penetrometer and on-site analyses. Designed a multi-phase extraction system to recover free, dissolved, and residual contamination simultaneously. The site is currently being addressed in the VRP. Recycling Facility (Roanoke and Salem, VA) – Developed and implemented a removal action plan for a former battery recycling operation, a former metal fabrication facility, and a scrap metal recycling facility. The investigation included delineation of soil and concrete contamination above the removal response goal set by the U.S. Environmental Protection Agency (US EPA), installation of groundwater sampling wells, and construction monitoring. RCRA Corrective Action (Franklin, Radford, Crozet, Suffolk, and Hopewell, VA) – Served as project manager for four National Corrective Action Priority Scoring high priority and one low/medium RCRA corrective action sites in VA. Three of the sites are facility-lead, one is being managed by the US EPA under an administrative order, and one is being managed by the VADEQ under a post-closure permit modification. Responsibilities included the development of work plans, sampling and analysis plans, quality assurance project plans, community relation plans, and health and safety plans for each site. Designed and implemented soil, sediment, and groundwater sampling using hollow-stem, rotosonic, GeoProbe, and vibrocore drilling methods. Virginia-Lead RCRA Corrective Action (Crozet, VA) – Served as project manager for a state-lead RCRA corrective action site in Virginia. Site has one unit in post-closure and up to 5 other SWMUs that will be addressed under the corrective action program. US Army National Guard (various facilities across VA) – Served as project manager for environmental services contract with the Virginia Army National Guard. Performed UST and aboveground storage tank assessments, indoor air quality surveys, and asbestos surveys at various armories across Virginia. Municipal Solid Waste Landfill (Colonial Heights, VA) – Supervised closure of a 150-acre municipal solid waste landfill. Closure included the removal of over 400 drums of hazardous waste, installation of a groundwater recovery and injection system, methane recovery trench, and the construction of an impermeable clay cap. Various Government Facilities (Suffolk and Petersburg, VA) – Conducted UST compliance audits and subsurface investigations at over 50 government facilities containing more than 200 petroleum USTs. Abandoned Quarry (Chesterfield County, VA) – Reviewed and provided comments on a geological/hydrogeological evaluation of an abandoned quarry to a municipal planning commission relative to the proposed reopening of the quarry adjacent to a subdivision.

Page 3 JONATHAN P. WADDELL, EIT project manager

Profile Jonathan Waddell has nearly ten years of environmental engineering consulting experience, specializing in characterization and remediation at federal and industrial sites impacted with various contaminants of concern including chlorinated solvents, metals, petroleum hydrocarbons, polychlorinated biphenyls (PCBs), and polycyclic aromatic hydrocarbons (PAHs). He is well-versed in groundwater flow and contaminant migration, innovative remediation and delivery technologies, and bio-geochemical processes within complex geologic systems. Jonathan has been involved primarily with characterization and remediation projects at impacted sites underlain by complex geologic media (i.e. fractured rock, glacial tills, heterogeneous alluvial deposits, etc.) located within the states of Georgia, North Carolina, Virginia, and Ohio.

Education MSCE, civil engineering – Georgia Institute of Technology BSCE, civil engineering – Georgia Institute of Technology

Registrations Engineer in training

Professional History GES project manager USGS civil engineer Engineering Strategies, Inc. civil engineer

Training Loss Prevention System (LPS) OSHA HAZWOPER – initial and refresher Hazardous Waste and Non-Hazardous Training – RCRA Understanding and Accelerating Remediation of Contaminated Groundwater – Regenesis Report Planning, Writing, and Colleague Review – USGS Submersible Pump Operation and Installation – NGWA Groundwater Field Techniques – USGS Accelerated Bioremediation of Chlorinated Solvents – RTDF Water-Quality Principles – USGS

Publications Holloway, O.G., and J.P. Waddell, “Design and Operation of a Borehole Straddle Packer for Groundwater Sampling and Hydraulic Testing of Discrete Intervals at US Air Force Plant 6, Marietta, Georgia,” USGS Open-File Report 2008-1349, 24 pp., web-only publication available at http://pubs.usgs.gov/of/2008/1349 (2008).

