Prepared for: 151890 Georgia Pacific Atlanta, GA
WorkPlan Slope Stabilization Measures Crown Vantage Landfill Site, located in Alexandria Township, New Jersey Revised in Accordance with^EPA Letter Dated March 5, 2007
Time Critical Removal Action under EPA Administrative Agreement and Order On Consent Docket No. CERCLA 02-2005-2017
ENSR Corporation April 2007 Document No.: 03060-062-300
ENSR AECOM Georgia-Pacific Georgia-Pacific LLC Law Department 133 Peachtree Street NE (30303-1847) P.O. Box 105605 Atlanta, Georgia 30348-5605 (404) 652-4662 (404) 584-1461 fax April 30, 2007 www.gp.com
Mellonie S. Fleming Counsel Environmental VIA HAND DELIVERY
U.S. Environmental Protection Agency Removal Action Branch 2890 Woodbridge Avenue Bldg. 209 (MS-211) Edison, NJ 08837 / ATTN: Nick Magriples, OSC and Lou DiGuardia, OSC
RE: Administrative Agreement and Order on Consent for Removal Action Crown Vantage LandfiU Superfund Site - CERCLA Docket No. 02-2005-2017
Dear Mr. Magriples and Mr. DiGuardia,
Enclosed please find Georgia-Pacific LLC's(GP) Work Plan for the Slope Stabilization Measures at the Crown Vantage Landfill Site, located in Alexandria Township, New Jersey (WorkPlan). .
The Work Plan has been revised to address the comments received by GP and its consultant, ENSR, dated March 5 and April 16,2007. Please not the signature page of the QAPP requires the signature of an EPA representative.
On-site mobilization activities have begun under the conditional approval of the Work Plan. Formal EP.^ approval of the Work Plan is needed to begin the dmm-search and constmction phase of the project. The kick-off meeting to begin construction is currently scheduled for May 7. If additional changes to the Work Plan are necessary, please notify us immediately.
Sincerely, }
Mellonie S. Fleming \
Enclosures Prepared for: Georgia Pacific Atianta, GA
WorkPlan Slope Stabilization Measures Crown Vantage Landfill Site, located in Alexandria Township, New Jersey Revised in Accordance with EPA Letter Dated March 5, 2007
Time Critical Removal Action under EPA Administrative Agreement and Order On Consent Docket No. CERCLA 02-2005-2017
Prepared By Kathy Whool' Project Specialist
Reviewed By Donald P. Hessemer Senior Program Manager
Reviewed By Steven J. Surman, P.E. Senior Project Manager/Project Engineer
ENSR Corporation April 2007 Document No.: 03060-062-300 ENSR AECOM ENSR
Contents
1.0 Introduction 1-1 1.1 Background 1-1 1.2 Statement of Project Goals 1-2 1.3 Compliance with Applicable Guidance and Regulations 1 -3 1.4 Distribution of Site Documentation 1-3 1.4.1 Work Plan Distribution List 1-3 1.4.2 Field Documentation 1-4 1.5 Site Access 1-5
2.0 Site IVlanagement Plan 2-1 2.1 Site Security / Site Access 2-1 2.1.1 8' Tall Chain Link Security Fence 2-1 2.1.2 Signage : 2-2 2.1.3 Gates 2-2 2.1.4 Main Gates '. 2-2 2.1.5 Support Zones 2-2 2.1.6 Post-Construction Requirements 2-3 2.2 Waste Disposal Practices 2-3 2.2.1 Drum Storage and Consolidation 2-3 2.3 Key Personnel and Management Responsibilities 2-4 2.3.1 Consultant Project Managers (PM) 2-4 2.3.2 Consultant Site Safety Officer (SSO) 2-4 2.3.3 Consultant Resident Engineer ; 2-4 2.3.4 Consultant Project Coordinator 2-5 2.3.5 Consultant Site Superintendent ; 2-5 2.3.6 Public Affairs/Relations 2-6 2.3.7 Contractors and Subcontractors 2-6
3.0 Scope of Work 3-1 3.1 Site Preparation 3-1 3.1.1 Temporary Erosion Control 3-1 3.1.2 Dust Control Measures 3-2 3.1.3 Site Clearing Operations 3-3 3.1.4 Selective Grubbing Operations 3-3 3.1.5 Site Security 3-4 3.1.6 Well Abandonment 3-4 3.2 Infra-Structure Construction 3-5 3.2.1 Material Staging Area 3-5 3.2.2 Fence Modifications '. 3-5
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3.2.3 Temporary Haul Road Construction, Tracking Pad, and Access Road Improvements ..3-5 3.2.4 Equipment Refueling 3-6 3.2.5 Drum/Waste Storage and Sampling Pad Construction 3-7 3.3 Construction Trailer 3-7 3.4 Decontamination 3-7 3.4.1 Personnel Decontamination 3-8 3.4.2 Equipment Decontamination 3-8 3.4.3 Sampling Equipment Decontamination 3-9 3.5 Drum Handling and Removal 3-9 3.5.1 Hazard Identification 3-9 3.5.2 Abandoned Cylinders 3-10 3.5.3 Drum Handling , ...3-10 3.5.4 Drum Management ..3-10 3.6 Wall Zone Sub-Grade Preparation 3-10 3.6.1 Excavation 3-11 3.6.2 Sub-Grade Preparation 3-11 3.7 Geo-Web Reinforced Wall Construction 3-12 3.7.1 Geo-Grid Placement 3-13 3.7.2 Geo-Web Construction and Filling 3-13 3.7.3 Reinforced Wall Zone Construction 3-13 3.8 Drum and Waste Removal 3-13 3.8.1 Container Search 3-13 3.8.2 Drum Removal and Sampling 3-14 3.8.3 Transportation and Disposal... 3-14 3.9 Stormwater Control Features 3-15 3.9.1 Top of Slope Stale and Scour Protection Apron 3-15 3.10 Site Restoration 3-15 3.10.1 Geoweb Fascia 3-16 3.10.2 Materials Staging Area 3-16 3.10.3 Temporary Haul Roads, Sampling Pad, Storage Pad 3-16 3.10.4 Plantings / Reseeding 3-16
3.11 Demobilization 3-16
4.0 Heaith and Safety Plan (HASP) 4-1
5.0 Sampling and Analysis Plan (SAP) 5-1 5.1 Site Specific Sampling and Analysis 5-1 5.2 Sample Shipment Guidelines 5-1
6.0 Quality Assurance Project Plan (QAPP) 6-1
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7.0 Contingency Plan 7-1 7.1 Responsibilities 7-1 7.1.1 Personal Injury or Illness ...7-1 7.1.2 Spill or Discharges : 7-1 7.1.3 Emergency Response and Notification of Releases 7-1 7.1.4 Chain of Command 7-2 7.1.5 Emergency Response Plan 7-2
8.0 Treatability Studies 8-1
9.0 Applicable or Relevant and Appropriate Requirements (ARARs) 9-1
10.0 Schedule 10-1
10.1 Notifications 10-2 10.2 Progress Reports 10-2 10.3 Final Reporting 10-2
11.0 Reference to EDR Plans and Specifications 11-1 11.1 Construction Drawings and Specifications 11-1 11.2 Property and Topographic Survey 11-1 11.3 Construction Drawings 11 -2
List of Appendices
Appendix A EPA Correspondence/Orders
Appendix B Sampling and Analysis Plan (SAP)
Appendix C Transportation and Disposal Plan (T&D Plan)
Appendix D Health and Safety Plan (HASP)
Appendix E Quality Assurance Project Plan (QAPP)
Appendix F Well Abandonment Procedures
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1.0 Introduction
The purpose of this Work Plan is to provide the scope of work for the activities presented in ENSR's . Engineering Design Report (EDR)^ - Slope Stabilization Measures for the Crown Vantage Landfill, located in Alexandria Township, New Jersey, dated July 21, 2006. The EDR provides a framework, by means of construction drawings and technical specifications, for implementing time-critical actions in accordance with the Administrative Agreement and Order on Consent (AOC) between the US Environmental Protection Agency (EPA) and Fort James Operating Company (FJOC) for Removal Action, Docket No. CERCLA-02-2005-2017, effective May 26, 2005, for the Crown Vantage Landfill Site or the "Site." This Work Plan provides details of the Site Security Plan, Drum Samplihg and Removal Plan, Quality Assurance Plan, Health & Safety Plan as identified in the AOC. The initial Work Plan submitted to the EPA in September 2006 was modified to address comments in EPA's March 5, 2007 letter and discussions during a conference call with EPA on March 13, 2007.
These time-critical actions are defined in the EDR as part of the AOC Docket No. CERCLA-02-2005-2017, and include stabilizing the face of the landfill to prevent further erosion caused by the flooding of the Delaware River, securing the Site against unauthorized access, and a search across the surface of the landfill to identify, retrieve, and dispose of any drums/containers/pails and their contents that are present above the ground surface, in order to minimize direct contact threats with any drummed materials. The removal action is designed to address bank stabilization only and does not address any other exposure pathways for this site.
As required in the AOC, each contractor and subcontractor working on the Site will be provided a copy of this Work Plan. A copy of the Administrative Order CERCLA-02-2005-2017 is provided in Work Plan Appendix A, identified as "EPA Correspondence/Orders." A copy of the Administrative Order will be maintained in the site trailer along with the Work Plan for easy access by all site personnel. A copy of the USEPA Removal Site Evaluation Memorandum, dated May 25, 2004 will also be included under the EPA/Correspondence/Orders tab. The May 25, 2004 USEPA Removal Site Evaluation Memorandum contains the site-specific list of hazardous substances, pollutants, and/or contaminants known to be documented at the Site.
1.1 Background The inactive landfill is located on the east bank of the Delaware River, approximately Vz mile south of a former paper mill, in Hunterdon County, Alexandria Township, New Jersey. The landfill historically accepted various types of wastes for approximately 40 years starting the 1930s. Reportedly, coal ash, household trash, appliances, construction debris, chemical solvents, metal foil, waste paper and paper fiber were deposited in the landfill while it was in operation. In 1991, under the guidance of the New Jersey Department of Environmental Protection (NJDEP), a preliminary investigation of the Site revealed that there were approximately 800 drums on the surface of the landfill and volatile organic compounds (VOCs) present in the soil. FJOC and NJDEP removed a large portion of these drums from the site.
On September 29, 2004, the EPA initiated an emergency removal action to stabilize the Site in the areas along the western landfill face that'were impacted by the flooding from the rainfall associated with the remnants of Hurricane Ivan. Due to the past flooding and emergency actions undertaken by USEPA, the topography and vegetative cover have been altered. During the period of April 2-4, 2005, another major flood even occurred which impacted the Crown Vantage Landfill shoreline. EPA mobilized under the existing emergency response
' The EDR was approved by EPA In a letter from EPA, dated August 24, 2006
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action to further stabilize the shoreline. This flood event was documented to be the third highest within 100 years.
During tate June 2006, another flood occurred at the Site, in which the water level crested over the top of the landfill. After the water receded to the toe of the landfill a site inspection was conducted on July 5, 2006 by a representative from Consultant and EPA. Based on the observations made during the inspection there were no indications of significant erosion of the landfill due to the flooding event.
the entire landfill is approximately 10 acres in size and is located at the edge of the Delaware River. A security fence surrounds the perimeter of the landfill. The western edge of the landfill consists of a debris/dirt slope; a vegetated area exists at the southern end, which gently slopes toward the Delaware River. The slope of the landfill is approximately 20 to 25 feet tall at its highest point at the northwest corner of the site. A stone road provides access to the toe of the landfill. Between the slope of the landfill and the Delaware River are a small island and an intermittent flow channel. During high flows, the river level rises creating a "stream" between the island and the river. Approximately 100 yards south of the northwest corner, the stream returns to the main channel of the river. As the river level rises, the island becomes covered and the force of the river is directed at the landfill face. Further south the slope becomes gentler, and the scouring and erosion is less evident.
The proposed slope stabilization measures design is presented in ENSR's July 21, 2006 EDR, which includes a description and rationale for the proposed design.
1.2 Statement of Project Goals Slope Stabilization Measures at the Crown Vantage Landfill are being performed under the EPA AOC as a Time-Critical Removal Action. The purpose of this Work Plan is to supplement the EDR as a guide for the wall installation activities and slope stabilization measures at the former Crown Vantage landfill as approved by the US EPA as a time-critical removal action. The time-critical actions to be implemented at the Crown Vantage landfill pursuant to the AOC will generally include: (1) stabilizing the landfill face in order to eliminate the potential for containers and other waste materials from being released into the Delaware River, (2) immediately securing the site against unauthorized access, and (3) performing a search across the entire surface of the landfill to identify, retrieve, and dispose of any exposed drums, containers and/or pails and their contents that are present above the ground surface in order to minimize direct contact threats with these materials. \ The project involves two distinct operational goals:
1. Construction of slope stabilization measures by installing a barrier wall at the landfill face along the Delaware River. The proposed slope stabilization design will consist of the following four primary components:
• An imported stone aggregate foundation; • A geosynthetic reinforced wall containing a stone aggregate backfill reinforced with Geoweb® and Geogrids®, constructed at the toe of the landfill rising to a maximum height of 128 feet above mean sea level (amsl); • Toe scour protection consisting of geotextile fabric, and a proper gradation of imported stone aggregate and rip-rap; and • Vegetated facia of the geosynthetic wall system using a blend of topsoil, seed mixture, and aggregate for Geoweb® in-fill.
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2. During the construction of the barrier wall various excavations will be conducted. It is assumed that during excavation operations, drums will be encountered and removed. The entire surface of the landfill will also be inspected for drums. Drums at the surface or partially buried drums will be removed. Drum handling measures are described in the Sampling and Analysis Plan for Drum Removal (SAP) provided in Appendix B of this Work Plan. 1.3 Compliance with Applicabie Guidance and Regulations All contractors and subcontractors must conform with applicable guidance and regulations, as established by the regulatory agencies in the following documents:
• U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), Code of Federal Regulations, Title 29 (29 CFR), Part 1910.120.
• U.S. Department of Labor, OSHA, 29 CFR, Part 1910.1200.
• U.S. Department of Labor, OSHA, 29 CFR, Part 1910 and Part 1926.
• National Institute for Occupational Safety and Health (NIOSH)/OSH/VU.S. Coast Guard (USCG)/EPA, , Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, Publication No. 85-115, 1985.
Refer to Work Plan Section 3.1.6.1 for well abandonment procedures pursuant to NJDEP Chapter 9D - Well Construction and Maintenance; Sealing of Abandoned Wells (NJAC 7:9D).
1.4 Distribution of Site Documentation A full copy of the Work Plan, including but not limited to Work Plan, HASP, QAPP, SAP and T&D, will be provided to all personnel for their internal distribution, including site supervisors, consultant supervisor, consultant field crew, and other contract personnel performing the time-critical removal actions described in this document. At a minimum, a full copy of the final Work Plan will be provided to the list of document recipients provided in this section of the Work Plan. In addition, a full copy of the Work Plan will be maintained in an on-site trailer for the duration of performance of drum removal and slope stabilization/wall installation measures for easy access to site personnel. All persons, including site visitors, will be required, to read and sign-off on the HASP if they are to enter the work area as defined in the HASP.
A copy of the Administrative Order CERCLA-02-2005-2017 and a copy of the USEPA Removal Site Evaluation Memorandum, dated May 25, 2004 are provided in USEPA Correspondence/Orders appendix of this Work Plan.
In addition, the following reference documents will be readily available for reference on site at the site trailer:
• Emergency Response Guidebook (latest Version)
• 2006 TVLs and BEIs
• NIOSH Pocket Guide to Chemical Hazards (August 2006 or latest version)
1.4.1 Work Plan Distribution List The distribution of the Work Plan will be as follows:
1. in accordance with the AOC, five (5) copies of the Work Plan and three (3) copies of all other documents need to be provided to:
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USEPA Removal Action Branch 2890 Woodbridge Avenue Bldg. 209 (S-21i) Edison, NJ 08873 Attn: Louis DiGuardia, On-Scene Coordinator
One (1) copy to:
Office of Regional Counsel USEPA 290 Broadway, 17* Floor NewYork, NY 10007-1866 Attn: Sarah Flanagan
2. Project team distribution as follows:
One (1) copy each to:
Susan Richardson Kilpatrick Stockton LLP Suite 2800,1100 Peachtree Street Atlanta, GA 30309-4530
One (1) copy each to:
Georgia-Pacific 133 Peachtree Street NE Atlanta, GA 30303-1847
Attn: Mellonie Fleming, John Harrod, Paul Montney, Gail Smith
ENSR 20 New England Avenue Piscataway, NJ 08854 Attn: Donald Hessemer, Steve Surman, Steve Kostage Terra Contracting, LLC 2612 Miller Road Kalamazoo, Ml 49001 Attn: Steve Taplin, President
3. Distribution to NJDEP: A copy of all documentation submitted to USEPA will be provided to the NJDEP bureau office as designated by USEPA. As discussed on March 13, 2007, USEPA will be responsible for fonwarding site documentation to NJDEP, as deemed appropriate by the USEPA On-Scene Coordinator.
1.4.2 Field Documentation EPA retains the right to review all field documentation. Also, in accordance with the Record Retention requirements stated in the Order, all site documentation must be maintained "until three (3) years after Settling Party's receipt of USEPA's notification pursuant to the Notification of Completion of Work. All non-identical
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copies of records, documents and information of what ever kind, nature or description relating to performance of the Work Plan activities shall be preserved and retained (including records or documents in electronic form) by the Contractor and/or Subcontractors.
All field documentation will be maintained in accordance with the Records Retention policy contained within the order. At a minimum, the Site Safety Officer, Resident Engineer, Project Coordinator, and Site Superintendent may collect information and document field activities. This does not exclude other contractors, subcontractors or site visitors from keeping their own field documentation. Contractors and subcontractors may have project documentation and records retention polices beyond which is described in the Work Plan.
1.5 Site Access Access Agreements were provided in Appendix 6 of ENSR's July 21, 2006 Engineering Design Report (EDR), and the Block and Lot designation and survey line are depicted in the site basemap of the Construction Drawings referenced in this Work Plan . The most recent site boundary and topographic survey, dated January 14, 2006,was prepared by Borbas Surveying and was provided with the Work Plan Construction Drawings. Access agreements have been obtained for the (1) Norman Falk property Block 17.01 Lot 2.02 for access to the landfill property, and (2) for access to the Crown Vantage Landfill Superfund Site itself. The owner of the Crown Vantage Landfill property Block 17.01 Lot 1 (Alexandria Township) is listed as Crown Paper Company. The Crown Vantage Landfill is bounded to the south and southeast by parklands owned by the NJDEP on Block 17.01 Lot 15 and 15.01, respectively; to the east-northeast by lands owned by Norman Falk on Block 17.01 Lot 2.02 through which access to the Crown Vantage Landfill site is obtained from County Route 619 aka Frenchtown Road. The public access recreational trail immediately bounding the eastern fenceline boundary of the Crown Vantage Landfill site is designated as Block 17.01 Lots 100 and 100.01 along the former Pennsylvania Railroad Company easement.
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2.0 Site IVlanagement Plan
Applicability of this Work Plan extends to all Consultant employees working on site and all contractors and subcontractors. All site workers will familiarize themselves with the contents of this Work Plan and ancillary plans:
• Engineering Design Report (EDR) • Health and Safety Plan (HASP) • Sampling and Analysis Plan for Drum Removal (SAP) • Quality Assurance Project Plan (QAPP) • Transportation & Disposal Plan (T&D Plan) All Consultant employees and subcontractors working on site will be required to read and signoff on the HASP prepared for slope stabilization measures described in this Work Plan. This Work Plan will be revised if unforeseen activities are required for on-site implementation or on-site conditions arise that were unanticipated. All addendums to this Work Plan will be submitted to the EPA On-Scene Coordinator (OSC).
2.1 Site Security / Site Access Methods for limiting access to the site during time-critical removal actions include fencing, signage, and enforcement of the designation of zones (Support Zone, Contamination Reduction Zone and Exclusion Zone) delineated in the HASP by the SSO.. In general, site hours of operation during implementation of this Work Plan may extend from 0600 Hours to 2000 Hours. Site hours of operation may be reduced or extended if site conditions warrant. During non-operational hours the access gate to the Support Zone will be secured (locked). All equipment will be staged in the designated staging area. Road access to the site will be chained and/or posted as "Closed." Upon arrival to the site, the Consultant SSO or Consultant Project Coordinator will perform a site walkover to inspect site security fencing/signage and will report any instances of vandalism and/or trespassing to the local police. Measures will be taken to repair fencing that has been damaged to limit on-site access to unauthorized personnel.
Public notification of ongoing remedial and slope stabilization will be made to local landowners within 200' of the property. In addition, signs will be placed on the fence bordering the public walkway to inform users of the ongoing work activities and hours of operation.
If site work hours begin or extend to after dark, provisions will be in place for site lighting. It is recommended that no heavy equipment be operating in exclusion zone after twilight. It is anticipated that (2) portable light towers will be on-site for purposes of equipment repair, fueling and maintenance. If work activities are required under low-light (twilight) hours, these towers will also be available in the event of any emergency type situation whereas longer hours are mandated.
Specific construction specifications for site security measures are provided on Drawing No. 2A and 2B, Sheets 3 and 4 (Site Security Plan) of the EDR, including:
2.1.1 8' Tall Chain Link Security Fence Specifications for the chain link fence include:
1. Fence and signage shall be inspected once per week and after storm events by the Site Superintendent during construction.
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2. All unauthorized breaches of fence or damage to signage shall be addressed by the contractor immediately using temporary fencing or signage. Permanent repairs shall be made within 10 working days of identifying the damage.
3. New fencing shall be installed in accordance with the Details IA - IC on Drawing 7.
2.1.2 Signage Specifications for signage include:
1. Contractor shall install and secure signage every 100 linear feet and 6 feet high, along the existing fence line (North, East and South). Refer to Details 2A-2E on Drawing 7.
2.1.3 Gates ' • - Gate specifications for 20-foot wide double swing gates include:
1. Gates shall remain open during working hours and locked during non-working hours with chain link and key lock.
2. Site Superintendent shall be responsible for ensuring gate is open during working hours and locked and secured during non-working hours.
2.1.4 Main Gates Main Gates will consist of 20-foot double wide swing gates with the following specifications:
1. Working hours at the site will be 0600 Hours to 2000 Hours (6 AM to 8 PM), seven days per week (if necessary).
2. All visitors shall contact the Project Coordinator (Steve Kostage - ENSR) at 978-337-1519 seventy-two (72) hours prior to site entry.
3. All visitors and site personnel must sign in and out at the project trailer. Any unauthorized visitors shall be reported to the Site Superintendent.
4. All visitors and site personnel shall provide the Site Superintendent vyith a copy of OSHA Hazwoper certification prior to entering the site.
5. The Site Superintendent shall maintain a key log to track which personnel possess a copy of the site key(s).
2.1.5 Support Zones Support Zone specifications include:
1. Project trailer and storage shed shall be locked and secured during non-working hours to prevent unauthorized access. .
2. Signage shall be installed at main entrance of exclusion zone (EZ entrance) to alert personnel of required PPE and training requirements to enter the EZ.
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2.1.6 Post-Construction Requirements The AOC specifies that provisions for placement of a fence or barrier preventing access onto the landfill along its western edge shall be implemented after the time-critical removal actions have been completed. A plan for periodic inspection (once per quarter) and maintenance of all fencing and warning signs (signage) will be implemented after the time-critical removal actions have been completed. The AOC states that any fence or barrier installed along the western edge of the landfill shall be placed in such a manner as to be able to withstand peak flows. As approved in the EDR, signage will be posted along the western edge of the landfill face since evidence from past flood events has shown that any fencing installed along the Delaware River shoreline has been destroyed. The EDR has specific signage along the western edge for this reason. Signage will be installed on trees along the shoreline at a height of 6-feet as indicated in the EDR. Maintenance will consist of repairs of breaches and/or any other type of damage where security is compromised until termination of the AOC.
As described below in Section 3.9 (Site Restoration), inspection and maintenance of the vegetation survival rate will be conducted for a period of two years following completion of landfill stabilization measures.
2.2 Waste Disposal Practices A transportation and disposal (T&D) plan addressing the proper off-site disposal of staged drums, containers and pails and their contents is provided in Appendix C. The T&D plan will be implemented in compliance with the Resource Conservation and Recovery Act ("RCRA"), 42 U.S.C. §§ 6901-6991, and Section 300.440 of the National Contingency Plan (NCP). Upon receipt of waste classification analytical results, waste disposal transportation and disposal services will be contracted based on the disposition of the waste. All disposal facility certifications, approvals and insurance certificates for each facility will be fonwarded to the EPA OSC as specified in the AOC. All waste materials will be sent to a RCRA Permitted and CERCLA approved TSD Facility via a licensed and permitted transporter. Copies of all manifests and bill of ladings will be maintained onsite. Certificates of Disposal for all waste shipped off site will be submitted to the EPA OSC in the Final Report. Copies of manifests, bills,of lading, and certificates of disposal and destruction will be provided in the Final Report submitted to USEPA.
2.2.1 Drum Storage and Consolidation Drummed waste that contains free liquids or solids that cannot be bulked with other materials will be stored in the salvage drums. These drums will be placed on the drum/waste storage and sampling pad depicted on Drawing 3B (Site Preparation Plan) of the EDR further discussed below in Section 3.2.5. The drums will be placed in rows no more than two wide with the labels and identifying marks turned toward the aisle. Aisles will accommodate a skidsteer.
Recovered wastes will be staged in a designated area for subsequent off-site disposal. All disposable PPE will be containerized and disposed-of off-site in the same manner as all Investigation-Derived Wastes, including decontamination fluids. Up to (3) roll-off boxes will be placed on the drum/waste storage and sampling pad. The boxes will be used to bulk like wastes. Like wastes may consist of:
• Empty drums, carcasses and remnants • Non-hazardous solid wastes • Other regulated, solid wastes Wastes not shipped off-site will be covered at the end of each work day. All roll-off boxes will be equipped with roll type tarps for storage purposes. Waste characterization and classification activities will be performed within a reasonable time frame to meet specific RCRA storage requirements to limit storage time on-site of all waste streams.
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2.3 Key Personnel and Management Responsibilities The Consultant will be responsible for coordinating all on-site activities with US EPA and other federal, state and local agencies. The Consultant will also direct all subcontractor activities on site in accordance with this Work Plan. The Consultant personnel designated below will have specific management responsibilities as described below. The Consultant Project Manager and Consultant Project Coordinator will also serve as the communication point between FJOC and other Consultant personnel and subcontractors. A flow chart (Table 1) is provided below at the end of this Section that presents the positions and responsibilities of key personnel.
US EPA will be notified of the name(s), qualifications(s) of any other contractors or subcontractors retained to perform the work at least seven day prior to commencement bf the Work Plan. A copy of the Administrative Agreement and Order on Consent for Removal Action (AOC) will be provided to each contractor and subcontractor retained to perform the work required by the AOC.
2.3.1 Consultant Project Managers (PM) The Consultant PM (Steve Surman-ENSR) is the individual who has the primary responsibility for successful completion of this project. As such, the PM is also responsible for ensuring that the requirements of the HASP,'QAPP, and SAP are implemented in accordance with the EPA AOC.
2.3.2 Consultant Site Safety Officer (SSO) The SSO (Theresa Willfong) will be on-site during all activities covered by this HASP. The SSO is responsible for enforcing the requirements of HASP once work begins. The SSO has the authority to (1) immediately correct all situations where noncompliance with this HASP is noted, (2) immediately stop work in cases where an immediate danger is perceived and (3) initiate emergency response procedures in accordance with Section 11.0 of the HASP. In addition to ensuring that the contents of the HASP are implemented, the roles and responsibilities of the SSO include, but are not limited to, the following:
Collect, manage and file all HASP documentation of Consultant personnel and subcontractors Maintain a log of all on-site visitors Maintain daily air monitoring logs Maintain all equipment calibration logs Review site conditions and perform Job Hazard Analysis if new site conditions warrant HASP revision Conduct daily Health and Safety briefing with all on-site personnel and subcontractors Ensure that all on-site personnel have, read the HASP and maintain all HASP signoffs
Collect and maintain on-site documentation of HASP training requirements for all on-site personnel.
Ensure that there is an adequate supply of PPE available on site.
Performs a daily inspection of on-site conditions upon arrival and prior to departure to/from the work zone arid records/documents any incidents of vandalism, new hazards to site conditions, and any other observations that may affect the scheduled work.
2.3.3 Consultant Resident Engineer the roles and responsibilities of the Consultant resident engineer (Vladimir Raskin/ENSR and Hue Quan/ENSR) include, but are not limited to, the following:
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Provide full-time on-site monitoring of the construction work under the direct supervision pf the Engineer of Record Review submittals provided by the Contractor, including but not limited to laboratory test results, surveys, construction materials, construction equipment, and shop drawings in accordance with the construction drawings and specifications Monitor all work performed by the construction contractor and subcontractors Interprets drawings and specifications Organize and conduct weekly construction meetings Maintain project file documentation Develop detailed progress reports Review Contractor's progress payments'against actual work completed Conducts inspection of completed work Reviews engineering and construction proposals Reviews change order requests ; Maintains an independent set of drawing markups for comparison of those maintained by the construction contractor Review constructor quality control files, field documentation and record keeping Signs-off on construction contractor daily logs
2.3.4 Consultant Project Coordinator The Consultant Project Coordinator (Steve Kostage - ENSR) role will be to provide direct supervision of the Site Superintendent, perform subconti'actor oversight as needed, coordinate all work plan activities between various Consultant project personnel and subcontractors, and ensure that all project documentation is filed appropriately. The Project Coordinator is the direct contact point with EPA for all project correspondence and is the field service liaison with EPA. The Consultant Project Coordinator will also have the responsibility of the following: <
• Ensuring compliance with all applicable regulatory requirements for a time critical removal action • Monitors the work performed by the construction contractor and other contractors (waste disposal, laboratory, surveyor, etc.). • Verifies that all on-site permits, supporting documentation and clearances have been approved and documented for filing purposes • Maintains project file documentation • Provides progress reports and reviews submittal schedules • Prepares and/or reviews change order requests
2.3.5 Consultant Site Superintendent The Consultant Site Superintendent (Hank Wylam), has overall responsibility for completion of all field activities in accordance with Work Plan, S&A Plan, and the QA/QC Plan and is the communication link between project management and the field team. Specific responsibilities of the Consultant Site Superintendent include:
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Directing and coordinating on-site activities in accordance with this Work Plan and informing site personnel, contractors and subcontractors of the activities to be performed each day Providing direct oversight of the Contractor and subcontractors on site Assisting in the execution of Consultant Project Coordinator activities, described above Assigning specific duties to field team members Mobilizing and demobilizing of the field team and subcontractors to and from the site Ensuring that on-site resources (employees, equipment, and subcontractor) are operational and sufficient for completion of the Work Plan tasks at hand Resolving any logistical problems that could potentially hinder field activities, such as equipment malfunctions or availability, personnel conflicts, or weather dependent working conditions, Maintains all waste disposal documentation and bill of ladings Handling any field emergency situations and has the authority to issue a "stop-work" order in situations where potential hazardous substances and/or conditions arise on the work site Maintains a log of all hazardous and non-hazardous waste disposal shipments Resolving any logistical problems that could potentially hinder field activities, such as equipment malfunctions or availability, personnel conflicts, or weather dependent working conditions, and Implementing field QC including issuance and tracking of measurement and test equipment; the proper labeling, handling, storage, shipping, and chain-of-custody procedures used at the time of sampling; and control and collection of all field documentation.
2.3.6 Public Affairs/Relations The public affairs/relation individual(s) designated by FJOC will coordinate media events and news releases to communicate on site actions and progress. The following individuals shall serve as the lead communicators between Contractors and the general public.
Gail A. Smith Georgia Pacific - Director, External and Environmental Communications Phone: 404.652.4738
John Harrod Georgia-Pacific - Senior Environmental Engineer Phone: 404.652.6871
2.3.7 Contractors and Subcontractors Based on the current scope of work presented in this Work Plan for Slope Stabilization Measures, the following contractors and subcontractors will be utilized in execution of the Work Plan. All contractors and subcontractors are expected to read and signoff on the HASP prepared for the site and to provide the required health and safety documentation to the SSO prior to arrival at the site. All Consultant employees, contractors and subcontractors are expected to participate in daily health and safety tailgate briefings. Other than those contractors and subcontractor mentioned below, FJOC wiil notify EPA of the name(s) and qualifications of any other contractors or subcontractors retained to perform work at the site within at least seven (7) days prior to commencement of such work in accordance with the AOC.
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2.3.7.1 Surveying The surveyor selected for the scope of work presented in this Work Plan is Borbas Surveying, Inc. located in Boonton, NJ.
2.3.7.2 Engineering/Wall Design The geotechnical subcontractor selected for the scope of work presented in this Work Plan is Sor Consulting Engineers, Inc. located at 98 Sand Park Road, Cedar Grove, New Jersey. Sor Consulting Engineers, Inc. completed the Geotechnical Investigation Report provided in the July 2006 EDR.
InterSol Engineering, Inc. provided supporting analyses and testing of the wall design elements. InterSol Engineering, Inc. is located at 540 Moorelands Cresent, Milton, Ontario, Canada L9T 4B4.
2.3.7.3 Site Preparation and Wall Installation The site preparation and wall installation contractor selected for the scope of work presented in this Work Plan is Terra Contracting LLC located in Kalamazoo, Ml.
2.3.7.4 Analytical Services Analytical services will be provided by a Contract Laboratory Program (CLP) certified laboratory or by a non- CLP laboratory that meets the requirements of the Administrative Agreement and Order on Consent for the scope of work presented in this Work Plan. The laboratory will also be responsible for site delivery of sample bottles, decontaminated sampling equipment, and sample preservatives, and pickup of laboratory sample coolers, on an as-needed basis, for delivery under chain-of-custody for sample log in at the laboratory. All laboratories contracted to perform under this work plan will be identified and the laboratory qualifications will be provided to EPA prior to performing laboratory services in accordance with the AOC.
2.3.7.5 Waste Disposal Waste disposal and waste disposal transportation services will be required throughout the duration of wall installation and slope stabilization activities. United Enviro Services, Inc. was previously identified by FJOC to provide waste disposal services for the scope of work presented in this Work Plan. Upon review of waste characterization sampiing results, all transporters and disposal facilities designated to transport and receive such wastes will be identified and a list of alternate transporters and disposal facilities will be provided to EPA prior to the commencement of disposal activities in accordance with the AOC.
2.3.7.6 Drilling The drilling subcontractor previously utilized by Sor Testing at the site during the geotechnical investigation was General Borings of Prospect, CT. Drilling services are not anticipated to be necessary for execution of this Work Plan. Should the need for additional drilling services be identified during the field program, FJOC will provide EPA with the name and qualifications of the driller contractor or subcontractors to be selected for the work.
J:\Project\Georgia-Pacific\03060-062 Milford CV 2-7 Aoril 2007 LandfiH\WorkPlan\FINAL-April200AENSRWorkPlan-CVLandfill- FINAL-4192007.doc TABLE 1 Flow Chart of Key Personnel and Management Responsibilities Crown Vantage Landfill - Alexandria Twp. NJ Time-Critical Removal Action EPA On Scene Coordinator Lou DiGuardia
Settling Party - Fort James Operating Conipany Coordinates all on-site activities with EPA and other federal, state, and local agencies Consultant Project Manager
Consultant Project Coordinator- Steve Kostage/ENSR & EngineerjjfRecord • Ensures compliance w/ regulatory requirements for a time critical removal action Steve Surman/ENSR • Monitors work performed by contractors I Responsible for ensuring that the requirements of • Verifies approval and documentation of all on-site permits, supporting documentation HASP, QAPP, and SAP are implemented in accordance and clearances with EPA AOC • Maintains project file documentation • Provides progress reports and reviews submittal schedules • Prepares/reviews change order requests
Consultant Site Safety Officer (SSO) Consultant Site Superintendent Consultant Resident Engineer Theresa Willfong/ENSR Hank Wylam/ENSR Vladimir Raskin/ENSR and • Enforce the requirements of HASP once Responsible for completion of field Hue Quan/ENSR work begins activities in accordance with Work Plan, Full-time on-site monitoring of the Collect/Manage/File HASP documentation S&A Plan, and the QA/QC Plan construction •| Correct situations of noncompliance with Direct and coordinate on-site activities; Review submittals provided by the ! HASP: perform Job Hazard Analysis; daily informing site personnel, contractors and Contractor Health and Safety briefing; maintain all subcontractors of the activities to be Monitor work contractor and subcontractors HASP signoffs; maintain on-site performed each day Interprets drawings and specifications documentation of HASP training Provide direct oversight of the contractors Organize and conduct weekly construction requirements Assist Consultant Project Coordinator meetings • Stop work for perceived immediate danger, Assign specific duties to field team Maintain project file documentation initiate emergency response members Develop detailed progress reports • Maintain a log of all on-site visitors Mobilize and demobilize field team and Review Contractor's progress payments " Maintain daily air monitoring logs subcontractors to and from the site against actual work completed • Maintain all equipment calibration logs Ensure on-site resources are Inspect completed work • Ensure available PPE on site operational/sufficient for completion of the Review engineering/construction proposals, • Perform daily inspection of on-site Work Plan tasks and change order requests conditions upon arrival and prior to Resolve any logistical problems Maintains independent set of drawing departure to/from the work zone and Maintain waste disposal documentation and markups for comparison of those records/documents any incidents of bill of ladings maintained by the construction contractor vandalism, new hazards to site conditions, Handle field emergency situations; Review constructor quality control files, and any other observations that may affect authority to issue a "stop-work" order in field documentation and record keeping the scheduled work situations where potential hazardous substances and/or conditions arise on the work site Maintain a log of all hazardous and non- hazardous waste disposal shipments
Contractor Field Team - Terra Contracting
Contractors and Subcontractors Read and signoff on the HASP prepared for the site and to provide the required health and safety documentation to the SSO prior to arrival at the site Contractors and/or Subcontractors mav include: • Surveyor • EngineeringAVall Design • Site Preparation and Wall Installation • Analytical Services • Waste Disposal • Drilling
WP - Admin Flow ChartFINAL-revI .doc 4/10/2007 f ENSR
3.0 Scope of Work
3.1 Site Preparation Site preparation operations will be initiated upon mobilization to the site. Preparation operations include installation of erosion control measures, tree removal, selective stump removal, vegetation removal, temporary road construction, and stone tracking pad and access road improvements. On-site excavation activities will conform to Section 02200 (Earthwork) Construction and Material Specifications provided in Appendix 5 of the EDR. Refer to Drawings 3A and 3B, Sheets 4 and 5 of 13, of the EDR.
3.1.1 Temporary Erosion Control Temporary erosion control structures and location for implementation are depicted on Drawings 3A and 3B (Site Preparation Plan), and Drawing 8 (see Details 1 and 2) of ENSR's July 21, 2006 Engineering Design Report (EDR). Temporary erosion control measures will be installed prior to initiation of on-site construction activities. Erosion control measures will consist of:
• Installation of silt fence around the material staging area • Installation of a turbidity curtain in the Delaware River • Installation of silt fence along the top of the slope of the landfill. Silt fence will be modified to facilitate construction activities, as needed. Installation of sedimentation and erosion control will conform to Section 02273 (Sedimentation and Erosion Control) Construction and Material Specifications provided in Appendix 5 of the EDR. Additional construction details are provided on Drawings 3A and 3B, Sheets 4 and 5 of 13 of the Site Preparation Plan and Drawing 8 (Soil Erosion and Sedimentation Control Details). As detailed in the construction drawings of the EDR, haybales and/or silt fence will be utilized at the site during the construction activities. It is at the discretion of the site engineer and contractor to determine which soil erosion and sediment control measure is appropriate for each phase of the construction activities.
3.1.1.1 Silt Fence A 24" silt fence will be placed along the east, south and west sides of the proposed material staging area and along the top of the slope of the landfill, prior to construction. The silt fence will be trenched in approximately 6" deep using a walk behind trencher. Following the installation of the fence the trench will be manually backfilled. The approximate location of silt fencing is depicted on Drawings 3A and 3B of the EDR. The details of silt fence are provided on Drawing 8 of the EDR.
3.1.1.2 Turbidity Curtain A turbidity curtain will be installed in the Delaware River along the south/western edge of the landfill. The curtain will enter the river upstream of the construction, at approximate location Sta. 15-1-40 to 15-1-60, and extend downstream past the construction area, approximate location Sta. 3-i-20, as shown on Drawings 3A and 3B (Site Preparation Plan) of the EDR. The turbidity curtain will be installed in accordance with the details provided on Drawing 6B of the EDR (see Details 6A-6C).
In accordance with USEPA letter dated March 5, 2007,"the appropriate river authorities must be notified before installation of the turbidity curtain and marker buoys." The Site Superintendent will be provided with the specific contact information for proper notification of turbidity curtain installation activities. The information to be provided will include at a minimum, the location, installation dates and duration of turbidity installation,
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including marker buoys. The identification and notification of "river authorities" will be coordinated with EPA and will, include public notification of local fishing, boating and canoe clubs and/or other river agencies.
The turbidity curtain system will consist of two main elements:
1. For river flow diversion, a silt-dam constructed of an adjustable and permeable turbidity curtain measuring 7' deep, complete with 6" closed cell foam buoys and ballast chain, will be installed at the upstream end of the project area.
2. For containment, an adjustable and impermeable turbidity curtain measuring 7' deep, complete with 6" closed cell foam buoys and ballast chain, will be installed along the entire project area.
Steel T posts will be driven into the river bottom every 20'. Pipe, measuring 2" in diameter and approximately 8' long, will be placed on the steel'T' posts. A 5/16" stainless steel cable will be run through the curtains. Stainless steel 'snap clips' will secure the curtain to the pipes.
Upstream and downstream of the turbidity curtains marker buoys will be placed. These buoys will be held in place with a fluke style river anchor and 7' of chain. Each buoy will be equipped with a hazard warning sign and light.
Along the curtain white, flashing, photosensitive marker lights will be installed every 75'.
The initial step in turbidity curtain installation will be the placement of the marker buoys upstream and downstream of the work location. These buoys will be manually placed by personnel equipped with waders and all appropriate safety equipment. Specific personal protective equipment (PPE) requirements are provided in the HASP. Based on the current, depth to water, and river conditions at the time, a boat may be utilized for turbidity curtain and marker buoy deployment. Refer to the HASP for additional boat safety measures.
The steel T posts will be driven into the river bottom using a pneumatic driver. Personnel, equipped with all appropriate safety equipment, will enter the river in waders to deploy the T posts. Should the depth of the river prohibit this operation, a pontoon boat will be brought to the site, thereby allowing personnel to stand on the deck and drive the posts.
The curtain cabling will then be installed on the curtain. As the curtains are deployed, from the upstream end of the river working downstream, the curtain will be secured to the 2" pipes.
The maker lights will then be placed along the turbidity curtain on top of the 2" pipes. See Section 7.0 Contingency Plan of this Work Plan for contingency measures to address turbidity curtain installation during a potential major flood event.
3.1.2 Dust Control Measures Primary dust control measures will be addressed through the installation of the temporary'stone access roads and tracking pads which will limit the amount of dust generated due lo vehicle movement. Also, deliveries to the site will be made to outside the designated zones further reducing on-site traffic. If visual observations indicate that dust is an issue and secondary dust suppression measures may be needed, a water spray will be applied from a water truck or temporary water storage tank to minimize ambient dust levels. A pressurized water pump can be utilized to suppress dust levels in the immediate excavation/waste handling areas as needed. A 20,000 gallon frac tank will be mobilized to the site for dust control and decontamination operations. The water within the tank will be non-potable. Additional dust monitoring measures are covered in the HASP. ENSR will have dust monitors on site and will conduct dust monitoring as deemed necessary by the SSO based on site activities and site conditions.
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3.1.3 Site Clearing Operations Site clearing operations consist of tree and brush removal as well as vegetation removal. FJOC will work with EPA in the field during the course of construction to minimize impacts to surrounding habitat and removal of trees without jeopardizing the wall's structural integrity. Site clearing operations will conform to Section 02100 (Clearing and Grubbing) Construction and Material Specifications provided in Appendix 5 of the EDR. Additional construction details are provided on Drawings 3A and 3B, Sheets 4 and 5 of 13 (Site Preparation Plan) of the EDR.
3.1.3.1 Tree Removal Tree removal will be conducted by using a hydraulic shear attached to an excavator as well as with chain saws. The shearing operations will typically be conducted by 'topping' the trees first and then shearing the trunk lower to the ground. In the case where the tree trunks are too large to accommodate the shear opening, the tree trunks will be cut using a chain saw. As the roots of the trees are providing a great arnount of soil stability, the trunks will be cut very close to the ground and the roots left in place. Refer to Drawings 3A and 3B, Sheets 4 and 5 of 13 (Site Preparation Plan) of the EDR.