Page 1 JONATHAN P. WADDELL, EIT project manager

Representative Projects Industrial Site (Sanford, NC) – As project manager, prepared and implemented a Phase I Remedial Investigation Work Plan to investigate chlorinated solvent impacts, metal impacts, and non-UST petroleum releases within the confines of the North Carolina Department of Environment and Natural Resources (DENR) Registered Environmental Consultant (REC) Program. Currently in the process of submitting the Phase I Remedial Investigation Report, finalizing the Phase II Remedial Investigation Work Plan, and re-estimating cost-to-closure. Industrial Site (Crozet, VA) – Serving as project manager, prepared the Phase I RCRA Facility Investigation (RFI) work plan and associated Phase I RFI reports; developed and refined the site conceptual model; designed and managed source-area investigations; designed and is constructing a large-scale source-area interim measures within fractured bedrock that includes combined soil vapor extraction (SVE) and enhanced bioremediation; conducted innovative fractured-rock hydrologic tests including pulse interference and tracer tests; performed site-wide analyses of microbial reductive dechlorination potential under the auspices of the Virginia Department of Environmental Quality (VDEQ). Air Force Plant (Marietta, GA) – Participated in several investigations including determining discrete zones of chlorinated ethene (PCE/TCE) discharge into an off-site, downgradient creek using samplers; analysis of historical water-quality data to determine temporal trends with respect to degradation of chlorinated ethenes and bio-geochemical processes; investigation of the hydraulic response of a heterogeneous, anisotropic fractured rock body to a three-step, constant-rate pumping test; and literature review of remedial technologies applicable to the underlying fractured rock. Contributed to the fabrication of a borehole straddle-packer system utilized to investigate TCE contamination and hydraulic properties in fractures as deep as 600 feet beneath the land surface. Collected water-quality and hydraulic data within discrete fractures in bedrock, analyzed borehole geophysical logs and straddle packer results, and contributed to the volumetric characterization of contamination in deep fractured bedrock as well as setting the stage for potential use of enhanced bioremediation. Faucet-Manufacturing Site (Elyria, OH) – Serving as project manager, prepared Phase I and Phase II environmental site assessment reports; managed source-area investigations and soil waste classifications; prepared technical specifications for two large-scale soil removal events; managed the Phase I soil removal event and two enhanced bioremediation events; co-managed the Phase II soil removal activities; evaluated remedial performance and microbial reductive dechlorination potential; prepared remedial feasibility reports; and is in the process of preparing the No Further Action (NFA) letter under the auspices of the Ohio Environmental Protection Agency (OEPA) – Voluntary Action Program (VAP).

Page 2 JONATHAN P. WADDELL, EIT project manager

Presentations and Seminars Waddell, J.P., M.S. Bennett, and J.R. Field, “Source Zone Removal followed by Enhanced Bioremediation in Chlorinated Ethene-Impacted Fractured Sandstone,” The Tenth International In-Situ and On-Site Bioremediation Symposium, May 5-8, 2009, Baltimore, Maryland. Parcher, M.A., J.P. Waddell, E. Nugent, M.S. Bennett, and W. Benni, “Site-Specific Modeling to Target Remediation of Industrial Impacts,” in: Sass, B.M., Conference Chair, Remediation of Chlorinated and Recalcitrant Compounds, Proc. of the Sixth International Conference on Remediation of Chlorinated and Recalcitrant Compounds, Monterey, California, May 2008, ISBN 1-57477-163-9, publ. by Battelle, Columbus, Ohio. Waddell, J.P., J.R. Field III, M.S. Bennett, and K.S. Novakowski, “Remediation of Chlorinated Ethene Impacts within Fractured Crystalline Rock,” in: Sass, B.M., Conference Chair, Remediation of Chlorinated and Recalcitrant Compounds, Proc. of the Sixth International Conference on Remediation of Chlorinated and Recalcitrant Compounds, Monterey, California, May 2008, ISBN 1-57477-163-9, publ. by Battelle, Columbus, Ohio. Bennett, M.S., J.R. Field III, J.P. Waddell, and K.S. Novakowski, “Investigation and Identification of a Chlorinated Ethene Source Zone in a Fractured Crystalline Rock,” in: Proc. of the 2007 US EPA/NGWA Fractured Rock Conference: State of the Science and Measuring Success in Remediation, Portland, Maine, September 24-26, 2007, pp. 207-208. Bennett, M.S., J.P. Waddell, J.R. Field III, and K.S. Novakowski, “Preparation for Enhanced Bioremediation in a Chlorinated Ethene-Contaminated Fractured Crystalline Rock,” in: Proc. of the 2007 US EPA/NGWA Fractured Rock Conference: State of the Science and Measuring Success in Remediation, Portland, Maine, September 24-26, 2007, pp. 77-78. Bennett, M.S., J.P. Waddell, and K.S. Novakowski, “Site Characterization in Preparation for Application of Interim Remedial Technologies in a Chlorinated Ethene-Contaminated Fractured Crystalline Rock,” in: Abstracts of 15th Annual Davis S. Snipes/Clemson Hydrogeology Symposium, Clemson, South Carolina, April 16-18, 2006, pp. 2-3. Waddell, J.P. and G.C. Mayer, “Effects of Fenton’s Reagent and Potassium Permanganate Applications on Indigenous Subsurface Microbiota: A Literature Review,” in: Hatcher, K.J., ed., Proc. of the 2003 Georgia Water Resources Conference, University of Georgia, Athens, Georgia, April 23-24, 2003. Waddell, J.P., K.D. Pennell, and F.E. Löffler, “Microbial Study on Chlorinated Ethene Biodegradation within Rottenwood Creek Sediments Affected by Low-Flow Groundwater Discharge,” in: Abstracts of Tenth Annual Davis S. Snipes/Clemson Hydrogeology Symposium, Clemson, South Carolina, April 18, 2002, pp.36-45. Gonthier, G.J. and J.P. Waddell, “Trichloroethene Presence in Rottenwood Creek near Air Force Plant 6, Marietta, Georgia, Summer 2000,” in: Hatcher, K.J., ed., Proc. of the 2001 Georgia Water Resources Conference, Institute of Ecology, University of Georgia, Athens, Georgia (2001) pp .586-589.

Page 3 Moen Incorporated 2609 Cox Mill Road, Sanford, NC February 2010

ATTACHMENT D – MEMBRANE INTERFACE PROBE STANDARD OPERATING PROCEDURE

Phase II Remedial Investigation Work Plan

Page 1 Revision 2.4 Date 7/1/2008

STANDARD OPERATING PROCEDURES (SOP) For MEMBRANE INTERFACE PROBE SYSTEM

COLUMBIA Technologies, LLC 1448 S. Rolling Rd, Baltimore, MD 21227, 410-536-9911 Fax: 410-536-0222

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 2 Revision 2.4 Date 7/1/2008

Table of Contents

1.0 BACKGROUND 3 1.1 APPLICATIONS 3 2.0 SETUP 3 3.0 START UP 4 4.0 LOGGING PROCEDURES 5 5.0 LOGGING PROCEDURES (cont.) 5 5.1 FLOW TESTS 6 5.2 RESPONSE CHECK and TRIP TIME 6 5.3 ANCHOR SYSTEM 8 5.4 STRINGPOT 9 5.5 MEMBRANE REPLACEMENT 9 5.6 SHUTDOWN PROCEDURES 10 LOADLIST 11-12 MIPS PERFORMANCE TEST SOLUTION PREP 13

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 3 Revision 2.4 Date 7/1/2008

STANDARD OPERATING PROCEDURES (SOP) For MEMBRANE INTERFACE PROBE SYSTEM

Reviewed By: Title Signature Date

Doug McInnes Laboratory Director

1.0 BACKGROUND

The Membrane Interface Probe System (MIPS) is used for the detection and measurement of volatile organic compounds (VOC's) vertically through the subsurface. The self-heating probe, with a gas permeable membrane and dipole conductivity sensor, is advanced into the subsurface at predetermined increments. As the probe advances, the heat generated by the probe volatilizes any VOC's in the subsurface. The VOC’s then pass through the membrane, and enter into the carrier gas stream. When the carrier gas reaches the surface, it is run through a Nafion dryer and then fed directly into a Shimadzu GC 14A equipped with a PID, an ECD and an FID. The response is then recorded and displayed graphically along with the conductivity measurements.