'.i. • Once on the ground, the trees will be cut into manageable lengths for removal from the work area. Large trunks, limbs, and branches will be transported to a staging area where they will subsequently be chipped using a tub-grinder. Smaller limbs and branches will be chipped in the immediate area of clearing using an 18" chipper.
Areas subject to tree removal include the wall construction work area along the bank of the Delaware River and the wall construction work area along the top of the west slope of the landfill. The top of slope will be cleared to allow the construction of a temporary haul road and subsequent placement of erosion control features in this area.
3.1.3.2 Vegetation Removal To perform the landfill surface drum reconnaissance, vegetation will be removed as directed by EPA. Where necessary, personnel will incorporate the use of weed whips to cut non-woody vegetation from the landfill surface in order to expose any surface drums. As this operation is conducted,.personnel will stake and flag any exposed or partially exposed drums.
3.1.4 Selective Grubbing Operations Selective grubbing operations include the removal of selective tree stumps generated from the tree removal operations. Most stumps and root systems will be left in place as they are providing a great amount of soil stability. Additional construction details are provided on Drawings 3A and 3B, Sheets 4 and 5 of 13 (Site Preparation Plan) of the EDR.
Vegetation and topsoil will be removed where staging areas are constructed. In no case will topsoil removal exceed 6". The topsoil stripped for the material staging area construction will be stockpiled along the south side of the proposed material staging area. At project conclusion this material can be placed over the material staging area and reseeded.
Vegetation existing along the western slope of the landfill will be removed in order to eliminate any 'slip' zone along the landfill face/reinforced wall interface. Any trees, including stumps, within the work area of the western landfill slope.will be removed.
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3.1.4.1 Stump Removal
Selective stump removal operations will be conducted using an excavator and dozer (where required). Once removed, the stumps will be transported to a staging area where large tree trunks/limbs/branches are staged for subsequent tub grinding.
In other cases, where the topography is favorable and root masses will not impede wall construction, the stumps will be ground in place.
3.1.4.2 Vegetation and Topsoil Removal Vegetation and topsoil to be removed for staging area construction will be accomplished using a dozer and end-loader. Materials will be stockpiled adjacent to the work areas. At the conclusion of site activities these materials can be placed back over the staging areas for re-vegetation or left stockpiled.
3.1.4.3 Slope Vegetation Removal
Slope vegetation removal will be accortfplished using an excavator. The operations will be conducted from the top of the west landfill slope. Materials removed from the slope will be placed within, the landfill directly east of the wall construction area.
Where the slope exceeds the reach of the excavator, the machine will be moved to the bottom of the slope and remove remaining vegetation. These materials will be loaded into an off-road truck or end-loader for transportation ahd placement within the landfill directly east of the wall construction area.
3.1.5 Site Security A copy of the site access agreements were provided in Appendix 6 of the July 2006 EDR for reference. Site security will be maintained during the duration of the project to prevent unauthorized entry. All visitors to the site will be expected to sign-in at the construction trailer staged in the Support Zone. All materials deliveries will be made outside the Support Zone to reduce the number of vehicles / persons accessing the active portion of the site.
3.1.5.1 Fencing and Signage Existing site security fencing will be inspected during site preparation activities to insure all fencing is free of breaches or damage. Repairs will be made immediately. Fencing will be inspected on a daily basis during construction activities. Signage will be installed on the fence fabric for notification purposes. Additional signage will be installed on the existing fencing and/or on trees along the water's edge where there is only partial fencing. Site security plans are presented on Drawings 2A and 2B of the EDR. Additional fencing specifications are provided on Drawings 3A and 3B, Sheets 4 and 5 of 13 (Site Preparation Plan) of EDR.
3.1.6 Well Abandonment Select monitoring well and piezometers will be abandoned by a well driller licensed in the State of New Jersey prior to the start of wall construction activities in accordance with NJAC 7:9D as specified on Drawing 3A, Sheet 4 of 13 (Site Preparation Plan) of the EDR.
3.1.6.1 Abandonment of Monitoring Wells and Piezometers A well driller licensed in the State of New Jersey will abandon select groundwater monitoring wells and piezometers prior to the start of the wall construction activities. All well and piezometer abandonment activities
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will be conducted in accordance with applicable NJDEP requirements. No overdrilling is anticipated, in general an attempt will be made to pull out the casing. In the event that the casing can not be removed then the casing will be cut at the ground surface and grouted to the surface. Well abandonment procedures are detailed in NJDEP Chapter 9D - Well Construction and Maintenance; Sealing of Abandoned Wells (NJAC 7:9D) that is provided under a separate Appendix F of the Work Plan with a tab entitled "Well Abandonment."
3.2 infra-Structure Construction Infra-structure construction includes; material staging area, fence modifications, temporary haul roads, drum/waste sampling pad and the drum/waste storage pad. Construction specifications for Site Preparation Plan are provided on Drawings 3A and 3B (Site Preparation Plan), Sheets 4 and 5 of 13, of the EDR.
3.2.1 Material Staging Area
A material staging area is to be constructed directly south of the current location of the site trailer. This area will encompass approximately 1 acre and be located outside of the existing site fence.
Once grubbing operations are complete, as specified in Section 4.1.3, an 8 oz. geotextile fabric wiil be placed on the prepared sub-grade. The fabric will then be covered with a 1' layer of 1 Vi' quarry stone. Refer to Drawing 3B (Site Preparation Plan) and Detail 4 on Drawing 7 of the EDR.
3.2.2 Fence Modifications Truck traffic will be routed into the northeast corner of the newly constructed material staging area. Materials will be dropped in this area and stockpiled for subsequent movement into the site. A gate will be installed in the site fence near the northwest corner of the material staging area. During the course of field operations this will allow the material transportation equipment to remain in the exclusion zone. Equipment working in the materials staging area will remain in the 'clean' zorie throughout materials loading operations. This operation will eliminate the need to decontaminate material transportation equipment that would otherwise enter the materials staging area during loading operations. To prevent theft of materials from the site, additional security fencing around the materials staging area may be installed. The fencing would follow the same specification as the site perimeter fence.
3.2.3 Temporary Haul Road Construction, Tracking Pad, and Access Road Improvements
A temporary haul road for construction access will be constructed along the top of the west slope of the landfill. The road will serve as a stable base to operate heavy equipment as well as to transport materials into the job site. This roadway will extend from the main east/west access road, (coming from the support zone and into the site), to the north tying into the existing site roadways at the northwest corner of the landfill.
The temporary haul road will be constructed by preparing a somewhat level sub-grade using a dozer, (should drums be encountered during this operation please refer to the drum management practices descried in the SAP, provided in Appendix B. An 8 oz. geotextile fabric will be placed on the prepared sub-grade. Geotextile installation will conform to Section 02282 (Geotextile) Construction and Material Specifications provided in Appendix 5 of the EDR. The fabric will then be covered with a 1' layer of 1 V-i' quarry stone. It is estimated that this road will be approximately 1,000' long and 20',wide. The stormwater/backwash swale will ultimately be constructed over the temporary haul road (refer to Drawings 4A and 4B, Wall Alignment and Construction Plan of the EDR.
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/ A stone tracking pad will be installed directly west of the support zone. It will consist of a 12" thick layer of 2"- 4" clean stone as shown on Drawing 3B (Site Preparation Plan) and Detail 4 on Drawing 7 of the EDR. The tracking pad will be used for decontamination purposes and to prevent the tracking of soils off site.
The site access road will be improved, as needed, to maintain easy access to the site and tracking of soil into the support zone. The limits of construction access road(s) will vary based on site conditions and construction requirements (refer to Drawings 3A and 3B (Site Preparation Plan) of the EDR.
3.2.4 Equipment Refueling A double-walled fuel tank, approximately 1,000 gallons capacity, will be placed at the staging area contained within a lined berm. Some equipment will fuel at this tank (e.g., loaders, off-road dump trucks) while excavators and dozers will have the fuel brought to them. Portable fuel tanks to fuel heavy equipment will be utilized on the work site. These portable tanks will be normally in the bed of a pickup truck or in an off-road type vehicle capable of carrying a fuel tank. These vehicles will travel from a designated fuel transfer location to where heavy earth moving equipment is being used in the exclusion zone that needs to be refueled.
The following health and safety precautions will be taken during on-site refueling:
1. Fueling of heavy equipment will require that personnel be in control of the fueling nozzle at all times. The first person will be stationed at the fueling nozzle of the piece of equipment being fueled to control the fueling operation. This person will operate the fueling nozzle and will stop theyflow of fuel into the tank that is being filled when the desired level is reached.
2. The person stationed at the fueling point will be able to visually check the fuel level in the piece of equipment that is being fueled so that fuel does not run over the fueling port on the piece of equipment. Maximum fill heights on the equipment will not be achieved. This is to help prevent any spillage from overflow.
3. Fueling the equipment will also require a second person to stand by the electrical shut off switch for the fuel pump. That person will stop the fuel pump running when the nozzle person has finished putting fuel into the tank. In the event the person in control of the fueling nozzle cannot shut the fueling nozzle off due to equipment malfunction, the secondary person will shut the pump off. In addition, the second person will be responsible to observe the hose, and will immediately shut the pump off if a leak in the hose is observed.
4. A containment tub will be put down under the piece of equipment that is being fueled prior to fueling it. The containment tub will be placed on visqueen sheeting that extends beyond the perimeter of the tub. In the event that fuel should splash or run out of the fueling nozzle, it would run onto and be contained by the containment tub. This precaution will prevent fuel from spilling on to the ground.
5. When fueling of equipment is required, the equipment will be moved as far from the river as practical and positioned so that the fueling port on the equipment is turned toward the river. Placing the fueling port towards the river will allow easier access to clean up a spill that is not contained by the above described controls. This equipment position will result in the fueling port being positioned as far away from the river . as practical and will decrease the possibility of spilled fuel reaching the water's edge.
6. Portable fueling trucks will carry sorbent materials such as oil dry and sorbent pads. In addition, a 20 Ib. fire extinguisher will be within a 50 foot radius of the fueling area. The initial response to any spill will consist of eliminating the cause of the spill.
7. Cleanup operations will commence immediately thereafter, and may consist of any one or more of the following:
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• Deployment of oil dry of other sorbent materials • Using a vacuum tanker to pickup any ponded/pooled products • Deployment of oil boom in the case of a spill that impacts a body of water. The boom would be deployed outside the point of impact. • The boom can then be retrieved to consolidate the spill and commence removal operations. Removal operations could consist of the deployment of absorbent pads or booms as well as the operation of the vacuum tanker. • Impacted cleanup materials, as well as impacted soils or water, will be managed for off-site disposal similar to the management and disposal of investigation-derived wastes.
3.2.5 Drum/Waste Storage and Sampling Pad Construction The drum/waste storage and sampling pad will be constructed in the following manner:
A sub-grade, approximately 7,500 square feet (150' x 50'), will be prepared and leveled. At the perimeter of the sampling pad a 1' berm will be constructed. An 8 oz. geotextile fabric will be placed over the prepared sub-grade and perimeter berm. 40-mil liner will be placed over the geotextile fabric. A second layer of 8 oz. fabric will be placed over the 40-mil liner. A 6" layer of cushion sand will be placed over the 40-mil fabric. A 6" layer of road gravel will be placed over the cushion. The location of the drum and waste storage and sampling pad is depicted on Drawing 3B (Site Preparation Plan) of the EDR. Drum and waste storage and sampling pad construction specifications are provided on Drawing 7, Detail 5 of the EDR. Actual dimensions will be dictated by site conditions. The drum pad is situated on higher ground approximately 200-feet inland of the top of bank. The drum storage pad can be equipped with a small soil berm encased in geotextile to decrease the drum pad flooding potential. Please refer to the drum and waste management work practices provided in the SAP in Appendix B.
3.3 Construction Trailer A construction trailer(s) will be utilized during on-site activities. The construction trailer and sanitary (restroom) facilities will be situated within the facility fencing within the Support Zone.
3.4 Decontamination
Decontamination operations will be conducted throughout all project operations. It is the intent to minimize equipment decontamination operations through efficient scheduling and implementation techniques. The materials staging area is situated outside the work zone outside the fencing to reduce the number of trucks requiring decontamination.
Water suppiy for decontamination will be provided by a water truck or other water storage containers or tanks staged adjacent to the decontamination pad installed as described below in Section 3.4.2.
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3.4.1 Personnel Decontamination
Personnel will don safety equipment commensurate with the site HASP provided in Appendix D. During all field operations personnel will pass through the contamination reduction zone while entering or exiting the exclusion zone. The contamination reduction zone (CRZ) will include the following components:
• Trash containers for disposal safety garments • Overboots will be removed prior to entering the CRZ, as a result, decontamination tubs and brushes may not be necessary
• A table for safety equipment and accessories The contamination reduction zone will be cordoned off with orange, temporary security fence and underlain with road gravel.
Personnel decontamination will be conducted in accordance with the HASP. Decontamination procedures may be modified with the consent of the EPA OSC. All personnel decontamination will occur in the decontamination areas set-up within the CRZ. At a minimum, gross contartiination for Level D will include:
1. Remove overboots prior to entering CRZ, or discard disposable booties or Wash/Rinse outer boot
2. Remove and discard outer PPE (tyvek)
3. Remove and discard outer PPE glove
4. Remove respirator (dispose of cartridges), if applicable
5. Wash/Rinse respirator and hang to dry
6. Rinse/Dry hard hat
7. Remove inner (later) PPE gloves
Decontamination fluids will be repackaged in 55-gallon, USDOT approved drums and shipped off site for disposal following any waste characterization analysis required by the receiving transportation and disposal facility (TSDF). All used PPE will be bagged for subsequent off-site disposal in the same manner as all Investigation-Derived Wastes.
3.4.2 Equipment Decontamination
An equipment decontamination pad will be constructed within the exclusion zone. All equipment will undergo thorough decontamination (i.e., dry and wet) prior to exit from the exclusion zone. Equipment decontamination pad construction will consist of the following:
Approximately 20' x 20' pad area A 2' x 2' sump will be constructed in one corner of the pad The prepared sub-grade will be covered with a 40 mil HDPE liner. 6" layer of sand over the 40 mil liner Timbers for tracked equipment to move in and across the pad
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Equipment will enter the decontamination pad traversing across the timbers. Once on the pad.the equipment will be decontaminated using a steam cleaner. All water collected in the sump will be pumped into 55-gallon, US Department of Transportation (USDOT) approved drums and shipped off-site for disposal following any waste characterization analysis required by the receiving TSDF. The size of the decon pad may vary dependent upon the size and number of vehicles and may be enlarged to accommodate more vehicles. Equipment repairs will be performed by 40-hour trained personnel equipped with the proper PPE or after full decontamination of equipment.
At the conclusion of equipment decontamination operations, the pad will be removed. The sand and liner will be shipped off site for disposal following any waste characterization analysis required by the receiving TSDF.
3.4.3 Sampling Equipment Decontamination
Sampling equipment decontarnination is described in the SAP, provided as Appendix B.
3.5 Drum Handling and Removal The entire surface of the landfill will be inspected for drums. Any drums at the surface or partially buried drums, will be removed throughout the entire landfill area. The drum handling scope of work will address the standard . operating procedure, (SOP), when drurns are encountered throughout the execution of this project, including but not limited to, those discussed in Section 5.0 of this Work Plan. Drum reconnaissance, inspection and drum opening activities are further discussed in Section 2.0 (Drum Screening) of the SAP. In general, the drums that could be encountered throughout the course of this project will be treated as unknowns. Some information relative to the types of wastes and characterization of waste materials present within the landfill is provided in a Woodward Clyde report dated August 1992 and provides information relative to surface drums previously removed from the site. Specifically, organic compounds such as methyl ethyl ketone present the greater risk to exposure. Throughout the execution of field operations any drums encountered will be assumed to carry the greater risk until proven otherwise.
The hazards associated with drum handling operations may include chemical hazards associated with the compounds present such as (1) fire and explosion, (2) exposure by inhalation and/or (3) exposure through skin, contact. Including and in addition to the hazards addressed in the HASP, physical hazards associated with drum handling include (1) drum pressurization and the release of contents during puncture or removal of tops . or bungs, (2) sharp edges from damaged drums, tops and rings, and (3) pinch points while handling drums in close proximity to other drums or objects.
3.5.1 Hazard Identification Any drum encountered will be handled as an unknown with any variable present. In general, some drum construction generalizations can be made:
Steel drums usually held oils, flammables or toxics. Seldom did these drums contain corrosive liquids. Stainless steel drums typically contained corrosive liquids Plastic drums were typically used to contain dilute concentrations of corrosive liquids Fiber (cardboard) drums typically contained solids , ' Bulging Drums • ' . - Could contain or could have contained frozen material. - Could be pressurized or at one time been pressurized. - Are or have been under pressure due to a chemical reaction.
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3.5.2 Abandoned Cylinders Abandoned cylinders (that are intact) will be flagged and located via GPS during the drum reconnaissance operations. A sub-contractor specializing in reactive/explosive wastes and gas cylinders will be contracted to remove said materials. Various techniques are employed in dealing with such wastes including on-site treatment.
A cylinder with unknown contents and/or at an unknown pressure presents a variety of hazards including, but not limited to: compressed gas, flammable, corrosive, oxidizer, pyrophoric, toxic. These hazards result in: high pressure release, fire, explosion, fuming gas, release of toxic gas. If it is determined, by a trained technician, that it would be unsafe to manually operate the main cylinder valve, it will be necessary to perform a remote cylinder opening. Safe distance for cylinder handling will be dependent upon the cylinder contents and/or size and the site condition. Appropriate measures for dealing with abandoned cylinders are included in the appendix with the SOPs. PPE will be determined by cylinder contents or if contents are unknown, will be based on the highest possible hazards, as will be dictated by the HASP.
3.5.3 Drum Handling Soil excavation operations wil| be conducted using a hydraulic excavator equipped with a toothed bucket. In order to carefully expose buried drums, excavation operations will be conducted in 6" lifts. Should a drum(s) become exposed, a second excavator equipped with a barrel grapple will remove the drum from the excavation area. Any drum recovered whole or partial drums with material contained within them will be placed directly into a salvage drum. A supply of overpack drums will be readily available for use in overpacking drums of varying sizes and shapes. Severely bent or dented drums are generally not suitable for overpacking, and drum contents will be transferred into a new container. Drums may be placed on pallets for easy transfer within the storage area.
Any material spilled from drums during removal, i.e., liquids, discolored solid product, etc., will be collected and contained. All drum markings and/or labels must be recorded and photographed, as is consistent with the referenced guidance document and EPA-ERT Drum Trak/Drum Pad Software available through the ERT website. A copy of the drum log/tracking sheet is attached at the end of this section of the Work Plan.
Drum remnants and empty drums will be stockpiled close to the excavation area and subsequently transported to the staging area for off-site disposal/recycling. This technique will be used to handle surface drums found during the landfill reconnaissance.
3.5.4 Drum Management In general the following drum management guidelines will apply or as othenwise addressed in the HASP. During intra-site drum transportation, salvage drums containing whole or partial drums with waste will be transported to the drum sampling pad using a skid steer or end-loader. Following drum sampling and field characterization, drums will be (1) removed from salvage drums and bulked with like wastes; or (2) remain in the salvage drums, be numbered and placed on the drum storage pad discussed below.
3.6 Wall Zone Sub-Grade Preparation The following details the operations required to prepare a stable sub-grade for the reinforced wall construction. FJOC will work with EPA in the field during the course of construction to minimize fill in the floodplain without jeopardizing the wall's structural integrity or the objective of the wall. Additional construction details are provided on Drawings 3A and 3B (Site Preparation Plan), Drawings 4A and 4B, (Wall Alignment and Construction Plan) of the EDR. Cross-sectional details and wall elevations are provided on Drawing 5 (Elevations and Cross-Sectional Details Plan) of the EDR. Existing and proposed cross-sections are provided
J:\Project\Georgia-Pacific\03060-062 MilfordCV 3-10 • Anril 2007 Landfill\WorkPlan\FINAL-April200AENSRWorkPlan-CVLandfill- P uu FINAL-4192007.doc ' , - ENSR on Drawings 6A-6C of the EDR. Any proposed revisions or changes to the Wall Alignments and Construction Plans will be submitted in writing to EPA for approval prior to implementation.
3.6.1 Excavation In order to accommodate a smooth linear transition of the existing slopes to the new surface of the reinforced wall, excavation of existing soils will be required. Soils at the base of the slope will be excavated in preparation for the foundation of the wall. These excavated soils will be placed in the fill areas, located directly behind the reinforced zone of the wall. Should drums/waste be encountered, they will be handled in accordance with the drum/waste management practices described in the SAP, provided in Appendix B. All materials excavated and subsequently placed for fill will be graded and compacted using a vibratory roller.
3.6.2 Sub-Grade Preparation
The sub-grade for the reinforced wall will be prepared in two methods; they consist of: (1) Existing Sub-Grade Preparation, and (2) Select Aggregate Placement.
3.6.2.1 Existing Sub-Grade Preparation
The current base elevation varies throughout the length of the wall construction area. Sub-grade elevations proposed in the specifications will require varying degrees of cuts and fills. Anywhere that a cut is proposed, the cut material will be transported to a suitable location behind the proposed wall where it will be placed and compacted.
When establishing the sub-grade, an excavator and/or dozer will be used to perform the cuts. Off-road trucks will be used to transport the cut materials to the proposed fill locations. A dozer and compactor wiil be used to place and compact any cut materials within the proposed fill areas.
3.6.2.2 Select Aggregate Placement
A select aggregate fill, clean 1 1/2" stone, will be placed from Sta. 13+75 (approx) to Sta. 4-1-75 (approx). The stone will be installed to a base elevation of 116 before starting the placement of the geoweb.
This material will be transported into the work area using off-road dump trucks and placed using a dozer.
3.6.2.3 Sub-Grade Scour Protection
Sub-grade scour protection consists of two distinct operations:
Excavation
A toe trench will be excavated along the extent of the wall construction zone from Sta. 4+75 to Sta. 14+00. This trench will range in depth from 2' to 5' below native and competent soils for anchoring purposes. This excavation will be accomplished using an excavator. All materials removed from the excavation will be transported to and placed in the wall fill areas.
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Wall Scour Protection
The specifications call for two types of wall scour protection. Installation of stone riprap will conform to Section 02271 (Riprap) Construction and Material Specifications provided in Appendix 5 of the EDR.
1. From location 4+75 to location 10+00 the scour protection will consist of the following components:
a. A geosynthetic filter fabric will be placed on the prepared toe trench sub-grade. b. A 6" layer of Vi" to 1 Vi' filter aggregate will be placed over the fabric using an excavator and fine graded with general labor. c. The riverside edge of the geosynthetic fabric will be wrapped over the riverside edge of the filter aggregate and anchored by the next layer of imported material. d. An 18" layer of max. 12" diameter stone will be placed over the filter fabric. This material will be placed with an excavator and moved into place at select locations by general labor.
2, From location 10+00 to location 14+00 the scour protection will consist of the following components:
a. A geosynthetic filter fabric will be placed on the prepared toe trench sub-grade. b. A 6" layer of !4" to 1 Vi' filter aggregate will be placed over the fabric using an excavator and fine graded with general labor. c. The riverside edge of the geosynthetic fabric will be wrapped over the riverside edge of the filter aggregate and anchored by the next layer of imported material. d. An 18" layer of max. 12" diameter stone will be placed over the filter fabric and filter aggregate. This material will be placed with an excavator while general labor moves the stone into place at select locations. e. A 36" layer of max. 24" diameter stone will be placed over the max. 12" stone. The material will be placed with an excavator equipped with a grapple. All materials in this phase of work will be delivered to the material staging area. The materials will be re loaded into off-road dump trucks using an end-loader. The off-road dump trucks will deliver the materials to the work area for subsequent placement operations.
} 3.7 Geo-Web Reinforced Wall Construction
The GeoWeb reinforced wall will consist of five distinct components:
A Geogrid reinforcement The Geoweb fascia Reinforced soil zone Placement of general fill behind reinforced soil zone Wall scour protection
Specific construction details are provided on Drawings 4A and 4B, of the Wall Alignment and Construction Plan and on Drawing 5, of the Wall Elevation and Cross Sections Plan in the EDR.
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3.7.1 Geo-Grid Placement The Geogrid reinforcement will be manually placed under the Gebweb fascia and extended under the reinforced wall zone. The Geogrid will be staked, or weighted, in place during the deployment of the Geoweb fascia and the select fill in the soil reinforced zone. Geogrid fabric installation will conform to Section 02417 (Geogrid Fabric Underlayment) Construction and Material Specifications provided in Appendix 5 of the EDR.
3.7.2 Geo-Web Construction and Filling
The Geoweb will be expanded over a stretcher frame. The stretcher frame will be placed, with the threaded rod dowels pointed down, on the Geogrid. Deployed sections of Geoweb will be stapled together at the tabs located at each end of the Geoweb sections. The deployed Geogrid sections will then be filled with a select aggregate fill mixed with topsoil. The select aggregate fill will consist of a 2" x 4" clean stone. The Geoweb cells will be overfilled by approximately 2" to accommodate compaction. Once compaction operations are complete the Geoweb will be leveled using a simple screed. Installation of the of the Geocell retaining wall and slope protection system will conform to Section 02710 (Geocell System) Constructiori and Material Specifications provided in Appendix 5 of the EDR.
Geoweb filling operations will be conducted using an excavator. Materials will be delivered to the wall construction location using off-road dump trucks. The material will be compacted using a small vibrating roller. The cells will be leveled using a 2"x4" board being moved across the Geoweb cells similar to a concrete screed.
During the Geoweb installation, site restoration and erosion control methods will be deployed. The Geoweb fascia section at elevation 118.5 will be underlain with a geotextile fabric. The geotextile fabric will run under this layer of Geoweb and behind the overlying Geoweb layers to prevent the filtration of topsoil and seed into the clean stone. Grass seed and a flexible growth membrane will be applied to the fascia using mechanical methods from the top of the landfill and will conform to Section 02925 (Flexible Growth Medium) Construction and Material Specifications provided in Appendix 5 of the EDR.
3.7.3 Reinforced Wall Zone Construction As the Geoweb fascia is placed, the reinforced soil zone will be constructed in 6" lifts. A clean 1 1/2" stone will be used to provide stability and drainage behind the wall. These materials will be transported into the construction area using off-road dump trucks. The stone will then be placed with an excavator and graded using a small dozer. Each lift will be compacted using a vibratory roller.
3.8 Drum and Waste Removal The time-critical actions to be implemented at the Crown Vantage landfill pursuant to the AOC will also include the performance of a search across the entire surface of the landfill to identify, retrieve, and dispose of any exposed drums, containers and/or pails and their contents that are present above the ground surface in order to minimize direct contact threats with these materials.
3.8.1 Container Search A container search will be conducted across the surface of the landfill (including the face in order to identify, retrieve, and dispose of any drums, containers, pails and their contents that are present or partially present above the ground surface of the landfill. All retrieved material (e.g., drums, containers, pails) shall be identified, categorized, and addressed in accordance with the AOC as presented in the SAP provided in Appendix B. Appropriate analysis and sampling methods will be utilized for the categorization of any waste material identified and retrieved during the removal actions for subsequent off-site disposal.
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3.8.2 Drum Removal and Sampling Drum removal and sampling activities are discussed in the Sampling and Analysis Plan provided in Appendix B. Various types of solid waste (paper rolls, paper and foil trimmings, brick, concrete, and other miscellaneous construction debris and trash) may be excavated from the landfill during site preparation and soil excavation activities. As discussed above under excavation and sub-grade preparation, where possible all materials removed from the excavation will be transported to and placed in the wall fill areas. If any solid waste (e.g., large paper rolls, large pieces of metal debris) is deemed unsuitable for placement with excavated soils in fill areas located directly behind the reinforced zone of the wall, the excavated solid waste deemed unsuitable for fill will be staged in a designated waste staging area for either subsequent reuse as fill material to be placed on top of the landfill or sent off-site to a permitted disposal facility.
3.8.3 Transportation and Disposal All containerized and non-containerized wastes retrieved from the landfill surface that are characterized and sampled for off-site disposal will be disposed of in accordance with the AOC as described in the Transportation and Disposal Plan provided in Appendix C. EPA will be notified of the names and addresses of all off-site waste treatment, storage, or disposal facilities selected by FJOC to receive wastes from the site, and notification will be provided to EPA at least five days prior to off-site shipment of such wastes for EPA approval in accordance with the AOC.
3.8.3.1 Waste Management The proposed removal action at the Crown Vantage Landfill site may potentially include the off-site management or disposal of materials (e.g., soils, drums, etc.). The potential exists that the materials for off- site management or disposal may be classified as a Resource Conservation and Recovery Act (RCRA) waste. 40 CFR Part 262 contains the federal standards for RCRA, and New Jersey has been delegated the authority to administer these standards through its state hazardous waste management regulations (Refer to NJAC 7:26). To determine the applicability of RCRA, any materials removed from the landfill for off-site management or disposal would be analyzed by the Toxicity Characteristic Leaching Procedure (TCLP) to determine whether they are characteristic hazardous waste under RCRA. Wastes that are determined to exceed TCLP allowable concentrations (and therefore be hazardous), would be disposed or managed off-site in a RCRA Subtitle C or state-equivalent Treatment, Storage, or Disposal Facility (TSDF). Wastes that are determined to be below TCLP allowable concentrations (and therefore nonhazardous), would be disposed or managed off site in a RCRA Subtitle D or state-equivalent TSDF.
The potential also exists that the materials for off-site management or disposal may be classified under the Toxic7 Substance and Control Act (TSCA) as poly-chlorinated biphenyl (PCB) remediation waste. 40 CFR Part 761 contains the federal standards for TSCA. According to the USEPA guidance document "Remedial Actions for Superfund Sites with PCB Contamination" (EPA 1990), TSCA does not apply to PCBs with concentrations less than 50 milligrams per kilogram (mg/kg) or parts per million (ppm). To determine the applicability of TSCA, any materials removed from the landfill for off-site management or disposal would be analyzed for PCBs. If concentrations exceed 50 ppm, the materials would be disposed or managed off site under TSCA.
Further, if materials are transported off site, the regulations contained in 49 CFR Parts 171-179, which establish the procedures for packaging, labeling, and transporting hazardous materials, would apply. Materials for off-site disposal or management would be packaged in accordance with these regulations.
Finally, EPA's Guidance Document for Cleanup of Surface Tank and Drum Sites (May 1985) and Drum Handling Practices at Hazardous Waste Sites (Jan. 1986) provide guidance for the removal and management of drums. On-site drum handling practices will comply with these EPA guidelines, and such practices will be incorporated into the Sampling and Analysis Plan developed for the proposed removal action.
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3.8.3.2 Site Specific Constituents Site specific constituents have been identified at the Site based on historic sampling results. A list of site specific compounds documented at the sife is provided in "Table 1: Summary of Analytical Results from Soil and Waste Samples Collected at the Crown Vantage Landfill on November 12 and 13, 2003" which was provided in the USEPA Removal Site Evaluation Memorandum dated May 25, 2004. A copy of this document is appended to this work Plan under the tab entitled "EPA Correspondence/Orders." To meet the provisions for all waste steams to be analyzed for the TCL/TAL compounds, plus MCPA and MCPP, which were listed in Table 1 of the EPA Removal Site Evaluation memorandum dated May 24, 2005, but do not appear on the TCL. This constituent list will be incorporated into waste characterization sampling activities to assure that all potential underiying hazardous constituents (UHC's) are properly evaluated as requested by EPA.
Once specific drums have been categorized into separate waste streams, based on waste classification and ' profile sampling for waste disposal facility selection criteria, then a minimum of one (1) sample per waste stream will be collected to adequately characterize TCL volatiles, semivolatiles, pesticides and PCBs and TAL metals and cyanide compounds found at the site. Two herbicides, 2-methyl-4-chlorphenoxyacetic acid [MCPA] and 2-(2-methyl-4-chlorophenoxy)propionic acid [MCPP], will also be analyzed due to their reference in the EPA Removal Site Evaluation memorandum. The frequency and number of samples collected will be dependent upon one or more of the following site specific conditions encountered in the field (e.g., total number of drums encountered, like consistency of the material encountered between individual drums, field screening results, any other visual or measurable waste characterization that results in the identifying of individual drums vyith similar inherent characteristics).
3.9 Stormwater Control Features stormwater features will be installed to protect the wall during overland flow and backwash after flooding events. These features consist of a stone-lined swale at the top of the landfill and a scour protection apron. The proposed stone-lined swale was designed behind the wail for the purposes of diverting stormwater runoff and receding floodwaters away from the face of the wall. The swale will also serve as an access and constmction road for future maintenance purposes.
3.9.1 Top of Slope Stale and Scour Protection Apron
A stone-lined stormwater swale, consisting of 4" size stone will be constructed at the top of slope. The swale vvill be constructed in a trapezoidal shape. The swale will be directed toward the southern end of the wall where a stone-lined apron will be installed for scour protection. The proposed location of the stone-lined stormwater swale is depicted on Drawings 4A and 4B of the EDR.
Soils excavated during the swale construction operation will be placed within the landfill and graded to match existing topography or used as landfill cover. Should drums/waste be encountered they will be handled in accordance with the SAP provided in Appendix B.
The swale will be shaped using an excavator. The swale will then be fine graded using a dozer.
3.10 Site Restoration Site restoration activities will vary throughout the site. Post-remediation restoration activities will be undertaken to remove all machinery, equipment, supplies, and waste materials and to restore the site as close > to pre-remedial conditions as practical. Stone/gravel covered roadways that currently exist at the site will ^ remain in-place so that continued access for site inspections and monitoring can be attained. Final restoration conditions will be subject to EPA approval and will consider the approval of property owners that may be
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The restoration areas include: (1) Geoweb Fascia, (2) Materials Staging Area, and (3) Temporary Haul Roads, Sampling Pad, Storage Pad.
3.10.1 Geoweb Fascia
Geoweb Fascia restoration activities are discussed above in Section 4.4.2 under Geoweb Construction and Filling techniques.
3.10.2 Materials Staging Area The topsoil placed along the south side of the materials staging area will be spread over the gravel placed during the construction of the area-i^^The topsoil will be graded smooth and prepared to receive grass seed. The area will then receive straw mulch that will be crimped in place.
3.10.3 Temporary Haul Roads, Sampling Pad, Storage Pad The temporary haul road, sampling pad and storage pads will be left in place at project conclusion. Any contaminated materials associated with the drum and waste handling operations will be removed from these areas and disposed of off-site in accordance with the drum and waste management plan.
3.10.4 Plantings / Reseeding A wall inspection and maintenance program will be implemented post-construction as discussed in Section 7.0 of the July 2006 EDR. The inspection and maintenance of the wall will be conducted for a period of two years after the completion of the stabilization action and planting of vegetation (i.e., germination of the seed mixture). If an 80-percent survival rate of the vegetation is not achieved two years after the completion of the stabilization, the vegetation will be replanted and maintained for an additional year after an 80-percent survival rate has been achieved as described in the EDR.
3.11 Demobilization Site demobilization activities will begin at the conclusion Of wall installation and slope stabilization measures have been completed in accordance with EPA AOC. Site demobilization activities may commence during or at the conclusion of site restoration activities. During site demobilization, all waste containers will be removed from the site, including but not limited to, drums, roll-offs, totes, etc. A site inspection will be conducted to confirm that all designated wastes, investigation-derived wastes, and bags of non-hazardous trash have been properiy removed from the site. All temporary storage facilities will be removed. When long-term on-site activities have come to a conclusion an arrangement will be made for the removal of all portable sanitary facilities.
A portion of the access road, located immediately adjacent to the support zone, will be stabilized with stone as detailed in the construction drawings of the EDR. The access road to the landfill will be maintained on a regular basis during the course of the construction activities to maintain site accessibility. After completion of construction activities, the stabilized portion of the access road will be replenished with stone, as needed. Other parts of the access road will be returned to pre-existing conditions (i.e, fill in ruts) as reasonably practical. Continued "post-construction" access to the Crown Vantage Landfill property will be necessary to continue the site inspection and monitoring activities as needed by USEPA and other authorized site
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4.0 Health and Safety Plan (HASP)
A site-specific Health and Safety Plan (HASP) has been developed by ENSR provided in Appendix D. It establishes the health and safety procedures required to minimize potential risk to the Consultant, contractors, subcontractors and ENSR personnel involved with the environmental i-emedial actions and investigations at the Crown Vantage Landfill.
The provisions of this HASP apply to Consultarit personnel and subcontractor personnel who may potentially be exposed to safety and/or health hazards related to activities conducted pursuant to the AOC. The implementation of health and safety at this project location will be the shared responsibility of the Consultant Project Manager (PM), the Consultant Regional Health and Safety Manager (RHSM), the Consultant Project Site Safety Officer (SSO) and other Consultant personnel and Consultant's contractors implementing the proposed scope of work.
This HASP has been written to comply with the requirements of OSHA's Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120). All activities covered by this HASP must be conducted in complete compliance with this HASP and with all applicable federal, state, and local health and safety regulations. Personnel covered by this HASP who cannot or will not comply will be excluded from site activities. y
This plan will be distributed to each employee involved with the proposed remedial and investigative activities at the site, including subcontractor employees. Each employee must sign a copy of the attached health and safety plan sign-off sheet. In addition, a copy of this HASP will be provided to the local emergency response services (e.g., police, fire, EMT). Directions to the local hospital are. provided in the HASP.
For the purpose of implementing the proposed remedial actions contained within this Work Plan, no confined space entry will be performed under this scope of work. If confined space entry situations arise during the course of implementing the scope of work, then an on-site hazards analysis will be performed and the site- specific HASP will be revised to cover this activity.
Specific regulatory agency guidance referenced in the AOC includes:
• US Department of Labor, Occupational Safety and Health Administration (OSHA), Code of Federal Regulations, 29 CFR 1910.120, ; • OSHA 29 CFR Part 1910.1200 • OSHA 29CFRPart 1910 and Part 1926. • National Institute for Occupational Safety and Health (NIOSH)/OSHA/US Coast Guard (USCG)/EPA, Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, Publication No. 85-115, 1985.
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5.0 Sampling and Analysis Plan (SAP)
The Sampling and Analysis Plan (SAP) in Appendix B details the methods and procedures during site-specific sampling and data evaluation of sampling activities included in the scope of work, including but not limited to, waste characterization sampling of investigation derived waste, drum characterization sampling, and soil, sediment, groundwater and/or surface water sampling conducted in conjunction with the remedial actions proposed for the site. EPA retains the right to take split samples of all material removed as part of this action.
A separate Quality Assurance Project Plan (QAPP) is provided as discussed below. The SAP will use the procedures set forth in "Test Methods for Evaluating Solid Wastes" ("SW-846"), November 1986 or as updated for sampling and testing. The SAP will also be implemented in accordance with the relevant applicable methods as specified in the following EPA published documents:
• "Guidance Document for Cleanup of Surface Tank and Drum Sites," May 1985
• "Drum Handling Practices at Hazardous Waste Sites," January 1986,
"Characterization of Hazardous Waste Sites - A Methods Manual, Volume I - Site Characterization, and Volume II - Available Sampling Methods, "August 1985 and December 1984.
A full copy of these reference documents will be maintained in a separate binder in the site trailer along with the Work Plan for easy access by all site personnel, on an as needed basis.
5.1 Site Specific Sampling and Analysis \ As discussed above in Section 3.8.3.1-"Waste Management" site specific constituents have been identified at the Site based on historic sampling results. A list of site specific compounds documented at the site is provided in "Table 1: Summary of Analytical Results from Soil and Waste Samples Collected at the Crown Vantage Landfill on November 12 and 13, 2003" was provided in the USEAP Removal Site Evaluation Memorandum dated May 25, 2004. A copy of this document is appended to this Wori< Plan under the tab entitled "EPA Correspondence/Orders." As requested by USEPA, to meet the provisions for all waste steams to be analyzed for the TCL/TAL compounds, plus MCPA and MCPP, which were included iri the EPA Removal Site Evaluation memorandum, this constituent list will be incorporated into waste characterization sampling activities to assure that all potential underiying hazardous constituents (UHC's) are properiy evaluated.
Once specific drums have been categorized into separate waste streams, based on waste classification and profile sampling for waste disposal facility selection criteria, then a minimum of one (1) sample per waste stream will be collected to adequately characterize TCL volatiles, semivolatiles, pesticides and PCBs and TAL metals and cyanide compounds found at the site. Two herbicides, 2-methyl-4-chlorphenoxyacetic acid [MCPA] and 2-(2-methyl-4-chlorophenoxy)propionic acid [MCPP], will also be analyzed due to their reference in the EPA Removal Site Evaluation memorandum. The frequency and number of samples collected will be dependent upon one or more of the following site specific conditions encountered in the field (e.g., total numberof drums encountered, like consistency ofthe material encountered between individual drums, field screening results, any other visual or measurable waste characterization that results in the identifying of individual drums with similar inherent characteristics
5.2 Sample Shipment Guidelines it is anticipated that sample shipment by air and/or over land will be utilized for the shipment of soil, liquid and/or waste samples to laboratories and disposal facilities for waste profiling purposes. As discussed in the SAP under Section 3.11-"Sample Shipment," Department of Transportation (DOT) and/or International Air
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Transport Association (lATA) regulations will be foliowed for sample shipment. ENSR has a well-defined hazardous materials shipping program and follows lATA requirements for all air shipments of hazardous materials. Based on field screening data, ENSR will determine if the samples are hazardous and if so, the appropriate shipping name to assign to the samples (i.e. environmentally hazardous substance, liquid, n.o.s. or flammable liquid n.o.s.). ENSR will ensure that all applicable package marking and labeling requirements are met and will ensure that the proper shipping papers are completed for each shipment. Only ENSR staff that has completed function-specific haz-mat shipping training will be authorized to ship hazardous samples from the site.
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6.0 Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan (QAPP), provided as Appendix E, will be implemented in accordance with the relevant applicable methods as specified in the following EPA published documents:
• "Environmental Response Team Standard Operating Procedures," OSWER Directive Numbers 9360.4-02 through 9360.4-08, • 'Test Methods for Evaluating Solid Wastes," (SW-846), • "EPA Requirements for Quality Assurance Project Pjans - QA/R-5" (EPA/240/B-01/003), March 2001, and • "EPA Guidance for Quality Assurance Project Plans - QA/G-5" (EPA/600/R-98/018), February 1998.
EPA chain of custody procedures will be followed during sampling activities. SW-846 will be used for all sample collection and analysis activities conducted pursuant to the AOC..
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7.0 Contingency Plan
7.1 Responsibilities The SSO has the responsibility of initiating the contingency plan in the event of an accident or emergency. First aid and medical information including, but not limited to the following will be posted in the Support Zone within an easily accessible area for all on-site personnel:
• Site-specific HASP • Names or field personnel trained in first-aid • Map and directions to the local hospital (contained in the HASP) • List of emergency phone numbers for police, fire, EMT, local hazardous materials teams, and National Emergency Response Team.
7.1.1 Personal Injury or Illness In the event of a health related injury or illness that requires more than first aid treatment, the SSO will initiate on-site emergency activities in accordance with Section 11.0 of the HASP (Emergency Response), including the following, as applicable:.
• Contact local emergency response personnel (police, fire, EMT). The SSO or designee must remain on the phone with the 911 operator until the emergency response (police, fire department, EMTs) arrive on the scene. If the injured employee can be moved from the accident area, he or she will be brought back to the CRZ where their PPE can be removed. If the person is suffering from a back or neck injury, the person will not be moved and PPE removal will not be required. The SSO or designee must accompany the injured person to the local hospital if off-site treatment is required. • The SSO must contact the Consultant RHSM and PM as soon as the injured person has been removed from the danger or emergency response personnel have arrived at the scene and the SSO can relinquish immediate care to the responding agency (police, fire, EMT).
7.1.2 Spill or Discharges In the event or a spill or discharge of a hazardous material or oil, immediate steps must be taken to minimize • the migration of the material on the lands or into the waters of the state unless there is an immediate threat to human health and welfare.
Air monitoring of site activities is described in the HASP. The HASP provides air monitoring thresholds anticipated for the scope of work contained within this Work Plan. If air monitoring action levels are exceeded at any time during the normal course of the scope of work, then work activities will cease until air monitoring action levels have fallen below action levels or steps can be taken to effectively reduce the amount of disturbance (e.g., wetting of soils during soil removal activities).
7.1.3 Emergency Response and Notification of Releases In the event of any action, occurrence, or incident during pertormance of the work that causes or threatens a release of waste material or hazardous substances from the site that constitutes an emergency situation or
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may present an immediate threat to public health or the environment, appropriate actions will be taken to minimize, mitigate and/or contain the release or threat as discussed above and in the HASP.