1.1 APPLICATIONS

The standard flow rate for the nitrogen within the transfer line is 40 mL/min. This can vary depending on the ambient air temperatures and the approximate concentrations of the contamination. If the ambient air is 40 degrees or lower, the flow should be increased to 50 mL/min. If the site investigation is focused on locating lower concentrations such as defining the outer edge of a plume, or the contaminant of concern is a known “low responder”, the flows can be adjusted to be within 20-30 mL/min as deemed appropriate by the operator. When looking for high levels of contamination in source areas or NAPLs, the flow may be increased to be within 50-60 mL/min.

2.0 SETUP

When looking at the back of the controller box, on the right hand side, there is a port labeled Nitrogen Source. This is where the nitrogen supply enters the system. To the left of the nitrogen source is the input for detector 1 and detector 2. The green connector, to which is the detector electrometer leads are attached, is inserted here. The trunk line is what connects the MIP unit to the controller box and the GC; the following assumes that the trunk line is already connected to the MIP. The trunk line consists of 6 wires, and 2 lengths of 1/16” Teflon or PEEK tubing. The brown insulated

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 4 Revision 2.4 Date 7/1/2008

wires are the thermocouple lead and is made up of 2 individual wires, red and yellow. These two wires are connected to the male thermocouple connector (yellow). The red wire goes to the negative pole, and yellow to the positive: the polarity is clearly marked on the connector. The male thermocouple connector is connected to the socket labeled Thermocouple at the back of the controller box. The remaining 4 wires are associated with the Heater and Conductivity connector. The probe heater wires (both yellow) are connected to the top 2 lugs of this connector. The Dipole soil conductivity wires (red/white) are connected to the bottom 2 lugs of the connector. The 2 lengths of tubing should always be joined by a Swagelok union when not attached to the controller box and GC. This is to prevent any particulate matter from getting inside the tubing and potentially causing a clog. The first length of tubing is always connected to the port labeled Regulated Out at the back of the controller box first. This is so that any particulate matter that may have entered into the tubing is expelled, so be sure that the nitrogen is flowing through the controller box. The second length of tubing is then connected to the inlet of the dryer tube. If PEEK tubing is used, the line coming from the controller is Teflon, and the line returning from the probe to the GC is PEEK. Remember that when attaching the gas lines they are to be hand tight and then a ¼ turn with a wrench.

3.0 START UP

 Fill the generator with unleaded gasoline and check engine oil  Turn on generator and flip circuit breaker to “on”  Plug in extension cord, and use bungi cord to secure to top of generator  Check to ensure that nitrogen has greater than 400 psi, replace tank if lower  Turn on nitrogen source, and check that regulator reads 60 psi out  Open prime regulator on MIP controller box  Turn on GC, press start on keypad, column and injector are set to ambient, while detector is set to 300 degrees  Turn power on to MIP controller box  Turn on power and heater for PID lamp  Select your detectors, by changing the electrometer at the rear of the GC.  If working with the FID, plug in air compressor and turn on hydrogen (60 psi)  Light FID  Take out Rod rack.  Check flows and membrane…section 5.1  Turn on the probe heater  Turn on laptop and complete the parallel port connection  Open MIP software.  Response check…section 5.2

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 5 Revision 2.4 Date 7/1/2008