1. Immediate notification shall be made to the(1) EPA OSC, or if unavaiiabie, (2) the Chief of the Removal Action Branch of the Emergency and Remedial Response Division of EPA, Region 2 at (732)321-6658.
2. in the event of any release of a hazardous substance from the site, immediate notification shall aiso be made to the National Response Center at (800) 424-8802.
3. New Jersey Department of Environmentai Protection (NJDEP) Toil-Free Hotiine for Reporting Spiiis and Emergencies 1-877-WARNDEP (1-877-927-6337), has been estabiished for reporting spills, hazardous discharges and other environmental emergencies.
7.1.4 Chain of Command The chain of command for reporting spills, hazardous discharges and other environmental emergencies and incidents will be the following, unless othervvise directed by the OSC:
1. The Site Supervisor (SS) or Site Safety Officer (SSO) will notify the EPA OSC, if on site, then contact the PC
2. If EPA OSC is not on site, SS/SSO needs to notify the PC, then make notifications to (1) EPA, (2) NRC and (3) NJDEP.
7.1.5 Emergency Response Plan This section of the Work Plan addresses site implementation measures in order to be prepared in the event of a major flood event after mobilization of equipment. Precautionary measures to be implemented will include the following, at a minimum: (1) staging and storage of heavy equipment and machinery on high ground at the end of each work day (i.e., at the end of each work day, heavy equipment, and machinery will be moved to a designated area of higher elevation); and (2) placement of fuel containers, exhumed waste materials designated for off-site disposal, waste storage pads, delivery areas, on portions of site outside the 10-year flood line to the extent that it is reasonably practicable.
On-site Spill Response
All incidental spills due to the potential spilling or leaking of drummed contents, or improper refueling of site equipment is anticipated to be limited in quantity and capable of being contained on-site prior to reaching any nearby waterways, the river or any off-site areas (outside the landfill limits). Refueling activities are described in the Work Plan Section 3.2.4-Equipment Refueling. Emergency response equipment, including but not limited to, spill kits, absorbent pads, sorbent materials, drums, shovels, sand bags, and other materials to contain small spills will be made readily available and staged in a centrally localized area of the site for easy access.
To address potential discharges to the water, floating booms will be installed in the river, in similar fashion to the turbidity curtain, for the purpose of containing any potential releases to the water. As a precaution, an 8" sorbent boom can be placed within the curtain at the time of deployment of the curtain and maintained throughout the project. Small spills, 100 gallons or less, that reach the water but are contained within the curtain can be managed by the Contractor. Ih addition to the spill kits, a small, portable vacuum tanker mounted on a tractor can be provided to readily clean-up small spills where sorbents are not efficient. In the case of a small water borne spill. Contractor can deploy this equipment for small skimming operations.
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Vacuum tanker service is within 2 hours if required through a local vendor. Larger spills that reach the water, outside the curtain, will require the enlistment of a spill response contractor.
Any large releases to the water surface will be remediated in a timely fashion by a contractor that specializes in cleaning up spills on water. FJOC has a national contract with a spill response company for emergency response with an estimated response time of 1-hour (1.5- to 2-hours on the weekend). A list of the specific 24- hour emergency response cleanup contractors that specialize in the cleanup of spills on water surfaces covered under this contract can be provided.
Contingency Measures for Turbiditv Curtain during Maior Flood Event
The on-site engineer and site superintendent will determine whether the curtains will be removed or relocated, based on the predicted severity of the impacts at the site from the storm/flood. Weather forecasts will be obtained from the weather services identified above in an effort to forecast the predicted severity. Therefore, •this determination will be made based on the predicted severity (i.e, rainfall amount, wind speeds) of the storm, the amount of time to respond to addressing the curtains before the storm/flood, and the potential hazards (i.e, lightning, fast moving water) at the time of removing or resituating the curtains. The on-site Site Safety Officer, with the support of the Consultant Regional Health & Safety Manager (RHSM) will be consulted to determine whether this task can be accomplished without jeopardizing safety of the workers addressing the curtains.
A major storm event may be characterized by one of the following:
A storm event that results in the rise of the Delaware River water levels to a point beyond the mid-way mark along the western slope of the landfill face (estimated 120 feet above mean sea level NGVD)
A storm event egual to or exceeding the magnitude of the following Flood Categories (in feet) for the Delaware River at Frenchtown^:
Delaware River Flood Stabe ® Frenchtown • i'Feet abo*e Datum;99.9' \ ^-i' i-
Major Flood Stage 20
Moderate Flood Stage 18
Flood Stage 16
Action Stage 14
A storm event equal or exceeding the magnitude of the following historical crests:
Historical Crests (1) 27.79 ft on 1955/08/20 (2) 24.40 ft on 1903/10/10 (3) 23.60 ft on 2005/04/4
^ Gauge reading only collected at the Delaware Joint Bridge and Toll Commission at the Frenchtown station in high-water situations. Gauge reading only in high-water situations, but are recorded when the water level reaches Action Stage.
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(4) 23.40 ft on 2006/06/29 (5) 21.93 ft on 1936/03/19 (6) 21.70 ft on 1936/03/13 (7) 20.70 ft on 2004/09/19 (8) 18.60 ft on 1942/05/24 (9) 17.30 ft on 1952/12/12 (10) 15.75 ft on 1973/06/30.
Emergency Recognition and Preventative Measures
This section presents resources that can be accessed for local area gauging and monitoring of the Delaware River. Current Watches, Warnings and Advisories for New Jersey are issued by the National Weather Service http://www.weather.qov/alerts/. This web page contains watches, warnings and advisories that are in effect for New Jersey and the file is usually updated about every two minutes. Current flooding, outlooks, hydrologic conditions, flood statements, watches and warnings are continually updated. The Advanced Hydrologic Prediction Services (AHPS) is a web-based compilation of hydrologic and precipitation monitoring data provided with forecasts of the magnitude and uncertainty of occurrence of floods or droughts, monitor the flood stage of local rivers,, and enable "individuals to make more informed decisions about risk based policies and actions to mitigate the dangers posed by floods and droughts." http://newweb.erh.noaa.qov/ahps2/index.php?wfo=phi Current conditions are also available from National Weather Service website http://www.erh.noaa.qov/er/phi/. The Crown Vantage Landfill is situated within the Philadephia/Mount Holly (PHI) National Weather Service monitoring station. Upstream Delaware River conditions, which can give a good idea of pending snow melt, dam releases and upstream flooding potential and actual locations where flooding is occurring is available from the National Weather Service, Binghampton, NY (BMG) station at http://www.erh.noaa.qov/er/bmq/.
In addition, emergency response eguipment, including but not limit to, spill kits, absorbent pads, shovels, sand bags, and other materials to contain small spills will be made readily available and staged in a centrally localized area of the site for easy access. To address potential discharges, absorbent booms will be staged on site that can be readily deployed.
Pre-Emergency Planning and Coordination with Outside Parties
Prior to initiating on-site activities, the local emergency response and fire department capabilities will be determined in the event of a large spill or discharge event of the magnitude that cannot be easily contained utilizing on-site measures and has the potential to migrate outside the landfill limits.
Evacuation routes and procedures are currently addressed in the HASP. In the event of a flood event that covers all or a portion of the western face of the landfill, heavy eguipment, vehicles, containers and other equipment will be moved to higher ground (on the eastern portion of the landfill limits) if the river levels have not yet peaked. The above website will be consulted for anticipated river conditions, flood watches and weather advisories.
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8.0 Treatability Studies
No treatability studies are anticipated to be required to execute the scope of work contained within this Work Plan.
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9.0 Applicable or Relevant and Appropriate Requirements (ARARs)
As discussed in Appendix 7 of the July 2006 EDR, applicable or relevant and appropriate requirements (ARARs) for conducting the removal action have been reviewed, although as per USEPA's "Superfund Removal Procedures, Guidance on Consideration of ARARs during Removal Actions" (EPA/540/P-91/011, August 1991), CERCLA does not require removal actions to comply with ARARs. The National Contingency Plan requires ori-site removal actions to identify and comply with federal and state ARARs to the extent practicable, considering the urgency of the situation and the scope of the action to be taken. The, ARARs considered for the Crown Vantage Landfill Slope Stabilization Measures are summarized in the Summary of Substantive Requirements (SRD), provided in Appendix 7 of the EDR. Wetlands are not present in the proposed work area for the removal action based on ENSR's Wetlands Sun/ey Report dated July 2006, (as provided.in the July 2006 SRD, thus ARARs pertaining to wetlands are no longer applicable or relevant and appropriate. Notation: it should be noted that various federal and state agencies were provided the SRD, and EPA and ENSR have receiyed verbal approval of the SRD but have not yet received a written response from these agencies, including but not limited to:
• NJDEP Land Use Regulation Program (LURP)
• National Parl< Service, Wild and Scenic Rivers Notification
• US Army Corps of Engineers, Phiiadeiphia District, Clean Water Act, Section 404, Nationwide Permit Program Documentation
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10.0 Schedule
A preliminary schedule is provided in Table 10-1 forthe completion of work plan tasks described herein and subject to the review and approval of US EPA pursuant to Time Critical Removal Action under EPA AOC, Docket No. CERCLA-02-2005-2017. Commencement of work is required within twenty-one (21) days after US EPA's approval of the Wori< Plan in accordance with the terms and the Agreement and Order between US EPA and Fort James Operating Company (Fort James). This table details the proposed project scheduling for accomplishing the on-site assigned tasks identified in the EDR and Wori Based upon EPA's conditional approval ofthe Wori< Plan^ provided on April 16, 2007, the work under the Work Plan will commence with the start of Administrative Tasks, which includes the procurement of subcontracts and preparing project personnel, at a minimum. The duration of the Administrative Tasks is estimated to be approximately 15 days from conditional approval. In conjunction with the Administrative, site mobilization and site preparation activities will occur between April 23, 2007 and May 4, 2007. These activities will include, but not limited to, mobilization and furnishing of the site trailers, ordering supplies and materials, preparation of the construction material staging area, and installation of soil erosion and sediment controls. Clearing and grubbing will commence during the week of May 7, 2007. The Drum Search Phase is anticipated to start during the week of May 14, 2007 and end before June 2007. The start of the Construction Phase for the wall is anticipated to coincide with the end of the drum search phase. The construction of the wall is estimated to end during the week of August 20, 2007. The following week demobilization activities will commence and then end approximately 15 days later, during the week of September 10, 2007. The duration ofthe Construction Phase is estimated to be 102 days. The completion date ofthe removal activities is anticipated to be September 10, 2007, the last day of demobilization. Per the AOC, within 30 days of the completion date of the removal activities, a Final [Report summarizing the actions to comply with the AOC, will be submitted to the EPA for review and approval. The Final Report is anticipated to be submitted to EPA by October 10, 2007. EPA should note that the proposed schedule is subject to change based on unanticipated conditions imposed by EPA and other agencies. The schedule is also subject to change due to severe weather conditions, poor field conditions, and force majeure. The schedule will be extended, as needed, to account for any ofthese conditions. Interim schedules may change based upon unanticipated site conditions and force majeure events such as adverse weather conditions and other conditions beyond control of FJOC that may cause an extension of schedule. ^ The original construction schedule was based upon the receipt of EPA approval ofthe revised Work Plan no less than two weeks from start of field activities with a start date of April 16,2007 for site activities. EPA conditional approval was received on April 16, 2007, which pushed back the start of field activities to April 23,2007. In the revised schedule. Table 10-1, weekend days are included as workdays since the 7-month AOC timeframe for the completion of all Work for on- site Slope Stabilization Measures does not exclude weekend days. J:\Project\Georgia-Pacific\03060-062 Milford CV -10-1 Anrii 9nm Landflll\WorkPlan\FINAL-April2007\FINAL-DOCUMENT-Conditional- Approval-041907\ENSRWorkPlan-CVLandfill-FINAL-4192007.doc ENSR 10.1 Notifications US EPA must be notified.within 7 days in advance of any sample collection activities to be conducted on site, unless shorter notice is agreed to by US EPA. 10.2 Progress Reports During the implementation of the time-critical landfill slope stabilization measures, written progress reports will be submitted to US EPA every 14*^ day after receipt of USEPA's approval of the Work Plan until a written Notice of Completion of Work is received from US EPA. The progress report will include, as applicable, the following items: • Description of actions taken toward achieving compliance with the AOC during the previous two-week period, • All sampling results and tests and all other data received during that period in the implementation of the Work Plan, • Description of all actions which are scheduled for the next two-week period, • "Other information relating to the progress of the work as is customary in the industry," • A schedule for the field activities that are expected to occur during the upcoming month, and • Other information regarding the percentage of completion, including a description of all delays encountered or anticipated that may affect the future schedule for completion of the Work Plan and include a description of all efforts made to mitigate delays encountered or anticipated. 10.3 Final Reporting A final report will be submitted to US EPA for review and approval within thirty (30) days after completion of all activities required under the AOC that summarizes the actions taken to comply with the AOC. The Final Report will conform, at a minimum, to Section 300.165 of the NCP "OSC Reports." The final report will include the following: A synopsis of all work performed under the AOC, A detailed description of all EPA-approved modification to the Work Plan that occurred during performance of the work, A listing of quantities and types of materials removed from or handled on the site, A listing of the ultimate destination and disposition of the material recovered from or handled on the site, A presentation of the analytical results of all sampling and analyses performed, including QA/QC data and chain of custody records, Accompanying appendices containing all relevant documentation generated during the work, including, manifests, bill of ladings, invoices, bills, contracts, permits, and certificates of destruction. An accounting of expenses incurred by the "Settling Party" at the site, and Certification signed by a person who supervised or directed the Final Report preparation. J:\Project\Georgia-Pacific\03060-062 Milford CV "10-2 Aoril 2007 Landfill\Wori CONSTRUCTION SCHEDULE CROWN-YANTAGE-LANDFILL SLOPE STABILIZATION MEASURES ID Task Name Duration Start Finish Predecessors 2007 Aug Sep I Oct Nov Dec Jan Feb I Mar Jun Jul Aug I Sep Oct Nov I EPA Approval of Workplans 204 days' Mon 9/25/06 : Mon 4/16/07' ^. EPA Review and Approval 204 days , Mon 9/25/06 Mon 4/16/07"' '-. Administrative Setup 18 days' fue4/177(Di7 Fri 5/4/07 h i I '16 days' Thu 4/19/07 Fri 5/4/b7"'j' i Subcontract Procurement I 18 days]' Tue 4/17/07 Fri 5/4/071 j Project Personnel Preparation I _ i_ 39 days I IVIon 4/23/07 thu 5/31/071 T brum Search Phase j Mobilization and Site Prep 12 clays' Mon 4/23/07 Fri*5/4/07^ Install Soil Erosion Measures 8 days I MonAmm Mon 5/7/671 I i Clear and Grub Mo'n 5/14/07 8 days I Mon 517/07 Drum Search Thu 5/31/07 8,9 17 days I Tue'~5/15/0'7 11 Construction Phase 102 days Fri 6/1/07 rinbn 9/10/07 6,1 12 Mobilization and Site Prep todays Fri 6/1/07 Sun 6/10/07 13 Install Soil and Sed Erosion Measures 5 days Mon 6/4/07 Fri 6/8/b> I 14 Wall Construction 75 days Mon 6/11/07 ^'Fri 8/24/07 15 Seed 39 days Tue 7/17/07 " Fril/24/67 16 Demobilization 15 days Mon 8/27/07 ' Mon 9716/07 17 Final Report 30 days Mon 9/10/07 TueTd/9/07 18 Prepare Final Report 30 days '' IVl'on 9/ld7o'7 fuel 0/9/67 _Project: 4-26-07 WPSchedule.mpp Task Progress Summary External Tasks Deadline ate: Fri 4/27/07 Split Milestone Project Summary Extemal Milestone ^ 1. Subject to conditions imposed by and approval of EPA and other agencies. Page 1 2. Subject to weather, field conditions, force majeure. 3. Schedule is based upon EPA granting approval of WorkPlan no less than 2 weeks from start of field activities. ENSR 11.0 Reference to EDR Plans and Specifications The July 2006 EDR details the slope stabilization details to be implemented at the Crown Vantage landfill site. Various drawings and plan specifications were provided in the July 2006 EDR which are incorporated by reference into this Work Plan. These drawings, plans and specifications will be consulted on site on a daily basis for the implementation of the Work Plan slope stabilization measures. 11.1 Construction Drawings and Specifications EDR construction specifications have been developed to facilitate the Site preparation activities and construction of the wall components. As presented in the July 2006 EDR, these specifications supplement the Construction Drawings to assist the Contractor and Engineer with identifying labor, equipment, materials, construction techniques, and quality control measures necessary to build the geosynthetic reinforced wall system as designed. A set of Construction Drawings supplements the Construction Specifications in the July 2006 EDR provide a technical illustration for the proposed design plan. The Construction Drawings will be consulted throughout the duration of the on-site implementation phase and provide the Contractor and " Engineer with the details and quality control measures, respectively, to facilitate the implementation phase. A list of the drawings referenced from the EDR is provided below in Section 11.3. 11.2 Property and Topographic Survey A topographic and property survey was conducted for the Site to establish the existing topography, property boundary, perimeter of the site, river bank location, and other Site features. These survey maps are provided with the Construction Drawings referenced in the EDR as provided below in Section 11.3. . These maps serve as the base map for most of the Construction Drawings. It should be noted that the construction of the wall is subject to change from the proposed plans based on actual, unknown, or unexpected site conditions, including unknown variables of the landfill. Please note that the relative topography along the water's edge is variable and subject to dynamic changes due to periodic storm events such as those experienced during the recent April 2005 and similar flood events. Existing and Proposed Conditional are depicted on Drawing 1-1 of the EDR and show the general location of on-site fencing, monitoring wells and piezometers, existing gravel access roads, floodway and flood hazard area lines, 100-year and 500-Year FEMA Flood Line, and proposed fill/riprap placement within limits of the river. J:\Project\Georgia-Pacific\03060-062MilfordCV "l-l.-l Anril 2007 Landfill\WorkPlan\FINAL-April2007\ENSRWorkPlan-CVLandfill- ^ FINAL-4192007.doc ENSR 11.3 Construction Drawings A'list of Construction Drawings to implement Slope Stabilization Measures for the Time Critical Removal Action at the Crown Vantage Landfill is provided below and will be referenced throughout Work Plan implementation, as provided in the EDR prepared by ENSR. Siope Stabilization Measures, Time Critical Action, Crown Vantage LandfiU, Hunterdon County, Alexandria Township, New Jersey - Construction Drawings Drawing No. Sheet Description — Cover Cover Page . IA 1 of 13 Existing Conditions 2A 2 of 13 Site Security Plan 2B 3 of 13 Site Security Plan 3A 4 of 13 Site Preparation Plan 3B 5 of 13 Site Preparation Plan 4A 6 of 13 Wall Alignment and Construction 4B 7 of 13 Wall Alignment and Construction 5 Sof 13 Elevations and Cross Sectional Details 6A 9 of 13 Existing and Proposed Cross-Sections 6B 10 of 13 Existing and Proposed Cross-Sections 6C 11 of 13 Existing and Proposed Cross-Sections 7 12 of 13 Details 8 13 of 13 Soil Erosion and Sediment Control Attachment 1,2,&3 Borbas Topographic Survey, Dated 7-13-05 Attachment Borbas Property Survey, Dated 1-14-06 Note: Sheets 1 through 13 of 13 dated 7/21/06 \ J:\Project\Georgia-Pacific\03060-062 Milford CV 11-2 April 2007 LandfimWorkPlan\FINAL-April2007\ENSRWorkPlan-CVLandfill- FINAL-4192007.doc ENSR AECOM Appendix A EPA Correspondence/Orders J:\ProjecftGeorgia-Pacific\03060-062 Milford CV April 2007 Landfill\WorkPlan\FINAL-April2007\ENSRWorkPlan- CVLandfill-FINAL-4192007.doc C ) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY X, REGION n 290 BROADWAY NEW YORK. NBW YOWC 10007.t8« May 26.2005 VUFACSIMBLK Jeffrey N. Martin, Esq. Partner Hunton & WiUiams, LLP 1900 K Street, N.W. Washington, D.C. 20006-1109 Rc: Crown Vantage Landfill Site Alexantiria Towaahip. Hunterdon Countv. New ]saS2L Dear Mr. Martin; Enclosed please find a copy of the Administrative Agreement and Order on Consent for Removal Action (Order) with regard to the Crown Vantage UmdfiU S^jerfund Site in Alexandria Township, in Htmterdon County, New Jersey. A copy ofthe Order will also be sent , , to you via mail. The Acting Director for the Emergency & Remedial Response Division g (ERRD) of die U.S. Environmental Protection Agency (EFAX William McCabe signed the Order on May 25,2005. Pursuant to EPA Delegation No. 14-14-C, Mr. McCabe as the Acting Division Director of ERRD has been delegated the authority to sign this Order on behalf of EPA. The effective date pursuant to paragraph 108 of the Order is tibe day the Order is served upon cotmsel for Settling Party via ftcsimile after it is sigried by the Regional Adttiinistrator or hCT 7i delegate. Thus, the effective date for the Order is May 26,2005. Feel free to reach me at (212) 637-3154 if you have any questions with regard to this matter. Sincerely, William J. Reilly, Jr. Assistant Regional Counsel ZMr.(ss^imwnfl.m£iC«U:(l!80.WK!!:SINfla^ 34 The undersigned representatives of Settling Party certify thai ihcy arc fully authorized to enter into the terms and conditions ofthis Agreement and Order and to bind the parties they represent to this document. Agreed this<2it'S^ay of ijJfi_L, 2»«t. For Settling Party Pw-t'57.wt^ O^^^j^uy (U^^e^ Title ^iC'M^il^ij.A. //{^ It is so Ordered and Agreed this 7 v^' day of . 2iVi' BY:/>/idi.i..,.r.L/yA<^ DATE: ^^'..^^C-:'- Name William McCabe R«%kna( EFFECTIVE DATE: Jl^j2fi.x«>» 3S:XT 900Z-9e-At*4 .mi;iC9Wffl»,lOMO.ITOH8l»lM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 IN THE MATTER OF: Crown Vantage Landfill Site ADIVONISTRXTIVB AGREEMENT AND Alexa^Township.Hunte«loaCoun °^j^^ONCONSENTF0RREMOm Fort James Operating Company U.S. EPA Region 2 Settling Party CERCLA Docket No. 02- 2005 - 2Q] 7 Proceeding Under Sections 104. loe^ai 107. and 122 ofthe Compreheniive STr'S-^i Compensation. ?;J}''^^'^>«y Act, as amended. 42 U S C < 9604.9606(a), 9607. and 9622 ^ i DiXl •35:11 S002-g2-AbW Jaui|i)t(8||litOU»}$t3lyMP0:»S002l3ZISiVI]A3«iiClsa9Y(i 2 I. JURISDICTION AND GENERAL PROVISIONS 3 II. pAl^TOSBQUNP 3 III. DEFINITIONS ...3 IV. FINPINqS.OF.PAOT • 5 V CQNaUSiONSOFLAW 8 VI. DETERMlNATIOh^S 9 VII. AGREEMENT ANP ORDER 10 vm. DESIGNATION OF CONTRACTOR AND PROJECT COORDINATOR lO IX. WQ.RKT0.B6PE|tFQRMEP: " XI. PLANS AND REPORTS REOUIRINO EPA APPROVAL t« XII. REPORTING 17 XIU. SITE ACCESS 19 XIV. ACCESS TO INFORMATION 20 r XV. RECOim RETENTION 21 XVI. COMPLIANCE WITH OTHER I.AWS 21 . XVII. EMERGENCY RESPONSE AND NOTIFICATION OF RJEI-EASES 22 XVm. PAYMENT OF RESPONSE tjlQST^ 23 XDt. FORCE MAJEURE 24 XX. STIPULATED AND STATUTORY PENALTIES 26 XXL COVENANT NQT TO SUE BY EPA. „ 26 XXn. RESERVATIONS QF RIGHTS BY EPA i 27 XXIII. COVENANT NOT TO SUE BY SETTUNG PARTY. _ 26 XXIV. OTHER CLAIMS 28 XXV. CONTRIBUTION PROTECTION AND RIGHTS 29 XXVI. INDEMNIFICATION : 29 XXVII. . INSURANCp 30 XXVm. FINANCIAL ASSURANCE 30 ^tMWSffl^REUTIONS - 3^^ I XXXI. MODIFICATIONS „ ..31 XXXIL ADDITIONAL REMOVAI- ACTION. 31 XXXIII NOTICE OF COMPLETTON OF WQRK 32 XXXlVSEVERABILITY/INTEGRATrON/APPENDlCES 32 XXXV. EFFECTIVE DATE 33 Did LSi'.W S00e-92-A«W L JURISDICTION AND GENERAL PROVISIONS 1. Tbis Administrative Agreement and Order on Consent ("Agreement") is entered into voluntarily by tbe United Stetes Environmental Protection Agency ("EPA") and Fort James Operating Company ("Settling Party"). This Agreement and Order provides for the perfonnance ofa time-critical removal action by Settling Party at the property located in Alexandria Township, Hunterdon County, New Jersey, the "Crown Vantage Landfill Site" or the "Site." 2. This Agreement is entered into pursuant to the authority vested in the Administrator of the U.S. Environmental Protection Agency {"EPA") by Sections 104, 106,107, and 122 ofthe Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended ("CERCLA") 42 U.S.C. §§ 9604,9606(a), 9607, and 9622 which authority has been delegated to the Regional Administrators of the EPA by EPA Delegation No. 14-14-C and redelegated to the Director of the Emergency and Remedial Response Division, 3. EPA has notified the State ofNew Jersey (the "State") ofthis time-critical action 1 pursuant to Section 106(a) of CERCLA, 42 U.S.C. § 9606(a). s 4. EPA and Settling Party recognize that this Agreement has been negotiated in good faith and that the actions undertaken by Settling Party in accordance with tbis Agreement do not constitute an admission of any liability. Settling Party does not admit, and retains the right to controvert in any subsequent proceedings other than proceedings to implement or enforce this Agreement, the validity of (be findings of facts, conclusions of law, and determinations in Sections IV, V and VI ofthis Agreement Settling Party agrees to comply with and be bound by the terms of this Agreement and fiirther agree that they will not contest the basis or validity of this Agreement or its terms. i II. PARTIES BOUND 5. This Agreement applies to and is binding upon EPA and upon Settling Party and their successors and assigns. Any change in ownership or corporate stanis of a Settling Patty including, but not limited to, any transfer of assets or real or personal property shall not alter such Settling Party's responsibilities under this Agreement. 6. Settling Patty shall ensure that its contractors, subcontractors, and representatives receive a copy ofthis Agreement and comply wilh this Agreement. Settling Party shall be responsible for any noncompliance with this Agreement. in. DEFINITIONS 7. Unless otherwise expressly provided herein, terms used in this Agreement which arc defined in CERCLA or in regulations promulgated under CERCLA shall have the meaning assigned to them in CERCLA or in such regulations. Whenever terms listed below are used in this Agreement or in the appendices anached hereto and incorporated hereunder, the following definitions shall apply: a. "Action Memorandum" shall mean the BPA Action Memorandum relating to the Site that was approved on March 18,2005, by the Regional Administrator, EPA Region 2, or his/her delegate, and all attachments thereto. The Action Memorandum is attached as Appendix 1. b. "Action Mcmorandum/Enforcemem" shall mean the EPA Action Memorandum relating to the Site that was approved February 10,2005, by the Regional Administrator, EPA Region 2, or his/her delegate, and all attachments thereto. The Action Memorandum/Enforcement is attached as Appendix 2. c. "CERCLA" shall mean the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended, 42 U.S.C. §§ 9601, et seq. d. "Day" shall mean a calendar day. fii computing any period of time under this Agreement, where the last day would fall on a Saturday. Sunday, or Federal holiday, the period 1 shall nm until the close of business ofthe n«tt working day. e. "Effective Date" shall be the effective date of this Agreement as provided in Section XXXV. f. "EPA" shall mean the United States Environmental Protection Agency and any successor departments or agencies of the United States. ' g. "Future Response Costs" shall mean all costs, including, but not limited to, direct and indirect costs, that the United States incurs pursuant to Section XDI (cost and attorneys fees and any monies paid to secure access, inclulding the amount of just compensation). I Section XVII (Emergency Response and Notification of Releases), Paragraph 74 (Enforcement of the Agreement) and Paragraph 83 (Work Take Over); h. "Interest" shall mean interest at the rate specified for interest on investments of the EPA Hazardous Substance Superftind established by 26 U.S.C. § 9507, compounded annually on October I of eacb year, in accordance with 42 U.S.C. § 9607(a). TTje applicabic rate of interest shall be the rate in etfect at the time the interest accrues. The rate of interest is subject to change on October! of eaoh year. i. 'l^andfiU face" shall mean the westem edge along the Delaware River. The extent ofthe landfill is identified in the Aerial Photographic Analysis of Crown Vantage Landfill Site, U.S, EPA, National Exposure Research Laboratory. March 2004. j. "National Contingency Plan" or "NCP" shall mean the National Oil and Hazardous Substances Pollution Contingency Plan promulgated pursuant to Section 105 of CERCLA, 42 U.S.C. § 9605, codified at 40 C.F.R. Part 300, and any amendments thereto. 3MQ BS:XT S002-92-AtW i£/i0"d t?0TE i£9 2T2 k. "NJDEP" shall mean the New Jersey Department of Environmental Protection and any successor departments or agencies of the State. I. "Agreement" shall mean this Administrative Agreement and Order on Consent and all appendices attached hereto (listed in Section XXXDI). In the event of conflict between this Agreement and any appendix, this Agreement shall control. m. "Paragraph" shall mean a portion ofthis Agreement identified by an Arabic numeral. n. "Parties" shall mean EPA and Settling Party. o. "RCRA" shall mean the Solid Waste Disposal Act; as amended, 42 U.S.C. §§ 6901,%/ seq. (also known as the Resource Conservation and Recovery Act). p. "Settling Party" shall mean the Fort James Operating Conpany. q. "Section" shall mean a portion ofthis Agreement identified by a Roman numeral. . r. "$ite" shall mean the Crown Vantage Landfill Site, encompassing approximately ten acres, located off of Milford-Frenchtown Road in Alexandria township, Hunterdon County, New Jersey and depicted generally on the Alexandria Township tax map as Block 17.01 Lot 1 attached as Appendix 3. s. "State" shall mean the State of New Jersey. i • t, "Waste Material" shall mean 1) any "hazardous substance" under Section 101(14) of CERCLA, 42 U.S.C. § 9601(14); 2) any pollutant or contaminant under Section 101(33) of CERCLA, 42 U.S.C. § 9601(33); 3) any "solid waste" under Section 1004(27) of RCRA, 42 U.S.C. § 6903(27); and 4) any mixture containing any of the constituents noted in (1), (2), or (3), above.) 7\ , '^ u. "Work" shall mean all activities Settling Party is required to perform under this Agreement, IV> ErAFmPlNGS OFrACT 8. The Site is an abandoned, inactive landfill located off of Milford-Frenchtown Road, just south ofa vacant paper mill, in Alexandria Township, Hunterdon County, Ncw Jersey, The approximately 10-acrc landfill has an estimatad 1.500 feet of frontage directly on the eastern shore ofthe Delaware River. The Site is adjacent to the northemmost section ofthe Delaware _ oyo 9S:Tt sees-gs-Abw ZMi:{sHRii)N0jlVlill0,mCiMl!ir.a80,l«^ Raritan Canal State Park. The Delaware and Raritan Canal foot path and a com field bound the Site to the east The closest residences are approximately 0.3 miles north ofthe Site. 9. The landfiU waa utilized by the adjacent paper mill, known as the Milford mill, as well as other nearby paper mills (Riegelsville, Warren Glen and Hughsville), for the disposal of waste beginning in the late 1930's through the early 1970's. Some municipal solid waste may also have beeh deposited into the landfiU. Aerial photographs ofthe Site beginning in 1938 reveal a path leading fh>m Milford-Frenchto<«m Road to the Site. 10. NJDEP conducted investigations at the Site between 2002 and 2003, including the excavation of test pits and the removal and disposal of waste material and containers discovered at the surface and in the subsurface ofthe' landfill. Analysis of samples collected trom the drums for disposal purposes identified that a majority ofthe samples exceeded the regulatory limits for the RCRA-characteristic of ignitability and that a portion of the samples exceeded the regulatory level for the RCRA> characteristic of toxicity. NJDEP also rqmrted that surfiice soil samples 1^ collected from the exposed tkce of the landfill alongside the river showed exceedences of both the state residential and nonresidential standards for metals and semivolatiles in many ofthe samples. 11. On June 25,2003, EPA received a request from NJDEP to evaluate the Site for CERCLA Removal Action consideration. Several site visits were conducted by EPA between June and November, 2003. During the site visits, pigment waste was observed on the surface of the landfill, solvent odors were identified emanating from aacks and fissuresi n the landfill, and badly degraded drums ofwaste were observed present near the sur&ce of die landfill. Flood waters from the Delaware River had overflowed the westem toe of the landfill and scoured the face revealing buried drums, some of which containing blue pigment had leaked their contents near the river. A sample of this material collected by EPA confirmed the presence of elevated •r'l- levels of lead. EPA also noted that the fence v^ch NJDEP had installed arouiid the Site had been severely damaged along the riverdu e to elevated water and flow level, allowing access by i the public to the Site. 12. EPA sampled waste, air. suiface soil, sediment and surface water. The analytical results indicated that significantiy elevated levels of a variety of CERCLA-designated Hazardous Substances, as listed in 40 C.F.R. Table 302.4, are present ithroughout the Site. Some ofthe 71 substances found included poly-aromatic hydrocarbons ("PAH"), benzene, tetrachloroethene, trichloroethene, heptaehlor, lead, pesticides, PCBs and chromium. 13. EPA concluded tbat a CERCLA Removal Action was warranted at rhe Sire to stabilize the exposed landfill face in order to eliminate the potential for containers and other waste materials from being released into the Delaware River. EPA also recommended the removal of drums and other waste materials along the face of the landfill and other exposed areas, as well as the implementation of Site scctirity measures. These findings are described in EPA's Reraoval Site Evaluation ("RSE"), dated May 25,2004, which was prepared in accordance with the NCP, 40 C.F.R. 300.410 and is attached as Appendix 4. 14. EPA apprpved an Action Menjorandum/Etiforcement on Fcbtuaiy 10,2005 which concluded that the acmalor threatened release ofa hazardpus substance from the Site, if not addressed by implementing the recommeiided response action, may present and imminent and substantial endangerment to public health, welfare, or the environment This document was prepared in accordance with the "Superfimd Removal Procedures Action Memorandum Guidance" (OSWER Directive No. 9366.3-01, Deceriiber 1990). 15. EPA conducted an addidonal site visiton September 20,2004 after the remnants of Hurricane Ivan resulted in the Delaware River risingwel l above fiood stage. It was determined that the river had crested above the fkce ofthe landfill. EPA observed a portion ofthe landfill face that had experienced some erosion due to the ftotxl waters sloiigh off into the Delaware River. The portion ofthe landfall that sloughed off had previously been sampled by EPA and contained elevated levels of PAHs, heavy metals, PCBs, and pesticides. As the water level subsided over the next two weeks and the entire face of became accessible and visible, additional areas of die landfill face were observed to have suffered significant slou^fiig and erosional damage. 16. On September 29,2004, an emergency rempval actioii was initiated by EPA to stabilize areas ofthe landfill iface tbat were severely impacted by the flooding. Rip-rap was placed on these areas to prevent additional releases into the river. In addition, EPA collected some waste material which had been released from the landfill, including several drums pf organic solvent, pigments and other colored, solid inaterial, 17. EPA approved an Action Memorandum March 18,2005, which concluded that the actual or threatened release of a hazardous substance from the Site, if not aiddressed by implementirig the emergency response'action, may present and imminent and substantial , endangerment to public bealth, welfkre, or the envirpnment This document was prepared in accordance with the "Superfiind Removal Procedures Action Memorandum Guidance" (OSWER i Directive No, 9360.3-01, December 1990). 18. EPA propbsed the Site to be listed on the National Priorities List on September 23, 2004, 19. During the time ih which the landfill was utilized for the disposal of paper mill- related wastes, it was owned and operated by Riegel Paper Corporation, The other mills that contributed waste tp the Site, Riegelsville, Warren Glen and Hughsville, were owned and operated by Riegel Paper Corporation. 20. Beginning in 1972, a series of coqporaie transactions took placo in which ownership of the Site shifted. On Januaty 3,1972, Riegel Paper Corporation merged with Federal Paper Board Company, Inc, with Federal Paper Board Company surviving. On Februaiy 23,1972, Federal Paper Board Company then sold its assets, including the Milford mill and the Site, as well as the Riegelsville, Warren Glen and Hughsville paper mills, to a ncwly-fptmcd company. Riegel Products Corporation, which expressly assumed all liabilitcs ofthe Federal Paper Board Company (previously known as Riegel Paper Corporation) operations in New Jersey, On the i£y0Vd W£i£9 2T2 . . . Dap , . 6S:TT S002-92-A«W same day, Southwest Forest Industries acquired 100% ofthe stock of Riegel Products Corporation, which became a wholly-owned subsidiary of Southwest 21. On November 8,1977, Fort James Corporation, which was then named James River Corporation, purchased the stock of Riegel Products Corporatioa firom Southwest Forest Industries. The stock transaction included the Milfprd mill and the Site, as well as the Riegelsville, Warren Glen and Hughsville paper milts. 22. On April 29, 1989, Riegel Preducts Cprporation and James River U.S. Holdings, Inc., both subsidiaries of James River Corporation, were merged into a newly-named company, James River Paper Company, Inc., which was later renamed Fort James Operating Company. Thia transaction resulted in James River Paper Company. Inc. becoming tiie owner of the Milford mill, the Site, as well as the Riegelsville, Wan-en Glen and Hughsville paper mills. James River conducted a surface cleanup ofthe Site under the direction ofthe NJDEP in 1992. 23. On August 15, 1995, James River Corporation and James River Papw Company, Inc. executed a corporate spin-off in whieh Crown Vantage, Inc. and its subsidSaiy. Crown Paper Company, received certain assets pf James River Corppration and James River Paper Cpmpany, Inc.. including the Milfbrd mill and the Site. Crown Vantage, Inc. expressly assumed all environmental liabilities associated with these assets. J.... 24. Georgia Pacific acquired Fort James Corporation in July of2000. In 2001, the Site was formally abandoned by Crown Vantage, Inc. as part of a bankruptcy filing under Chapter 11 ofthe United States Bankniptcy Code, This proceeding had the effect of removing the landfill from the bankruptcy estate with ownership of the landfill reverting to the debtor. Crown Vantage, Inc., which is currently a dormant corporation. In 2001, Crown Vantage, Inc. reached an agreement with NJDEP under which Sl million was dedicated to address the environmental liabilities ofall Crown Vantage's sites in Ncw Jersey. After Crown Vantage was liquidated, the i NJDEP referred the site to EPA. 25. On October 27,2003, EPA sent an Inforraation Request to Georgia-Pacific Corporation, the indirect parent of Settling Party. Based upon Georgia-Pacific's response and other available information, EPA notified Settling Party by letter dated November 22,2004, that it was a potentially responsible party pursuant to Section 107(a) of CERCLA, 42 U.S.C. §9607(a). V. fif A CONCLUSIONS QF LAW 26. Based on the Findings of Fact set forth above, and the Administrative Record supporting this removal action, EPA has determined that' a. The Crown Vantage Landfill Site is a "facility" as defined by Section 101(9) of CERCLA, 42 U.S.C: $ 9601(9). 00:SI S002-92-AbW i£/Wd f0T£ c. Settling Party is a '>erson" as defined by Section 101(21) of CERCLA, 42 U.S.C. § 9601(21). d. Settling Party is a responsible party under Section 107(a) of CERCLA, 42 U.S.C. § 9607(a), and is jointly and severally liable for perfprisance pf a response acticn at the Site. i. Settling Party was the "ownar" and/pr "operator" of the ftcility at the time of disposal ofhazardous substances at the £icility, as defined by Section 101(20) of CERCLA, 42 U.S,C, § 9601(20), and within the meaning of Section I07(aX2) of CERCLA, 42 U.S,C, § 9607(aK2). ii. Settling Party arranged for disposal or treatment, or arranged with a transporter for D-ansport for disposal or treatment of hazardous substances at the facility, within the meaning of Section 107(8)(3) of CERCLA, 42 U.S.C. § 9607(a)(3), e. The conditions described in the Findings of Fact above constimte an acmal or threatened "release" of a hazardous substance from tbe facility as defined by Section 101 (22) of CERCLA, 42 U.S,C.§ 9601(22). f. The removal action required by this Agreement is necessary tp protect the public health, welfare, or the environment and, if canned out in compliance with the terms ofthis Agrecmteit, will be considered consistent with tbe NCP, as provided in Section 300,700(c)(3Xi») 1 ofthe NCP. r • • VI. EPA DETIERMINATIONS 27. The conditions described in the Findings of Fact above cpnstitute a threat to public health, welfare or the environment based upon factors set forth in Section 300.415(b)(2) ofthe 1 NCP. Afl documented in the Action Memorandum/Enforcement and the Action Memorandum, these factors include, but arc not limited to, the following conditions: a. potential exposure to nearby human populations from hazardous substances, pollutants Ofcontaminants; b. hazardous substances or pollutants or contaminants are present in drums, barrels, ranks or other bulk storage containers that may pose a threat of release; 0a:St S002-92-AtM :/Zfd t'BTE i£.S 2T2 jf«:(svu«i)H()IW,mCiMUm.lo™ 10 c. hazardous substances or pollutants or contaminants in soils, largely at or near the surface, may migrate; d. weather cpnditions exist that may cause hazardous substances to migrate pr be released; e. threat offire or explpsipn exist that may cause a release pf hazardous substances, pollutants or contaminants; and f. actual or pptential exposure to nearby aiumals or the fpod chain ftom hazardcus substances, pollutants or cpntaminants, vn. AGgJEEMENTAlHP.QRPES 28. Based upon the foregoing EPA Findings of Fact, EPA Conclusions of Law, EPA Detenninations, and the Administrative Record for Ais Site, it is hereby agreed and ordered lhat Settling Party shall cpmply with all provisions ofthis Agreement, including, but not limited to, all attachments to this Agreement and Order and all documents incorporated by refereiice into this Agreement and Order. vm. DESIGNATION OF CONTRACTOR AND PROJECT COORDINATOR. 29. Within seven (7) days after the Effective Date of this Agreement, Settling Party shall designate a Project Coordinator who shall be responsible for the administraiion of actions by Settling Party required by ^is Agreement and shall submit to EPA the designated Project Coordinator's name, address, telephone number, and qualifications. To the greatest extent possible, the Projeet Coordinator shall be present on Site or readily available during Site work. EPA retains the right to disapprove of die designated Project Coordinator for good cause. If EPA disapproves of the designated Project Coordinator, Settling Party shall retain a different I Project Coordinator and shall notify EPA of that person's name, address, telephone number, and. qualifications within seven (7) days following EPA's disapproval. Receipt by Settling Party's Project Coordinator of any notice or communication from EPA relating to this Agreement shall constitute recaipt by all Settling Party, Settling Party may change its designated Project Coordinator, subject to approval by EPA as set forth in tUs Paragraph. Settling Par^ shall notify EPA at least seven (7) days before s^ch a change is made. The initial nodfication may be made orally, but shall be promptly followed by a written notice. 30. Settling Party shall retain one or more contractors to perform the Work and shall notify EPA of the name(s) and qualifications of such contractcr(s) within fourteen (14) days of the Effective Date. Settling Party shall also notify EPA ofthe name(s) and qualification(s) of any other contractor(s) or subcontractor(s) retained to perform the Work at least seven (7) days prior to commencement of such Wpik. EPA retains the right to disapprove of any or all ofthe connectors and/or subcontractors retained by Settling Party; If EPA disapproves ofa selected contractor. Settling Party shall retain a different contractor and shall notify EPA of that contractor's name and qualifications withm seven (7) days of EPA's disapproval. T0:2T S002-92-AWW iC/CT'd catE i£9 2t2 oao 2^(|:($$-uiui)N(}|M,mei£92».m^ 11 31. Settling Party shall provide a copy of this Agreement to each contractor and subcpntractpr apprpved and retained to perform tbe wprk required by this Agreement and Order. Settling Party shall include in all cpntracts or subcpnfracts entered into for wpric required under this Agreement provisions stating that sucb contractcirs or subcpntractprs. including its agents and emplpyees, shall perform activities required by such cpntracts or subcontracts in compliance with this Agreement and all applicable laws and regulations. Settling Party shall be resppnsible 1- for ensuring diat its contractors and subcontractors perform tbe work contemplated herein in accordance with this Agreement. [ DC >yQRKTQgB?]PRFORMgP 32. Settling Party shall perform all actions necessaiy to implement the actions detailed in this Agreement and Order consistent with the Action Memorandum/Enforcement The time- critical actions to be implemented generally inchide, but are nnt limited tp, stabilizing the landfill face m order to eliminate the potential for containera and pther waste materials from being released into the Delaware River; immediately securing the Site against unauthorized access; and a search across tbe entire surface of die landfill to identify, retrieve, and dispose of any drums/containers/^ails and their contents diat are present above the ground surfiice, in order to 1 minimize direct contact threats with these materials. 