4.0 LOGGING PROCEDURES

 Use a rotary drill steel, or pre-probe punch to create a pilot hole if going through asphalt or concrete.  Place the rod wiper under the foot of the probe, and line it up with the pilot hole.  Set anchor system, if needed…section 5.3  Put the slotted drive cap on the probe drive head, and insert the probe into the hole in the rod wiper, so that the tip of the probe is even with the ground.  Connect the umbilical and string-pot…section 5.4  Check the pressure readings, temperature and detector baselines.  Press trigger to on position and commence probing.  Push the probe 1-foot, and then wait 1 minute.  Continue at this rate, until probe temperature can not recover to above 100 C. Extend the hold time to achieve minimum temperature if required.  If necessary change the attenuation of the GC and the MIP if the response begins to approach the end of the current range. (see section 5.2)  If temperature recovery improves, resume the 1-foot for 1 minute rate.  If the contaminant is known to at or below a certain depth, it is ok to push straight to that depth without stopping. The log will still supply accurate depth and conductivity data.  When looking for NAPL, it may be useful to push at 6-inch intervals.  Once the target depth has been reached, wait the necessary 1 minute and turn the trigger “off”.  Release the string-pot string from the counter weight, and disconnect the umbilical.  Press F5 on the computer to end the log and save the data.  Exit out of the MIP software and open the Display log.  Recall the appropriate file, adjust the scaling to the predetermined uniform scale.  Print out MIP log

5.0 LOGGING PROCEDURES (cont.)

 Start pulling the rods out of the ground, and replace on cart.  When all the rods are out and on the rack, decon with Liquinox and water.  Decon the rod wiper.  If high levels were encountered, it may be useful to clean the membrane with methanol.  Prior to the next location, visually inspect the probe and tighten if necessary,

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 6 Revision 2.4 Date 7/1/2008

check mass flows and temperatures.  If moving system to perform another log, prepare equipment for travel and repeat the above procedures. If there are no more logs to perform shutdown the system…section 5.6

5.1 FLOW TESTS

There are several critical flows that need to be monitored, and possibly adjusted to maximize the efficiency of the MIP system. These include the pressure from the supply tank to the prime regulator, the flow rate throughout the transfer line, the mass flow, and the flow rate inside the dryer tube. This is done at the beginning of everyday, and again if deemed necessary by Columbia’s analyst due to changing field conditions.

 The prime regulator on the front of the MIP controller box needs to be set to 20 psi using a small flathead screwdriver.  The mass flow should be adjusted to 5 using the dial under the gauge.  Fill the sample bulb of the flow meter half way with snoop.  Disconnect the nitrogen line at the inlet of the dryer tube, and attach a 1/16” female-to-female adaptor.  Insert adaptor into the flow meter line.  Squeeze sample bulb gently to produce a single bubble.  Adjust the mass flow dial until the meter reads 40 mL/min.  Lock the mass flow dial in place, and record both mass flow and dial setting.  Disconnect the nitrogen line, and attach the meter to the outlet of the dryer tube.  The measured flow out of the Dryer tube should be 80 mL/min.  Adjust the flow accordingly using the control valve on the opposite end of the dryer tube.  Disconnect the meter, and turn the power off.  The remaining volume of snoop in the sample bulb should then be poured onto the membrane to check for leaks.  If bubbles appear around the perimeter of the membrane, use membrane wrench to tighten, and check again.  If excessive leak at center of membrane, replace membrane…section 5.5  Put the meter away.

5.2 RESPONSE CHECK and TRIP TIME

Although the MIP system cannot be calibrated, the system can be monitored for reproducibility and proper performance. Using detector specific compounds, a response check is performed before every MIP log. This procedure can performed using solvent vapors (a “Response Test”), or using aqueous solutions of known compounds (a “Performance Test”). Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 7 Revision 2.4 Date 7/1/2008

RESPONSE TEST: This is done by introducing the headspace of a neat organic compound to the membrane, and then measuring the response against pre-set acceptable limits. The “trip time”, or the time it takes for a mass to move across the membrane and cause a detector response, needs to be measured at the time of a response check.

 Scroll the MIP software up to view the response vs. time screen  Hit F-1 to bring up attenuation screen, change D1 and D2 to a value of 10  On the GC control pad, to change the range from 1 to 10 for PID/FID press DET- (1or 2)-enter, Range-1-enter. For the ECD, press DET-3-enter, Range-1-enter.  To determine the trip time, introduce Butane from a lighter into the membrane, while simultaneously starting a stopwatch.  Record the time it takes from when the butane enters the membrane to when you first see a response on the screen.  This value is entered into the MIP software on the main screen when starting a new log, and recorded in the logbook.  Continue with the response checks by choosing the appropriate compound. For the PID use neat benzene, the ECD use neat trichloroethylene and for the FID use the butane from a lighter.  Introduce the vapor for 4 seconds, then wait 7, and repeat 2 more times.  Record the response that appears on the screen.  Repeat the above for each detector  The response needs to be greater than 1E+6 mV.  When checks are complete, resent to the attenuations to the appropriate levels.

PERFORMANCE TEST: A performance test is used to evaluate detector response from target compounds in aqueous solution. Standard compounds such as Benzene and TCE are also commonly used for performance tests, but specific target compounds for a site may be used as well. The “trip time”, or the time it takes for a mass to move across the membrane and cause a detector response, needs to be measured at the time of a performance check.

 Scroll the MIP software up to view the response vs. time screen  Record MPT number from the field computer in the field logbook  Hit F-1 to bring up attenuation screen, change D1, D2 and D3 to a value of 10  On the GC control pad, to change the range from 1 to 10 for PID/FID press DET- (1or 2)-enter, Range-1-enter. For the ECD, press DET-3-enter, Range-1-enter.  To determine the trip time, introduce Butane from a lighter into the membrane, while simultaneously starting a stopwatch.  Record the time it takes from when the butane enters the membrane to when you first see a response on the screen.  This value is entered into the MIP software on the main screen when starting a new log, and recorded in the logbook. Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 8 Revision 2.4 Date 7/1/2008

 Continue with the performance checks by choosing the appropriate compound. For the PID use a benzene solution (or other site-specific target compound), the ECD use a trichloroethylene solution (or other site-specific compounds). The FID response is still evaluated using butane from a lighter unless some site-specific compound is chosen for testing.  Prepare Stock Standard of compound(s) of interest (see MIPS Performance Test Solution Prep spreadsheet)  Immerse the probe in a container of clean water (commonly a 2” PVC tube) to stabilize the baseline.  Check the stability of the detector vs time data on the MIP software  Prepare 500 ml Testing standard from Stock Standards, place in 2” PVC Tube.  Turn the Trigger on  Insert the probe into the test solution of known concentration for 45 seconds  Return the probe to the tube containing clean water, allow baseline to re-stabilize  Turn Trigger off  Record trip time and response for each detector in field notes  Enter Performance Test Responses into the Performance Test Tracking spreadsheet.  Record probe and membrane cumulative depths in the Performance Test Tracking spreadsheet  Compare results to previous measurements  If the result varies more than 50% for any detector, begin trouble-shooting evaluation. Note any corrective actions performed in field notes  When checks are complete, resent to the attenuations to the appropriate levels.

5.3 ANCHOR SYSTEM

Due to the sensitivity of the probe membrane, an anchoring system is recommended to push the MIP and rods into the subsurface, so to avoid using the hammer and potentially damaging the MIP down-hole. Using a centered starting position, move the Geoprobe unit to the extreme left, before bringing it 4 inches back towards center. This is the location that the first anchor will be set. Using the rotation feature of the Geoprobe 5400, turn the anchor to depth, leaving just the stem visible above the ground surface. To set the other two anchors, swing the Geoprobe unit to the extreme right position before bringing it 4 inches back towards center, then swing it back to centered starting position, extend the Geoprobe unit to the extreme forward position and then back 4 inches. Place the anchor plate over the foot of the Geoprobe, and the 3 auger stems. It is very important that when setting the plate that the probe’s vertical movement of the hammer is not obstructed. The chain vices are then secured to the auger flights, which will lock the anchor plate to the foot of the probe.