33. The removal action shall specifically include tbe Work listed below: a. Site Security. A planTor providing Site security shall be implemented including, but not limited to, measures to be taken to keep unauthorized personnel firom entering the Site during the conduct ofthis time-critical action and after it has been completed. This plan shall include provisions for placement of a fence or banrier preventing access onto the landfill along its western edge, and maintenance ofall ffeiicing and warning signs present at the Site unti! i the term specified in subsection (d) below. Any fence or barrier along the westem edge should be placed in such a manner as'to be able to withstand peak flows. Tbe maintenance, which will include repairs of breaches and/or any other type of damage where security is compromised, will be until termination of this Agreement and Order. Tbis task shall be integrated widi the stabilization action. b.f '•m^miTimmP'iA detailed Engineering Design Report shall be produced which will be mo^ic^ upon concepts outlined in 'Technical Memorandum - Bank Stabilization Plan, Crown Vantage Landfill, Alexandria Township, New Jersey, June 2004," prepared under the Reponse, Engineering and Analytical Contract by Lockheed Martin for die U.S. EPA Environmental Response Team, attached as Appendbc 5. The implementation ofthis stabilize the entire face ofthe landfill along the Delaware River. TBiT 'otl^^p^iHrd^^^^^^^^^^^^^TTi^gincering Design should consider, but not be limited to, peak flows, drainage, topography ofthe landfill and the i£/fT'd din t0!2T S002-92-AWW 12 surrounding areas, impact to waste containets and material known to be present widiin tbe face of the landfill, and impact to cpntamination known to be present between the face pfthe landfill and die Delaware River. c. Cpnstniction. Based upon die Engineering Design, implementation pf die design and cpmplete cpnstrucdpn pf die stabilization action shall be accomplished. d. Maintenaiice of Stabilization Aption. After constrw action has been completed,; ' r.yiTi-- -- . an ei^ty percent survival rate is not achieved tie end ofthis two year period, Setding Party shall repluit vegetation and maintain it for an additional year after an ei^ty percent survival rate has been achieved. The maintenance, which will include repairs of breaches and/or ai^ other type of damage where security is compromised, vnll be until termination of tbis Agreement and Order. Thia task shall be integrated widi the stabilization acnnn. e. Container Search. A search across die surface ofthe landfill (including die face) shall be conducted in order to identify, retrieve, abd dispose pf any dtums/containers/pails and their contents that are present pr partially present above the groimd surface. All retrieved material shall be identified, categon'zed, and addressed as per Paragraph 35 below. f. Sampling/fieldl testing. Appropriate analysis and sampling niediods (sample frequency, composiring techniques, etc.) shall be utilized, as necessaiy, for any investigatory work conducted, or for any waste materials identified and retrieved during any portion ofthe removal action prior to removal fitim the Site, for off-site disposal, g. Transportation and Disposal. All containerized and non-containerized waste, 1 PPE and crushed drums shall be disposed of in accordance widi die approved Transportation and Disposal Plan, Settling Party shall notify EPA of die names and addresses ofall off-site waste treatment, storage, or disposal facilities selected by Settling Party to receive wastes from die Site, Settling Party shall provide such notification to EPA at least five (5) days prior tP off-Site shipment of such wastes for EPA's approval. r; pfi ^ 34. Submission of Engineering Design. Witfiin sixty (60) days of the Effective Date, f'jL.j^'OK Settling Party shall submit to EPA for approval a draft Engineering Design Report for the AT/^ stabilization action modeled upon concepts outiined in "Technical Memorandum - Bank Stabilization Plan, Crown Vantage Landfill, Alexandria Township, New Jersey, June 2004,' The engineering design shall include cpnstruction-ready plans and specifications. 35, Submission of'^ _ contammg aragrapfis 32 and 33 above will be 20:2T S082-92-AWW iSySl'd t-BTE ii. Settling Party shall use QA/QC piwcdures in accordance with the QA/QC Plan submitted and approved by EPA pursuant to diis Agreement and iQiZX S002-g2-A«W 7X/gi"d f0TE iZS 2T2 14 shall use standard EPA Chain ofCustody procedures, as set fprdi in the National Enforcement Investigations CenK^r Policiea and Procedures Manual, as revised in November 1984, and the National Enforcement Investigations Center Manual for the Evidence Audit published in September 1981, and SW-846, for all sample collection and analysis activities conducted pursuant to diis Agreement. iii. If perfprmance pf any subsequent phase of the work required by this Agreement requires alteration of ihe QA/QC Plan, Setding Party shall submit to EPA for review and approval proposed amendments to tbe QA/QC Plan. iv. For any analytical woric performed, including diat dpne in a fixed labpratpiy, in a mobile labpratory, or in on-site screening analyses, Settling Party must subrait to EPA a "Non-CLP SuperfUnd Analytical Sendees Tracking System" fprm for each non-Cpntiact Labpratpry I^ogram (CLP) labpratpty utilized during a sampling eveiit, within thirty (30) days after acceptance ofthe analytical results. Upon completion, such documents shall be submitted to die EPA On-Scene Coordinator, with a copy of die form and trai^mittal letter to: Regional Sample Control Center Coordinator (RSCC) U.S. EPA, Division of Environmental Science and Assessment MS-215 2890 Woodbridge Avenue Edison, NJ 08837 V. Settling Party shall only use laboratories that have a documented Quality System that complies widi ANSI/ASQC E-4 1994. "Specifications and Guidelines for Quality Systecns for Environmental Data Collection and Environmental Technology Programs" (American National Standard), January 5, I 1995, and "EPA Requirements for Quality Management Plans - QA/R-2" (EPA/240/B-01/002). March 2001 or equivalent documentation as determined by EPA. EPA may consider laboratories accredited under the National Environmental Laboratory Accreditation Program ("NELAP") as meeting the Quality System requirements, vi. Upon request by EPA, Settiing Party shall have such laboratory analyze samples submitted by EPA for QA mom'toring. Setding Party shall provide to I^A die QA/QC procedures followed by all sampling teams and laboratories performing data collection and/or analysis. vii. Upon request by EPA, Settling Party shall allow EPA or its authorized representatives to take split and/or duplicate samples. Settling Party shall notify EPA not less than 7 days in advance of any sample collection activity, unless shorter notice is agreed to by EPA. EPA shall have the right to take any additional samples that EPA deems necessaty. Upon request, EPA shall allow l£/Ll "d t'0tE i£.S 2T2 oao 15 Settling Party to take split pr duplicate samples pf any samples it takes as part of .its pversight of Setding Party's implementation pf the Work. d. A transportation and disppsal plan which shall address the prpper disppsal of G die stored drums and pails'to treatment, storage and disppsal fiicilities in cpmpliance witii the Resource Conservation and Recovety Act ("RCRA"), 42 U.S.C, §§6901-6991, and Section C 300.440 ofthe NCP, e. A diagram depicting, to the extent knPwn and determined, all work and safety zoi)es, including but not limited to: exclusion zones, cpntaminant reduction zones, staging and 0 sampling areas, waste segregation areas, and command posts, all located fh>m fixed reference points and plotted to scale. A detailed proposed project schedule for accomplishing die assigned tasks. The schedule shall provide for cpn^letion of all Wpik required by this Agreement by np later than seven (7) months from the date pf EPA approval of ^e Work Plan. 36. EPA eidier will approve the Engineering Design and/or the Work Plan, or will require modificarions thereto pursuant to Paragraphs 44-47, below. Once approved, or approved with modifications, die Engineering Design and die Woric Plan, the schedule, and any subsequent modifications shall be incorporated into and become fiilly enforceable under this C Agreement . 37. Commencement of Work. Widiin twenty-one (21) days after EPA's approval of the Work Plan, Srttiing Party shall commence implementatipn ofthe EPA-approved Work Plan. Settling Party shall fully implement tiie EPA-approved Work Plan in accordance with the terms and schedule therein and in accordance with this Agreement I 38. Settling Party shall npt commence any Work except in conformance witii .the terms of this Agreement and Ordor. a 39. Post-Removal Site Control, hi accordance with the Worie Plan schedule, or M otherwise directed by EPA, Settling Party shall submit a proposal for post-removal site control ]| consistent with Scctton 300.415(0 of flic NCP and OSWER Directive No. 9360.2-02. Upon EPA il approval. Settling Party shall imf^ement such comrola and shall provide EPA wid) documentation pf all post-removal site conti-ol arrangements. X. ON-SCENE COOIRDINATOR. OTHER PERSONNEL. AND MODIFICATIONS TO EPA-APPROVED ENGINEERING DESIGN AND WORK PLAN 40. The EPA On-Scene Coordinatprs ("OSCs") for die Site are: Nick Magriples and Lpuis DiGuardia, Removal Action Branch, Emergency and Remedial Response Division, U.S. Environmental Protection Agency, 2890 Woodbridge Avenue, Building 209 (MS-211), Edison, ie/BT'd t^0XZi£.3ZXZ oao t^:2T S002-92-At*l MMliOim.m€iC9n2:(!IS3.lim:Slia XI. PLANS AND REPORTS REQUIRING EPA APPROVAL 44. IIffE EP A disapproves or otherwise requires any modifications to any plan, report or I other item i ^^'^ ^^'^ approval pursuant to diis AgrecmCTt and Order, ^^^^^ Any "notice of disapproval will include an ej^lanation of why the plan, report, or other item is being disapproved. Settling Party shall address each ofthe comments and resubmit tiie plan, report, or |j other item with tiie required changes widiin the tirae stated above. At such time as EPA ll detcrminestiiatdieplan, report, or odier item is acceptable, EPA will transmit tp Settiing Party a written statement to that effect ( ... 45. If any resubmitted plan, report, or pflier item, or portion thereof, is disapproved by EPA, EPA may again direct Settiing Party to make die necessaty modifications thereto, and/or EPA may amend or develop the item(s) and recover the costs firom Settling Party of doing so. Settling Party shall implement any such item(s) as amended or developed by EPA, 46. BPA shall be the final arbiter in any dispute regarding flie sufficiency or acceptability of all documents submitted and all activities performed pursuant to this Agreement and Order. 17 EPA may modify dipse dpcuments and/pr perform nr require die perfprmance of additional wbrk unilaterally, 47. All plans, reports and odicr submittals required to be submitted to EPA pursuant to diis Agreement and Order, upon approval by EPA, shall be deemed to be incorporated in and an enforceable pan of this Agreement and Order. 48. During die implementation of diis Agreement, Settling Party shall prpvide written kWDOEtfettBBI rarty receives fixjm EPA a writwif Nofice of Completion of Work (as defined in paragraph 105). Sucb progress reports shall, among pdier tilings, (a) describe the actions taken toward aciuevuig compliance widi ^'s Agreement during die previous two-week peripd, (b) include all results of sampling and tests and all other data received by Setding Party during diat period in the implementation of die Work required hereunder, (c) describe all acti'ons which are scheduled for die next two-week period, (d) provide other information relating to the progress of work as is customaty in die industry, (e) and inchide infonnation reganUng percentage of completion, all delays encountered or anticipated that may aSkct die fbture schedule for completion of the Work required hereunder, and a descriptipn ofall efforts made to mitigate diosc delays or anticipated delays. After Settling Party receives a written Notice of Completion of Work, Settling Party shaU provide episodic written progress reports to EPA after any maintenance activities are conducted at the Site, 49. Settling Party shall include in die biweekly progress reports required in Paragrapb 48, above, a schedule for die field activities which are expected to occur pursuant to this Agreement and Order during the upcoming montii. Setding Party shall, in addition, provide EPA wifli at I least one week advance nptice of any change in diat schedule. 50, Th^^^^^^^^red to in Paragraph 52. below, and other documents submitted by Setding Party to EPA which purpoit f Q*;^'"^"^ ^ wifli die terms of diis Agreement ahd Order1^3|Sffeli^||^^^^^^^^^who has been delegated this responsibility by die Settling Party and whose qualifications have been found by EPA to be acceptable pursuant to Paragraph 29 of this Agreement and Order. 51,' The Engineering Design, Work Plan, flie Final Report, and other documents required to be submitted to EPA under this Agreement shall be sent to die following addressees: 5 copies ofthe Engineering Design and th^ Work Plan and } copies ofall other documents tp: U.S. Environmental Protection Agency Removal Action Branch 2890 Woodbridge Avenue S0:2T S00e-g2-AtlW JLfiOfiyJto: Office pf Regipnal Counsel United States EnvironmentiU Protection Agency 290 Broadway, 17tii Floor New Yprk, New York 10GO7-I866 Attention: William J. Reilly, Esq, 52. Widiin tiiirty (30) days after completion ofall removal activities required under diis Agreement and Order, Setding Party shall submit for EPA review and approval a Final Report summarizing flie actions taken to comply with diis Ag^ement and Order. The Final Report shall conform, at a roininram, with the requirements set forth in Section 300.165 of die NCP, entitied "OSC Reports." The Final Report shall include: , a. a synopsis of all Work performed under tiiisAgreement ; i' b. a detailed description of all EPA-approved modifications to the Work Plan which occurred during Settiing Party's perfonnance ofthe Work required under this Agreement; c. a listing of quantities and types of materials removed fiom the Site or handled on-Site; d. alistingof the ultimate destination and disposition of those materials: e. a presentation of die analytical results of all sampling and analyses performed, including QA/QC data and chain of custody records; f. accompanying appendices containing all relevant dpcumentarion generated during flie work (fcg^, manifests, invoices, bills, conbacts, permits, and certificates of destiuction); g. an accounting of expenses incurred by the Setding Party at the Site; and 1 h, tiie following certification signed by a person who supervised or directed the [ ? preparation of the Final Report: "I certify that tfie information contained in and accompanying this certification is true, accurate, and complete." 53. EPA either will approve the Final Report or will require modifications thereto pursuant to Section XI, above. 54. Off-Site Shipment^. LZnZ-d .0TE:^9 2T2 S0:2T S002-92-A«W 19 Site to an out-of-state ''^•^'^ '^^^^^ of Waste Material fiom die , OSWER Dfrective9330.2!o7TffCt^^^^^^ ^'^^""wtal official in die ^ceiTgS .However, diis notification req^entSlrf'f'^^'^"'^ voIumeofallsuchshipmentSrl^ if ormation: 1) tfie naie^SattW ^! "^^^^^^on die following f PPcd; 2) the type and quant tySS^ w^^^^^^ ^'V^ Waste Material is to bT c for the shipment of die W^2tS S^"'S 3) die expecte Sctfling Party following fli?awSfti;^l'l^^^^ ^ '"^ ^'H be determined bv provide the information requSy p^^S^^^^ oftiiecontractandbeforoTwaS^ Sitetoanofr-sitlo^lafgti^ m iv'S °P*^tinK cS^SSr ' proposed 121(d)(3). 42 U.S.C. § 962I(V). STc hazardous substances, pollutantt. or cTtarSna^il 1^^ ^h*" only send complies with therequiremems of t^m^^JT^'' ^^"^'° "^''^^facilityihar I sentence. Sc«toPa««.i««^^ -^^'ofsuch^TS^-tt xm. otherv^ise specified in wnring by thToSC^S?^'^?^!r^*'*^^^^^^ or as -ng Its best efforts they ar/un^bKo^^^^ notify EPA ffafter cn agreements. For pu^wses of diis Paragraph, 90S2T S002-92-AtlW zMiilsMiHiiiwawiiid.mJiCJZwso.w^^^^ 20 "best effbrts** includes die payment of reasonable sums of money in consideratipn pf access. Settling Party shall describe in writing its efforts to obtain access. EPA may dien assist Settling Party in gaining access, tP tfie extent necessaty to effectuate die response actinns described herein, using such means as EPA deems apprppriate. Settling Party shall reimburse EPA for all costs and attomey*s fees incurred by die United States in obtaining such access, in accordance with the procedures in Section XVHI (Payment of Response Costs). 57. Notwithstanding any provision of diis. Agreement, EPA retainsal l of its access autiiorities and rights, including aiforcement autiiorities related tiiereto, under CERCLA, RCRA, 0 and any other applicable stamtes or regulations. XIV. ACCESS TO INFORMATION 0 58. Settling Party shall provide to EPA, upon request, copies of all documents and information within its possession or control or fliat of its contiactors or agents relating to acti-vities at the Site or to tiie implementation ofthis Agreement, including, but not limited to, sampling; analysis, chain ofcustody records, manifests, tiiicking logs, receipts, reports, sample traffic routing, correspondence, or other documents or information related to the Work. Settling Party shall also make available to EPA, for purposes of investigatipn, infonnation gathering, or testimony, its employees, agents, or representatives with knowledge of relevant facte conceming the performance of the Work. 59. Settling Party may assert business confidentiality claims covering part or all ofthe docuraents or information submitted to EFA under this Agreement to die extent permitted by and in accordance witii Section 104(e)(7) of CERCLA, 42 U,S,C. § 9604(e)(7), and 40 C.F.R. § 2.203(b). Documents or information detennined to be confidential by EPA will be afforded die protection specified in 40 C.F.R. Part 2, Subpart B. If no claim of confidentiality accompanies documents or infonnation when they are subnnitted to EPA, or if EPA has nptified Settiing Party i that the documents or infonnation are not confidential under the standards of Section 104(eK7) of CERCLA or 40 C.FJt Part 2, Subpart B, die public may be given access to such documents or information without fiuther notice to Setding Party. 60. Setding Party may assert tbat certain documents, records and other information are privileged under the attorney-client privilege or toy other privilege recognized by federal law. If the Settling Party asserts such a privilege in Ueu of providing documents, it shall provide EPA with the following: 1) the title of die document, record, or infonnation; 2) the date of flie document, record, or information; 3) the name and titie of die author of tbe document, record, or information; 4) die name and title of each addressee and recipient; 5) a description of die contents of die document, record, or infoimation; and 6) die privilege asserted by Settling Party. However, no documents, repprts or other information created or generated pursuant to the requirements of this Agreement shall be withheld on the grounds that they are privileged. 61. No claim of confidentiality shall be made witfi respect to any data, including, but not limited to, all sampling, analytical, monitoring, hydrogeologic, scientific, chemicai, or t^TE l£.S 2T2 i0:2t S002-92-AWW 21 engineering data, or any odier documents or information evidencing conditions at or around die Site. XV. RECORD RETENTIOI^ 62. Until tiiree (3) yeara after Settling Party's receipt of EPA's notification pursuant to Section XXXIII (Notice of Completion of Work), Settling Party shall preserve and reuin all non- identical copies of records and documents (including records or documents in electronic form) now in its possession or conhxil or which come into its possession or control diat relate tn any manner to the performance of die Work or the liability of any person under CERCLA widi respect to the Site, regardless of any corporate retention policy to die contiary. Until 3 years after Settling Party's receipt of EPA's notification pursuant to Section XXXIII (Notice of Completion of Work). Settling Party shall also insfruct its contractors and agents to preserve all documents, records, and information of whatever kind, nature or description relating to performance ofthe Work. d^Umentsrrecord^ infoimation are privileged uiider die attorney- client privilege or any other privilege recognized by federal law. If Settiing Party asserts sucb a privilege, it shall provide BPA wifli die following: 1) the title of the document, record, or infonnation; 2) die date of die document, record, or infomiation; 3) die name and tide of tiiie author ofthe document, record, or infoimation; 4) die name and tide of each addressee and recipient; 5) a description of die subject of the document, record, or information; and 6) flie privilege asserted by Settling Party. However, no documents, reports or Other information created or generated pursuant to die requirements ofthis Agreement shall be widiheld on the grounds that I they are privileged. 64. Settiing Party hereby certifies diat to die best of its knowledge and belief, after diorough inquity, it has not altered, mutilated, discarded, destroyed or odierwise disposed of any records, documents or other information (other flian identical copies) relating to its potential liability regarding the Site since notification of potential liability by EPA or rhe State or die filing of suit against it regarding die Site and diat it has fiilly complied with any and all EPA requests 1 for infonnation pursuant to Sections 104(e) and 122(e) of CERCLA, 42 U.S.C. §§ 9604(e) and 9622(e), and Section 3007 of RCRA, 42 U.S.C. § 6927, XVI. COMPUANCE WITH OTHF.R VAW^ 65. Settiing Party shall perform all acti'ons required pursuant to this Agreement and Order in accordance witii all applicable local, state, and federal laws and regulations except as provided in Section 121(c) of CERCLA, 42 U,S,C. § 6921(c), and 40 CF R, §§ 300.400(e) which states that pcmiits are not required for actions taken on-site, and 300.4150), In accordance widi 40 C.F.R. § 300.415(j), all on-Siie actions required pursuant to this Agreement shall, to the extent (l£/fS'd t?0tE i£9 2T2 OMO l0iZ% S002-92-AbW 22 practicable, as detennined by EPA, considering the exigencies of die situation, attain applicable or relevant and appropriate requirements ("ARARs") under ffederal eiivironracntal pr state environmental or facility siting laws. Settiing Party shall identify ARARs in die Work Plan subject to EPA approval XVII. EMERGENCV RESPONSE AND NOTIFICATION OF RELEASES 66. In the event of any action or occurrence during perfonnance ofthe Work which causes or threatens a release of Waste Material fixim the Site diat constituties an emergency E simation or may present an immediate direat to public health or welfare or the environment. Settling Party shall immediately take all appropriate action. Settling Party shall take diese actions in accordance with aU applicable provisions of tfiis Agreement, including, but not limited to, die 0 Health and Safety Plan, in order to prevent, abate or minimize such release or endangerment caused or threatened by flie release. Settling Party shall also immediatel]? notify flic OSC or, in n die event of his/her unavailability, die Chief of die Removal Action Branch of die Emergency and II Remedial Response Division ofEPA, Region 2 at (732) 321-6658. In die event tfiat Settling Party fails ti) take appropriate response action as required by this Paragraph, and BPA takes such m action instead. Settling Party shall reimburse EPA all costs of die response action not inconsistent '$ with die NCP pursuam to Section XVm (Payment of Response Costs), f' 67. In addition, in the event of any release of a hazardous substance firom the Site, Settling Party shall immediately notify die National Response Center at (800) 424-8802. 68. Settling Party shall submit a written report fo EPA witfiin seven (7) days after each release, setting forth the events fliat occurred and flie measures taken or to be taken to mitigate any release or endangerment caused or direatcned by tfie release and to prevent the reoccurrence ofsuch a release. This reporting requirement is in addition to, and not in lieu of, reporting under Section 103(c) of CERCLA, 42 U.S.C. § 9603(c), and Section 304 of die Emergency Plannbig 1 and Community Right-To-Know Act of 1986,42 U.S.C, § 11004, et seq. ^ XVUI. PAYMENT OF RESPONSE Cn5tT.S 1 69. Setding Party shall pay EPA all Future Response Costs as defined by this Agreement and Order not inconsistent wifli the NCP. On a periodic basis, EPA will send Settling Party a bill requiring payment diat includes a SCORPIOS Report. Settling Party shall make all payments within forty-five (45) days of receipto f each bill requiring payment, except as otherwise provided in Paragraph 79 of this Agreement 70. Any payments that Settling Party is required to make pursuant to tiiis Section shall be via electronic fiinds transfer ("EFT"). Payment shall be remitted via EFT to Mellon Bank, Pittsburgh, Pennsylvania as follows: To make payment via EFT, Settling Party shall provide the following infonnation to its bank: i£/S2'd >0T£: ISS Z\Z DiO 80:21; S002-92-AfcM 23 - Amount of Payment - Tide of Mellpn Bank account to receive die payment: EPA - Account cede fpr Mellpn Bank account receiving tbe paymeni: 9I08iS44 - Mellon Bank ABA Routing Number: 043000261 - Name of Settling Party - Case Number: CERCLA.02-2005.2017 - Site/spill identifier 02UF Along with this information. Settling Party shall instruct its bank to remit payment in the required amount via EFT to EPA's account with Mellon Bank. To ensure diat Settling Party's payment ia properly recorded, Setding Party shall send a letter, within one week of die EFT, which references the date of die EFT, the payment araount, the name » [ of the site, the case number and Settling Party's name and address to die EPA addresses in Paragraph 51, above, in addition to the following address: 1 U.S, Environmental Protection Agency Donald Pace, Acting Chief Financial Management Branch 290 Broadway New Yoik, NY 10007 XDC. FORCE MAJEURE 71. Settling Party agrees to perform all requirements ofthis Agreement within die time limits established under diis Agreement, unless the performance is delayed by %/oree majeure. For puiposes of tbis Agreement, a force majeure is defined as any event arising from causes beyond the contirol of Settling Party, or of any entity controlled by Settling Party, including but I not limited to its contractors and subcontractors, which delays or prevents performance of any obligation under this Agreement despite Settling Party's best efforts to fiilfill the obligation. Force majeure does not include financial inability to complete tiie Work, increased cost of performance, or a failure to attain performance standards/action levels set forth in the Action Memorandum/Enforcement 72. If any event occurs or has occurred that may delecy the performance of any obligation under this Agreement, whedier or not caused by a force majeure event, Settling Party shall notify EPA orally within 48 hours of when Settling Party first knew fliat the event might cause a delay. Widiin seven (7) days thereafter, Settiing Party shall provide to EPA in writing an explanation and description of the reasons for die delay; the anticipated duration of the delay; all actions taken or to be taken to prevent or minimize the delay; a schedule for implementation of any measures to be taken to prevent or mitigate the delay or the effect of the delay; Settling Party's rationale for attributing such delay to a force majeure event if tiiey intend to assert such a claim; and a statement as to whether, in the opinion of Settiing Party, such event may cause or contribute to an 60:2t S002-92-AtW i£/<3Z'd t«TE 24 endangerment to public healdi, welfare or tilie environment. Failure to comply wifli the above requirements shall preclude Settling Patty frpm asserting any claim of force majeure fpr that event for die period of tirae ofsuch failure to comply and for any additional delay caused by such [ failure. 73. If EPA agrees fliat die delay or anticipated delay is attributable to amorce mqjeure event, the time for performance of tfie obligati ons under this Agreement that are affected by the force majeure event will be extended by EPA for such time as is necessaty to complete those obligations. An extension of die time for performance of tfie obliptions affected by flieforc e majeure tvaxt shall not, of itself, extend the time for perfonnance of any other obligation. If EPA does not agree tbat die delay or anticipated delay has been or will be caused by aybrcemq/eure ' everit, EPA will notify Setding Party io writing of its decision. If EPA agrees diat the delay is attributable to a force majeure event, EPA will notify Settling Party in writing of flie length of the c extension, if any, for performance of die obli^tions affected by the force majeure event 1 XX. STIPULATED AND STATUTORY PENALTIES 74. If Settling Party fails, without prior EPA approval, to con^ly with any of the material requirements or time limits set forth in or established pursuant to fliis Agreement, and such failure is not excused under die terms of Section XDC, above (Foree Majeure), Settling Party shall, upon demand by EPA, pay a stipulated penalty to EPA in flie amount indicated below: a. For all requirements of this Agreement, other than the timely provision pf biweekly progress reports required by Paragraph 48 of this Agreement, stipulated penalties shall accrue in the amount of $1,000 per day, per violation, for tbe first fourteen (14) days of noncompliance: $ 1,750 per day, per violation, for the 1 Sdi dirough 30th day of noncompliance; and $3,500 per day, per violation, for the 3 i" day of noncompliance and beypnd. 1 t b. For the biweekly progress reports, stipulated penaltiea shall accrue in the amount of $ 250 per day, per violation, for die first fourteen (14) days of noncompliance; $500 per day, per violation, for die I5di dirough 30th day of noncompliance; and Sl .000 per day, per C violation, for the 31st day of noncompliance and beyond |l c. In the event that EPA assumes perfonnance ofa portion or afl die Work ^ pursuant to Paragraph 83 (woik takeover). Settling Party shall be liable for a stipulated penalty of up to $600,000. EPA agrees tfiat any penalty assessed against Setding Party under this Paragraph I shallbereducedjifapproprlate, by the percentage ofwork completed by Settling Party, The ^ amount of the stipulated penalty for fliis subsection shall be subject to dispute resolution as follows: ' i, the amount oftiie stipulated penalty shall be the subject of informal negotiations between flip parties that shall not exceed seven (7) days from die demand for the stipulated penalty, unless modified by written agreement of dte parties; l£/LZ'd \>21Z i£9 2T2 DdO S0:2T S00Z-92-AfclW 25 ii, Ifthe parties do not resolve tfie dispute by informal negotiations, die position advanced by BPA shall be considered binding unless within G seven (7) days aft^ die cbitipletion of die infbrmal negotiations period, Settling Party serves a written Statement pf Position on tfie matter. inciuduig, but not limited to, any factiial data analysis or ppinion supporting diat position anti any supporting documentation relied on by Settling Party to flie Stiategic Intcgnition Manager, EPA, Region 2. Witiiin seven (7) daya of receipt of Settling Party's Statement of C Position, EPA shall have seven (7) days to serve a written Statement of Position on die matter, including, but not limited to, any factiial data analysis or opinion supporting that position and any supporting C documentation relied on by EPA to the Strategic Integration Manager, EPA, Region 2, 1 iii. Following receipt of Settling Party's and EPA's respective Statement of Positions, flic Strategic Integration Manager, Emergtticy and Remedial Response Division will make a final decision resolving die dispute. Such decision shall be binding on Settling Party 75. Any such pctialty shall accrue as ofthe first day after the applicable deadline has 0 passed and shall continue to accrue until the noncompliance is conected or EPA notifies Settiing Party that it has determined that it will perform the tasks for which there is non-compliance. Such _ penalty shall be due and payable forty-five (45) days following receipt ojf a written demand fitim [ ^ EPA, Payment ofany such penalty to EPA shall be made in accordance widi paragraph 70, by electronic fbnds transfer, vvifli a notation offlie index number of flus Agreement A letter stating the basis for die penalty, the name and address of Settling Party, die name of die Site, and die B BPA Region number shall accompany any such payment; a cppy pf the letter shall be mailed to the BPA addressees listed in paragraph 51, above. Settling Party shall pay interest onany amounts overdue undw diis paragraph. Such interest shall begin to accrue on flic fitst day that the respective payment is overdue. Interest shall accrue at the rate ofintcrest on investments ofthe Hazardous Substances Superfiind, in accordance wiflj Section 107(a) of CERCLA. 76. Follovving EPA's determination lhat Settling Party has failed to comply witfj a 1 requirement of this Agreement and Order, EPA may give Settling Party written notification of flie failure and describe die noncompliance. EPA may send Settling Party a written demand for payment ofthe penalties. However, penalties shall accmeas provided in the preceding Paragraph regardless of whetfier EPA has notified Settling Paity of a violation. 77. Even ifviolations are simultaneous, separate penalties shall accnic for separate , violations of diis Agreement and Order. Penalties accnic and are assessed per violation per day. Penalties shall accnic after EPA has notified Settiing Party pf a violation or act of ncncompliance and Setding Party has failed to cure the violation within se^^en (7) days. The payment of penalties LH/eZ'd I70TZ 26 shall not alter in any way Settling Party's obligation to complete die performance of the Work required under this Agreement and Order. 78. Notwithstanding any odier provision of fliis Agreement, failure of Settling Party to comply with any provision of dus Agreement may subject Settling Party to civil penalties of up to thirty-two thousand five hundred dollars ($32,500) per violation per day, as provided in Section 106(b)(1) of CERCLA, 42 U.S.C, §9606{bXl), unless such failure to comply is excused by EPA under the terms of Section XDC, above. 79. Notwithstanding any otfier provision of fliis Section, EPA may, in its unreviewable discretion, waive any portion of stipulated penalties that have accrued pursuant to this Agreement r. and Order. XXI. COVENANT NOT TO SUE BY EPA 80. In consideration of fhe actions that will be performed and the payments that Avill be made by Settiing Party under die terms of tin's Agreemcmt and Order, and except as otherwise specificalty provided in this Agreement and Order, EPA covenants not to sue or to take administrative action againat Settling Party pursuant to Sections 106 and 107(a) of CERCLA, 42 U.S.C. §§ 9606 and 9607(a), for performance ofthe Woik and for recovety of Fuhire Response Costs as defined in this Agreement and Order. This covenant not to sue shall take effect upon the Effective Date and is conditioned upon die complete and satisfactoty performance by Setding Party of all obligations under tbis Agreement and Order, including, but not limited to, payment of Futiire Response Costs as defined in tfiis Agreement and Order pursuant to Section XVIII. This I covenant not to sue extends only to Settling Party and does not extend to any otfier person. XXIL RESERVATIONS OF RIGHTS BY EPA B 81. Except as specifically provided in this Agreement, nodiing herein shall limit die power and authority of EPA or the United States to take, direct, or order all actions necessaty to protect public healdi, welfare, or the environment or to prevent, abate, or minimize an actual or C tfireatened release ofhazardous substances, pollutants or contaminants, or hazardous or solid waste on, at, or fix>m the Site. Furdier, nothing herein shall prevent EPA from seeking legal or equitable relief to enforce die terras ofthis Agreement, ftom taking other legal or equitable action as it deems appropriate and necessaty, or firom requiring Settling Party in the fbture to perform additional activities pursuaiit to CERCLA or any odier applicable law. 82. The covenant not to sue set forth in Section XXI above does not pertain to any c matters other than those expressly identified tfierein. EPA reserves, and tfiis Agreement is without prejudice to, all rights against Settling Party wifli respect to all other matters, including, but not limiced to: a, claims based on a failure by Settling Party to meet a requirement ofthis Agreement; ^/62-d <.0TE iJZS 2T2 3iO 0i;:2T S002-92-AbW JWi:(sww^H()llWIIW.mCiMZ«:(!t93ilie:a^ \ • 2^^ b. liability for costs not included within tfie definition of Future Response Costs; c. liability for perfonnance of response action otiier tfian Woik; 0 d. criminal liability; e. liability for damages for injuty to, destiuction of, or loss of natiiral resources, and for tbe costs of any natural resouree damage assessments; f. liability arismg from the past, present; or ftitiire disposal, release or threat of release of 0 Waste Materials outside of die Site; and g. liability for costs incurred or to be incurred by the Agency for Toxic Subst^ces and Disease Registry related to the Site. c 83. Work Takeover. In die event EPA determines tfiat Settling Party has ceased implementation of any portion of tfie Work, is serioiisly or repeatedly deficient or late in its performance ofthe Work, or is implementing the Work in a manner which may cause an endangerment to human health or the environment, BPA may assume die performance of alt or any portion of the Work as BPA detemines necessaty. Costs incurred by tfie United States in performing the Work pursuant to tbis Paragraph shall be considered Future Response Costs that Settling Party shall pay pursuant to Section XVIII (Payment of Response Costs). Notwidistanding any other provision ofthis Agreement, EPA retainsal l authority and reserves all 0 rights to take any and all response actions authorized by law. L XXin. COVENANT NOT TO SUE BY SETTLING PARTY 84. Settling Party covenants not td sue and agrees ndt to assert any claims or causes of action against die United States, or its contractors or emplpyees, widi respect tp die Work, or this Agreement, including, but not limited to: a. any direct or indirect claim for reimbursement from the Hazardous Substance Superfiind estabfishcd by 26 U.S.C. § 9507, based on Sections 106(b)(2), 107.111,112, or 113 of CERCLA, 42 U.S.C. §§ 9606(bX2), 9607.9611,9612, or 9613, or any other provision of law; b. any claim arising out of response actions at or in coimection with die Site, including any claim under tiie United States Constitiiti'on, die New Jersey State Constitution, die Tucker Act. 28 U.S.C. § 1491, the Equal Access tb Justice Act, 28 U.S.C. § 2412, as amended, or at common law; or c. any claim against tfie United States pursuant to Sections 107 and 113 of CERCLA, 42 U.S.C. §§ 9607 and 9613, relating to the Site. yeC-d >0TE Z\:ZX S002-92-AbW l£/\£'d P2\£. i£9 2T2 3ao 3Mi:(s>i«i«NOIiV!ilW,mCiE9MO.l0m:8l« 89. Except as provided for in flie waiver of claims in paragraph 86. nodiing in fliis Agreement shall affect any right, claim, interest, defense, or cause of action of any party hereto with respect to Uiird parties. 90. No action or decision by EPA pursuant to this Agreement shall give rise to any right to judicial review, except as set forth in Section 113(h) ofCERCLA, 42 U.S.C. § 9613(h). XXV. CONTRIBUTION PROTECTION AND RIGHTS 91. The Parties agree that tfus Order constitiites an admioistirative settiement for purposes c of Section 113(f)(2) ofCERCLA, 42 U.S.C § 9613(fK2), and that Scttlmg Party is entitied, as of the Effective Date, to protection from contribution actions or claims as provided by Sections 113(f)(2) and 122(hX4) ofCERCLA. 42 U.S.C. §§ 96l3(iX2) and 9622(h)(4), for "matters ^ addressed" in this Order. The "matters addressed" in this Order are die Work and Futtire RjBsponse Costs as defined in tfiis Agreement and Order. 92. The Parties agree diat diis Order constitutes an administtative settlement for puiposes of Section 113(f)(3)(B) ofCERCLA, 42 U.S.C. § 9613(fX3XB), pursuant to which Settling Party has resolvedit s liability to the United States for Woric pcafoimed under tfiis Order and for recoveiy of Future Response Costs as defined in tbis Agreement and Order. 93. Except as pro-vided in Section XXfll (Covenant Not to Sue by Settiing Party), nothing in this Order precludes the United States or Setding Party from asserting any claims, causes of action, or demands against any person not a party to tin's Order for indemnificati'on, contribution, or cost recoveiy. Nodiing herein diminishes die right ofthe United States, pursuant to Sections 113(f)(2) and (3) ofCERCLA, 42 U.S.C. § 9613(fX2)-(3), to pursue any such persons to obtain additional response costs or response action and to enter into settlements that provide contribution I protection to such persons. XXVL INDEMNIFICATION 94. Settling Party shall indemnify, save and hold harmless the United States, its officials, ^ agents, contractors, subcontractors, employees aod representatives &om any and all claims or % causes of action arising fhim, or on account of; negligem or odier wrangfiil acts or omissions of Settiing Party, its officera, directors, employees, agents, contractors, or subcontractors, in cartying out actions pursuant to fliis Agreement In addition. Settling Party agrees to pay tiie United States all costs incurred by the United Srates. including but not limited to attorneys fees and oflier expenses of litigation and settlement, arising fliom or on account of claims made against the United States based on negligent or other wrongftil acts or omissions of Settiing Party, its officers, directors, employees, agents, contractors, subcontractors and any persons acting on their behalf or under their control, in canying out activities pursuant to this Agreement The United States shall not be held out as a party to any conttact entered into by or on behalf of Settling Party t>0T£i£9 2T2 2T:2T S002-92-AWW 30 in carrying put activities pursuant to diis Agreement. Neitfier Settling Party nor any such contractor shall be considered an agent of the United States. 95. The United States shall give Settling Party notice of any claim for which the United States plans to seek indemnification pursuant to this Section and shall consult widi Settling party prior to settling such claim. 96. Settling Party waives all claims against the United States for damages or reimbursement or for set-off of any payments made br to be made to die United States, arising from or on account of any contract, agreement, or arrangement between Setding Party and any G person for performance of Woric on or relating to thti Site, including, but not limited to, claims on account of constiiuction delays. In addition, Settiing Party shall indenmify and hold harmless die United States widi respect to any and all claims for damages or reimbursement arising from or on C account of any contract, agreement, or arrangement between any one or. more of Settling Party and any person for perfonnance of Work on or relating to flie Site, including, but not limited to, claims on account of constiuction delays. XXVIL INSURANCE 97. At least seven (7) days prior to commencing any on-Sitc work under this Agreement, Settling Party shall insure diat its contracton and consuhants secure, and maintain for the duration of this Agreement, comprehensive general liability insurance and automobile insurance G with limits of one nullion dollars, combined single liinit, Wiflun die same time period. Settling Party shall ensure that its contractors and consultanti; provide EPA widi certificates of such insurance and a copy of each insurance policy. In addition, for the duration of the Agreement, L: Setding Party shall ensure that its contractiirs or subcontractors satisfy, all applicable laws and regulations regarding flie provision of worker's compensati'on insurance for afl persons 1 perfonning die Work on behalf of Settling Party in furdierance of tin's Agreement XXVin. FINANCIAL ASSURANCE 98. Settling Party shall demonstrate its ability to complete tfie Work required by this Agreement and to pay all clauns fliat arise ftom die performance ofthe Work by presenting to EPA within fourteen (14) days of die effective date of this Agreement the submission ofa corporate 10-K report, to allow EPA to determine that Settling Party bas sufficient assets 1 available to perfonn the Work. Settling Party shall demoristiate financial assurance in an amount no less flian the estimated cost of the Work to be performed by die Settiing Party under this Agreement. If EPA determines that the financial assurances submitted by Settiing Party pursuant to this Paragraph are inadequate, Settling Party shall, witfiin seven (7) days after receipt of notice of EPA's determination, obtain and present to EPA for approval additional financial assurances meeting the requirementso f this Paragraph. XXVIV. COMMUNITY RELATIONS £T!2T S002-g2-AUW i£/££'d l£S 2T2 ' • ... ..-'..-'/ ' 31 •. . ,•; 99. Settling Party shall cooperate with EPA Ul providing information relating to the work required hereunder to the public. As re XXPC OVERSIGHT 100. Dming implementiition of diis Agreement, Settling Party and its contractor(s) sm^ subcontractors shall be available for such conferences widi EPA and inspections by BPA or its autiiorized representatives as EPA may (letermlne are necessaty to adequately oversee the work c being carried out or to be carried out by Settling Party, mcluding inactions at the; Site and its laboratories where an^ytical work is being done hereunder. 101. Setding Party and its employees, agents, contractor(s) and consultant(s)sbalI cooperate witfi EPA in its efforts tp oversee Settling Party's implementation of this Agreement XXX. MODIFICATIONS 102. This Agreement may be amended by mutual agreement of EPA and Settling Party, Such amendments shall be in writing and shall have as dieir effective date the date on which such amendments are signed by EPA. 103. No informal advice, guidance, suggestion, or comment by the OSC or other EPA representatives regarding reports, plans, specifications, schedules, or any other writing submitted t by Settling Party shall relieve Setding Party of its obligation to obtein any formal approval required by this Agreement, or to comply with all requirements of tfiis Agreement, unless it is formally modified. Approval shall not be unreasonably widdield by the OSC or any other EPA 8 representetives. I XXXI. APPITWNALRfiMQVAt. ACTION L • • • • ;„.;, . •' - - • 104. IfEPA determines that additional removal actions consistent with the work required by this Agreement and Order are necessaty to protect public healdi, welfare, or the environment. i| EPA will notify Settiing Party of tfiat determination. Unless otiierwise steted by EPA, widiin tiiirty (30) days of receipt of notice ilrom EPA tfiat additional removal actions are necessaty to protect public healtii, welfare, or the environment. Settling Party shall submit for approval by EPA a Work Plan for the additional removal actions. The plan shall conform to die applicable requirements of Section IX (Work to Be Perfoimed) of tfiis Agreement Upon EPA's approval of the plan pursuant to Section XI, Settiing Patty shall implement die plan for addin'onal removal actions in accordance with the provisions and schedule contained iherein. This Section does not alter pr diminish the OSCs authprity to make oral modifications to any plan or schedule pursuant to Sections X and XXXI (On-Scene Coordinator, Other Personnel, and Modifications to EPA- Approvcd Engineering Design and Work Plan) and (Modifications).: ^/tC-d ;0Te^9 2T2 ^ ; . : ^^=2^ S002-92-A«4, 32 XXXn. NOTICE OF COMPLETION OP WORK 105. When EPA determines, after EPA's review of die Final Report, tfiatal l Work has been fblly performed in accordance with this Agreement, with die exception of any continuing obligations required by this Agreement, including maintenance of tfie stebllization action and site security measures, EPA will provide written notice to Settling Party. IfEPA determines tfiat any such Work has hot been completed in accordance witfi diis Agreement, EPA will notify Settling G Party, provide a list of die deficiencies, and require fliat Settling Party modify the Work Plan if appropriate in order to conect such deficiencies. Setfliog Party shall implement tfie modiiSed and approved Work Plan and shall submit a modified Pinal Report in accordance with flie EPA notice. Failure by Settiing Patty to implement die approved modified Woric Plan shall be a violation of this Agreement. G XXXm. SEVERABELITY/INTEGRATION/APPENDICES 106. Ifa court issues an Order that invalidates any provision ofthis Agreement and Order or finds that Settling Party has sufficient cause not to con^ly with one or more provisions ofthis Agreement, Settiing Party shall remain bound to comply wifli all provisions of this Agreement not invalidated or detennined to be subject to a sufficient cause defense by die court's Agreement 107. Tbis Agreement and Order and its appendices constitute the final, complete and exclusive agreement and understanding amo^g tfie Parties with respect to die settlement embodied in diis Agreement The parties acknowledge that fliere are no representetions, agreements or understandings relating to tfie settlement oflier flian tfiose expressly conteined in i: tbis Agreement The following appendices are atteehed to and incorporated into tfus Agreement and Order: 1 Appendix 1 - "Action Memorandum" for tiie Site that was apiuroved on March 18,2005, by die Regional Administrator, EPA Region 2, or his/her delegate, and all attachments diereto. Appendix 2 - "Action Mcrnorandum/Enforcement" for the Site that was approved on February 10,2003, by tiie Regipnal Administrator, EPA Region 2, or his/her delegate, and all attechments tiiereto. Appendix 3 • Alexandria Township tax map as Block 17.01 Lot 1. Appendix 4 - EPA's Reraoval Site Evaluation ("RSE"). dated May 25,2004, which was prepared in accordance wifli the NCP, 40 C.F.R. 300.410. Appendix 5 - Technical Memorandum - Bank Stabilization Plan, Crown Vantegc Landfill, Alexandria Township, NewJersey, June 2004. 33 I. andOrdris^rtXTolTelf^^^^^^^ on flip day on which tfie Agreement signed by thelegforSwS^^^ G G i 1 G I G i£/9E-d fBtC iCg 212 _^ OHO flsZT S^2-92-AbW (X. d "KlXijM;(5»»«iliioii«iM.wi{iaM;ii».iiiwsM,Hm^^ ^ 34 The undersigned representetives of Settling Party certify that dtoy are fiilly autiiorized to enter into tfieterm s and conditions of tfiis Agreement and Order and to bind tiie parties they represent to this document Agreed diisc^iL^ay of ^JirtL 2Mfe. For Settling Party G Title BtfMT^Lu.*. l/c*. /^^nd^-J^ c It is so Ordered and Agreed diis day of^«f • IQ^. DATE: Name William McCabe R»toisWSdffll»l»ra»K^tJt^Slj>l*e). Acting Director, Emergency & Remedial Region2 Response Division U.S. Environmental Protection Agency G EFFECTIVE DATE: JEiu^j26,iuoo» I. 1 t'TsZT S002-92-AtW ^ISL/iSi'd t?atE i£9 212 /J^ ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 2^BR0ADWAY NEW YORK, NBW yOlUCl0007-t86< ffjl 5>S^**^ FACSIMILE REQUEST AND COVER SHEET /^ . J^^^^ G <2 TO: Jeffrey N.Martin, Esq. G Partner OFFICE: HuntonA Williams, IXP 1900 KStircct, N.W. G Washington, D.C. 20006-1109 PHONE: (202)955-1500 FAX: (202)778-2201 FROM: WILLIAM J. REILLY, JR. G ASSISTANT REOIONAL COUNSEL OFFICE: OFFICE OF REGIONAL COUNSEL NEW JERSEY SUPERFUND BRANCH PHONE: (212)637-3154 E FAX: (212) 637-3096 CONFIRMATION (212) 637-3251 G DATE: May 26,2005 SUBJECT: Crown Vantegc Landfill Site AOC Niunber of Page* (including cover sheet) 36 i£yt0*d t'STE i£9 2X2 EStTT S002-92-AtlU Remtnai Sue EvaluiUion I'or the Crown \'uni;iye Lundt'ill Sue. ,Ale.\jndn;i Township. Hiinierdon Couni\. .New Jerse\ Sick .Magriples. On-Scene CoordinatorA Removal Action Branch File J, INTRODUCTION On June 25. 200?i. the United States Environmental Protection Agenc> (EP.A.). Removal .Action Branch received a request from the New Jerse\ Depanment of Environmentai Protection (NJDEP) to evaluate the Crown Vantage Landfill (Site) for Comprehensive Environmental Response. Compensation and Liability Act (CER(?L.A) Removal .Action consideration. There has been a release of CERCLA-designated hazardous substances at the Site, which is a facilily as det'ined under seciion 101(9) of CERCLA. Drums of waste matenal. including RCR.A-chaructcristic hazardous w astes, have been buried and abandoned at the Sue. Elev ated lev els of volatile oreanics. heavy metals, and pesticides have been detected in these drums, manv of which v\ hen excavated have been found to be damaged. .Vluch of the uncontainerized waste m;itenal at the Sue consists of ash that contams elevated levels of CERCL.A-designiiied hazardoui substances. Organic v^ipors have been detected in the subsurface ofthe landfill and in areas of subsidence al near-explosive levels. The western face of the landt'ill. situated adiacent to the Delaware River, is being impacted bv ihe scouring effects ofthe river. Rising waier level> in Ihe river this past year have increased the contact lime with the uncapped landfill I'acc. Drums and other vvasie malerials along the western face oflhe landfill are exposed and pose the potential for a release. .Although the landfill is fenced, it is accessible along the Delaware River. Based on ihe available informalion. a CERCLA Removal Action is wananied at the Crown Vantage Landfill. The site is currently being evaluated for potential .National Prionties List (.NPL) consideration. n. SITE CONDITIONS AND BACKGROUND A. Sile Description 1. Physical location The Site is located off of Milford-Frenchtown Road, just south of a vacant paper mill, in Alexandria Township, Hunterdon County. New Jersey (see.Figure I). It is an abandoned, inactive landfill situated along the Delaware River between the river and Milfoid-Fienchiown Road. The ten-acre landfill has an estimated L.'iOO feci of frontage directly on the eastern shore ofthe Delaware River and is an estimated 400 feet at its greaiesi width. It is situated adjacent to ihenonhemmosl ,section ofthe Delaware Raritan Canal State Park, a popular recreational area. The Delaware and Rantan Can.il foot path and a com field bound the site to the east. The former pajvr mill propertv is adjacent to ihc landfill lo the northwest, wiih UN ( aeration lagoon situated directlv nonh of the Sue wnhin 600 feci. The closesi residences .nv situated approximatelv 0.,'^ miles north ofthe Site. The top<.>giaphy of the Site is genti) sloping except for an estimated 2.*>-foot drop along the river The Site is vegciaied with oi>en field plant species and a varietv of tree species The steep western slope to the river coniains mature trees. Based on flood plain data, the entire Site is situated w ithin the .SO-year flood plain of the Delaware River. .A 10-\ear flood would inundate most of the western face of the landfill. The closesi surface water intake to the Site that is used for drinking water puijioses is from the Delaware and Rantan Canal in Lambertville. .New Jerse>. The Delaware River feeds the canal ai^ Bulls Island State Park. L'niled Water, which supplies an estimated .i.4(K) persons in Limbeilv llie. uses the intake only for emergencv puiposes. The Delaw arc River is considered a fisherv and supports populations of blueback hening. small mouth bass, .American shad, hickorv shad, river hening, and channel catfish. It is de.signated a Wild and Scenic River south of Frenchtown. New Jersev and nonh of ,\lillord. New Jersev. According to the National Wetlands Inventor), palustrine wetlands are located along the Delavvare River in Frenchtown. Stockton, and Lambenville; .New Jersev and in Lumberville. Pennsv Iv ama. Giound water i.-. the source of drinking water within a I'our-mile radius ot the Site. .A ponion o\ the -New Jersev population vvithin four miles of the Sue receives their water from municipal wells. The Milford Water Dcjianmcnt and the Frenchtown Water Depanment serve Milt(Md .md Frenchtown, respectively. The two wells in Miltord are located approximately 1 to I' z miles from the Site, to the northwest, and service approximateK 2,000 persons. The two vsells in Frenchtown are located Vi lo .'^'2 miles from the Site, to the southeast, and .servKc approxim.iielv L.^OO persons. The water from the.se wells is blended, the remainder of the population within four miles of the Sile is served by private wells. Ii is estimated that nearlv 400 persons utilize , private wells within one mile ofthe Sue. it is believed that all oflhe dnnking waiei wells near the Site are located up slope and upgradient from the area of suspected contamination. The shallow ground water flow dircdion in the area is reponed 10 be towards the Delaware River. 2. Sile characteristics The Site was abandoned by Crown Vantage Paper, a former owner of ihe nearby Milford paper mill, as pan ofa bankruptcy filing in 2001 under Chapter 11 oflhe United States Bankruptcy Code. According to a Preliminary Site invcstigaiion Repon and a Memorandum of .Agreement prepared for James River Corporaiion. the landfill accepted vanous ixpes of w astes from nearbv Riegel Pa|K'r Co. facilities lor a|ipro\iinatcly ,40 years, beginning in the late I9.^0s. it is reponed lhat flyash, cinders, and bottom ash from the paper mill's coal burning steam plant; household trash and constiuction debris, including concrete, roofing shingles, metal ductwork, household appliances. .'^-gallon fuel drums, and plastic blocks; metal foil; olf-specificaiion paper; v\astewater treatment plant sludge; paper tiber sludge; and .>.'s-gallon drums v\ere deposited in the landfill while it was in operation. The .^.^-gailon drums were from the press room wastes (vamish, shellac, isopropyl alcohol, toluol, melhvethvl ketone. Cellosolve. Crysalone. inks ..md dves) and possible coating operation wasles (nitrocellulose, toluene, zinc oxide, eibyl acetate. . methylethyl ketone, alcohol, and dyes). It is also reponed that these operaiion w asies were also directly disposed of in the landfit!. Currenii) the landfill is uncapped, but significanlly vegetated The fill material in, the landfill,is approximately 20 to 25 feel ihick al its maximum and forms a- steep slope along its western edge. The majontv of ihe fill appears lo be fivash w uh badiv degrading drums and debris mixed in. At higher water levels the river erodes into the exposed side of ihe landfill causing significant scour, and according to the NJDEP. the release of materials into the liver. Aerial photographs oflhe Site beginning m 19}$ reveala path leading from .Milford-Frenchtown Road lo the Site: The Site al lhat lime was a distinctly-shaped wooded area along the nver bounded b\ larmland to the east, and dipping tow aids the river. Significant alteration of ihe Sue was evident m a photograph I'rom 19.^0 By that date, filling had taken place across more than 50*"^ oflhe Sue and was radialing oiitwards towards the nver. The fill along the southern hall oi the Sue had nearlv extended to the nver by this time. The available aerial photograph:, indicate that the landfill reached itsgreatest lateral extent sometime between 196.'^ and 197.'^' A'anous trenches, gullies, ponds, and excavations into the landlill were noted during the analvsis of the hi.siorical aenal photographs. B;ised on an analvsis of the historical aerial photographs, the volume of materia! deposited at the landfill is estimated to hav e been ,^ 1.^,000 cubic \ards; . 3.' Sue assessment activiiies/observations Several site visiib were conducted by the Removal Action Branch between June 200." and . .November 2003. The initial site visit was conducted with the .NJDEP tm June 25. 2003. .At the time, the NJDEP was in the process of completing a limi'ied response aclion Dunrig the visit, pigment waste was observed on the surface ofthe landfill, solvent odors were identified emanating from cracks and fissures in the landfill, and al least teri badIv degr.ided buned drums of vv aste were observed present near the surface on the landfill. Flood waters from the Delaware River had overflowed the western toe of the landfill and scoured the face revealing buned drums. Two of these drums containing a blue pigment had leaked^lheir contents near the riv er. A sample of this material previously collected by the NJDEP revealed elev ated levels of lead. A subsequent sample of this inaterial collected by EPA coii'fiim.ed the presence of 77.1(K) niii/ka of lead. Air monitoring vyas conducted throughout ihc Site dunng a July 22. 2003 site visit using a : Ludlum Model 19 radiation mcier and a R,AE Systems .MuliiR.AE five-gas meiei-. which included a photoionization delcclor^PID). oxygen meter, carbon monoxide meter, hydrogen'sulfide incier. and combustible gas indicator (CGI). The nidiation meter indicated slmhtlv above background , radiation measurements (up lo 5 microroentgen per hour above backgnuind. within ihiGC leei ol the ground). Areas were identifiied otTof the main pathwav al the Site, near the center ot ihc landfill, w here odors typical of organic solvents were identified. These areas were near subsidences that had occuned where test pits had been prev louslv excav ated bv the NJDEP .Monitoring at these locations with the PID indicated breathing zone readmgs ranging from 5 to 15 units above background. .Al one of the IcKations direcllv above the ground suriace. PID readings peaked at 1.500 units above background, oxvgen levels dropped to 13'^. and the CGI peaked at 20'^ of the lower explosive limit. On November 12 and 13. 20f)3. EP.A personnel and coniractor repieseniaiives hom the Removal Suppon Team (RST) and the Environmental Response Team s Research. Engineenng and ' Analvtical Contractor (RE.AC) conducted a sampling eveni at the Site lo suppon an Integrated .Assessment (I.A). The effon included the collection of 10 surface soil samples. 14 sediment samples. 4 surface water samples, and 5 waste samples in and around the Sue (see Figure 2i The soil and waste sample locations were chosen judgmenialK to k>caie and identitv potential sources ofcontamination. .All ofthe soil samples, except for the two background s;imples. were collected eiiher trom ihe landt'ill tace or between the nver and the landlill lace. Both background soil samples were collected approximately 750 feet east and southeast of the Sue. The sediment and surface water samples were collected from vanbus locations along the Delaware River, including both upsiream and downstream. The waste samples were collected from vanous surface locations ai or ne.ir the landfill's face. The analyses conducted on the samples included: Target Compound List organics. Target .Analyte List inorganics, cvanide. herbicides, and lull Toxicitv Chariiciensiic Leachate Procedure (TCLPi. .Analvsis of the sediment ^ample^ incluJeJ total organic carbon and panicle size analvsis. It was noted during these sile visits thai there are multiple paihwavs situated thii^ughout the kindfill. One path passes over the center of ihe landfill and is w ide enough U>r v ehicul.ir ii.illic It is reixined th.it these paths were maintained bv the paper mill until around 2U(ll lor ihe recrcaiumal use of employees and nearby iesidenis. .Another path bounds the landfill along the Delaware River and slopes gentiv upward from north lo souih. It is reponed that during a Mav 31, 2001 inspection of the Sue b\ the .NJDEP and personnel from the ow ners ol the paper mill at the lime that deienoraling 55-gallon drums vvere encountered protruding from the landlill all along the Delaware River. The drums were reponed to be emptv and no odors were detecled. This inspeciion occuned approximately ten years after the former ow ner of the paper mill had removed drums and other matenals from the surface of the landfill. Also observed dunng the May 2001 inspection were old tires, smaller metal drums, metal duel work, paper debns, aluminurn foil laminated paper, and other assoned debns. It was reponed that the highest concentrations of drums were observed along the southern reaches oflhe edse oflhe landfill. A fence installed around the Site by the NJDEP had been severely damaged along the river due to the elevated vvater and tlow levels, and from impact by large poitions of fallen trees that loutineh fall into and flow down the Delaware River. The damage to the fence required ihai most of the portion along the river.,bank be removed. Some of the posts werC'Tcplaced and stninds of w ne. signs, and caution tape vvere placed to,mark the landfil Elevated flows subscquenilv lunher damaged some of the remaining posts. The honhw eslcm edge of the landfiU appears to be iinpacied to a greater extern b\ ihc flow o) ihe river. A ponion ofthe coastal topoeraphy:in this area projects inio the nver as it nanows and ha-> formed a small island. Thi.s area contains large mature trees and piles of trees and iree limbs that have migrated to this point from upstream During periods ol excess flow in the river, the water channels between the face of the landfill and this island. As w aier levels increase, this flow channel eventually covers the island. The flood w aiers^enier and impact the face ot the landfill directly at this point. It is from this point south to an area where the nver has attained its smaller width that the most significant erosional ciamage has bccuired. Drum,carcasses. st;iined soil; pigments, ash. roils of paper, and met.al debns are visible in the lace of' the landlill. The known-kev problem areas al the Site include the presence of buned drums and w;iste ' material, contaniinated soils, and subsurface organic vapors. The nver's impact on the-landljll face and rcsuliani direct contacl. with exposed vvasie materia! is the pnmaiy concern. 4. Release or ihre;ilened release inlo the environment of a hazardous substance, or pulluiant or contaminant ^ During the earlv 1990s. the tbrmer ow ner of the properiy. James Ri v er Paper Coip.. conducted a preliminaiy investigation al the Site which included removal.and disposal of surlicial containeis and waste maieinal. Sampling of the vanoiis v\asie streams ideniilied: benzene, toluene, ethylbenzene' xy lenes, acetone, methyf isobutyl ketone, methv lene chlonde. 1.2-dichloroeihene. trichloroelhene. siyrenc. carbon disulfide, and 4-meihyl-2-pentanone. .A soil gas survey identified leirachloroeihene. 1.1.1-inchloroeihane. tnchloroethene. benzene, toluene. ;ind xvlene^ in the landfill soils. • • . . The -NJDEP conducted a limited investigation at the Site dunng the penod mid-2002 through mid-2003. Il included the excavation of test pits, and the removal and dispo^al of waste ni.iicn.il and containers discovered at ihe.surface aiid in the subsurface A lota! ot' 99 drums were excavated and overpacked.46 of which were found to coniain some ponion of liquid Dunng the initial hazard categorization screening process, a majority ofthese drums were found toconiain organic vapors ranging up to hundreds and thousands of parts per million, as measured b\ a PID Analysis of 17 composite samples collected from the diums for disposal puiposes identif ied lhal 13 ol' the samples exceeded the regulatory limit of 140 degrees Fahrenheit for the RCR.A characierisiic of ignitabillty. all igniting at room temperature (77 degrees Fahrenheit). Six of ihe samples exceeded the regulatory level tor the RCRA characteristic of toxicity using TCLP. The limiis were exceeded, mosi of them significantly, for l">enzene. 2-butanonc. letrachloroethenfe. tnchloroelhylene and heptaclor. Benzene was detected in two samples at a TCLP conceniiaiion greater tban 2.50 times the regulatory limil. Tetrachlorethene was detecled m two sainples at TCLP conccniralions greater than 900 limes and .30,000 limes the regulaiory limit, respectively. Trichloroelhylene was delected in two samples at TCtP conccniralions greater than 8,500 times and 17,000 times the regulaioiy limit. .Many ol ihe oilier .samples coniained deieciahlt.- ICVLIS UI contaminants in ihe leach.iie. an indicalion thai although ihc limits were nol exceeded, ih.ii iheie was leachable matenal present. Several of the composite samples detecled low levels ol cyanide and polychlonnated biphenyls (PCBs). On April 25. 2()03. the .NJDEP collected 22 surface soil (0-6 inches) samples trom ihe Sue I he NJ DEP reponed lhat samples collected from the exposed face of the landfill alongside the nver showed exceedences of both the state residential and nonresidential standards for metals and semivolatiles in many of the samples. These mclude lead, copper, v anadium, and numerous individual polyaromatic hydrocarbons (P.AHs). including but not limited lo. ben70(a)anihi;icene benzo(a)pyrene. benzolbilluoranihene. benzolkitluoranihene. dibenzuia.h i.mihracene. and indenot 1.2.3ipyiene. It was reponed that there were sporadic exceedences of the state leMdeniKil standards tor dieldrin. DDE, and total PCBs. The NJDEP also rept)ned that other PAHs. including but not limited lo, acenapthene. chry sene, dibenzof uran. fluoranthene. t'luorenc. naphthalene, phenanthrene. phenol, and pyrene, as well as those listed previously in this paragr;iph. exceeded the Severe Effects Level (SEL) Sediment Screening Cniena. Il should be npied lhal this dala did not undergo a rigorous data validation rev lew and it is bemg pre.senii.u only as screening d.iia indicative oflhe type of cont;iminaiion that is prcscni ai ihe Sue. Table 1 lisis a summary of the analytes/compounds identified in soil and waste samples coilecied al the Sue by EP.A on November 12 and 13. 2003 and their respective maximum eonceniiai I'abk' 1: Summary of .Analylical Results from Soil and Wasie Sample^ Collected at the Crown \'aniai;e Landfill on November 12 and 13. 2003 Siil)^l;mci- M;i\lllUII1l XlvdI.i C'liiutnliMtiDn 1 inii'NL'' IVIAIIIIIM) 4 4 Mill 4 (1 Mill i.hn Hill Hill i:.S(io "T.IUCI IlKkol 441 \an;idiuni 044 ?.Oll T49 luphilijlonc 4!jJ Ji t'lijplntu'fiL' 40(1 J n .ivIC Jihcii/iirmuii IW J Tahlf 1: (continued) SiilKljnii- M.ixiinujii Midij t'niHi'iilialidii Di'Uclwl tllKWOflO .v>0 J plicnjillliivik' .vslXM u jsK' 840 J «JMC nuoiuiuhcnc .s.:oo J WUMC p>l.'il.'• 4,-OOJ . ^\ JNIV IX'PVih .1 ijllllll JiCIK' :.su(i J ua^U' i.lir\ voiii'. : -WJ I "j^ii.' hjii/iii h illiiui iiiislicnc :.;:ouj licii/ii- k 'lluiirjiUlK-iK- TOOJ ncii.'ii. J ip\ 1 L'liL' :;.uutj J :iij,-:i.. i.:.-vd'p:.i.'n.- i .-dol • •:.v:.. ;:.:. . 4s(( 1 •.'..IO.. Ivn/ii. u.li.i 'pcrv k'lic SSU J IV .IML' Ji-!i-h':ii.'.lpl''.!lu:.ilv' 14dfi I 'i: VV.|.;.- 4 4-IW 2 S. p,-nl,i^!ii.iiuplK'i'.ivl ,v.,.;.- .ir.vli.i-1:^4 :o Mill \1CP.A sso \va^k' MCPP i:u vvj^k- • 2-iiiv;!li\l-4-v.hKirv>ptienvi\\;k'L'iit-.Kid. ?-f--mei)i\l-4-chltiri>pfiirnvi\> ipi.ipiiink';k id .A soil Sample collected iVom ihc f'ace oflhe norihwest ectge oflhe landfill.nc.ir the pvunl where the Delaware River directly impacts the landfill exceeded ihe TCLP limit for chromiuin (5.0 mg/I). The sample was coilecied in an area where drum carcasses, fragments, and other debris are exposed.' A waste sample collected from the remnants of a container that appeared \o hav e once held either piginent or paint sludge, located approximiilely 400 feet funher svuiih .iKiiii: Ihc face of the landfill, exceeded the TCLP limn for lead (5.0 mg/i). Many of ihc PAHs delected in ihe waste samples idemified in Table 1 were deiecled in the soil . • • " 7 -/ ' samples collected withm the ten-year flood plain significanlly above the level-, louiid in ilni e , bav-'kgiound soil samples. Several pesticides and PCBs. which were nol delected m the background samples, were idemified in ihis same ;iiea. PCBs. which were nvii deiccied m ihe upsiream sedimeni samples, were ideniified in .seditiicnt sarnples collected adjacent ivi the Sue An herbicide known as 2-melhyl-4-chlorophenoxyacetic acid (MCPA) was identified m the majority of the samples collected by EP.A. .All bul one of the sedimeni samples cvillecied. including the upstream samples, contained this compound al eoncenlrations ranging from 70 mg/kg to 680 mg/kg. The highest conceniiaiion was identified in a sediment s;imple coilecied adjucent lo the Sile. A sample collected approximately 250 feet upstream of the creek thai bounds the former Milford paper mill to ihe nonh revealed 400 mg/kg of .MCP.A. fhi.N lik.iih.;. is approximately 4.750 feet upsiream ofthe landfill. Two waste samples collected near the souiheasiern ponion oflhe landfill, at points of relatively higher elevation than the imiiacied northwestem edge, ideniified ,MCP.A. The highest concentration identified in a waste sample was SSO mg/kg. 2-(2-methyl-4-chlorophenoxy )propionic acid (MCPP) was identified m vine ol these two waste samples at 120 mg/kg. Seven of the ten soil samples coilecied coniained .MCP.A The highest concentration (310 mg/kg) was identified in a soil sample collected near the northwestem edge of the landfill, ll should be noted ihat these herbicides were not deiecied m eiiher of the iw o background soil samples. .All ol the m.iienals listed above except tor vanadium. MCP.A. and .MCPP are L'ERCL.A designated Hazardous Substances, as listed in 40 CFR Table 302.4. The analy tical data presenled above is a summary of the most significant data available from the aforementioned reporis. Il is nol meant to be inclusive of all of ihe analyies or conipounds dciecicd ;u ihe Sue The miechani.sm for past releases.lo the environmeni a|ipe;irs ivi have been ihc wa>ie dl^po^.l! practices al ihe Sile. W'asle materials, including drums, were deposucd at the site ;ind buned over a period of several decades. Cun-ently. although there hiive been at least two activms ai the Sile in the past to remove waste containers, the full extent ofcontamination and ihe deposiUvm vil waste material and drums is nol known, and remains uninitig;ited. .Although fenced, ihe Sue is accessible from ihe river, which is widely used forrecrealional purposes. The Delaw,ire River s nsing w iiier levels are impacting the landfill. Surficial coniamination and waste containers may be transponed of'fsiie by the river's flow along the western face of the landlill. The majority oflhe samples collected during the November 2003 sanijilmg event were from within the 10-year flood plain ofthe Delaware River. Based on visual observations of the water level made during site visits in late June 2003 and mid-November 2003. nu)si of ihese s;imple locations would have been flooded. Ba.sed on Delaware River Basin Commission (DRBC) stream flovv and gauge dala frvim Riegelsville and Trenlon. .New Jersey, and compar.itive observ ations of Ihe DRBC data from June and ,Novemlior 2003, il appears that flooding of this nature has occuned at the Sile at least five limes since February 2003. The presence of liquid waste materials in deieriorated (.hums, buried over .sevenil decades, is indicative lhat there would likely be a release occurring. Test pits conducted by the NJDEP have 8 . confirmed this. Polcniial exists I'or downward flow or absorption of ihc released w.isie m.iieii.il inio the flyash that is ubiquitous al the landlill. Tbe faci that there is no evidence o\ leachate or ground water flow in the form of springs v isibly discharging along the western face of ihe landlill may be an indicalion lhat the ground waler. precipitation, and the subsurface coniaminanis are flow ing in a dow nw ard direciion. Future releases of drums, wasie material, flyash. and contaminated soils will continue unabaicd lo the Delaw are River should conditions remain unmitigaied. The landf ill is not capped anu ihe vvesiem face ofthe landfill is un.secure. Materials released could imp.ici |x-isons using ihe rivei. Persons accessing ihe Sue tVom ihe nver could be unknowingly exposed lo ihe wasie malerial. During the penod June 2003 through January 2004. the Delaware River's monthly average flow rates were approxiinately T'QQ'i above historical norms In September and October 2003. ihe monthly average flow rales ranged from between AOtYi to 600''i above normal. The observed piecipilation for the Delaware River Basin above Tienton. New Jersey from Januarv ihn>ugh mid-October 2003 was 9.33 inches above normal. If these hydrologic conditions continue, the releases could potentially increase as the landfill face is further eroded. 5. .NPL status The Crown Vantage Landfill is not an .NPL site. .An Integrated .Assessment is cunentiv bemg performed and funher pie-iemedial activ mes are expected lo deiermine wheiher the Sue shviuld be placed on the .NPL. 6. .Map. pictures and other graphie lepresenialions .Appendix .A provides a senes of photographs laken during the removal ;issessmcni !h;ii .ne indicalive ol recent conditions al the Sue. B Other .Actions to Date I. Prev ious actions During the early 1990s. James River Paper Coip. conducted a preliminary investigaiion of ihe Site which included; monitoring well installation and ground water sampling: a soil gas survev: ;i magnetometer survey: and a characienzatum of drums at the landfill suriace. I he invesiigalion revealed ihe presence of approximaiely 800 drums on the suriace of the landfill and volatile oiganic vapors present in the soil. After consolidation, the company subsequently removed approximately 19.5 Ions of off-specification paper rolls. 475 empty drums, and 69 panially-f ilied to filled drums containing wastes, including flammableliquid s and soil combined with pigmenls. dyes or paint sludges. St;iined soil w as ideniified possibly as a result of the dumping of chemicals. Sampling oflhe waste; streams identified numerous haz;irdous substances. There have been no previous Federal actions laken at the Sue. 2. Cuntnt actions Cunently. there are no Federal actions taking place ;il the Sue C. Stale and Local .Authoniies' Role 1. Slate and Iwal actions to dale The -NJDEP issued nonces of violation bf ihe .New Jersey Spill Compensaiion .Act and the Solid Waste Manaaement .Act to James River Paper Coiporation on .Apnl 23. 1991 forthe discharge ol' a hazardous substance and I'oi constructing and operating a landfill without DepartmenI appivival, respectively. The company entered into a voluntary Memorandum of Agreemeni w uh ihe NJDEP to address discharges in ihe drum disposal area. .As pan ofa bankruptcy .seiilemeni with Crown X'antage, the NJDEP received SI millon to uiiii/^ for costs incuned for closure, cleanup, remov al. and oversight necessary to bnng any -.md .ill Crovvn \'antage related propenies in ihe State of New Jerscy toiher than ihe paper milli inio compliance wuh applicable laws. \\'iih a ponion ofthese funds, the NJDEP insialled .i fence around mosi oflhe landfill (the metal f'abric had to be removed from the fence iilvmg pvinionN VH the nver due to damage from high water levels); placed warning signs; huili gr;ivel access IVKKN ihroughviui the sue: evillecied siiriaee soil >ain)iles: cvmducied a series ol icsi pn> ihroughvuii me landfill; and excavaied. overpacked. and disposed of-)^) drums of waste ;ind I 1 rolloffs ci>ntaining drum carcasses, metal debns. .ind l.irge paper products from the landfill 2. Potential lor coniinued Siaie/local response ,Ai this time il is not known vvheiher ihere will be any luiuie Stale or local ;ictiv)iis taken al ihe Site. III. THREAT TO PL BLIC HEALFH OR WELFARE OR THE EN\ IRONMENT. AND STATUTORY'AND REGULATORS ALTHORI flES A. Threats to Public Health or \\'elfare There is a potential exposure to nearby human populations from hazardous stibslances. polluiants or contaminants (40 CFR §3U0.415(l))(2)(i)). The Sile is an un.secure landfill that received chemicals and waste malerial over a period of several decades. CERCL.A h;izardous substances, including RCR.A-charactenstic hazardous wasles. have been identified at the Sile ;iiid in panicular, in the surface soils along the Delaware River, the ponion ofthe Site thai rem;iins accessible to the public. .Many of these substances, such as the P.AH compviunds. benzene, tetnichloroethcnc. inchlonxrihcne. hcpiachlor, and chromium ;ire know n i>r suspected carcinogens. Ixad is a cumulalive poison. Exposure to MCPA leponcdly causes ineveisible eye damage. Exposure lo elevated levels of volatile organic compounds delected in deierioraied 10 drunis'excavaicd froni ihe landf ill and in vapoi s emahaimg .I'miii subsidences al ihe lop nl ihc v.iiindl-ill Prior to ihe f'en'ceinsiailaiion. it 'is reponed that the Site was used by workers from,!he nearby ,; . paper plant during'breaks'and by iiiouniaiht»ikei"s. Path ways thai existed through the hmdiill ,. iTiade fbr easier access. Th(?-Si.le-w-as .refK>riedlv.used'as.a-shbn-.cut by kayakers, by, bird , vvatchei'S. and other.recrealic)hai users of= the Delaware River due id'iis,pi"oximuy and location, adjiicenf to state pdrk lands. .A barbeque pit is present in an aiea at the top iif the landfill, :Acc es- to the Site.remains available since tiie ferice on the Delaware River side lisonly panial due to the • river's impact. The potential exi.sts foi; pei;sons to access the Sue from .ilong the nvei bank or directly via the nver. as in the case of a ka'yaker. .Persons accessing lhe Sue could come into ' direcrconiac.i w ith the,ex[50sed vvasie material located along the edge of ihe landlill-'pepending • 'on iHe activities of the persons accessing the Site, poieriiial exposure could occur ihnnigh derm.il .. contact! inhalation or mgesti6n.''The subsidence areas offer polcniial inh'alativm exposures tvi ' • ' eleS ated levels of'unknow n organic vapors. • ' ,. Hazardous- substances or po'iiluianis or.ooniaminan't's are presehi'ln druniV barrels, lankvor-oiher - Kilk storage,coniaibers ih.ii may pose-,alhrearbf release (40 Cl- R >!3()().4I5(h)(2)(iii)) Prev iou-- inv esiigaiions by boih ihe former ow ner/operafor and the NJDEP have rev ea led ihe piescnceol , drums coniaining hazardiiu.s subslanCesuil the Site. Soipe'of ihese conuimers could have.tx'en • pre sent ai this location for over-a half of a century.' Test piLscbnducied by'fhcNJDEP revea'cv.!'.. . ,thal many of these containers" are in deterjofa!ed;condiiion and it is',likely ih.ii .soine hav e released • thej'r vroriteni.s into the landfill. Jf is not known how many dnims are buried ai_ the landlill These ' cori taineis.posc a threat of'being exposed along.,ihe nver due to ihe scouring efleci vin ihe I'.uc v>j the landfill.. The presence (.if elev ;ited virganic x.apvirs in areas..ii ihe lop vil ihe l.mdtin is .I'n '; " ; indicalion of the release thai has occuned |n the siibsurlace. Il.is not know w hai eflect ihis rele'iise.is having lo ihe ground water-. Theproxiinuy ot;'the nvei"ni;ikes u-difficufi.to monitor-.-ihe shallow vvater fable bviiween ihe nver and the.landfill dtit^ uvihe fiver inierface at those dcpihs • and the.dilutiveei'f'ecis i)f the rivet'.: ;• • 'r : :'\ / . .• High lev eis of hazardous substances, or pollutants or cbiitaminants in,soils; l;iigely at or neai liie .surface., may 'migrate (40 (:.FR'§3'(|0.41'5.(l>)(2.Kiy)'). Elevated lev els ;of CERCLA hazardous sub.siance,s. including P.AHs and heav y- meials.-have bciin ideniified along the exposed ponion ol the landfill in the form of wiisie nviteiiai.and'coniaminated'stii'ls-. Thisponiqirol ihe laiidfilf is •:. vv iihm .ihe 10-year flood plain of the Delaware Riv.er. 'The face iif ihe landl ill along tlie Delaw are'' .' Riv er has been impacted by the riv'er's scouring effecl. which causes lhv.\se maien;ils to inigraie. , The increased flow rates.and lesuliani above riorinal vvater levels in the nver over the past vear hav ' W.e 'i'iihcrcd'ndi i i'phs-' ex ist. that may cause hazardous substances lomigrate or Ixrrclcased (40 CFR : §300.415(l))(2)(v)). During i>criods of:elev ated flovv. theDe!a\v;irc River is undcrculling and eroding the exposed.vvestcrfi .face of the laiidf'ill:'-.Over the past year, w atei" lev els have incre;ised • > dranialically on ihe D'elayvare River, resulling in the exposed face ie]>e;iledly beiiig baliercd by the nver's flood waters. The scounng is having a visible impact on the landfill's face This could potentially result in funher exposure and releases ot wasie maienal from ihe landfill. Threat offire orexplosion (40 CFR vj300.4l5(b)(2»(vi)i Elevated leveK of oig;inic vapors h.r.c been detected in the subsurface ofthe landfill and in areas of subsidence ;ii ihe upper ponion oi the landflll. There is ev idence of a past barbecue or campf ire near one of ihose areas. The presence of vapor levels at 20'^ oflhe lower explosive limil is an indication ihai ihere mav be a potential for a fire or explosion should an ignition source such as a brush or camp flre be present m those areas. B. Thre;its to ihe Environment There is an actual or ixiieniial exposure li.) nearby animals or ihe food chain Irom hazardous substances, pollutants or contaminants (40 CFR §3()(>.415(b)(2)(i)). The Delaware River is considered a fishery. American shad, hening. smallmouth bass, channel caUish. and walleve are caughi ihroughout the nver. including in the vicinity ofthe Sue. CERCL.A h.iz.udous substances, including RCR.A-characienstic hazardous wastes, P.AHs. heavy melals. .md PC B- have been identifled ai the Sue. These substances could impact ihe flsh and have the poienii.il iv enter the food ch.iin and be consumed by persons lishing in the area ol the Sue. fracks ideniiiied ihroughout the Site indicate lhal a v anety of animals pass through the Site and could poienu.illv be exposed lo and impacied by ihe wasie maienal ihai is preseni. H;i7ardous substances or pofluianis or conlaminants ;ire present in drums. b;inels. tanks or lUher bulk storage containers that may pose a threat of release (40 CFR v^30O.415(l))(2)(iii)i. .As the nver funher erodes the face ofthe kindflll. drums containing h;iz;irdoiis substances may be exposed and their contents released into the environment The potential exists lor these substances to impact the flsh and wildlife in the area ofthe Sile. High levels of ha/ardous subslances or pollutants or coniamin;mis in soils. I.ngely al or ne.ir ihe surflice. may migrate (40 CFR §300.415(l>)(2)(i\)). Elev;iied levels of hazardvius subsi.iiKcs have been identifled w ithin ihe 10-year flood plain of the Delaw;ii-e River. The lace vif ihe landflll along ihe Delaware River has been impacted by the river's scouring effeci, which causes ihesc matenals to migrate. The soil and wasie malerial along the face of the landflll are unprotected and readily available to migrate. The potential exists for a signif icant release to occur with increased flow rates and above normal water levels in the nver, which could potentially impact the flsh and w ildlife in the area of the Sile. Weather conditions that may cau.se hazardous subslances or pollutants or conlaminants to migrate or be released (40 CFR >j3()0.4l5(b)(2)(v)). During penods of elev ated flow. the Delaware River is undercutting and eroding the exposed western face ol the landflll Over the past year, waler levels have increased dram;itically on the Delaware River, resulling in the exposed face rcixratcdiy being battered by the river's flood waters. The scounng is hav mg a visible impact on the landflll's face. This could polenti;illy result in further exposure and 12 releases of w;isie ni;iteiial. which could poieniially impaci the fish and wildlile in ihe .irea ol ihe Sue. E.XPECTED CHANGE IN THE SITUATION SHOL LD ACTION BE DELAS EU Ok NOT TAKEN Delayed action w ill increase public health risk lo ihose persons that access the Sue In ;iddiiion', the potential exists for continued release of containers and migration of poienii.illy elev ated lev els of CERCL.A hazardous substances inio ihe Delaware River. ENFORCE.MENT To date. CERCL.A 104e Request for Information letters have been sent lo, and responses received from. Georgia-Paciflc Corp. and Smurflt-Sivme Container Covp. Addiiivmal seaiclx - and investigations are expected in order to determine if ihere .ire any other eniiucs thai should receive a CERCL.A 104e Request for Intvumaiion letter .A flnal dcieimmaiion on ihe PRP si.iu;- of these companies has not been completed. \ I. CONCLLSIONS Based on (he available iiilvirinalKin. a release v.)l CERCL.A hazaidvuis sLibsiaiucN ii.is vkMincu .li tbe Sue. The Sue is a tacility as deflned in CERCL.A. .A C ERCL.A Rennual Action is uarraiiieu to muigaie the ihreais and poieniial ihre.iis lo public health or well.ue and ihe environmeni pvKcu by the wasie maienal preseni al the Sue \1L RECO.M.MENDATIONS It is recommended that an action be taken lo stabilize the exposed kmdlill face in oider ui elimuKiie ihe pviieninil for coniainers and other w,aste materials frvim being released inui the Delaware River. The siabilizalion action should be able lo wuhsiand ihe nver's impaci durinv; increased flow rates fora period of time until a permaneni remedy is prepared U)r the Sue .Additional actions that are warranted at the Sile include: removal of drums, containers, and oiher Waste materials along the face ofthe landflll and other exposed areas; investigation ot the exieni ofcontamination and the presence of buried drums and containers: removal of drums, conuiineis and other waste matenals. as deemed necessary; investigation ofthe source of elev ated org.inic levels in the landflll subsurface; and invesiigalion of polcniial ground w ater conuiminalioh. 13 ^1-7 f<^6lOdiTDvoh( "l/z OuAb. FIGURE i .APPENDIX A: Photographs V Photo No. 1: Exposed druiTLS, :/^.KM:^ft'./c'^--/i waste, and debris at the northwest ^ comer of the Crown Vantage Landfill along tht Delaware River - July 22, 2003 Photo No. 2: Exposed waste and debris on the western face of tlie Crovvn Vantage Landflll along the Delaware River - July 22, 2003 Photo No. 3: Pathway adjaiisent to • the western facib ojf the Crown Vaiitage l^nd/ili atong the. , Delaw are River. Ind ications of high water, leveils on damaged feiice Npveniber T2, 2003 - ' Photo No. 4: Pathway adjacent to the w estern face bf tlie Crown Vantage iJindnjl along the . Delaware Riyer: Indications of high water levels cin trees - November 12 ; 2003 Photo No. 5: No^thv^•est comer of tlie Crown Vatifage LandfiU along the Delaware River, Location where the river channels between the landfill and a wooded area. Note: recent water level on fence post as indicated by leaves - November 12. 2003 Photo No. 6: Westem face of the Crown Vantage landfill along the Delaware River. Indications of dmnis, debris and waste malerial - November 12, 2003 Pljoto No. 7: Delaware River flooding along the westem face of the Crown Vantage LandfiU - June 25, 2003 Photo No. 8: Delaware River flooding .at the nonhwest comer of tlie Cro\\u Vantage Lindfill along the Delaware River (.see Plioto No. 1) - June 24, 2003 m^/^:^^-rm^p^//^ m^^^-z^ Photo No. 9: Exposed flya.sh on the westem face of the Crown Vantage Landfill along the Delaware River - June 25, 2003 ENSR AECOM Appendix B Sampling and Analysis Plan (SAP) April 2007 Prepared for: Georgia Pacific Atlanta, GA 6f ' '/^ ~>''lf^lC^Vl^^'i Sampling and Analysis Plan Slope Stabilization Measures Crown Vantage Landfill Site, located in Alexandria Township, New Jersey Revised in Accordance with EPA Letter Dated March 5, 2007 Time Critical Removal Action under EPA Administrative Agreement and Order on Consent, Docket No. CERCLA-02-2005-2017 ENSR Corporation April 2007 Document No.: 03060-062-302 ENSR AECOM Prepared for: Georgia Pacific Atlanta, GA Sampling and Analysis Plan Slope Stabilization Measures Crown Vantage Landfill Site, located in Alexandria Township, New Jersey Revised in Accordance with EPA Letter Dated March 5, 2007 Time Critical Removal Actiori under EPA Administrative Agreernent and Order on Consent, Pocket No. CERCLA-02-2005-2017 Prepared By Kathy Whooli ; Project Specialist Reviewed By Donald P. Hessemer Senior Program Manager ENSR Corporation April 2007 Document No.: 03060-062-302 ENSR AECOM ENSR Contents 1.0 Introduction .....1-1 1.1 Project Description ', 1-1 1.2 Purpose , , 1-1 1.3 References : 1-1 1.3.1 General References 1-1 1.3.2 Site Specific USEPA References 1-2 2.0 Drum Screening.... 2-1 2.1 Drum Reconnaissance/Inspection 2-1 2.2 Drum Opening 2-2 2.2.1 Manual Opening with a Bung Wrench 2-2 2:2.2 Drum Opening with a Drum Deheader.,. 2-3 2.2.3 Hand Pick, Pickaxe, and Hand Spike ;„.,. ,. 2-3 2.2.4 Backhoe Spike ;.,., '. ; 2-3 2.2.5 Hydraulic Drum Opener 2-3 2.2.6 Pneumatic Devices 2-3 3.0 Sampling ....3-1 3.1 Sampling Equipment/Apparatus ...3-1 3.2 Drum/Waste Storage and Sampling Pad 3-2 3.3 Initial Drum Field Screening ,,,3-2 3.4 Drum Sampling Methods , 3-2 3.5 Field Instrument Calibration 3-3 3.6 Sample Equipment Decontamination 3-4 3.7 Sample Frequency ...3-4 3.8 Sample QA/QC :,.. , 3-5 3.9 Laboratory Sample Analysis '. ....3-5 3.10 Sample Documentation , : 3-6 3.11 Sample Shipment Guidelines 3-7 4.0 Sample Preservation, Containers, Handling, and Storage 4-1 4.1 Sample Preservation ; 4-1 4.2 Sample Containers : , 4-1 4.3 Sample Handling., 4-2 4.4 Sample Designation 4-2 J:\Project\Georgia-Pacific\03060-062 Milford CV I April 2007 Landfill\WorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN- FINAL-4192007.doc ENSR \ / ., ^ . . ' - • • 4.5 Chain-of-Custody F'rocedures 4-3 4.6 Sample Security/Storage 4-3 5.0 Drum and Waste Recovery 5-1 5.1 Waste Stream Characterization ..;.-. 5-1 5.1.1 Waste Stream 1 (Drummed Flammable Liquids from Coating Operations),;, ..5-1 5.1.2 Waste Stream 2 (Rags and Other Materials Generated by the Coatings Process) 5-1 5.1.3 Waste Stream 3 (Waxy Substance from Coating Operations Containing MEK) 5-2 5.1.4 Waste Stream 4 (Soil Containing Pigments, Dyes and/or Paint Sludges) 5-2 5.1.5 Waste Stream 5 (General Solids with'No Headspace Readings) 5-2 5.1.6 Waste Stream 6'(Hard, Waxy Solid Substance) 5-2 5.1.7 . Waste Stream 7 (Oil Contaminated Rags)....,..,...; '. 5-2 5.2 Non-Hazardous Solid (Bulky) Waste 5-2 • . 5.2.1 Empty Drums, Carcasses and Remnants .;.5-3 5,2,2 Non-Hazardous Solid Wastes 5-3 5.3 Investigation Derived Wastes (IDW) 5-3 List of Attachments Attachment 1 EPA ERT SOP Docunients Attachment 2 1992 Woodward Clyde Consultants Report J:\Project\Georgia-Pacific\03060-062 Milford CV II , , ' • April 2007 Landfil^Wo^kPlan\FINAL-April2007\ENSRSAMPLINGPLAN- FINAL-4192007.doc -. ENSR 1.0 Introduction This Sampling and Analysis Plan (SAP) was prepared by ENSR to accompany ENSR's Work Plan prepared to address time critical removal actions at the Crown Vantage Landfill Site ("Site") situated in Alexandria Township, Holland Township, New Jersey. 1.1 Project Description As stated by the US Environmental Protection Agency (EPA), 'The time-critical actions to be implemented generally include,..., the stabilization of the landfill face in order to eliminate the potential for containers and other waste materials from being released into the Delaware River; immediately securing the Site against unauthorized access; and a search across the entire surface of the landfill to identify, retrieve, and dispose of any drums/containers/pails and their contents that are present above the ground surface, in order to minimize direct contact threats with these materials." The project involves two distinct operational goals to be implemented to comply with the United States Environmental Protection Agency (USEPA), Region 2, Administrative Agreement and Order on Consent (AOC) for Removal Action executed on May 26, 2005 between the EPA and the Fort James Operating Company (FJOC): • Construction of a barrier wall along the southwestern face of the Crown Vantage Landfill abutting the Delaware River shoreline. During the construction, of the barrier wall various excavations will be conducted. It is assumed that, during excavation operations, drums may be encountered. • The removal of surface drums, containers, and pails throughout the entire landfill area. The entire surface of the landfill will be inspected. Any drums, containers or pails (collectively referred to in this Plan as "drums") found at the surface or partially buried will be removed, 1.2 Purpose The SAP will address the sampling and analysis procedures to be implemented during the drum removal activities in order to identify and properly characterize drums and other containers and their contents removed from the landfill surface for ultimate off-site disposal at an appropriate disposal facility capable of accepting CERCLA wastes. 1.3 References This SAP was developed to include procedures and methods to be implemented to sample soil, waste, or the contents of containers that may be encountered during.the removal action. Sample analysis will be performed by a Contract Laboratory Program (CLP) certified laboratory in accordance with 'Test Methods for Evaluating Solid Waste" (SW-846) or equivalent non-CLP laboratory as indicated in the AOC. EPA will be notified of FJOC's use of a non-CLP laboratory as specified in the AOC. the SAP includes testing for compatibility and disposal characteristics, as needed, to properly identify the treatment and disposal methods for each category of waste found. Waste characterization and classification activities will be performed.within a reasonable time frame to meet specific RCRA storage requirements to limit storage time on-site of all waste streams. 