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 9 Revision 2.4 Date 7/1/2008

5.4 STRINGPOT

Attach the string-pot to the string-pot bracket, and then to the main anchoring bolt of the probe hammer. The string-pot bottom clamp must then be bolted to the foot of the hammer. Prior to operation, the cotter pin is to be removed from the foot bracket so that the counter weight is free to move, and then inserted into the eyebolt on top of the counter weight. When the string or cable connects these two devices, the cable should be parallel to the probe and perpendicular to the ground. It is essential that the string-pot cable be connected to the counter weight prior to the activation of the trigger, or the depth measurements will not be accurate. The umbilical should be attached to the string-pot before the activation of the trigger as well.

5.5 MEMBRANE REPLACEMENT

It is very important to note that while completing the following procedure to use great care when screwing in the new membrane. Be sure that the threads do not become cross-threaded. This would make a complete seal impossible, which will then greatly hinder the performance of the MIP system.

 Secure the probe in a vice.  Clean the membrane and surrounding area thoroughly.  Using the dental pick, clean out the 4 holes in the membrane.  Using the membrane wrench, carefully unscrew the membrane while applying equal pressure to the top of the membrane.  Remove the membrane, and use the pick to clean up the interior threads of the probe, while blowing out the freed dirt.  Remove the washer carefully so to not allow any dirt to fall into the chamber.  Insert a new washer  Thread the new membrane into position, and tighten with the membrane wrench.  Using Snoop, check for leaks around the perimeter of the membrane.  If bubbles appear around the edge, use the wrench to tighten more.  Continue to tighten, until there is a complete seal.  There will be a certain amount of gas escaping through the center of the membrane; this is acceptable. It usually takes about 75 to 100 feet to fully condition the membrane.

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 10 Revision 2.4 Date 7/1/2008

5.6 SHUTDOWN PROCEDURES

 Turn off the power supply to the heater.  Turn off the PID lamp and heater.  Turn off GC.  If using FID, close the valve to the tank of hydrogen.  When the probe temperature has returned to ambient, turn off power to MIP controller box.  Close the prime regulator on MIP controller box.  Close the valve to the tank of nitrogen.  Shutdown the computer.  Shutdown the generator, and close valve to gas line  Put everything back where you found it.

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 11 Revision 2.4 Date 7/1/2008

LOAD LIST

Quantity Item Description Part Number Vendor 2 Membrane Interface Probe MP3510 Geoprobe 5 Replacement Membrane MP3512 Geoprobe 2 Trunk line (Transfer line) MP2550 Geoprobe 2 String-pot SC160 Geoprobe 1 String-pot Mounting Bracket SC110 Geoprobe 1 String-pot Mounting Bracket for 66DT 11751 Geoprobe 1 String-pot Bottom Clamp SC111 Geoprobe 1 String-pot Piston Weight SC112 Geoprobe 2 String-pot Cordset (umbilical) SC161 Geoprobe 5 Gortex Strip 12138 Geoprobe 2 Slotted Drive Cap AT1202 Geoprobe 2 Slotted Pull Cap AT1203 Geoprobe 1 Rod Wiper AT1255 Geoprobe 2 LB Sample Tube (wire cavity) AT6621 Geoprobe 2 Adaptor, 1.25”->1.375” MP2512 Geoprobe 2 SP Drive Head, 1.375 GW1516 Geoprobe 1 Membrane Wrench 16172 Geoprobe 1 O-ring Pick AT102 Geoprobe 1 MIP Kit (O-rings, 1/16” ferrules & nuts, wirenuts, Silcosteel) Geoprobe 3 4 foot x 4 inch auger 10245 Geoprobe 3 Chain Vice 10075 Geoprobe 3 Auger Plates 10176 Geoprobe 1 Anchor Plate 15340 Geoprobe

1 Tool Box 1 100 Ft. Extension Cord 1 Space Heater 1 Road Atlas 1 Generator 1 Spare Gas Can 1 Quart of Motor Oil 1 Volt Meter 1 Snoop 1 Flow Meter 1 9-Volt Battery