1.3.1 General References The SAP will be implemented, where applicable, in accordance with the relevant applicable methods as specified in the following EPA published documents. J:\Project\Georgia-Pacific\03060-062.MilfordCV -1-1 Aoril 2007 Landfil^WorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- • 4192007.doc ENSR • "Guidance Document fpr Cleanup of Surface Tank and Drum Sites," May 1985 • "Drum Handling Procedure at Hazardous Waste Sites," January 1986 • "Characterization of Hazarclous Waste Sites - A Methods Manual, Volume I - Site Characterization," August 1985 • ' "Volume.ll-Available Sampling Methods," December 1984. A full copy of these reference documents will be maintained in a separate binder in the site trailer along with the Work Plan for easy access by all site personnel, on an as needed basis. 1.3.2 Site Specific USEPA References A list of site specific compounds documented at the site is provided in 'Table 1: Summary of Analytical Results from Soil and Waste Sampleis Collected atthe Crown Vantage Landfill on November 12 and 13,.2003" which was provided in the USEPA Removal Site Evaluation'Meniorandum dated May.'25, 2004. This document is appended to the Work Plan under a separate tab identified as "EPA Correspondence/Orders." The document identifies the site specific constituents, hazardous substance, pollutant and/or contaminants identified at the Site based on historic samplihg results to be considered in waste classification sampling activities. As requested by USEPA, to meet the provisions for all waste steams to be analyzed for the TCL and TAL compounds included in the EPA Removal Site Evaluation memorandum, this constituent list will be incorporated into waste characterization sampling activities to assure that all potential underlying hazardous constituents (UHC's) are properfy'evaluated. Once specific drums have been categorized into separate waste streams; based on waste classification and profile sampling for waste disposal facility selection criteria, then a minimum of one (1) sample per waste streahi will be collected to adequately characterize TCL volatiles,,semivolatiles, pesticides and PCBs and TAL metals and cyanide, found at the site. Two herbicides, 2-methyl-4-chlorphenoxyacetic acid [MCPA] and -2-(2- methyl-4-chlorophenoxy)propionic acid [MCPP], will also be analyzed due to their reference in the EPA Removal Site Evaluation'memorandum, The frequency and number of samples collected will be dependent upon one or more ofthe following site specific conditions encountered in the field (e.g., total number of drums encountered, like consistency of the material encountered between individual drums, field screening results, any other visual or measurable waste characterization that results in the identifying of individual drums with similar inherent characteristics). J:\Pro]ecl\Georgia-Pacific\03060-662 Milford cv 1-2 • Aoril 2007 Landfill\WorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- » 4192007.doc - - ENSR 2.0 Drum Screening During the container search across the face of the landfill, physical hazards associated with drum handling will be identified, such as, type of drum, drum pressurization (bulging), and drum labeling, 2.1 Drum Reconnaissance/Inspection Soil excavation operations to expose partially buried drums will ,be conducted using a hydraulic excavator equipped with a toothed bucket. In order to carefully expose buried drums, excavation operations will be conducted in 6" lifts. Should a drum(s) become exposed, a second excavator equipped with a barrel grapple will remove the drum from the excavation area. Any whole or partial drums recovered with material contained within them will be placed directly into a salvage drum. Drum remnants and empty drums will be stockpiled close to the excavation area and subsequently transported to the staging area for off-site disposal/recycling. This technique will be used to handle surface drums found during the landfill reconnaissance. Salvage drums containing whole or partial drums with waste will be transported to the designated drum sampling pad using a skid steer or end-loader; As discussed in the Work Plan, drum construction may provide a clue as tb the drum contents; however, since drums may have been reused for waste containerization, drum construction will be used as a guide only. All drum contents will be assumed hazardous until their contents have been identified/categorized, keeping in mind that drum labels may not accurately reflect drum contents, • Steel drums usually held oils, flammables or toxics. Seldom did these drums contain corrosive liquids. • Plastic drums typically contained corrosive liquids • Plastic drums were typically used to contain dilute concentrations of corrosive liquids • Fiber (cardboard) drums typically contained solids Also, solids and sludges are typically disposed of in open-top drums. Closed-head drums with a small bung opening generally contain liquids. Drum Inspection of condition will be noted in field notes or on drum identification sheet, including, • Condition of drum, carcass - corrosion, rest, leaking contents, remaining remnants' • Environmental conditions of drum location - odor, stained soils, high PID readings, etc. • Drum labeling - product label, symbols, words, hand markings or other markings on the drum indicating former contents and/or potential drum hazards (i.e,, flammable, ignitable, explosive, radioactive, toxic) • Signs that the drum is or has been under pressure (e,g., bulging) • Drums containing lab packs (e.g., discarded lab chemicals) • Explosive/shock sensitive drums - to be managed sieparately from other drums. All drum markings and/or labels will be recorded and photographed, as is consistent with the referenced guidance document and EPA-ERT Drum Trak/Drum Pad Software available through the ERT website. A copy of the drum log/tracking sheet is iricluded in the Work Plan at the end of Section 3. J:\Project\Georgia-Pacific\03060-062 Milford cv 2-1 Anril ?nn7 Landfil^WorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- ^ 4192007.doc ENSR Regarding drum condition and hazard identification, bijiging,drums; .•• • .. • Could contain or could have Contained frozen material • Cbuld be pressurized or at one time! have been pressurized 1 ' , , . Are oi-have been under pressure due to a ^ The results of initial drum inspection and Obsen/ation? will be documented on the Drum/Tank Sampiing Data . sheet included as SAP Attachment^ in EPA ERT SOP #2009 -Drum Sampling,, f he most recent version of , EPA ERT SOPs to.be referenced.with this Work; Plan are provided in SAP Attachment, identified with a tab . entitled "SOPs.'', • ^ • ,. ' :•..'•.••'''''..''• " '"'''''.--•• 2.2 Drum.Opening-'':/"- ; • Druni opening activities are described in ttie'.Wbi'k Plan; There are 3 basic techniques.lhat can be employed for drum opening: .1) manual opening with non-sparking b^ung wrenches, 2) drum deheading, and 3) remote drum punctul-ing or bung removal: In general,;drunn opening' activities will be conducted using one of these methods which are descnbed in detail below. ; ' • Drurri sampling operations will be nnonitored usipg a PID and combustible gas detectoK In the event that the LEL reaches or exceeds 10%, drum samplihg operations vyih be suspended. Specific personal protective equiphnent requirenri'ents fpr drum opening operations are addressed within Section 7.0-''Pe'rsonal Protective'Equipment'inlthe ,HASP. • 2.2;1 Manual Opening with a Bung VVrench Manual drum opening will be performed with a bung wrench or deheader only if, the drums are dbserved to be structurailly sound and are ndt known to be (1), under severe ^pressure, (2) shock sensitive, (3) highly reactive, (4) explosive, or (5) flarnmable. Bung wrencheSiare to be constructed of non-sparking materials normally . constructed of cast iron, brass, or a bronze-beryllium, npri-sparking alloy. IVIanual Opening Procedures 1, Don the appropriate personal protectiye equipment (PPE) as identified in the Health ,and Safety Plan • ; r'(HASP).'' *': ;„;'.,•' . "V • • ,iv . ' './"- '.::- y /../.." ' ' ' . 2. ' Position the Drum.- The'drum should be positioned in an. upright position;, either bung up or for drums -; / thathaye a bung opening on:the'side, lay the drijm-on its side . ' 3. Wrench the bung in a slow,, steaidypulling motion :across the drum,;. If the length .of the bung wrench ; handle, is inadequate to provide the amount of leverage needed„.attach, a pipe or bar (use cast iron, brass,orsimilarfynon-spa'rking"matenal)tO;theend'of the handle to provident ' J:\Proiecl\Georgia-Pacific\03060-062 MilfordCV. '• ' ' 0-2 '''•"' • 'A -I'pnn? LandfiH\WorkPlan\FINAL-April2007XENSRSAMPUNGPLAN-FINAL- r'. r ' • ''. , . •„ Aprii^uu/ 4192007.doc . /• ' .. - '.-'-. ' -- : ' • ' ..• '.•• -. ', : • - ' ' ' " ENSR 2.2.2 Drum Opening with a Drum Deheader When a bung can not be opened by a bung wrench, a drum can be opened manually using a drum deheader constructed of forged steel with an alloy steel blade designed to open and cut the lid of a drum off with a scissors-like cutting action. Drums with removable heads, however, will be opened by other methods. 2.2.3 Hand Pick, Pickaxe, and Hand Spike These tools are typically constructed of brass or other non-sparking alloy with a sharpened point that can penetrate the drum lid or head. The most commonly used hand picks and pickaxes-are depicted as an attachment to the EPA/ERT SOP #2009 - Drum Sampling provided in SAP Attachment 1, 2.2.4 Backhoe Spike The backhoe spike is a metal spike attached or welded to a backhoe bucket that is used for remote drum opening. This method greatly reduces the potential for personal exposure to the drum contents when opened. 2.2.5 Hydraulic Drum Opener Remotely operated hydraulic drum opening devises are also used as a remote method for opening drums. An example of a hydraulic drum opener is depicted as an attachment to the EPA/ERT SOPS #2009 - Drum Samplingi provided in SAP Attachment 1. These devices use hydraulic pressure to pierce through the wall of a drum. 2.2.6 Pneumatic Devices A pneumatic bung remover consists of a compressed air supply that is controlled by a heavy-duty, two-stage regulator. A high-pressure air line delivers compressed air to a pneumatic drill which is adapted to turn a bung fitting selected to fit the bung being removed (refer to EPA/ERT SOP #2009 - Drum Sampling provided in SAP Attachment 1). This device for remote bung opening does not permit the slow venting of a container, and should not be used to open pressurized drum without taking additionai precautions. This devise also can not open bungs that are rusted shut. J:\Project\Georgia-Pacific\03060-062 Milford CV 2-3 Anril ?nn7 Landfill\WorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- ^ 4192007.doc ENSR 3.0 Sampling Waste classification sampling will be conducted as part of this Time-Critical Removal Action in accordance with EPA Administrative Agreement and Order on Consent, Docket No. CERCLA-02-2005-2017 (AOC), A copy of the AOC is appended to the Work Plan under a separate tab entitled, "EPA Correspondence/Orders." EPA retains the nght to take split samples of all matenal removed as part of this action. The analyses of the TCL/TAL compounds plus MCPA and MCPP, which were listed in Table 1 of the EPA Removal Site Evaluation Memorandum dated May 24, 2005, but which do not appear on the TCL, will be incorporated into the revised QA/QC Plan. All analyses will be perfomied according to SW-846 analytical test methods as per Section B, Description of Work, 35.b. 3.1 Sampling Equipment/Apparatus Sampling equipment and materials required for sampling include, but are not limited, to the materials listed below: PPE Wide-mouth sample jars provided by the laboratory . Uniquely numbered samplihg labels 1 -gallon covered cans half-filled with absorbent material (e.g. vermiculite) Chain-of-custody forms Decon matenals, including but not limited, to: - Tap water - Pressunzed sprayers for tap water - Dl-Water - Reagents: - 10 % Nitric Acid, (if sampling for metals) - Acetone or Hexane (pesticide grade), (if sampling for organics) - Methanol - Galvanized steel buckets, pails - Plastic sheeting - Aluminum foil - Trash bags or containers - Long-Handled Brushes - Non-Phosphate Detergent - Nitric acid wash bottles (if metals will be included in analysis) - Acetone (or other solvent) wash bottles - Plastic buckets or pails to contain nitric and acetone wash solutions separately - Baking soda , - Safety glasses or splash shield - Emergency eye-wash bottle Sample Collection Equipment/Apparatus, including but not limited to: - Glass drum sampling thief tubes (dedicated one per sample) - Stainless steel or inert sampling trowels Drum opening tools, including but not limited to, those described in Section 2.0, above. J:\Project\Georgia-Pacific\03060-062 MilfordCV 3--| Anril 2007 Landfil^WorkPlan\FINAL-April2007\ENSRSAMPLlNGPLAN-FINAL- 4192b07.doc ENSR 3.2 Drum/Waste Storage and Sampling Pad All drums to be charactenzed for off-site disposal will be moved to the Drum/Waste Storage and Sampling Pad. As discussed in the Work Plan, the Drum/Waste Storage and Sampling Pad will be staged in a separate area away from the landfill face construction area. The Drum/Waste Storage and Sampling Pad will consist of approximately 7,500 square feet (150' x 50') leveled area, constructed of several liners with a sand layer and topped with a 6" layer of gravel. The Drum Storage and Sampling Pad will include the construction of a 1-foot high berm around the perimeter of the Drum Storage and Sampling Area as specified in the Work Plan, 3.3 Initial Drum Field Screening Drum sampling operations will be monitored using a photoionization detector (PID) and combustible gas detector. In the event that the lower explosive limit (LEL) reaches or.exceeds 10%, drum sampling operations will be suspended. ' When sampling bulging drums, the drums will be placed behind a blast shield and opened using a remote drum opener. Non-bulging, non-removable head drums with bungs will be opened slowly by removing the smaller of the bungs. Should a pressure release be detected, the sampler will step back and let the drum vent prior to completing the opening. Drums with removable heads, (open tops), will have the tops removed. This operation will be conducted with caution as nngs that become disfigured can spring from the drums when they are released. Non-sparking tools will be utilized for drum opening activities. Should a drum be inaccessible it will be moved to a location remote from the other drums and opened using a drum punch attached to a hydraulic excavator. Drum samples may be field screened on site using the following methods: • PID Readings • LEL Readings • pH for Aqueous Samples • Chemets Screening Kit for reactivity (reactive cyanide/sulfide) Haz-cat screening kits may be used for drum screening evaluation (e.g. it may be advantageous to have the Chlor-n-Oil test kits for PCB screening); however, this will be implemented considering the number, types and characteristics of drums recovered at the Site. If needed, a lab pack service company can be retained that can do on-site testing, as needed. Field screening procedures will be conducted in accordance with manufacturer's instructions. The results of drum field screening will be documented on the Field Test Data Sheet for Drum/Tanl< Sampiing sheet included as Attachment 2, in EPA ERT SOP #2009 -Drum Sampling, provided in SAP Attachment 1, 3.4 Drum Sampling Methods As discussed above and in the work Plan under Section 3.8,3,1-"Waste Management," to meet the provisions for all waste steams to be analyzed for the TCUTAL compounds, these analytes plus MCPA and MCPP, will be incorporated into waste characterization sampling activities to assure that all potential underlying hazardous constituents (UHC's) are properfy evaluated. J:\Proiect\Georgia-Pacific\03060-062 Milford CV 3-2 a-nl pnn7 Landfil^WorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- 4192007.doc ENSR Once specific drums have been categorized into separate waste streams, based on waste classification and profile sampling for waste disposal facility selection criteria, then a minimum of ohe (1) sample per waste stream will be collected to adequately characterize TCL/TAL compounds, plus MCPA and MCPP, found at the site. The frequency and number of samples collected will be dependent upon one or more of the following site specific conditions encountered in the field (e.g., total number of drums encountered, like consistency of the material encountered between individual drums, field screening results, any other visual or measurable waste characterization that results in the identifying of individual drums with similar inherent characteristics). Drum sampling operations will be conducted in Level B respiratory protection while sampling any unknown wastes. Should the contents of the drums be known, the sampling personnel will don personal protective equipment (PPE) as specified within the Health & Safety Plan (HASP). All solid waste samples will be collected using a stainless steel trowel or dedicated disposable scoop/spatula into an aluminum tray or stainless steel bowl and mixed thoroughly to obtain a homogenous sample. A sampling trier may also be used for the collection of solid waste samples. The sample will then be placed into its appropriate sample jar. If specified by the laboratory, samples for Toxic Characteristic Leaching Procedure (TCLP) volatile organic analysis (VOA) will be transferred directly into its appropriate sample container prior to homogenization to protect sample integrity. " ' , , All liquid waste samples will be collected using a dedicated glass drum sample thief. After sample collection, the used glass drums thieves will not be broken within drums sampled. If additional sampling is required, these broken glass pieces can cause safety concerns if additional sampling is required. A separate container will be designated for the disposal of glass drum thieves. The attached EPA/ERT SOP#2009 - Drum Sampling is provided as a reference in SAP Attachment 1. If soil sampling adjacent to drum locations is performed, refer to EPA/ERT SOP #2012 - Soil Sampling, provided as a reference in SAP Attachment 1, If waste pile sampling is performed, refer to EPA/ERT SOP #2017 - Waste Pile Sampling, provided as a reference in SAP Attachment 1. 3.5 Field Instrument Calibration Field screening procedures will be conducted in accordance with manufacturer's instructions. Field instrument calibration logs will be brought into the field and maintained for each field instrument. Each field calibration log will include the following, at a minimum: • Name of device and/or instrument calibrated • Device/Instrument serial and/or ID number • Frequency of calibration • Date/Time of Calibration • Method of calibration • Results of calibration • Name of person performing calibration , Documentation that field instrument calibration was performed will also be noted in the field log book. Field instrumentation calibration and operating procedures will be included in a separate binder to accompany the field-copy of the Work Plan and will readily available for reference with calibration logs in the on site trailer and thus included in the QA/QC Plan by reference. Field instrument calibration procedures will vary with the type and model of tfiat version of the equipment to be used. Manufacturer's instructions will be readily J:\Projecl\Georgia-Pacific\03060-062MilfordCV 3.3 Anril 2007 LandfiH\WorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- *^ 4192007.doc ENSR available for reference with calibration logs on site in the site trailer, but will not be included in the Q/VQC Plan due to the uncertainty of specific models being available at the time of field sampling. 3.6 Sample Equipment Decpntamination EP/V/ERT SOP #2006 - Sampling Equipment Decontamination is provided as a reference in SAP Attachment 1. In general, on-site decontamination of sampling equipment will include the following: 1. High-pressure water wash, where applicable 2. Equipment wash with non-phosphate detergent solution 3. Rinse with tap water 4. Rinse with distilled/deionized water 5. Rinse with 10% nitric acid solution (if sample will be analyzed for metals) 6. Rinse with distilled/deionized water 7. Solvent rinse with acetone or hexane (pesticide grade), or other solvent, if sample will be analyzed fdr organic compounds 8. Allow to air dry completely 9. Rinse again with distilled/deionized water' ' 3.7 Sample Frequency Waste disposal sample frequency will be dependent upon the number of drums encountered in the field and dependent upon drum contents and characterization into separate waste streams. At a minimum, laboratory sample analysis on waste samples will be conducted at a frequency of one per waste stream or one sample per ten (10) drums for larger waste streams. Sample frequency and parameter selection will also be dependent upon field conditions, results of field screening, and disposal facility profiling requirements. At a minimum, for disposal facility profile acceptance criteria, each composite sample will be analyzed for Ignitability (DOOl), Corrosivity (D002), and full TCLP parameters (D004 - D043, but not including pesticides and herbicides). PCBs, reactivity, and TCLP pesticides and herbicides will be included in composite sampling only if field screening indicates their presence. Total cyanide and total sulfide may be analyzed in place of reactive cyanide and sulfide, depending on the specific requirements of the disposal facility and current guidance from USEPA, As reported by Woodward-Clyde Consultants in the August jl 992,Surface Remedial Action Report, Old.Landfill Site, Milford, NJ (WCC 1992) "A total of sixty nine drums and seventeen waste stream samples were collected during the field program." On the basis of field obsen/ations! instrument readings, description and appearance, drummed contents were segregated and sampled as distinct waste streams. To address USEPA requirements that each sample should be evaluated separately for all constituents depending upon volume J:\Project\Georgia-Pacific\03060-062 Milford CV 3-4 .^1 LandfilftWorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- , P w 4192007.doc . . • • •••• ENSR recovered from the drum, minimum sampling frequency and site specific sampling analyte list is discussed below. ,, ' , At a minimum, the sample frequeincy will be dependent upon the type and quantity of materials recovered from each drum and disposal facility, selection criteria. Based on visual observations and knowledge of historic site conditions, a large nurnber of drums are expected to be in a deteriorated condition making sample collection from each distinct drum difficult. Many of the previously iderjitified waste streams have easily identifiable characteristics such as color, consistency, headspace readings, and other distinctive properties. As a result, each drummed contents will be evaluated separately by field measurerhents and observations, then each distinct material will be classified for waste disposal purposes. As discussed above under Work Plan Sectipn 3 8,3.1 -Waste Managernent, one sample collected from each waste stream will be analyzed for alt constituents (UHC's). Sample collection may be biased to the drumnied materials exhibiting the highest field instrument and/or headspace readings. Site specific constituents have been identified based on historic sampling results, and a list of site specific compounds documented at the site was provided in 'Table 1: Summary of Analytical Results from Soil and Waste Sarinples Collected at the Crown Vantage Landfill bn November 12 and 13, 2003" of the USEPA Removal Site Evaluation Memorandum dated May 25, 2004.. A copy of this document is appended to Work Plan under the tab entitled "EPA Correspondence/Orders,", As requested by USEPA, to meet the provisions for all waste steams to be analyzed for the TCIJTAL, these-analytes, plus'MCPA and MCPP, will be incorporated into waste characterization sampling activities to assure that all potential underfying hazardous constituents (UHC's) are properly evaluated. . , , Once specific drums have been categonzed into separate,waste streams, based on waste classification and profile sampling for waste disposal facility selection criteria, then a minimum of one (1) sample per waste stream will be collected to adequately characterize TCL/TAL compounds, plus MCPA and MCPP, found at the site. The frequency and number of samples collected will be dependent upon one or more of the following site specific conditions encountered in the field (e.g., total nurnber of drums encountered, like consistency of the material encountered between individual drums', field sci-eening results, any other visual or measurable waste characterization that results in the identifying of individual drums with similar inherent characteristics). 3.8 Sample QA/QC No trip blanks or field blanks are required for waste sample collection. Based on previous site drum sampling investigations, quality assurance/quality control.,(Q/\/QC) samples will include the collection of one field duplicate and one matrix,spike/matrix spike duplicate (MS/IVISD), Field duplicate samples will be identified in ' the same manner as other waste samples and will be docunnented in the field log book. QA/QC samples will include the collection of one field duplicate and one MS/MSD sample for each matnx at a ratio of 1 per 20 samples. Extra sample volume will be provided to the laboratory to allow for the performance of matrix spike sample analysis. Further Q/VQC details can be found in the QAPP in Appendix E to the Work Plan, 3.9 Laboratory Sample Analysis Sample analysis parameter selection will be based on field sample screening, waste origin, and disposal facility parameter selection. At a minimum, all waste samples will be analyzed for the following, or a , combination thereof.based on waste characterization and waste profiling requirements:. • TCLP Volatile Organics, (TCLP VOA)- SW-846 Methods 1311 /8260B • TCLP Semi-Volatiles (TCLP BNA) - SW^846 Methods 1311 / 8270C • TCLP Metals - SW-846 Methods 1311./ 6010 / 7470A (Mercury) J:\Project\Georgia-Pacific\03060-062MilfordCV 3.5 ' ' , . Anril 2007 Landfill\WorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- - ' npiwduu/ 4192007.doc, ; . ; • ' . ENSR RCRA Characteristic (Ignitability and Corrosivity) Other analytical parameters may be selected dependent upon disposal facility acceptance criteria, and may include the following based on the results of field screening: • TCLP Pesticides - SW-846 Methods 1311 / 8081A • TCLP Herbicides -SW-846 Methods 1311/8151A • Poly-Chlorinated Biphenyls (PCBs) - SW-846 Method 8080 • Cyanide-SW-846 Method 9012A • RCRA Characteristic - Sulfide and Cyanide Reactivity As discussed above in Section 3,7-"Sample Frequency," at a minimum, one sample collected from each waste stream will be analyzed for the constituents (UHC's) referenced below. These analyses include all the UHCs currently identified at the site as per listed in Table 1 of the USEPA Removal Site Evaluation Memorandum dated May 24, 2005. TCL Volatile Organics - SW-846 Method 8260B > TCL Semivolatiles - SW-846 Method 8270C TCL Pesticides - SW-846 Method 8081A TCL Poly-Chlorinated Biphenyls (PCBs)- SW-846 Method 8082 Herbicides (MCPA and MCPP only) - SW-846 Method 8151 TAL Metals - SW-846 601 OB with Mercury SW-846 7471A Cyanide - SW-846 Method 9012A 3.10 Sample Documentation All details of site activities, drum locations, sample locations, observations, visitors, etc. will be documented in the field log book. All sample documents are to be completed legibly in ink. Any corrections in the field log book are to be crossed out with a single line and initialed by the writer. At a minimum, log book entries should include: Site name, project number Personnel on site, including subcontractors and visitors to site Weather conditions Date and times of all entries Descriptions of all site activities, site entries and exit times Site observations Drum location (note distance/direction to nearest Station #), drum condition, markings, contents, waste characterization observations (separate drum log will be completed for each drum that is identified in the field on logs provided in Appendix B). Sample location, description, parameters, sample time, sample equipment used J:\Project\Georgia-Pacific\03060-062 Milford CV 3.5 . H LandfimWorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- . P "^uu 4192007.doc • - . ENSR • Field instrument readings, including calibration documentation • Descriptions of photographs • Site sketches All other observations and details are to be recorded in the field log book as necessary. Drum and sample locations may be designated by GPS. However, GPS coordinates may not be collected from each drum location if multiple drums are encountered dunng wall installation or if site or weather conditions warrant drum removal prior to collecting GPS measurements. However, initial GPS measurements will be taken, as a baseline at each location of a previously or newly exposed drum location (as they are encountered). The purpose of GPS measurement of exposed drums will be to document a more precise location of exposed drums so that they can be permanently marked onto the site survey for recovery during drum removal operations. Sample locations will be marked/staked/flagged in the field for later GPS measurement, as appropriate. 3.11 Sample Shipment Guidelines It is anticipated that samjale shipment by air and/or over land will be utilized for the shipment of soil, liquid and/or waste samples to laboratones and disposal facilities for waste profiling purposes. As stated in work Plan Section 5,0-"Sampling and Analysis Plan (SAP)," Department of Transportation (DOT) and/or International Air Transport Association (lATA) regulations will be followed for sample shipment, ENSR has a well-defined hazardous materials shipping program and follows lATA requirements for all air shipments of hazardous materials. Based on field screening data, ENSR will determine if the samples are hazardous and if so, the appropriate shipping name to assign to the samples (i.e, environmentally hazardous substance, liquid, n.o.s. or flammable liquid n.o.s.). ENSR vvill ensure that all applicable package marking and labeling requirements are met and will ensure that the proper shipping papers are completed for each shipment. Only ENSR staff that has completed function-specific haz-mat shipping training will be authonzed to ship hazardous samples from the site. V J:\ProjecftGeorgia-Pacific\03060-062 Milford CV 3.7 ..., . LandfimWorkPlan\FINAL-April200AENSRSAMPLINGPLAN-FINAU- ^. 4192007.doc ENSR 4.0 Sample Preservation, Containers, Handling, and Storage Solid and liquid samples, as applicable, will be collected from the contents of exposed drums removed from the landfill face. 4.1 Sample Preservation The samples to be collected from the drums are considered waste samptes; therefore, no preservatives will be added to the sample containers since there is the potential for the waste sample material to react with the sample preservative. The QAPP outlines the holding times for all samples. All samples, however, will be preserved on ice and cooled to 4° C. A temperature blank sample will be included in each shipped cooler to verify that the samples were maintained at 4°, C (-i-/- 2° C). Samples will also be stored in sample coolers and protected from sunlight to minimize any potential reaction to light sensitivity. 4.2 Sample Containers Sample containers will be prepared and provided by the laboratory. Waste samples will be placed in 500cc, wide mouth, amber glass jars (with Teflon-lined screw caps) and numbered in accordance with the container from which they were removed. Actual volume of waste sample material required for sample analysis will be determined by the laboratory dependent upon sample analysis required. Sample labels will include the following information printed in black or blue permanent ink on the sample labels: Site and Project number , Sample Date Sample Time Sample Identification Number Grab or composite designation Sampler Name Method of Sample Preservation: Ice Sample Analytical Parameters Requested As stated in USEPA letter dated March 5, 2007, all container(s) designation (i.e,, DS01-500) must be included on all sample labels and chain-of-custody documentation, and trip reports will be provided for quick reference. Trip Reports will be prepared to document sampling and sample shipment activities. An example of the Thp Report, provided as Attachment 1 to the USEPA letter dated March 5, 2007 will be included for use as an appended reference in this SAP under SAP Attachment 1 (EPA ERT SOP Documents), J:\Projecl\Georgia-Pacific\03060-062 MilfordCV 4.-| • Aoril 2007 Landfil^WorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- 4192007.doc ENSR 4.3 Sample Handling Waste sample container handling specifics are provided below: 1. Place sample container in, two (2) Ziplock plastic bags. 2. Place each bagged container in a 1-gallon covered can containing absorbent packing material (e.g., vermiculite). Place lid on the can, 3. Mark the sample identification number on the outside of the can; 4. Place the marked cans in a cooler, and fill remaining space with absorbent packing material. 5. Fill out chain-of-custody form for each cooler, place in plastic, and affix to inside lid of sample cooler, 6. Secure and custody seal the lid of the sample cooler. 7. Arrange for the appropriate transportation mode consistent with the type of hazardous waste involved. 8. Ice packed into the.cooler will also be contained in large sized (Ziplock) plastic bags. 4.4 Sample Designation The exact locations of all drum and waste sample points will be field selected. All drum locations will be marked in the field with individual flags, flagging and/or fluorescent paint marking the original location. Drum locations will be identified by approximate distance and direction to closest Station # or Quadrant identified in the field. All drum locations will be surveyed by the project surveyor at the conclusion of drum sampling activities. Each drum will be assigned a unique and sequential double digit number. Drums will be labeled and numbered dunng sampling operations. Sample identification labels may contain the following sample designations: 1, D=Drummed or B=Bulk sample 2, S=Solid, L=Liquid, or M=Mixed Waste 3. ##-Double Digit Drum Sequentially Numbered 01 through 99 4. Nearest Station #-00 through 1500, or known Survey Spike For example, a drum of solids that was the first to be identified situated at Station No. 500 along the landfill face would be assigned sample designation "DS01-500", J:\Proiect\Georgia-Pacifio\03060-062 MilfordCV 4-2 Aoril 2007 Landfil^WorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- ^ 4192007.doc ENSR 4.5 Chain-of-Custody Procedures Chain-of-custody (COC) will be provided either by the Consultant or the contracted laboratory and will be completed in accordance with QAPP provided as Appendix E to the Work Plan. Refer to the QAPP for an example COC, EPA ERT SOP documents are appended to this SAP as SAP Attachment 1-"EPA ERT SOP Documents." ' 4.6 Sample Security/Storage Each of the samples bottles will be sealed; caps will be secured with custody seals. Sealed bottles will be placed in large metal or plastic coolers, and packed with absorbent material (e.g., vermiculite). Once the COCs have been sealed in a plastic bag and affixed to the inner lid of the sample cooler, COC seals will be used to secure the sample cooler on both sides. The lid will be custody sealed on two sides with custody seals to document any evidence of tampering. The COC will be maintained fro the time the sample is collected to the time the sample arrives at the laboratory. When samples,(or sample coolers) are not under the direct control of the,individual responsible for them, the samples will be stored on iCe in the sample cooler sealed with a custody seal and placed in a secure/locked location. EPA guidance for the Packing, Marking, Labeling, and Shipping of IHazardous Material Samples is also provided in SAP Attachment 1. J:\Project\Georgia-Pacific\03060-062MilfordCV 4.3 . Landfil^WorkPlan\FINAL-April2007\ENSRSAMPUNGPLAN-FINAL- 4192007.doc ENSR 5.0 Drum and Waste Recovery Exposed drums, containers, and other waste encountered along the surface of the landfill will be recovered as discussed in the Work Plan prepared by ENSR, The drums that are encountered throughout the course of this project will be treated as unknowns; however, Appendices 1 - 4 of.the Administrative Order provide information relative to the types of wastes previously identified as present vyithin the landfill. A Woodward Clyde Consultants (WCC) report, dated August 1992), provides information relative to, surface drums previously removed from the site. A copy of the text of.the 1992 WCC report is provided in SAP Attachment 2 of this SAP, Following drum field characterization/screening'and sampling, drums will be 1) removed from salvage-drums and bulked with like wastes; or 2) remain in the salvage drum si be numbered and filaced on the drum storage pad, A RCRA Chemical Waste Compatibility List is provided in SAP Attachment 1 (EPA ERT SOP Documents) and will be consulted to deterhiine the compatibility wastes to be bulked for off-site disposal. Drummed waste that contains free liquids or solids that cannot be bulked with other materials will be stored in the salvage drums. These drums will be placed oh the waste storage pad. The drums will be placed in rows no more than two wide with the labels and identifying marks turned toward the aisle. Aisles will accommodate a skid steer as detailed in the Work Plan, - - 5.1 Waste Stream Characterization All drums containing matenal will be handled as follows: Upon completion of field charactenzation and drum screening (see Section 3.0), each drum will be categorized into a waste stream as described within the WCC Report, If the characteristics of a particular drum do not match any of the seven waste streams listed, apfjropnate analyses will be run, . Wastes anticipated to be encountered are expected to. be characterized into seven general waste streams for purposes of bulking materials of similar composition and compatibilityfor off-site disposal, as a hazardous waste, as follows: 5.1.1 Waste Stream 1 (Drummed Flamrhable Liquids from Coating Operations) Waste Stream 1 includes over-packed drums of liquids reportedly originating from the mill coating operations and is suspected to contain solvents. This waste stream was previously classified as a Waste Flammable Liquid using Waste Classification Codes DOOl (Ignitable), D635 (Methyl Ethyl Ketone) and FOOS (NON HAL SOLV & STLBTM). 5.1.2 Waste Stream 2 (Rags and Other Materials Generated by the Coatings Process) Waste Stream 2 includes rags and other matenal generated during the coatings process. This waste stream contained the second highest levels of volatile organics reported at 32,569.parts per million (ppm) during previous WCC investigations conducted in 1992. Waste Stream 2 reportedly contained detectable concentrations of chrbmium, lead, copper and zinc, but only lead exceeded theTCLP regulatory level of 5 ppm. There are no regulatory TCLP levels for copper or zinc. This waste stream was previously classified as a Waste Flammable Liquid using Waste Classification Codes DOOl (Ignitable), D008 (Lead), D035 (MEK) and F003 (NON HAL SOLV & STLBTM). J:\Project\Georgia-Pacific\03060-062MilfordCV 5-"I April 2007 LandfimWorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- 4192007.doc ENSR 5.1.3 Waste Stream 3 (Waxy Substance from Coating Operations Containing MEK) Waste Stream 3 includes a waxy substance generated by the coating process and may contain toluene and MEK. This waste stream contained one of the highest levels of volatile organics reported at 51,756 ppm during previous WCC investigations conducted in 1992. This waste stream was previously classified as a Waste Adhesive, Flammable Liquid using Waste Classification Codes DOOl (Ignitable), FOOS (NON HAL SOLV & STLBTM) and F005 (NONHL SOLV & STLBTM). 5.1.4 Waste Stream 4 (Soil Containing Pigments, Dyes and/or Paint Sludges) Waste Stream 4 includes soil containing waste pigments, dyes and/or paint sludges. This waste stream is most evident by the coloring of the waste. The waste stream did not show a response to headspace analysis on previous investigations. Waste Stream 4 also contained detectable levels of lead, copper and zinc, but lead levels were reported below TCLP lead levels. This waste stream was previously classified by WCC on the hazardous waste manifest as a Hazardous Waste Solid using Waste Classification Codes D008 (Lead) and FOOS (NON HAL SOLV & STLBTM). No explanation was given in the report other than the waste stream description may differ from onginal WCC waste stream descnptions because the TCLP and TCL VO were not available dunng the field program but were available prior to completion of the waste classification forms. If TCLP lead values for this waste stream are below regulatory levels, the waste will not be characterized as a D008 waste. 5.1.5 Waste Stream 5 (General Solids with No Headspace Readings) Waste Stream 5 includes solids that do not show a significant response to headspace analysis and do not exhibit solvent or "volatile-like" properties or odor. Dunng previous investigations, VOC analytical results showed VOC compounds above New Jersey Residential Soil Cleanup Cnteria (RSCC), but below Non- Residential Soil Cleanup Critena (NRSCC) and other regulatory levels for volatiles. Based on previous WCC investigations. Waste Stream 4 contains the potential to be classified as "Ignitable," This waste stream was previously classified as a Hazardous Waste Solid using Waste Classification Code FOOS (NON HAL SOLV & STLBTM), 5.1.6 Waste Stream 6 (Hard, Waxy Solid Substance) Waste Stream 6 was identified as a generally hard, wax-like substance that did not show a response to headspace analysis. This waste stream was previously classified as a as a Non-Regulated, Non-Hazardous Solid, 5.1.7 Waste Stream 7 (Oii Contaminated Rags) Waste Stream 7 includes oil contaminated rags. This waste stream was previously classified as a Non- Regulated, Non-Hazardous Solid. 5.2 Non-Hazardous Solid (Bulky) Waste Dunng site preparation (vegetation clearing), drum removal actions, and installation of the barrier wall, solid bulky waste that may be encountered will be removed to the staging area that will house up to three (3) roll-off boxes placed on the waste storage pad. The boxes will be used to bulk like wastes. Like wastes may consist of: J:\Project\Georgia-Pacific\03060-062 Milford CV 5-2 4-^11 pnny LandfilftWorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- 4192007.doc ENSR 5.2.1 Empty Drums, Carcasses and Remnants Empty drums,' carcasses, and remnants will be collected and sent to a drum reconditioner for recycling or destruction. At a minimum, emptied drums will be tnple-rinsed prior to recycling. All rinseate water will be collected for off-site disposal. i 5.2.2 Non-:Hazardous Solid Wastes Non-Hazardous solid wastes, including discarded off-spec paper rolls, paper with foil backing will be retained on site. ,1 •j Where feasible, material that is not posing an immediate threat to human health or the environment (e.g., ash material and bther miscellaneous construction debris (wood, brick, concrete) that does not appear to be contam inated iby another waste stream will be redistributed within the landfill bounds. 5.3 Investigation Derived Wastes (IDW) Investigation Denved Wastes (IDW) generated during waste sampling activities are anticipated to include used personal protective equipment (PPE), plastic, and decon fluids including combined detergent wash and rinse water, nitric acid wash fluids, and acetone wash fluids. Where possible, decon wash fluids will be discharged directly to the .ground surface in an area where fluids will immediately soak into the ground (infiltrate) and not create a runoff concern. Nitnc acid wash fluids will be neutralized with baking soda and disposed of on the ground in the same manner as general decon wash fluids. Acetone wash fluids to be generated are expected to be limited ih quantity. As discussed in the Work Plan, all other decontamination fluids will be repackaged in 55-gallon, USDOT approved drums and shipped off site for disposal following any waste characterization analysis required by the receiving TSDF, I Used PPE will be packaged, transported and disposed of in accordance with all state and federal regulations. For the purposes of this document it will be assumed that these wastes will be transported to a hazardous waste facility meeting CERCLA requirements. A container will be identified on-site for containing used PPE waste. Likewise all used disposable sample equipment will be disposed of in accordance with all local, state and federal requirements. J:\Project\Georgia-Pacific\03060-062 Milford CV . 