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 12 Revision 2.4 Date 7/1/2008

LOAD LIST (cont)

Quantity Item Description Part Number Vendor 5 1.44 Floppy Disk 1 Printer 1 Ream of paper 1 Spare Ink Cartridge 1 Power/Parallel Cords 1 Printer Drivers on Disk 1 Cylinder of nitrogen 1 Cylinder of hydrogen 2 Regulators 2 Box of Nitrile Gloves 1 Lap Top w/ Software 1 Air Pump 1 Air Compressor 1 Fire Extinguisher 1 Spare PID Lamp 1 Neat Standards…mecl2, Toluene 1 Site Specific Neat Standards 1 Butane Lighter 1 Hard Hat 1 Pair of Safety Glasses 1 Ear Protection 1 Steel Toe Boots 1 OSHA 8 hr/ Medical Clearance

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.

Page 13 Revision 2.4 Date 7/1/2008

MIPS PERFORMANCE TEST SOLUTION PREP

50 MG/ML STOCK -- 100, 10, AND 1 MG/L (PPM) SOLUTIONS IN 500 ML DI

25 ml of 10 ml of Volume Volume Volume 50 mg/mL 50 mg/mL 0f 50 mg/L 0f 50 mg/L 0f 50 mg/L Compound Name Density Stock Stock Stock for Stock for Stock for from neat from neat 100 mg/L 10 mg/L 1 mg/L in 25 ml MEOH in 10 ml MEOH in 500 ml DI in 500 ml DI in 500 ml DI (g/L) (uL) (uL) (uL) (uL) (uL) Trichloroethylene 1.4642 854 341 1000 100 10 Methylene Chloride 1.33 940 376 1000 100 10 1,2 Dichloroethylene 1.27 984 394 1000 100 10 1,1-Dichloroethylene 1.213 1031 412 1000 100 10 1,1,2,2- Tetrachloroethane 1.586 788 315 1000 100 10 Benzene 0.8765 1426 570 1000 100 10 Toluene 0.87 1437 575 1000 100 10 Tetrachloroethylene 1.6227 770 308 1000 100 10 Carbon Tetrachloride 1.594 784 314 1000 100 10 Chlorobenzene 1.106 1130 452 1000 100 10 1,1,1-Trichloroethane 1.3376 935 374 1000 100 10 1,1,2-Trichloroethane 1.442 867 347 1000 100 10 1,1-Dichloroethene 1.2129 1031 412 1000 100 10 1,4-Dichlorobenzene 1.241 1007 403 1000 100 10 MTBE 0.7404 1688 675 1000 100 10 Hexanes 0.6603 1893 757 1000 100 10 MEK (2-butanone) 0.81 1543 617 1000 100 10 Ethylbenzene 0.87 1437 575 1000 100 10 m-Xylene 0.86 1453 581 1000 100 10 o-Xylene 0.88 1420 568 1000 100 10 p-Xylene 0.86 1453 581 1000 100 10 Methylene Chloride 1.33 940 376 1000 100 10 Diesel 0.81 1543 617 1000 100 10 Naphthalene 1.15 1087 435 1000 100 10 Acetone 0.79 1582 633 1000 100 10 1,2-Dichloroethane 1.24 1008 403 1000 100 10 Trichlorfluoromethane 1.374 910 364 1000 100 10 1,1-Dichloroethane 1.18 1059 424 1000 100 10 1,2-Dibromoethane 2.1 595 238 1000 100 10 tert_Butyl Alcohol (TBA) 0.79 1582 633 1000 100 10

Data contained herein is proprietary to COLUMBIA Technologies, LLC (COLUMBIA), and may not be used, disclosed, reproduced, recorded, modified, performed, or displayed, in whole or in part, without the prior written approval of COLUMBIA. This data is provided for review purposes only, with no transfer of License Rights. This data represents Trade Secrets and is non-releasable under the Freedom of Information Act. © 2000-2008 COLUMBIA Technologies, LLC All Rights Reserved.