5.3 . .. LandfimWorkPlan\FINAL-April2007\ENSRSAMPLINGPLAN-FINAL- Mpni <:uu; 4192007.doc I ENSR Attachment 1 EPA ERT SOP Documents April 2007 EXAMPLE TRIP REPORT GROUNDWATER SAMPLING EVENT SAMPLING TRIP REPORT Site Name: Unknown Site CERCLIS ID Nuinber: NYDGGGGGGGGO Sampling Dates: IG/IB/GG THRU. lO/21/OG CLP LAB Ntunber: GGGGG Site Location: NYC, NY Sample Descriptions: Refer to Tables 1-3 Sampling Personnel (Table 1) Name Organization Site Duties Jon Doe Region II USEPA, DESA/HWSB Sampling Operation/Team Leader Jane Doe Region IL USEPA, DESA/HWSB Sampler Sample Dispatch Data (Table 2): Nine(9)groundwater samples, one(l) environmental duplicate, one(l) equipment blanks, and three(3) trip blanks were shipped to US EPA, Region II, DESA, LABB for VOAs and .Hexavalent chromium (Cr6)analysis. Nine(9) groundwater samples, one(l) environmental duplicate, and one(l) equipment blanks were shipped to Acme Testing for TAL metals analysis. FedEx Airbill No Number o£ Nuinber and Type of Sample Time and Dates of Coolers Shipping 00000000000 1 3 Groundwa:ter Samples and 10/19/04 ® 1700 1 environmental duplicate TO: US EPA - LABB for VOAs and Cr6. Also 1 Trip Blank for VOAs only 00000000001 1 5 Groundwater Samples for 10/20/04 @ 1800 VOAs and Cr,6. Also 1 Trip ' TO: US EPA - LABB Blank for VOAs only Hand-carried .. N/A 1 Groundwater Samples and 10/21/04'@ 1600 1 Equipment Blank for VOAs TO: US EPA - LABB and Cr6. Also 1 Trip Blank for VOAs only 000000000002 1 • 10 Groundwater Samples, 1 10/21/04 @ 1700 rtn.UNKNOWN environmental duplicate. TO: ACME TESTING and 1 Equipment Blank for VOAs and Cr6. Sample Ntambers and Collection Points (3 Table) : A total of fifteen samples, for VOAs and twelve samples for Cr6 were shipped to US EPA LABB for analysis. Also, twelve samples were shipped to BONNER for TAL metals analysis Laboratory Analyses Sample Type Sample # Sample Collection Points EPA - VOAs Only 3 Aqueous B1M79 TB-1 (Trip Blank) samples for LABB B1M84 TB-2 (Trip Blank) lab QC • B1M92 TB-3 (Trip Blank) VOAs and Cr6 1 Aqueous (M)B1M94 EQ-1 (Equip Blank) sample for lab QC Groundwater (M)B1M80 MW-6S Samples (M)B1M81 MW-8S (M)B1M82 MW-8D (M)B1M83 GPC-MW-3 (M) B1M85 ,. GPC-EXW-1 (M)B1M86- GPC-EXW-2 (M)B1M87 GPC-MW-1 (M)B1M89 MW-15S . (M)B1M90 MW-16S (M)B1M91 MW-F (M)B1M93 MW-3 • ACME TAL metals 1 Aqueous (M)B1M94 EQ-1 (Equip Blank) sample for lab QC Groundwater (M)B1M80 MW-6S Samples (M)B1M81 . MW-8S (M)B1M82 MW-8D (M)B1M83 GPC-MW-3 • (M)B1M85 GPC-EXW-1 (M)B1M86 GPC-EXW-2 (M)B1M87 GPC-MW-1 • (M)B1M89 MW-15S (M)B1M90 MW-16S (M)B1M91 MW-F (M)B1M93 MW-3 Remarks: Sampled eight of the fifteen wells planned for the sampling event. Wells not sampled: MW-IS, MW-2S, MW-2D, MW-17S, MW-17D, GPC-MW-2, GPC-MW-2R. MW-2S and MW-2D were replaced by MW-G for MW-2S and MW-f for MW-2D. Reasons for not sampling these wells are as follows: MW-IS, there is a conex in the area were the well should be. MW-2S and MW-2D, there are seven wells in the area were MW-2S and MW-2D are supposed to be and none are marked. I named these wells A thru. G. See diagram below. MW-IS has of depth of 40.6 ft. All of the wells except for F were between 40 and 41 ft. I sampled MW-G at 40 ft in place of MW-2S. MW-2D has a depth of 92 ft. I sampled MW-F which was the deepest well in the group at a total depth of 73.8 ft for MW-2D. MW-17S and MW-17D, These two wells were not posted on the wells maps provided and so, could not be located. GPC-MW-2,, could not be found. GPC-MW-2R, could not be sampled due to problems with equipment. MW irs .11 r-vvi- cc ; RSCC RCRA's Chemical Waste Compatibility List The mixing of Group A materials with Group B materiais may have the potential consequences noted. - Group 1-A Group 1-B Acetylene sludge Acid sludge Alkaline caustic liquids Acid and water Alkaline cleaner Battery acid Alkaline corrosive liquids Chemical cleaners Alkaline corrosive battery fluid Electrolyte, acid Caustic wastewater Etching acid liquid or solvent Lime sludge arid other corrosive alkalies Pickling liquor & other corrosive acids Lime wastewater Spent acid Lime and water Spent mixed acid Spent caustic Spent sulfuric acid Potential consequences: Heat generation; violent reaction Group 2-A Group 2-B Aluminum Any waste in Group 1-A or I-B, Beryllium Calcium Lithium Magnesium Potassium sodium Zinc powder Other reactive metals and metal hydroxides , , Potential consequences: Fire or explosion; generation of flammablehydroge n gas Group 3-A Group 3-B Alcohols Any concentrated waste in Groups 1A or IB Water ' , Calcium Lithium Metal hydrides . , Potassium SOzCfc, SOCt, PCb, CHsSiCb , Other water-reactive waste Potential consequences: Fire, explosion, or heat generation; generation of flammable or toxic gases Group 4-A Group 4-B Alcohols Concentrated Group 1-A or 1-B wastes Aldehydes Group 2-A wastes Halogenated hydrocarbons Nitrated hydrocarbons Unsaturated hydrocarbons Other reactive organic compounds & solvents Potential consequences: Fire, explosion, or violent reaction Group 5-A Group 5-B Spent cyanide and sulfide solutions Group 1 -B wastes Potential consequences: Generation of toxic hydrogen cyanide or hydrogen sulflde gas Group 6-A Group 6-B Chlorates Acetic acid and other organic acids Chlorine Concentrated mineral acids Chlorites Group 2-A wastes Chromic acid Group 5-A wastes Hypochlorites Other flammable and combustible wastes Nitrates Nitric acid, fuming Perchlorates Permanganates Peroxides Other strong oxidizers Potential consequences: Fire, explosion, or violent reaction standard Operating Procedures (SOPs) Online Reference List #2006 Sampiing Equipment Decontamination http://www.ert.org/products/2006.PDF #2009 Drum Sampling http://www.ert.org/products/2009.PDF #2010 Tank Sampling http://www.ert.org/products/2010.PDF #2012 Soil Sampling http://www.ert.org/products/2012.pdf #2017 Waste Pile Sampling http://www.ert.org/products/2017.PDF SOP#: 2006 SAMPLING EQUIPMENT DATE: 08/11/94 DECONTAMINATION REV. #: 0.0 1.0 SCOPE AND APPLICATION water wash to facilitate residuals removal. The second step involves a tap water rinse and a The purpose of this Standard Operating Procedure distilled/deionized water rinse to remove the (SOP) is to provide a description of the methods used detergent. An acid rinse provides a low pH media for for preventing, minimizing, or limiting trace metals removal and is included in the cross-contamination of samples due to inappropriate decontamination process if metal samples are to be or inadequate equipment decontamination and to collected. It is followed by another distilled/deionized provide general guidelines for developing water rinse. If sample analysis does not include decontamination procedures for sampling equipment metals, the acid rinse step can be omitted. Next, a to be used during hazardous waste operations as per high purity solvent rinse is performed for trace 29 Code of Federal Regulations (CFR) 1910.120. organics removal if organics are a concem at the site. This SOP does not , address personnel Typical solvents used for removal of organic decontamination. contaminants include acetone, hexane, or water. Acetone is typically chosen because it is an excellent These are standard (i.e.. typically applicable) operating solvent, miscible in water, and not a target analyte on procedures which may be varied or changed as the Priority Pollutant List. If acetone is known to be required, dependent upon site conditions, equiprnent a contaminant of concem at a given site or if Target limitation, or limitations imposed by the procedure. Compound List arialysis (which includes acetone) is In all instances, the ultimate procedures employed to be performed, another solvent may be substituted. should be documented and associated with the final The solvent must be allowed to evaporate completely report. and then a final distilled/deionized water rinse is perfonned. This rinse removes any residual traces of Mention of trade names or commercial products does the solvent. not constitute U.S. Environmental Protection Agency (U.S. EPA) endorsement or recommendation for use. The decontamination procedure described above may be summarized as follows: 2.0 METHOD SUMMARY 1. Physical removal Non-phosphate detergent wash Removing or neutralizing contaminants from 2. Tap water rinse equipment minimizes the likelihood of sample cross 3. Distilled/deionized water rinse contamination, reduces or eliminates transfer of 4. 10% nitric acid rinse contaminants to clean areas, and prevents the mixing 5. Distilled/deionized water rinse of incompatible substances. Solvent rinse (pesticide grade) Air dry Gross contamination can be removed by physical 9. Distilled/deionized water rinse decontamination procedures. These abrasive and non-abrasive methods include the use of brushes, air If a particular contaminant fraction is not present at and wet blasting, and high and low pressure water cleaning. the site, the nine (9) step decontamination procedure specified above may be modified for site specificity. For example, the nitric acid rinse may be eliminated The first step, a soap and water wash, removes all if metals are not of concem at a site. Similarly, the visible particulate matter and residual oils and grease. solvent rinse may be eliminated if organics are not of This may be preceded by a steam or high pressure concem at a site. Modifications to the standard bristle scrub brushes or long-handled bottle brushes procedure should be documented in the site specific can be used to remove contaminants. Large work plan or subsequent report. galvanized wash tubs, stock tanks, or buckets can hold wash and rinse solutions. Children's wading pools can 3.0 SAMPLE PRESERVATION, also be used. Large plastic garbage cans or other CONTAINERS, HANDLING, similar containers lined with plastic bags can help segregate contaminated equipment. Contariiinated AND STORAGE liquid can be stored temporarily in metal or plastic cans or drums. The amount of sample to be collected and the proper sample container type (i.e., glass, plastic), chemical The following standard materials and equipment are preservation, and storage requirements are dependent recommended for decontamination activities: on the matrix being sampled and the parameter(s) of interest. More specifically, sample collection and analysis of 5.1 Decontamination Solutions decontamination waste may be required before begirming proper disposal of decontamination liquids C Non-phosphate detergent and solids generated at a site. This should be C Selected solvents (acetone, hexane, nitric determined prior to initiation of site activities. acid, etc.) C Tap water C Distilled or deionized water 4.0 INTERFERENCES AND POTENTIAL PROBLEMS 5.2 Decontamination Tools/Supplies C The use of distilled/deionized water C Long and short handled brushes commonly available from commercial C Bottle brushes vendors may be acceptable for C Drop cloth/plastic sheeting decontamination of sampling equipment C Paper towels provided that it has been verified by C Plastic or galvanized tubs or buckets . laboratory analysis to be analyte free C Pressurized sprayers (HjO) (specifically for the contaminants of C Solvent sprayers concem). C Aluminum foil C The use of an untreated potable water supply is not an acceptable substitute for tap water. 5.3 Health and Safety Equipment Tap water may be used from any municipal or industrial water treatment system. Appropriate personal protective equipment (i.e., safety glasses or splash shield, appropriate gloves, aprons or coveralls, respirator, emergency eye wash) C If acids or solvents are utilized in decontamination they raise health and safety, and waste disposal concems. 5.4 Waste Disposal ( C Trash bags C Damage can be incurred by acid and solvent C Trash containers washing of complex and sophisticated C 55-gallon drums sampling equipment. • C Metal/plastic buckets/containers for storage 5.0 EQUIPMENT/APPARATUS and disposal of decontamination solutions Decontamination equipment, materials, and supplies 6.0 REAGENTS are generally selected based on availability. Other considerations include the ease of decontaminating or There are no reagents used in this procedure aside disposing of the equipment. Most equipment and from the actual decontamination solutions. Table 1 supplies can be easily procured. For example, soft- (Appendix A) lists solvent rinses which may be required for elimination of particular chemicals. In general, the following solvents are typically utilized contaminants by neutralization, chemical reaction, for decontamination purposes: disinfection, or sterilization. 10% nitric acid is typically used for Physical decontamination techniques can be grouped inorganic compounds such as metals. An into two .• categories: abrasive methods and acid rinse may not be required if inorganics non-abrasive methods, as follows: are not a contaminant of concem. C Acetone (pesticide grade)!'' 7.1.1 Abrasive Cleaning Methods c Hexane (pesticide grade)'" c Methanol'" Abrasive cleaning methods work by rubbing and wearing away the top layer of the surface containing ' (I). Only if sample is to be analyzed for organics. the contaminant. The mechanical abrasive cleaning methods are most comrnonly used at hazardous waste 7.0 PROCEDURES sites. The following abrasive methods are available: As part of the health and safety plan, a Mgchani9al decontamination plan should be developed and reviewed. The decontamination line should be set up Mechanical methods of decontamination include using before any personnel or equipment enter the areas of metal or nylon brushes. The amount and type of potential exposure. The equipment decontamination contaminants removed will vary with the hardness of plan should include: bristles, length of time bmshed, degree of brush contact, degree of contamination, nature of the surface C The number, location, and layout of being cleaned, and degree of contaminant adherence decontamination stations. to the surface: C Decontamination equipment needed. Air Blasting C Appropriate decontamination methods. Air blasting equipment uses compressed air to force abrasive material through a nozzle at high velocities. C Methods for disposal of contaminated The distance between nozzle and surface cleaned, air clothing, equipment, and solutions. pressure, time of application, and angle at which the abrasive strikes the surface will dictate cleaning C Procedures can be established to minimize efficiency. Disadvantages of this method are the the potential for contamination. This may inability to control the amount of material removed include: (1) work practices that minimize and the large amount of waste generated. contact with potential contaminants; (2) using remote sampling techniques; (3) Wet Blasting covering monitoring and sampling equipment with plastic, aluminum foil, or other Wet blast cleaning involves use of a suspended fine protective material; (4) watering down dusty abrasive. The abrasive/water mixture is delivered by areas; (5) avoiding laying down equipment in compressed air to the contaminated area. By using a areas of obvious contamination; and (6) use very fine abrasive, the amount of materials removed of disposable sampling equipment. can be carefully controlled. 7.1 Decontamination Methods 7.1.2 Non-Abrasive Cleaning Methods All samples and equipment leaving the contaminated Non-abrasive cleaning methods work by forcing the area of a site must be decontaminated to remove any contaminant off a surface with pressure. In general, contamination that may have adhered to equipment. the equipment surface is not removed using Various decontamination methods will remove non-abrasive methods. contaminants by: (1) flushing or other physical action, or (2) chemical complexing to inactivate Low-Pres.sure Water 7.2 Field Sampling Equipment Decontamination Procedures This method consists of a container which is filled with water. The user pumps air out of the container to The decontamination line is setup so that the first create a vacuum. A slender nozzle and hose allow the station is used to clean the most contaminated item. user to spray in hard-to-reach places. It progresses to the last station where the least contaminated item is cleaned. The spread of High-Prgss»rg Wawr contaminants is further reduced by separating each decontamination station by a minimum of three (3) This method consists of a high-pressure pump, an feet. Ideally, the contamination should decrease as the operator controlled directional nozzle, and a high- equipment progresses from one station to another pressure hose. Operating pressure usually ranges farther along in the line. from 340 to 680 atmospheres (atm) and flow rates usually range from 20 to 140 liters per minute. A site is typically divided up into the following boundaries: Hot Zone or Exclusion Zone (EZ), the Contamination Reduction Zone (CRZ), and the Support or Safe Zone^(SZ). The decontamination line This system produces a water jet that is pressured should be setup in the Contamination Reduction from 1,000 to 4,000 atmospheres. This Corridor (CRC) which is in the CRZ. Figure I ultra-high-pressure spray can remove tightly-adhered (Appendix B) shows a typical contaminant reductiori surface films. The water velocity ranges from 500 zone layout. The CRC controls access into and out of meters/second (m/s) (1,000 atm) to 900 m/s (4,000 the exclusion zone and confines decontamination atm). Additives can be used to enhance the cleaning activities to a limited area. The CRC boundaries action. should be conspicuously marked. The far end is the hotline, the boundary between the exclusion zone and Rinsing the contamination reduction zone. The size of the decontamination corridor depends on the number of Contaminants are removed by rinsing through stations in the decontamination process, overall dilution, physical attraction, and solubilization. dimensions of the work zones, and amount of space available at the site. Whenever possible, it should be Damn Cloth Removal a straight line. In some instances, due to sensitive, non-waterproof Anyone in the CRC should be wearing the level of equipment or due to the unlikelihood of equipment protection designated for the decontamination crew. being contaminated, it is not necessary to conduct an Another corridor may be required for the entry and extensive decontamination procedure. For example, exit of heayy equipment. Sampling and monitoring air sampling pumps hooked on a fence, placed on a equipment and sampling supplies are all maintained drum, or wrapped in plastic bags are not likely to outside of the CRC. Personnel don their equipment become heavily contaminated. A damp cloth should away from the CRC and enter the exclusion zone be used to ,wipe off contaminants which may have through a separate access control point at the hotline. adhered to equipment through airbome contaminants One person (or more) dedicated to decontaminating or from surfaces upon which the equipment was set. equipment is recommended. Disinfection/Sterilization 7.2.1 Decontamination Setup Disinfectants are a practical means of inactivating Starting with the most contaminated station, the infectious agents. Unfortunately, standard decontamination setup should be as follows: sterilization methods are impractical for large equipment. This method of decontamination is Station 1: Segregate Equipment Drop typically performed off-site. Place plastic sheeting on the ground (Figure 2, Appendix B). Size will depend on amount of equipment to be decontaminated. Provide containers, pool with tap water. Several bottle and bristle brushes lined with plastic if equipment is to be segregated. should be dedicated to this station. Approximately Segregation may be required if sensitive equipment or^ 10-50 gallons of water may be required initially mildly contaminated equipment is used at the same depending upon the amount of equipment to time as equipment which is likely to be heavily decontaminate and the amount of gross contamination. contaminated. Station 5: Low-Pressure Spravers Station 2: Phvsical Removal With A High-Pressure Washer (Optional) , Fill a low-pressure sprayer with distilled/deionized water. Provide a 5-gallon bucket or basin to contain As indicated in 7.1.2, a high-pressure wash may be the water during the rinsing process. Approximately required for compounds which are difficult to remove 10-20. gallons of water may be required initially by washing with brushes. The elevated temperature of depending tipon the amount of equipment to the water from the high-pressure washers is excellent decontaminate and the amount of gross contamination. at removing greasy/oily compounds. High pressure washers require water and electricity. StatiQn ^: .Nitirig Agid Spravgrs A decontamination pad may be required for the high- Fill a spray bottle with 10% nitric acid; An acid rinse pressure wash area. An example of a wash pad may may not be required if inorganics are not a consist of an approximately 1 1/2 foot-deep basin contaminant of concem. The amount of acid will lined with plastic sheeting and sloped to a sump at one depend on the amount of equipment to be comer. A layer of sand can be placed over the plastic decontaminated. Provide a 5-gallon bucket or basin to and the basin is filled with gravel or shell. The sump collect acid during the rinsing process. is also lined with visqueen and a barrel is placed in the hole to prevent collapse. A sump pump is used to Station 7: Low-Pressure Soravers remove the water from the sump for transfer into a drum. Fill a low-pressure sprayer with distilled/deionized water. Provide a 5-gallon bucket or basin to collect Typically heavy rriachinery is decontaminated at the water during the rinsate process. end of the day unless site sampling requires that the machinery be decontaminated frequently. A separate Station 8: Organic Solvent Soravers decontamination pad may be required for heavy equipment. Fill a spray bottle with an organic solvent. After each solvent rinse, the equipment should be rinsed with Station 3: Phvsical Removal With Brushes And A distilled/deionized water and air dried. Amount of Wash Basin solvent will depend on the amount of equipment to decontaminate. Provide a 5-gallon bucket or basin to Priorto setting up Station 3, place plastic sheeting on collect the solvent during the rinsing process. the ground to cover areas under Station 3 through Station 10. Solvent rinses may not be required unless organics are Fill a wash basin, a large bucket, or child's swimming a contaminant of concem, and may be eliminated from pool with non-phosphate detergent arid tap water. the station sequence. Several bottle and bristle bmshes to physically remove contamination should be dedicated to this station . Station 9: Low-Pressure Soravers Approximately 10 - 50 gallons of water may be required initially depending upon the amount of Fill a low-pressure sprayer with distilled/deionized equipment tp decontaminate and the amount of gross water. Provide a 5-gallpn bucket or basin to collect contamination. water during the rinsate process. Station 4: Water Basin Station 10: Clean Equipment Drop Fill a wash basin, a large bucket, or child's swimming Lay a clean piece of plastic sheeting over the bottom plastic layer. This will allow easy removal of the Using a spray bottle rinse sampling equipment with plastic in the event that it becomes dirty. Provide nitric acid. Begin spraying (inside and outside) at one aluminum foil, plastic, or other protective material to end of the equipment allowing the acid to drip to the wrap clean equipment. other end into a 5-gallon bucket. A rinsate blank may be required at this station. Refer to Section 9. 7.2.2 Decontamination Procedures Station 7: Low-Pressure Spravers Station 1: Segregate Equipment Drop Rinse sampling equipment with distilled/deionized ' Deposit equipment used on-site (i.e., tools, sampling water with a low-pressure sprayer. devices and containers, monitoring instmments radios, clipboards, etc.) on the plastic drop cloth/sheet or in Station 8: Organic Solvent Soravers different containers with plastic liners. Each will be contaminated to a different degree. Segregatiori at the Rinse sampling equipment with a solvent. Begin drop reduces the probability of cross contamination. spraying (inside and outside) at one end of the Loose leaf sampling data sheets or maps can be placed equipment allowing the solvent to drip to the other in plastic zip lock bags if contamination is evident. end into a 5-gallon bucket. Allow the solvent to evaporate from the equipment before going to the next Station 2: Phvsical Removal With A High-Pressure station. A QC rinsate sample may be required at this Washer (Optional) station. Use high pressure wash on grossly contaminated Station 9: Low-Pressure Spravers equipment. Do not use -high- pressure wash on sensitive or non-waterproof equipment. Rinse sampling equipment with distilled/deionized water with a low-pressure washer. Station 3: Phvsical Removal With Brushes And A Wash Basin Station 10 : Clean Equipment Drop Scrab equipment with soap and water using bottle and Lay clean equipment on plastic sheeting. Once air bristle bmshes. Only sensitive equipment (i.e., radios, dried, wrap sampling equipment with aluminum foil, air monitoring and sampling equipment) which is plastic, or other protective material. waterproof should be washed. Equipment which is not waterproof should have plastic bags removed and 7.2.3 Post Decontamination Procedures wiped down with a damp cloth. Acids and organic rinses may also ruin sensitive equipment. Consult the 1. Collect high-pressure pad and heavy manufactiu-ers for recommended decontamination equipment decontamination area liquid and solutions. waste and store in appropriate dmm or container. A sump pump can aid in the Station 4: Eauinment Rinse collection process. Refer to the Department of Transportation (DOT) requirements for Wash soap off of equipment with water by immersing appropriate containers based on the the equipment in the water while brushing. Repeat as contaminant of concem. many times as necessary. 2. Collect high-pressure pad and heavy Station 5: Low-Pressure Rinse equipment decontamination area solid waste and store in appropriate dmm or container. Rinse sampling equipment with distilled/deionized Refer to the DOT requirements for water with a low-pressure sprayer. appropriate containers based on the contaminant of concem. Station 6: Nitric Acid Spravers ( required onlv if metals are a contaminant of concem) 3. Empty soap and water liquid wastes from basins and buckets and store in appropriate drum or container. Refer to the DOT equipriient to test for residual contamiriation. The. requirements for appropriate containers blank water is collected in sample containers for based on the contaminant of concem. handling, shipment, and analysis. These samples are treated identical to samples collected that day. A Empty acid rinse waste and place in rinsate blank is, used to assess cross contamination appropriate container or neutralize with a brought about by improper decontarnination base and place in appropriate, drum. pH procedures. Where dedicated sarnpling equipment is paper or an equivalent pH test is required for not utilized, collect one rinsate blank per day per type neutralization. Consult DOT requirements of sampling device samples to meet QA2 arid QA3 for appropriate drum for acid rinse waste. objectives. . » Empty solvent rinse sprayer and solvent If sampling equipment, requires the use pf plastic waste into an appropriate container. Consult tubing it should be disposed of as contaminated and DOT requirements for appropriate drum for replaced with clean tubing before additional sampling solvent rinse waste; '6. Using low-pressure sprayers, rinse basins, 10.0 DATA VALIDATION and bmshes; Place; liquid generated from this process into the wash water ,rinse Results of qiiality control samples will be evaluated container. • • for contamination. This information will be utilized to ' qualify the, environmental sample results in 7. Empty low-pressure sprayer water onto the accordance with the project's data quality objectives. ground. 8. Place all solid waste materials generated 11.0 HEALTH AND SAFETY from the decontamination area (i.e., gloves and plastic sheeting, etc.) in an approved When working with potentially hazardous materials, DOT dmm. • Refer to the DOT requirements follow OSHA, U.S. EPA, corporate, and other applicable health and safety procedures. for appropriate containers based on the contaminant of concem. Decontamiriation can pose hazards under certain 9. Write appropriate labels for waste and make circiimstances. Hazardous substances may be arrangements for disposal. Consult DOT incompatible with decontamination materials. For regulations for the appropriate label for each example, the decontamination solution may react with drum generated from the decontamination .contaminants to produce heat, explosion, or toxic process. products. Also, vapors frpm decontamination . solutions may pose a direct health hazard to workers by inhalation, contact, fire, or explosion; 8.0 CALCULATIONS The decontamination solutions must be detennined to This section is not applicable to this SOP'. •- be acceptable before use. Decontamination materials may degrade protective clothing or equipment; some 9.0 QUALITYASSURANCE/ solvents can permeate, protective clothirig. I f QUALITY CONTROL decontamination rnaterials do pose a health hazard, measures should be taken to protect personnel or A rinsate blank is one specific type of quality control substitutions should.be made to eliminate the hazard. sample associated with the field decontamination The choice of respiratory protection based on process. This sample will provide information on the' contaminants of concem, from the site may not be effectiveness of the decontamination process appropriate for solvents used in the decontamination employed in the field. •' ' process. Rinsate blanks are samples obtained by-: mnning Safety considerations should be addressed when using analyte free water over decontaminated samplirig abrasive and non-abrasive decontamination equipment. Maximum air pressure produced by 12.0 REFERENCES abrasive equipment could cause physical injury. Displaced material requires control mechanisms. Field Sampling Procedures Manual, New Jersey Department of Environmental Protection, February, Material generated from decontamination activities 1988. requires proper handling, storage, and disposal. Personal Protective Equipment may be required for A Compendium of Superfund Field Operations these activities. Methods, EPA 540/p-87/001. Material safety data sheets are required for all Engineering Support Branch Standard Operating decontamination solvents or solutions as required by Procedures and Quality Assurance Manual, USEPA the Hazard Communication Standard (i.e., acetone, Region IV, April 1, 1986. alcohol, and trisodiumphosphate). Guidelines for the Selection of Chemical Protective In some jurisdictions, phosphate containing detergents Clothing, Volume 1, Third Edition, American (i.e., TSP) are banned. Conference of Govemmental Industrial Hygienists, Inc., Febmary, 1987. Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, NIOSH/OSHA/USCG/EPA, October, 1985. APPENDIX A Table Table 1. Soluble Contaminants and Recommended Solvent Rinse TABLE 1 Soluble Contaminants and Recommended Solvent Rinse SOLVENT"* EXAMPLESOF SOLUBLE SOLVENTS CONTAMINANTS Water Deionized water Low-chain hydrocarbons Tap water Inorganic compounds Salts Some organic acids and other polar compounds Dilute Acids Nitric acid Basic (caustic) compounds (e.g., amines, Acetic acid and hydrazines) Boric acid Dilute Bases Sodium bicarbonate (e.g., Acidic compounds soap detergent) Phenol Thiols Some nitro and sulfonic compounds Organic Solvents Alcohols Nonpolar compounds (e.g., some Ethers organic compounds) Ketones Aromatics Straight chain alkalines (e.g., hexane) Common petroleum products (e.g., fiiel, oil, kerosene) Organic Solvent'^' Hexane PCBs 0) . Material safety data sheets are required for all decontamination solvents or solutions as required by the Hazard Communication Standard (2) , WARNING: Some organic solvents can permeate and/or degrade the protective clothing APPENDIX B Figures Figure 1. Contamination Reduction Zone Layout EXCLUBDN HEAVY COUmSNT DECONTAMINATION AKA EXIT PATH -SI—®- OOKTAMNATPN H.IO H['»l 5 ZOfC lii I u MONtTOmNC T EOUmtENT k MIESSOUT SAWnE AIIEA SUPPLY AREA SUTP CRT 8UPPUHT ZOfC ENTRY PATH : -HOTLINE ' --•CONTAMINATION CONTROL UNE • ACCESS CONTROL POINT-ENTRANCE : •;• ACCESS CONTROL POINT-EXPT 10 APPENDIX B (Cont'd.) Figures Figure 2. Decontamination Layout EXCLUBCN HEAVY EOUIPMENT ZOfC DECONTAMINATION AREA PHYSICAL. REMOVAL i>r o o WASH BASIN WTH SOAP ANO TAP WATER RINSE BASIN WITH TAP WATER CONTAkWAnON 11 I M il l> ti LOW PRESSURE SPRAYER ZONE wnn DISTILLED WATER NITRIC ACID SPRAYER (MAY NOT i£ REOUIRED) o LOW PRESSURE SPRAYER WITH DISTILLED WATER (MAY NOT K REOUatED) ORCANIC SOLVENT SPRAYER (MAY NOT BE REOUIRED) LOW PRESSURE SPRAYER wnn DIST1Li£D WATER NOT BE RCOUBCO) CLEAN EOUIPMENT DROP 8UPPUHI ZOfC I.ECEND - HOTLINE • ; CONTAMINATION CONTROL UNE PLASTIC SHEETING OVERLAPPING PLASTIC SHEETING 11 SOP#: 2009 DATE: 11/16/94 DRUM SAMPLING REV. #: 0.0 1.0 SCOPE AND APPLICATION 3.0 SAMPLE PRESERVATION, CONTAINERS, HANDLING, The purpose of this standard operating procedure AND STORAGE (SOP) is to provide: technical guidance on implementing safe and cost-effective response actions Samples collected from drums are considered waste at hazardous waste sites containing drums with samples and as such, adding preservatives is not unknown contents. Container contents are sampled required due to the potential reaction of the sample and characterized for disposal, bulking, recycling, with the preservative. Samples should, however, be segregation, and classification purposes. cooled to 4°C and protected from sunlight in order to minimize any potential reaction due to the light These are standard (i.e., typically applicable) sensitivity of the sample. operating procedures which may be varied or changed as required, dependent on site conditions, equipment Sample bottles for collection of waste liquids, sludges, limitations or limitations imposed by the procedure. or solids are typically wide mouth arriber jars with In all instances, the ultimate procedures employed Teflon-lined screw caps. Actual volume required'for should be documented and associated with the final analysis should be determined in conjunction with the report. laboratory performing the arialysis. Mention of frade names or commercial products does Waste sample handling procedures should be as not constitute U.S. Environmental Protection Agency follows: (U.S. EPA) endorsement or recommendation for use. 1. Label the sample container with" the 2.0 METHOD SUMMARY appropriate sample label and complete the appropriate field data sheet(s). Place sample Prior to sampling, dmms must be excavated, (if container into two resealable plastic bags. necessary), inspected, staged, and opened. Dmm excavation must be performed by qualified personnel. 2. ' Place each bagged sample container into a Inspection involves the observation and recording of shipping container which has been lined with visual qualities of each dmm and any characteristics plastic. Pack the container with enough non pertinent to the classification of the dmm's contents. combustible, absorbent, cushioning material Staging involves the physical grouping of dmms to minimize the possibility of containers according to classifications established during the breaking, and to absorb any material which physical inspection. Opening of closed dmms can be may leak. performed manually or remotely. Remote dmm opening is recommended for worker safety. The most Note: Depending on the nature and quantity widely used method of sampling a dmm involves the of the material to be shipped, different use of a glass thief This method is quick, simple, packaging may be required. The relatively inexpensive, and requires no transpprtation company or a decontamination. The contents of a dmm can be shipping/receiving expert should be fiuther characterized by performing various field tests. . consulted prior to packing the samples. 3. Complete a chain of custody record for each shippirig container, place into a resealable plastic bag, and affix to the inside lid of the tube (3 meters long) is positioned at the vapor space shipping container. of the drum. A rigid, hooking device attached to the tube, goes over the chime and holds the tube securely Secure and custody seal the lid of the in place. The spear is inserted in the tube and shipping container. Label the shipping positioned against the dmm wall. A sharp blow on container appropriately and arrange for the the end of the spear drives the sharpened tip through appropriate transportation mode consistent the dmm and the gas vents along the grooves. with the type ofhazardous waste involved. Venting should be done from behind a wall or barricade. Once the pressure has been relieved, the 4.0 INTERFERENCES AND bung can be removed and the dmm sampled. POTENTIAL PROBLEMS Because there is potential for accidents to occur during handling, particularly initial handling, dmms If buried drums are suspected, geophysical should only be handled if necessary. All personnel investigation techniques such as magnetometry or should be wamed of the hazards prior to handling ground penetrating radar may be employed in an drums. Overpack dmrris and an adequate volume of attempt to determine the location and depth of drums. absorbent material should be kept near areas where During excavation, the soil must be renioved with minor spills may occur. Where major spills may great caution to minimize the potential for drum occur, a containment berm adequate to contain the mpture. entire volume of liquid in the dmms should be constmcted before any handling takes place. If dmm Until the contents are characterized, sampling contents spill, personnel trained in spill response personnel should assume that unlabelled dmms should be used to isolate and contain the.spill. contain hazardous materials. Labelled dmms are frequently mislabelled, especially dmms that are reused. Because a dmm's label may not accurately 5.0 EQUIPMENT/APPARATUS describe its contents, extreme caution must be exercised when working with or around dmms. The following are standard materials and equipment required for sampling: If a dmm which contains a liquid cannot be moved without mpture, its contents may be immediately Personal protection equipment transfened to a sound drum using an appropriate Wide-mouth amber glass jars with Teflon method of transfer based on the type of waste. In any cap liner, approximately 500 mL volume case, preparations should be made,to contain the spill Other appropriate sample jars (i.e., spill pads, dike, etc.) should one occur. Uniquely numbered sample identification labels with conesponding data sheets If a drum is leaking, open, or deteriorated, then it must Drum/Tank Sampling Data Sheets and Field be placed immediately in overpack containers. Test Data Sheets for Dmm/Tank Sampling Chain of Custody records The practice of tapping dmms to determine their Decontamination materials contents is neither safe nor effective and should not be Glass thieving tubes or COLIWASA used if the dmms are visually overpressurized or if Coring device shock-sensitive materials are suspected. A laser Stainless steel spatula or spoons thermometer may be effective in order to determine Laser thermometer the level of the dram contents via surface temperature Dmm overpacks differences. Absorbent material for spills Dmm opening devices Drums that have been overpressurized to the extent that the head is swollen several inches above the level Bung Wrench of the chime should not be moved. A number of devices have been developed for venting critically A common method for opening dmms swollen dmms. One method that has proven to be manually is using a universal bung wrench. effective is a tube and spear device. A light aluminum These wrenches have fittings made to remove nearly all commonly encountered Pneumatic Devices bungs. They are usually constructed of a non-sparking metal alloy (i.e., brass, A pneumatic bung remover consists of a bronze/manganese, aluminum, etc.) compressed air supply that is controlled by a formulated to reduce the likelihood of sparks. two-stage regulator. A high pressure air line The use of a "NON-SPARKING" wrench of desired length delivers compressed air to does not completely eliminate the possibility a pneumatic drill, which is adapted to tum of a spark being produced. bung fitting selected to fit the bung to be removed. An adjustable bracketing system Dmm Deheader has been designed to position and align the pneumatic drill over the bung. This One means by which a dmm can be opened bracketing system must be attached to the manually when a bung is not removable with dram before the drill can be operated. Once a bung wrench is by using a drum deheader. the bung has been loosened, the bracketing This tool is consfructed of forged steel with system must be removed before the dram can an alloy steel blade and is designed to cut the be sampled. This remote bung opener does lid of a dmm off or part way off by means of not permit the slow venting of the container, a scissors-like cutting action. A limitation of and therefore appropriate precautions must this device is that it can be attached only to be taken. It also requires the container to be closed head dmms. Dmms with removable upright and relatively level. Bungs that are heads must be opened by other means. rusted shut cannot be removed with this device. Hand Pick, Pickaxe, and Hand Spike 6.0 REAGENTS These tools are usually constracted of brass or a non-sparking alloy with a sharpened Reagents are not typically required for preserving point that can penetrate the dmm lid or head dram samples. However, reagents will be utilized for when the tool is swung. The hand picks or decontamination of sampling equipment. • pickaxes that are most commonly used are commercially available; whereas, the spikes 7.0 PROCEDURES are generally uniquely fabricated four foot long poles with a pointed end. 7.1 Preparation Backhoe Spike 1. Determine the extent of the sampling effort, Another means used to open dmms remotely 1 the sampling methods to be employed, and for sampling is a metal spike attached or the types and amounts of equipment and welded to a backhoe bucket. This method is supplies needed. very efficient and is often used in large-scale operations. 2. Obtain necessary sampling and monitoring equipment. i Hydraulic Dmm Opener 3. Decontaminate or preclean equipment, and Recently, remotely operated hydraulic ensure that it is in working order. devices have been fabricated to open dmms. This device uses hydraulic pressure to force 4. Prepare scheduling and coordinate with staff, a non-sparking spike through the wall of a clients, and regulatory agency, if appropriate. drum. It consists of a manually operated pump which pressurizes fluid through a 5. Perform a general site survey prior to site length of hydraulic line. entry in accordance with the site specific Health and Safety Plan. 6. Use stakes, flagging, or buoys to identify and Symbols, words, or other markings on the mark all sampling locations. If required the drum indicating hazards (i.e., explosive, proposed locations may be adjusted based on radioactive, toxic, flammable), or further site access, property boundaries, and surface identifying the drums. obstructions. Signs that the dmm is under pressure. 7.2 Drum Excavation 4. Shock sensitivity. If it is presumed that buried drums are on-site and prior to beginning excavation activities, geophysical Monitoring should be conducted around the drums investigation techniques shoiild be utilized to using instruments such as radiation meters, organic approximate the location and depth of the dmms. In vapor analyzers (OVA) and combustible gas addition, it is important to ensure that all locations indicators (CGI). where excavation will occur are clear of utility lines, pipes and poles (subsurface as well as above surface). Survey results can be used to classify the drums into categories, for instance: Excavating, removing, and handling drams are generally accomplished with conventional heavy C Radioactive • constraction equipment. These activities should be C Leaking/deteriorating performed by an equipment operator who has C Bulging experience in dmm excavation. During excavation C Lab packs activities, drums must be approached in a manner that C Explosive/shock sensitive will avoid digging directly into them. C Empty The soil around the dram should be excavated with AU persormel should assume that unmarked dmms non-sparking hand tools or other appropriate means contain hazardous materials until their contents have and as the dmms are exposed, a visual inspection been categorized. Once a dmm has been visually should be made to determine the condition of the inspected and any immediate hazard has been drums. Ambient air monitoring should be done to eliminated by overpacking or transfening the dram's determine the presence of unsafe levels of volatile contents, the dmm is affixed with a numbered tag and organics, explosives, or radioactive materials. Based transfened to a staging area. Color-coded tags, labels on this preliminary visual inspection, the appropriate or bands should be used to identify the dmm's mode of dram excavation and handling may be category based on visual inspection. A description of each dram, its condition, any unusual markings, the determined. location where it was buried or stored, and field monitoring information are recorded on a Dram/Tank Dram identification and inventory should begin before Sampling Data Sheet (Attachment 1, Appendix A). excavation. Infonnation such as location, date of This data sheet becomes the principal record keeping removal, dram identification number, overpack status, tool for tracking the dram on-site. and any other identification marks should be recorded on the Drum/Tank Sampling Data Sheet (Attachment 1, Appendix A). 7.4 Drum Staging 7.3 Drum Inspection Prior to sampling, the drams should be staged to allow easy access. Ideally, the staging area should .be Appropriate procedures for handling drams depend on located just far enough from the dram opening area to the contents. Thus, prior to any handling, dmms prevent a chain reaction if one dram should explode or should be visually inspected to gain as much catch fire when opened. information as possible about their contents. The dmms should be inspected for the following: During staging, the drams should be physically separated into the following categories: those 1. Drum condition, corrosion, mst, punctures, containing liquids, those containing solids, those bungs, and leaking contents. containing lab packs, and those which are empty. This is done because the strategy for sarripling and driims are structurally sound (no eviderice of bulging handling drums/containers in each of these categories or deformation) and .their contents are known to be will be different. This may be achieved by visual non-shock sensitive, non-reactive, npn^explosive or inspection of the drum and its labels, codes, etc. non-flamrriable. Tf opening .the drum with bung Solids and sludges are typically disposed of in open wrenches is deemed safe, then certain procedures top drams. Closed head dmms with a bung openirig . should be implemented to minimize the hazard: generally contain liquid. . C , Field personnel should be fully outfitted with Where there is good reason to suspect that drams protective gear. , •-'•'''. contain radioactive, explosive, or shock-sensitive C ., Dmms should be positioned upright with the materials, these drams should be staged iri a separate, bung up,<.or, for drams with bungs on the isolated area. Placement of explosives and shock- side, laid on their sides with the bung plugs serisitive materials in diked and fenced areas will minimize the hazard and the adverse effects of any ,C The wrenchiri'g motion should be a slow^ premature detonation of explosives: , • steady pull across the drum. If the length of the bung wrench handle provides inadequate Where space allows, the druhi opening area should, be leverage for unscrewing the plug, a "cheater physically separated from the dram removal and dram bar" can be attached to the handle to improve staging pperations. Drams are moved from the leverage. ; i staging area to the drum opening area one at a tirne using forklift tracks equipped with driim grabbers or 7.5.2 Manual'Drum Opening with a Drum a banel grappler. In a large-scale dram handling ij Deheader ' . operation, drums may be conveyed to the' drurri opening area using a roller conveyor. Dmms may.be Drurns are operied with a drum deheader (Figure 2; restaged as necessary after opening-and sampling. ., Appendix B) by first positioning the cutting edge just inside the top chime and then tightening the 7.5 Drum Opening adjustrnent screw so that the deheader is held against • •'" .. ' - •" ' • X'" the side of the dmm; • Moving the handle of the There are three basic techniques available for opening deheader up and down while sliding the deheader. dmms at hazardous waste sites: .' along the chime will enable the entire top to be.rapidly , cut off if so desired. If the top chime of a dmm has C : Manual opening with non-sparking bung been damaged or badly dented it may riot be possible wrenches ' . ," to cut. the entire top off Since there is always the C Dram deheading ' possibility that a dram may be under pressure, the C . Remote dmm puncturing or bung removal initial cut should be made very slowly to allow for the • gridual release of ariy built-up pressure. A safer The choice of dram opening, techniques and technique would be to employ a remote method prior accessories depends on the number of drams to be to using the deheader.,. . opened, their waste contents, •and physical condition. • Remote dmm opening equipment should always be Self-propelled, dram openers which are either considered in order to protect worker safety. Under electrically or pneumatically driven are available and OSHA 1910.120, manual dmm opening.with bung can be used for quicker and rripre efficient deheading. wrenches or deheaders should be-performed ONLY with stmcturally sound dmms.arid waste contents that The dmm deheader should be decontaminated, as are known to be non-shock sensitive; non-reactive, necessary, after each dram is opened to avoid cross non-explosive, and non-flarfimable. ,• contarriiriation and/or adyerse chemical reactions from incornpatible materials. '• , 7.5.1 Manual Drum Opening with a Bung Wrench ' 7.5.3 Manual Drum Opening with a Hand ,Pick, Pickaxe, or Spike • /.• . • •;.When a.drum must b e opene:d an d neithe'r a ,bun•.g •'• • '^ Manual drum opening-with bung wrenches (Figure 1, Appendix 8) should not be performed unless the wrench nor a dram deheader is suitable, then it can be 7.5.5 Remote Drum Opening with opened for sampling by using a hand pick, pickaxe, or Hydraulic Devices spike (Figure 3, Appendix B). Often the drum lid or head must be hit with a great deal of force in order to A piercing device with a non-sparking, metal point is penetrate it. Because of this, the potential for splash attached to the end of a hydraulic line and is pushed or spraying is greater than with other opening methods into the dmm by the hydraulic pressure (Figure 5, and therefore, this method of drum opiening is not Appendix B). The piercing device can be attached so recommended, particularly when opening drums that a hole for sampling can be made in either the side containing liquids. Some spikes used have been or the head of the drum. Some of the. metal piercers modified by the addition of a circular splash plate near are hollow or tube-like so that they can be left in place the penetrating end. This plate acts as a shield and if desired and serve as a permanent tap or sampling reduces the amount of splash in the direction of the port. The piercer is,designed to establish a tight seal person using the spike. Even with this shield, good after penetrating the container. splash gear is essential. * • 7.5.6 Remote Drum Opening with Since drams, some of which may be under pressure, cannot be opened slowly with these tools, spray from Pneumatic Devices drams is common and appropriate safety measures must be taken. The pick or spike should be Pneumatically-operated devices utilizing compressed decontaminated after each drum is opened to avoid air have been designed to remove dram bungs cross contarnination and/or adverse chemical reaction remotely (Figure 6, Appendix B). Prior to opening the from incompatible materials. drum, a bung fitting must be selected to fit the bung to be removed. The adjustable bracketing system is then 7.5.4 Remote Drum Opening with a attached to the dram and the pneumatic drill is aligned over the bung. This, must be done before the drill can Backhoe Spike be operated. The operator then moves away from the dmm to operate the equipment. Once the bung has Remotely operated dmrri opening tools are the safest been loosened, the bracketing system must be available means of dram opening. Remote dram removed before the dmm can be sampled. This opening is slow, but provides a high degree of safety remote bung opener does not permit the slow venting compared to manual methods of opening. of the container, and therefore appropriate precautions must be taken. It also requires the container to be In the opening area, dmms should be placed in rows upright and relatively level. Bungs that are rasted with adequate aisle space to allow ease in backhoe shut cannot be removed with this device. maneuvering. Once staged, the dmms can be quickly opened by punching a hole in the dram head or lid 7.6 Drum Sampling with the spike. ' After the dram- has been opened, preliminary The spike (Figure 4, Appendix B) should be rnonitoring of headspace gases should be performed decontaminated after each dram is opened to prevent first with an explosimeter/oxygen meter. Afterwards, Cross contamination and/or adverse reaction from an OVA or other instraments should be used. If incompatible material. Even though some splash or possible, these instmments should be intrinsically Spray may occur when this method is used, the safe. In most cases it is impossible to observe the Operator of the backhoe can be protected by mounting contents of these sealed or partially sealed dmms. a large shatter-resistant shield in front of the operator's Since some layering or stratification is likely in any cage. This combined with the normal personal solution left undisturbed, a sample that represents the protection gear should be sufficient to protect the entire depth of the dmm must be taken. operator. Additional respiratory protection can be afforded by providing the operator with an on-board airline system. When sampling a previously sealed drum; a check should be made for the presence of a bottom sludge. This is easily accomplished by measuring the depth to apparent bottom then comparing it to the known interior depth. 7.6.1 Glass Thief Sampler In many instances a drum containing waste material will-have a sludge layer on the bottom. Slow insertion The most widely used implement for sampling drum of the sample tube into this layer; then a gradual liquids is a glass tube comrnonly refened to as a glass withdrawal will allow the sludge to act as a bottom thief (Figure 7, Appendix B). This tool is cost plug to maintain the fluid in the tube. The plug can be effective, quick, and disposable. Glass thieves are gently removed and placed into the sample container typically 6mm to 16mm I.D. and 48 inches long. by the use of a stainless steel lab spoon. Procedures for Use: It should be noted that in some instances disposal of the tube by breaking it into the dram may interfere 1. Remove the cover from the sample container. with eventual plans for the removal of its contents. The use of this technique should be cleared with the 2. Insert glass tubing almost to the bottom of project officer or other glass thief disposal techniques the dmm or until a solid layer is ericountered. should be evaluated. About one foot of tubing should extend above the dmm. 7.6.2 COLIWASA Sampler Allow the waste in the dmm to reach its The Composite Liquid Waste Sampler (COLIWASA) natural level in the tube. and modifications thereof are equipment that collect a sample from the fiill depth of a drum and maintain Cap the top of the sampling tube with a it in the transfer tube until delivery to the sample tapered stopper or thumb, ensuring liquid bottle. The COLIWASA (Figure 8, Appendix B) is a does-not come into contact with stopper. much cited sampler designed to permit representative sarripling of multiphase wastes from dmms and other Carefully remove the capped tube from the containerized wastes. One configuration consists of dram and insert the uncapped end into the a 152 cm by 4 cm I.D. section of tubing with a appropriate sample container. neoprene stopper at one end attached by a rod mnning the length of the tube to a locking mechanisrri at the Release stopper and allow the glass thief to other end. drain until the container is approximately two-thirds full. Manipulation of the locking mechanism opens and closes the sampler by raising and loweririg the Remove tube from the sample container, nepprene stopper. One model of the COLIWASA is break it into pieces and place the pieces in shown in Appendix B; however, the design can be the dram. modified and/or adapted somewhat to meet the needs of the sampler. Cap the sample container tightly and label it. Place the sample container into a canier. The major drawbacks associated with using a COLIWASA concem decontamination and costs. The 9. Replace the bung or place plastic over the sarnpler is difficult to decontaminate in the field and dmm. its high cost in relation to altemative procedures (glass tubes) make it an impractical throwaway item. It still 10. Log all samples in the site logbook and on has applications, however, especially in instances Dram/Tank Sampling Data Sheets. where a tme representation of a multiphase waste is absolutely necessary. 11. Perform hazard categorization analyses if included in the project scope. Procedures for Use 12. Transport the sample to the decontamination 1. Put. the sampler in the open position by zone and package it for transport to the placing the stopper rod handle in the T- analytical laboratory, as necessary. position and pushing the rod down until the Complete chain of custody records. handle sits against the sampler's locking block. 2. Slowly lower the sampler into the liquid Procedures for use: waste. Lower the sampler at a rate that permits the levels of the liquid inside and 1. Assemble the sampling equipment. outside the sampler tube to be about the same. If the level of the liquid in the sample 2. Remove the cover from the sample container. tube is lower than that outside the sampler, the sampling rate is too fast and will result in 3. Insert the sampling device to the bottom of a non-representative sample. the dram. The extensions and the "T" handle should extend above the drum. 3. When the sampler stopper hits the bottom of the waste container, push the sampler tube 4. Rotate the sampling device to cut a core of downward against the stopper to close the material. sampler. Lock the sampler in the closed position by turning the T-handle until it is 5. Slowly withdraw the sampling device so that upright and one end rests tightly on the as much sample material as possible is locking block. retained within it. 4. Slowly withdraw the sample from the waste 6. Transfer the sample to the appropriate container with one hand while wiping the sample container, and label it. A stainless sampler tube with a disposable cloth or rag steel spoon or scoop may be used as with the other hand. necessary. 5. Carefully discharge the sample into the appropriate sample container by slowly 7. Cap the sample container tightly and place it pulling the lower end of the T-handle away in a canier. from the locking block while the lower end of the sampler is positioned in a sample 8. Replace the bung or place plastic over the container. dram. 6. Cap the sample container tightly and label it. 9. Log all samples in the site log book and on Place the sample container in a carrier. Dram/Tank Sampling Data Sheets. 7. Replace the bung or place plastic over the 10. Perform hazard categorization analyses if dmm. included in the project scope. 8. Log all samples in the site logbook and on 11. Transport the sample to the decontamination Dmm/Tank Sampling Data Sheets. zone and package it for transport to the analytical laboratory, as necessary. 9. Perform hazard categorization analyses if Complete chain of custody records. included in the project scope. 7.7 Hazard Categorization 10. Transport the sample to the decontamination zone and package for transport to the The goal of characterizing or categorizing the contents analytical laboratory, as necessary. of drums is to obtain a quick, preliminary assessment Complete the Chain of Custody records. of the types and levels of pollutants contained in the drums. These activities generally involve rapid, non 7.6.3 Coring Device rigorous methods of analysis. The data obtained from these methods can be used to make decisions A coring device may be used to sample dram solids. regarding dram staging or restaging, bulking or Samples should be taken from different areas within compositing of the dram contents. the dmm. This sampler consists of a series of extensions, a T- handle, and the coring device. As a first step in obtaining these data, standard tests 1. All data must be documented on Chain of should be used to classify the drum contents into Custody records; Drum/Tank Sampling Data general categories such as auto-reactives, water Sheets, Field Test Data Sheet for Drum/Tank reactives, inorganic acids, organic acids, heavy Sampling, or within site logbooks. metals, pesticides, cyanides, inorganic oxidizers, and organic oxidizers. In some cases, further analyses 2. All instmmentation must be operated in should be conducted to more precisely identify the accordance with operating instructions as drum contents. supplied by the manufacturer, unless otherwise specified in the work plan. There are several methods available to perform these Equipment checkout , and calibration tests: activities must occur prior to sampling/operation, and they must be C the HazCat" chemical identification system documented. C the Chlor-N-Oil Test Kit , C Spill-fyter Chemical Classifier Strips 10.0 DATA VALIDATION C Setaflash (for ignitability) This section is not applicable to this SOP. These methods must be performed according to the manufacturers' instractions and the results must be 11.0 HEALTH AND SAFETY documented on the Field Test Data Sheet for Dmrn/Tank Sampling (Attachment 2, Appendix A). When working with potentially hazardous materials, follow U.S. EPA, OSHA, and corporate health and Other tests which may be performed include: safety procedures. C Water Reactivity More specifically, the opening of closed containers is C Specific Gravity Test (compared to water) one of the most hazardous site activities.- Maximum C Water Solubility Test efforts should be made to ensure the safety of the C pH of Aqueous Solution sampling team. Proper protective equipment arid a general awareness of the possible dangers will The tests must be performed in accordance with the minimize the risk inherent to sampling operations. instmctions on the Field Test Data Sheet for Employing proper dram opening techniques and Dram/Tank Sampling and results of the tests must be equipment will also safeguard personriel. The use of documented on these data sheets. remote sampling equipment whenever feasible is highly recommended. The specific methods that will be used for hazard categorization must be documented in the Quality Assurance Work Plan. 12.0 REFERENCES Guidance Document for Cleanup of Surface Tank and 8.0 CALCULATIONS Dmm Sites, OSWER Directive 9380.0-3. This section is not applicable to this SOP. Dmm Handling Practices at Hazardous Waste Sites, EPA-600/2-86-013. 9.0 QUALITYASSURANCE/ QUALITY CONTROL The following general quality assurance procedures apply: 9 ' APPENDIX A Attachments ATTACHMENT 1. Drum/Tank Sampling Data Sheet Samplers: Date: Site Name: Work Order Number: 3347-040-001- Container Number/Sample Number: REAC Task Leader: ?1TF INFORMATION: 1. Tenain, drainage description: 2. Weather conditions (from observation): MET station on site: No Yes CONTAINER INFORMATION: 1. Container type: Drain Tank Other:_ 2. Container dimensions: Shape: Approximate size:_ 3. Label present: No Yes: Other Markings: 4. Spill or leak present: No Yes Dimensions: 5. Container location: (Circle one) N/A See Map Other: 10 APPENDIX A (Cont'd) Attachments ATTACHMENT 1. Drum/Tank Sampling Data Sheet (cont'd) SAMPLE INFORMATION: 1. Description: liquid solid ( powder or crystals) sludge 2. Color: Vapors:_ Other: 3. Local effects present: (damage - environmental, material) FIFI.D MONITORING: 1. PID: Background (clean zone) Probe used/Model used Reading from contairier opening 2. FID: Background (clean zone) Reading from container opening 3. Radiation Meter: Model used Background (clean zone) Reading from container opening 4. Explosimeter/Oxygen Meter: Oxygen level from container opening LEL level from container opening 11 APPENDIX A (Cont'd) Attachments ATTACHMENT 2. Field Test Data Sheet for Drum/Tank Sampling Samplers: Date: Site Name: Work Order Number: 3347-040-001-_ Container Number/Sample Number: REAC Task Leader: SAMPLE MONITORING INFORMATION: 1. PID: Background (clean zone) Probe used/Model used Reading from sample 2. FID: Background (clean zone) Reading from sample 3. Radiation Meter: . Model used Background (clean zone) Reading from sample 4. Explosimeter/Oxygen Meter: Oxygen level (sample) LEL level (sample) SAMPLE DESCRIPTION: Liquid Solid Sludge Color Vapors WATER REACTIVITY: 1. Add small amount of sample to water: bubbles color change to vapor formation heat No Change SPECIFIC GRAVITY TEST (compared to water): 1. Add smali amount of sample to water: sinks floats 2. If liquid sample sinks, screen for chlorinated compounds. If liquid sample floats and appears to be oily, screen for PCBs (Chlor-N-Oil kit). 12 APPENDIX A (Cont'd) Attachments ATTACHMENT 2. Field Test Data Sheet for Drum/Tank Sampling (cont'd) CHLOR N OIL TEST KIT INFORMATION: 1. Test kit used for this sample: Yes No 2. Results: PCB not present PCB present, less than 50 ppm PCB present, greater than 50 ppm .100% PCB present WATER SOLUBILITY TEST: 1. Add approximately one part sample to,five parts water. You may need to stir and heat gently. [DO NOT HEAT IF WATER REACTIVE!] Results: total partial no solubility nH OF AOUEOUS SOLUTION: 1. Using 0-14 pH paper, check pH of water/sample solution: SPILL-FYTER CHEMICAL CLASSIFIER STRIPS: 1. Acid/Base Risk: (Circle one) Color Change Strong acid (0) RED Moderately acidic (1-3) ORANGE Weak acid (5) YELLOW Neutral (7) GREEN Moderately basic (9-11) Dark GREEN Strong Base (13-14) Dark BLUE 2. Oxidizer Risk: (Circle one) Not Present WHITE Present BLUE, RED, OR ANY DIVERGENCE FROM WHITE 3. Fluoride Risk: (Circle one) Not Present PINK Present YELLOW 13 APPENDIX A (Cont'd) Attachments ATTACHMENT 2. Field Test Data Sheet for Drum/Tank Sampling (cont'd) 4. Petroleum Product, Organic Solvent Risk: (Circle one) Not Present LIGHT BLUE Present DARK BLUE 5. Iodine, Bromine, Chlorine Risk: (Circle one) Not Present PEACH Present WHITE OR YELLOW SETAFLASH IGNITABILITY TEST: 140°F Ignitable: Non-lgnitable 160°F Ignitable: Non-lgnitable Ignitable: Non-lgnitable Ignitable: Non-lgnitable Ignitable: Non-lgnitable Ignitable: Non-lgnitable Comments: HAZCAT KIT TESTS: 1. Test: Outcome: Comments: 2. Test: Outcome: Comments: 14 APPENDIX A (Cont'd) Attachments ATTACHMENT 2. Field Test Data Sheet for Drum/Tank Sampling (cont'd) 3. Test: Outcome: Commerits: 4. Test: Outcome: Comments: 5. Test: Outcome: Comments: HAZCAT PESTICIDES KIT: Present: Not Present: Comments: 15 APPENDIX B Figures Figure 1. Universal Bung Wrench 16 APPENDIX B (Cont'd) , Figures Figure 2. Drum Deheader 17 APPENDIX B (Cont'd) Figures Figure 3. Hand Pick, Pickaxe, and Hand Spike PICKAXE HANO PICK HANO SPIKE 18 APPENDIX B (Cont'd) Figures Figure 4. Backhoe Spike 19 APPENDIX B (Cont'd) Figures Figure 5. Hydraulic Drum Opener 20 APPENDIX B (Cont'd) Figures Figure 6. Pneumatic Bung Remover 21 APPENDIX B (Cont'd) Figures Figure 7. Glass Thief Cover top of sampler with gloved Insert open tube (thief) sompler in containerized liquid. thumb. 3. Ploce open tube sampler over ^ oppropriote somple bottle and Remove open tube (thti^) sampler remove gloved thumb. from containerized liquid. 22 APPENDIX B (Cont'd) Figures Figure 8. COLIWASA — EM cstOMr) T hondl* ' —r 1 t33 GHcae) -«U6 cut**) aeklng blocte - • Pip*. PVC -trtutaUicaTrt 403 enaK*> U. 4.2« cnaN*> OB, Stopper ro* PVa 132 cnttOO Q.99 enO/e^ OS. Stopper. Stoppn-, woprtrw. M, .top«r«d. a9S oO/a«) PVC lock nut •B and waBtwr SAMPUNG POSITION CLOSED POSITION 23 SOP#: 2010 TANK SAMPLING DATE: 11/16/94 REV. #: 0.0 1.0 SCOPE AND APPLICATION continue with an LEL reading greater than 25%. The purpose of this standard operating procedure 3.0 SAMPLE PRESERVATION, (SOP) is to provide technical guidance for the CONTAINERS, HANDLING, implementation of sampling protocols for tanks and AND STORAGE other confined spaces from outside the vessel. Samples collected from tanks are considered waste These are standard (i.e., typically applicable) samples and as such, addition of preservatives is not operating procedures which may be varied or changed required due to the potential reaction of the sample as required, dependent on site conditions, equipment with the preservative. Samples should however, be limitations or limitations imposed by the procedure or cooled to 4EC with ice and protected from sunlight in other procedure limitations. In all instances, the order to minimize any potential reaction due to the ultimate procedures employed should be documented light sensitivity of the sample. and associated with the final report. Sample bottles for collection of waste liquids, sludges, Mention of trade names or commercial products does or solids are typically wide mouth amber jars with not constitute U.S. EPA endorsement or Teflon-lined screw caps. Actual volume required for recommendation for use. analysis should be determined in conjunction with the laboratory performing the. analysis. 2.0 METHOD SUMMARY Waste sample handling procedures should be as The safe collection of a representative sample should follows: be the criteria for selecting sample, locations. A representative sample can be collected using 1. Place sample container in two ziplock plastic techniques or equipment that are designed for bags. obtaining liquids or sludges from various depths. The stmcture and characteristics of storage tanks present 2. Place each bagged container in a 1-gallon problems with collection of samples from more than covered can containing absorbent packing one location; therefore, the selection of sampling material. Place the lid on the can. devices is an important consideration. 3. Mark the sample ideritification number on Depending on the type of vessel and characteristics of the outside of the can. the material to be sampled, one can choose a bacon bomb sampler, sludge judge, subsurface grab sampler, 4. Place the marked cans in a cooler, and fill glass thief, bailer or Composite Liquid Waste Sampler remaining space with absorbent packing (COLIWASA) to collect the sample. A sludge judge, material. bacon bomb or COLIWASA can be used to determine if the tank contents are stratified. Various other 5. Fill out chain of custody record for each custom-made samplers may be used depending on the cooler, place in plastic, and affix to inside lid specific application. of cooler. All sample locations should be surveyed for air 6. Secure and custody seal the lid of cooler. quality prior to sampling. At no time should sanipling Anange for the appropriate transportation C Chain of Custody records mode consistent with the type ofhazardous C Flashlight (explosion proof) waste involved. C Coolers C Ice 4.0 INTERFERENCES AND C Decontamination supplies POTENTIAL PROBLEMS C Bacon bomb sampler C Sludge judge C Glass thieves Sampling a storage tank requires a great deal of C Bailers manual dexterity, often requiring climbing to the top C COLIWASA of the tank upon a nanow vertical or spiral stairway or C Subsurface grab sampler ladder while wearing protective clothing and carrying C Water/oil level indicator sampling equipment. , C OVA (organic vapor analyzer or equivalent) C Explosimeter/oxygen meter Before climbing onto the vessel, a stmctural survey C High volume blower should be performed. This will ensure appropriate consideration of safety and accessibility prior to initiation of any field activities. 6.0 REAGENTS As in all opening of containers, extreme caution Reagents are not typically required for the should be taken to avoid ignition or combustion of preservation of waste samples. However, reagents volatile contents. All tools used must be constracted will be utilized for decontamination of equipment. of a non-sparking material and electronic instraments Decontamination solutions required are specified in must be intrinsically safe. the Sampling Equipment Decontamination SOP. All sample locations should be surveyed for air 7.0 PROCEDURE quality prior to sampling. At no time should sampling continue with a lower explosive limit (LEL) reading 7.1 Preparation greater than 25%. 1. Determine the extent of the sampling effort, 5.0 EQUIPMENT/APPARATUS the sampling methods to be employed, and the types and amounts of equipment and Storage tank materials include liquids, sludges, still supplies needed. bottoms, and solids of various types. The type of sampler chosen should be compatible with the waste. 2. Obtain necessary sampling and monitoring Samplers commonly used for tanks include: a bacon equipment. bomb sampler, sludge judge, glass thief, bailer, COLIWASA, and subsurface grab sampler. 3. Decontaminate or preclean equipment, and ensure that it is in working order. Tank Sampling Equipment Checklist: 4. Prepare scheduling and coordinate with staff, C Sampling plan clients, and regulatory agency, if appropriate. C Safety equipment C Tape measure 5. Perform a general site survey prior to site C Weighted tape line, measuring stick entry in accordance with the site specific equivalent Health and Safety Plan. C Camera/film C Stainless steel bucket or bowl 6. Identify and mark all sampling locations. C Sample containers C Ziplock plastic bags 7.2 Preliminary Inspection C Logbook C Labels 1. Inspect the extemal stmctural characteristics C Field data sheets of each tank and record in the site logbook. . , Potential sampling - points . should .be • If sampling storage tanks, vacuurn trucks, or evaluated for safety, accessibility and sample ... process vessels, collect at least one sample •quality. , ' ,' ' •• ' from each compartment in the tank. Samples should always be collected through an 2. Prior to opening a tank for internal opened hatch at the top of the tank. Valves inspection, the tank sampljng team shall: . near the bottom should not be used, because . of their questionable or unknpwn integrity. • ' C ; • Review safety procedures and If such a valve cannot be closed' once . emergency contingency plans with opened; the entire tank contents may be lost the Heahh and Safety.Officer. • to the ground surface.. Also, individual strata Q, ; Ensure that the tarik. is properly cannot be sampled separately through a valve ' , grounded. • • .' near the bottom. C ' Remove all sources of ignition from the immediate area. 3., Compare the three samples for visual phase differences. If phase differences. appear, 3. Each tank should be mounted'. using , * . systematic iterative sampling should be appropriate means. Remove manwaycovers perfonned. By halving the distance between using .non-sparking tools. , , two discrete sampling points, one can determine the depth of the phase change. 4. Collect air quality measurements for, each poteritial sample location using an 4. : . If another sarnpling port is available, sample, explosimeter/oxygen meter for a lower lj, as above to. verify the phase information. explosive limit (LEL/Oj) reading "and an OVA/HNU for an organic vapor 5. • Measure the inside diariieter.of the tank and concentration. Both readings should be taken determine the volume, of wastes using the from the tank headspace, above the sarnpling ' .J ' depth rneasurements. (Appendix A). port, and'in the breathing zone. Measuririg the extemal diameter may be rriisleading as some tanks are insulated or' 5. Prior to comriiencing sampling, the tank • have extemal supports that are covered. " . . . headspace should be cleared of ariy toxic or ' explosive vapor concentration usirig a high 6. Sludges can be collected usirig a bacon bomb volurne explosion proof blower. No work sampler, glass thief, or sludge judge. shall start if LEL readings exceed 25%. At 10% LEL, work can continue, but with 7. ' Record all infprrnation on the sample data extreme caution. • . sheet or site logbook. Label-the container with the appropriate sample tag. 7.3 Sampling Procedure 8. , Decontaminate sarripling equipment as per 1. Determine the depth pf any and all liquid, ' ;, the. steps!listed in the Sampling Equipment solid, and liquid/solid interface; and depth of Decontamination SOP. sludge using a weighted tape nieasure, probe line,,sludge judge, or equivalent. , 7.4 Sampling Devices 2. Collect liquid samples. from one (1) foot 7.4.1 Bacon Bomb Sampler . below, the surface, from mid-depth of liquid,, and from one (1) foot above, the bottom : The bacon bomb sampler (Figure 1, Appendix B) is sludge layer. This can be accomplished with , designed for the collection of material from various a subsurface grab sampler or bacon bomb. levels within a storage tank. It consists of a For liquids less than five (5) feet in depth, " cylindrical body, usually made of chrome-plated brass use a glass thief or COLIWASA to collect and bronze with an intemal tapered plunger that acts • the sample. as a valve to admit the sample.; A line attached to the top of the plunger opens and closes the valve. A line is attached to the removable top cover which has a length of the sludge judge. The sampler consists of locking mechanism to keep the plunger closed after 3/4" plastic pipe in 5-ft. sections, marked at 1-ft. sampling. increments, with screw-type fittings. Procedures for Use: Procedures for Use: 1. Attach the sample line and the plunger line to 1. Lower the sludge judge to the bottom of the the sampler. tank. 2. Measure and then mark the sampling line at 2. When the bottom has been reached, the pipe the desired depth: is allowed-to fill to the surface level. This will seat the check valve, frapping the 3. Gradually lower the sampler by the sample column of material. line until the desire level is reached. 3. When the unit has been raised clear of the 4. When the desired level is reached, pull up on tank liquid, the amount of sludge in the the plunger line and allow the sampler to fill sample can be read using the one foot before releasing the plunger line to seal off increments marked on the pipe sections. the sampler. 4. By touching the pin extending from the 5. Refrieve the sampler by the sample line bottom section against a hard surface, the being carefiil not to pull up on the plunger material is released from the unit. line and thereby prevent accidental opening of the bottom valve. 5. Cap the sample container tightly and place prelabeled sample container in a carrier. 6. Rinse or wipe off the exteripr of the sampler body. • : . 6. Replace the, flange or manway or place plastic over the tank. 7. Position the sampler over the sample container and release its contents by pulling 7. Log all samples in the site logbook and on up on the plunger line. field data sheets and label all samples. 8. Cap the sample container tightly and place 8. Package samples and complete necessary prelabeled sample container in a carrier. paperwork. 9. Replace the flange or manway or place 9. Transport sample to decontamination zone plastic over the tank. for preparation for transport tp analytical laboratory. 10. Log all samples in the site logbook and on '' field data sheets and label all samples. 7.4.3 Subsurface Grab Sampler 11. Package samples and complete necessary Subsurface grab samplers (Figure 3, Appendix'B) are paperwork. designed to collect samples of liquids at various depths. The sampler is usually constracted of 12. Transport sample to decontamination zone aluminum or stainless steel tubing with a . for preparation for transport to analytical polypropylene or teflon head fhat attaches to a 1 -liter laboratory. sample container. 7.4.2 Sludge Judge Procedures for Use: A' sludge judge (Figure 2, Appendix B) is used for 1. Screw the sample bottle onto the sampling obtaining an accurate reading of settleable solids in head. any liquid. The sampling depth is dependent upon the 2. Lower the sampler to the desired depth. outside of the sample container. 3. Pull the ring at the top which opens the 6. Release stopper and allow the glass thief to spring-loaded plunger in the head assembly. drain until the container is approximately 2/3 fulL 4. When the bottle is full, release the ring, lift sampler, and remove sample bottle. ' 7. Remove tube from the sample container, break it into pieces and place the pieces in 5. Cap the sample container tightly and place the tank. prelabeled sample container in a canier. 8. Cap the sample container tightly and place 6. Replace the flange or manway or place prelabeled sample container in a carrier. plastic over the tank. 9. Replace the bung or place plastic over the 7. Log all samples in the site logbook and on tank. field data sheets and label all samples. 10. Log all samples in the site logbook and on 8. Package samples and complete necessary field data sheets and label all samples. paperwork. 11. Package samples and complete necessary 9. Transport sample to decontamination zone paperwork. for preparation for ttansport to analytical laboratory. 12. Transport sample to decontamination zone for preparation for transport to analytical 7.4.4 Glass Thief laboratory. The most widely used implement for sampling is a In many instances a tank containing waste material glass tube commonly refened to as a glass thief will have a sludge layer pn the,bottom. Slow insertion (Figure 4, Appendix B). This tool is simple, cost of the sample tube down into this layer and then a effective, quick, and collects a sample without having gradual withdrawal will allow the sludge to act as a to decontaminate. Glass thieves are typically 6mm to bottom plug to maintain the fluid in the tube. The 16mm I.D. and 48 inches long. plug can be gently removed and placed into the sample container by the use of a stainless steel lab Procedures for Use: spoon. 1. Remove cover from sample container. 7.4.5 Bailer 2. Insert glass tubing almost to the bottom of The positive-displacement volatile sampling bailer the tank or until a solid layer is encountered. (Figure 5, Appendix B) (by GPI) is perhaps the most About one foot of tubing should extend appropriate for collection of water samples for volatile above the dmm. analysis. Other bailer types (messenger, bottom fill, etc.) are less desirable, but may be mandated by cost 3. Allow the waste in the tank to reach its ..and site conditioris. Generally, bailers can provide an natural level in the tube. acceptable sample, providing that the sampling personnel use extra care in the collection process. 4. Cap the top of the sampling tube with a tapered stopper or thumb, ensuring liquid Operation does not come into contact with stopper. Make sure clean plastic sheeting sunounds 5. Carefully remove the capped tube from the the tank. tank arid insert the uncapped end in the sample container. Do not spill liquid on the 2. Attach a line to the bailer. 3. Lower the bailer slowly and gently into the instances where a true representation of a multiphase tank so as not to splash the bailer into the waste is absolutely necessary. tank contents. Procedures for Use: 4. Allow the bailer to fill completely and retrieve the bailer from the tank. 1. Put the sampler in the open position by placing the stopper rod handle in the T- 5. Begin slowly pouring from the bailer. position and pushing the rod down until the handle sits against the sampler's locking 6. Cap the sample container tightly and place block. prelabeled sample container in a canier. 2. Slowly lower the sampler into the liquid 7. Replace the flange or manway or place waste. Lower the sampler at a rate that plastic over the tank. permits the levels of the liquid inside and outside the sampler tube to be about the 8. Log all samples in the site logbook and on same. If the level of the liquid in the sample field data sheets and label all samples. tube is lower than that outside the sampler, the sampling rate is too fast and will result in 9. Package samples and complete necessary a non-representative sample. paperwork. 3. When the sampler stopper hits the bottom of 10. Transport sample to decontamination zone the waste container, push the sampler tube for preparation for transport to analytical downward against the stopper to close the laboratory. sampler. Lock the sampler in the closed position by tuming the T-handle unfil it is 7.4.6 COLIWASA upright and one end rests tightly on the locking block. Sampling devices are available that allow collection of a sample from the ftill depth of a tank and maintain 4. Slowly withdraw the sample from the waste its integrity in the transfer tube until delivery to the container with one hand while wiping the sample bottle. The sampling device is known as a sampler tube with a disposable cloth or rag Composite Liquid Waste Sampler (COLIWASA) with the other hand. (Figure 6, Appendix B). The COLIWASA is a much cited sampler designed to permit representative 5. Carefiilly discharge the sample into a sampling of multiphase wastes from tanks and other suitable sample container by slowly pulling containerized wastes. the lower end of the T-handle away from the locking block while the lower end of the One configuration consists of a 152 cm by 4 cm LD. sampler is positioned in a sample container. section of tubuig with a neoprene stopper at one end attached by a rod ranning the length of the tube to a 6. Cap the sample container tightly and place locking mechanism at the other end. Manipulation of prelabeled sample container in a carrier. the locking mechanism opens and closes the sampler by raising and lowering the neoprene stopper. 7. Replace the bung or place plastic over the tank. The major drawbacks associated with using a COLIWASA concem decontamination and costs. The 8. Log all samples in the site logbook and on sampler is difficult to decontaminate in the field, and field data sheets and label all samples. its high cost in relation to altemative procedures (glass tubes) makes it an impractical throwaway item. 9. Package samples and complete necessary Disposable COLIWASA's are a viable altemative. paperwork. However, the COLIWASA is still the sampling device of choice for specific applications, especially in 10. Transport sample to decontamination zone illness, or death to the worker. Failure to recognize for preparation for transport to analytical potential hazards of waste containers is the cause of laboratory. most accidents. It should be assumed that the most unfavorable conditions exist, and that the danger of 8.0 CALCULATIONS explosion and poisoning will be present. Hazards specific to tank sampling are: There are no specific calculations for these procedures. Refer to Appendix A regarding 1. Hazardous atmospheres which are either calculations utilized in determining tank volumes. flammable, toxic, asphyxiating, or conosive. 9.0 QUALITY ASSURANCE/ 2. If activation of electrical or mechanical equipment would cause injury, each piece of QUALITY CONTROL equipment should be manually isolated to prevent inadvertent activation while workers There are no specific quality assurance activities are occupied. which apply to the implementation of these procedures. However, the following general QA 3. Communication is of utmost importance procedures apply: between the sampling worker and the standby person to prevent distress or injury 1. All data must be documented on field data going unnoticed. sheets or within site logbooks. 4. Proper procedures to evacuate a tank with 2. All instmmentation must be operated in forced air and grounding of equipment and accordance with operating instructions as tanks should be reviewed. supplied by the manufacturer, unless otherwise specified in the work plan. Equipment • checkout and calibration 12.0 REFERENCES activities must occur prior to sampling/operation and they must be Guidance Document for Cleanup of Surface Tank and documented. Dram Sites, OSWER Directive 9380.0-3. Dram Handling Practices at Hazardous Waste Sites, 10.0 DATA VALIDATION EPA-600/2-86-013. This section is not applicable to this SOP. 11.0 HEALTH AND SAFETY When working with potentially hazardous materials, follow U.S. EPA, OSHA, and corporate health and safety procedures. More specifically, the hazards associated with tank sampling may cause bodily- injury, x APPENDIX A Calculations Various Volume Calculations ^flY RFrTAMCUlAR CONTAINER SPHgRE Total Volume V-1/6 nO^ -0.523498D' Total Volume ''ortiol Volume V-HLW -1/3 nd^ (3/2 D-d) Partial Volume Totol Volume V-hLW V- „BDH Portiol Volume V-^rBDh Tffl^^ftlllAR KOMTAINER BIBHT CYUNDER Total Volume V-1/2 HBL bid Caae 1 T Partial Volume M V-1/2 hBL L Total Volume V-1/4nD2 H Partial Volume Cose 2 V-1/* IT h Portiol Volume V-1/2 L(HB-hB) r APPENDIX A (Cont'd) Calculations Various Volume Calculations (Cont'd) Cose 1 Co»# 2 Total Volume V- n/12 H(0,* +0, Dj+Dj^ ) Portiol Volume J- V- n/12 h(D,* +0, d+d^) SQUg Toted Volume Cose 1 Cose 2 V- n/12-D^H Partial Volume £ius_l \ V- n/12-d*h Partial Volume ttoae 2 V- n/l2-(0*H-d*h) P^ffftRH"^ rOMTAINER Cose 1 Partial Volume V-2/3 hdL Totol Volume V-2/3 HDL Case 2 Portiol Volume V-2/3 (HD-hd)-L APPENDIX B Figures FIGURE 1. Bacon Bomb Sampler 10 APPENDIX B (Cont'd) Figures FIGURE 2. Sludge Judge 5 top pipe -L|5X middle pipe 1 .^l^. bottom pipe 11 APPENDIX B (Cont'd) Figures FIGURE 3. Subsurface Grab Sampler 12 APPENDIX B (Cont'd) Figures' .. FIGURE 4. Glass Thief . 1. y Covsr top of sampler with glovsd Insert open tube (thief) «ompler in contoinerized liquid. thumb. 4. 3. Ploce open tube sompler over " ^ appropriate sample bottle ond Remove open tube (thief) lomplw remove gloved thumb. from contoinerired liquid. 13 APPENDIX B (Cont'd) Figures FIGURE 5. Bailer STAINLESS WIRE CABLE .1-1/4" O.D.xri.D.TEFT.ON EXTRUDED TUBING. 18 TO 3^ LONG ^ 3/4" DIAMETER GLASS OR TEFLON 1" DIAMETER TEFLON EXTRUDED ROD 5/16" DIAMETER HOLE 14 APPENDIX B (Cont'd) Figures FIGURE 6. COLIWASA — EJM enOMT) T hofidl* ' &39 encsm ackino block - • Pipe PVC -tTAnslunnt 4J3 cnaH*) UL 4.86 enQK*) OB. Stopper ro* PVa IK cn<«0*> a93 enC3/8*} OS. Stopper • Stopper, iMropr»n«. »9,. tap«r«A a9S CfO/B") PVC lock nut and iractwr SAMPUNG POSITION CLOSED POSITION 15 U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 , PAGE 1 of 13 REV 0.0 DATE 02/18/00 SOIL SAMPLING CONTENTS I. 0 SCOPE AND APPLICATION 2.0 METHOD SUMMARY 3.0 SAMPLE PRESERVATION, CONTAINERS, HANDLING, AND STORAGE 4.0 POTENTIAL PROBLEMS . . 5.0 EQUIPMENT ; 6.0 REAGENTS • ' 7.0 PROCEDURES 7.1 Preparation 7.2' Sample Collection , 7.2.1 Surface Soil Samples 7.2.2 Sampling at Depth with Augers and Thin Wall Tube Samplers 7.2.3 Sampling at Depth with a Trier 7.2.4 Sampling at Depth with a Split Spoon (Barrel) Sampler 7.2.5 Test Pit/Trench Excavation 8.0 CALCULATIONS 9.0 QUALITY ASSURANCE/QUALITY CONTROL 10.0 DATA VALIDATION II. 0 HEALTH AND SAFETY 12.0 REFERENCES 13.0 APPENDIX Figures SUPERCEDES: SOP #2012; Revision 0.0; 11/16/94; U.S.,EPA Contract 68-C4-0022. U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 2 of 13 REV 0.0 DATE: 02/18/00 SOIL SAMPLING 1.0 SCOPE AND APPLICATION The purpose of this standard operating procedure (SOP) is to describe the procedures for the collection of representative soil samples. Sampling depths are assumed to be those that can be reached without the use of a drill rig, direct-push, or other mechanized equipment (except for a back-hoe). Analysis of soil samples may determine whether concentrations of specific pollutants exceed established action levels, or if the concentrations of pollutants present a risk to public health, welfare, or the environment. These are standard (i.e., typically applicable) operating procedures which may be varied or changed as required, dependent upon site conditions, equipment limitations or limitations imposed by the procedure. In all instances, the actual procedures used should be documented and described in an appropriate site report. Mention of trade names or commercial products does not constitute U.S. Environmental Protection Agency (EPA) endorsement or recommendation for use. 2.0 METHOD SUMMARY Soil samples may be collected using a variety of methods and equipment depending on the depth of the desired sample, the type of sample required (disturbed vs. undisturbed), and the soil type. Near-surface soils may be easily sampled using a spade, trowel, and scoop. Sampling at greater depths may be performed using a hand auger, continuous flight auger, a trier, a split-spoon, or, if required, a backhoe. 3.0 SAMPLE PRESERVATION, CONTAINERS, HANDLING, AND STORAGE Chemical preservation of solids is not generally recommended. Samples should, however, be cooled and protected from sunlight to minimize any potential reaction. The amount of sample to be collected and proper sample container type are discussed in ERT/REAC SOP #2003 Rev. 0.008/11/94, Sample Storage, Preservation and Handling. 4.0 INTERFERENCES AND POTENTIAL PROBLEMS There are two primary potential problems associated with soil sampling - cross contamination of samples and improper sample collection. Cross contamination problems can be eliminated or minimized through the use of dedicated sampling equipment. If this is not possible or practical, then decontamination of sampling equipment is necessary. Improper sample collection can involve using contaminated equipment, disturbance of the matrix resulting in compaction of the sample, or inadequate homogenization of the samples where required, resulting in variable, non-representative results. 5.0 EQUIPMENT li^32X| U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 3 of 13 REV 0.0 DATE 02/18/00 SOIL SAMPLING Soil sampling equipment includes the following: Maps/plot plan Safety equipment, as specified in the site-specific Health and Safety Plan Survey equipment or global positioning system (GPS) to locate sampling points Tape measure Survey stakes or flags Camera and film Stainless steel, plastic, or other appropriate homogenization bucket, bowl or pan Appropriate size sample containers Ziplock plastic bags Logbook Labels Chain of Custody records and custody seals Field data sheets and sample labels Cooler(s) Ice .Vermiculite. Decontamination supplies/equipment Canvas or plastic sheet Spade or shovel Spatula ;V Scoop ' . Plastic or stainless steel spoons Trowel(s) Continuous flight (screw) auger , Bucket auger - Post hole auger Extension rods T-handle Sampling trier Thin wall tube sampler Split spoons Vehimeyer soil sampler outfit - Tubes - Points - Drive head - Drop hammer , . - Puller jack and grip Backhoe 6.0 . REAGENTS U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 4 of 13 REV 0.0 DATE 02/18/00 SOIL SAMPLING Reagents are not used for the preservation of soil samples. Decontamination solutions are specified in ERT/REAC SOP #2006 Rev. 0.0 08/11/94, Sampling Equipment Decontamination, and the site specific work plan. 7.0 PROCEDURES 7.1 Preparation 1. Determine the extent of the sampling effort, the sampling methods to be employed, and the types and amounts of equipment and supplies required. 2. Obtain necessary sampling and monitoring equipment. 3. Decontaminate or pre-clean equipment, and ensure that it is in working order. 4. Prepare schedules and coordinate with staff, client, and regulatory agencies, if appropriate. 5. Perform a general site survey prior to site entry in accordance with the site specific Health and Safety Plan. 6. Use stakes, flagging,o r buoys to identify and mark all sampling locations. Specific site factors, including extent and nature of contaminant, should be considered when selecting sample location. If required, the proposed locations may be adjusted based on site access, property boundaries, and surface obstructions. All staked locations should be utility-cleared by the property owner or the On-Scene-Coordinator (OSC) prior to soil sampling; and utility clearance should always be confirmed before beginning work. 7.2 Sample Collection 7.2.1 Surface Soil Samples Collection of samples from near-surface soil can be accomplished with tools such as spades, shovels, trowels, and scoops. Surface material is removed to the required depth and a stainless steel or plastic scoop is then used to collect the sample. This method can be used in most soil types but is limited to sampling at or near the ground surface. Accurate, representative samples can be collected with this procedure depending on the care and precision demonstrated by the sample team member. A flat, pointed mason trowel to cut a block of the desired soil is helpful when undisturbed profiles are required. Tools plated with chrome or other materials should not be used. Plating is particularly common with garden implements such as potting trowels. The following procedure is used to collect surface soil samples: U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 5 of 13 REV 0.0 DATE 02/18/00 SOILSAMPLING 1. Carefully reiriove the top layer of soil or debris to the desired sample depth with a pre-cleaned spade. 2. Using a pre-cleaned, stainless steel scoop, plastic spoon, or trowel, remove and discard a thin layer of soil from the area which came in contact with the spade. 3. If volatile organic analysis is to be performed, transfer the sample directly into an appropriate, labeled sample container with a stainless steel lab spoon, or equivalent and secure the cap tightly. Place the remainder of the sample into a stainless steel, plastic, or other appropriate homogenization container, and mix thoroughly to obtain a homogenous sample representative of the entire ' sampling interval. Then, either place the sample into appropriate, labeled containers and secure the caps tightly; or, if composite samples are to be collected, place a sample from another sampling interval or location into the homogenization container and mix thoroughly. When compositing is complete, place the sample into appropriate, labeled containers and secure the caps tightly. 7.2.2 . Sampling at Depth with Augers and Thin Wall Tube Samplers This system consists of.an auger, or a thiri-wall tube sampler, a series of extensions, and a "T" handle (Figure 1, Appendix A). The auger is used to bore a hole to a desired sampling depth, and is then withdrawn. The sample may be collected directly from the auger. If a core sample is to be collected, the auger tip is then replaced with •; • a thin wall tube sampler. The systern is then lowered down the borehole, and driven into the soil to the completion depth. The system is withdrawn and the core is collected from the thin wall tube sampler. I Several types of augers are available; these include: bucket type, continuous flight (screw), and post-hole augers. Bucket type augers are better for direct sample recovery because they provide a large volume of sample in a short time. When continuous flight augers are used, the sample can be collected directly from the flights. The continuous flight augers are satisfactory when a composite of the complete soil column is desired. Post-hole augers have limited utility for sample collection as they are designed to cut through fibrous,rooted , swampy soil and cannot be used below a depth of approximately three feet. The following procedure is used for collecting soil samples with the auger: ,' 1. Attach the auger bit to a drill rod extension, and attach the "T" handle to the drill rod. U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 6 of 13 REV 0.0 DATE 02/18/00 SOIL SAMPLING 2. Clear the area to be sampled of any surface debris (e.g., twigs, rocks, litter). It may be advisable to remove the first three to six inches of surface soil for an area approximately six inches in radius around the drilling location. 3. Begin augering, periodically removing and depositing accumulated soils onto a plastic sheet spread near the hole. This prevents accidental brushing of loose material back down the borehole when removing the auger or adding drill rods. It also facilitates refilling the hole, and avoids possible contamination of the surrounding area. 4. After reaching the desired depth, slowly and carefully remove the auger from the hole. When sampling directly from the auger, collect the sample after the auger is removed from the hole and proceed to Step 10. 5. Reiriove auger tip from the extension rods and replace with a pre-cleaned thin wall tube sampler. Install the proper cutting tip. 6. Carefully lower the tube sampler down the borehole. Gradually force the tube sampler into the soil. Do not scrape the borehole sides. Avoid hammering the rods as the vibrations may cause the boring walls to collapse. 7. Remove the tube sampler, and unscrew the drill rods. 8. Remove the cutting tip and the core from the device. 9. Discard the top of the core (approximately 1 inch), as this possibly represents material collected before penetration of the layer of concern. Place the remaining core into the appropriate labeled sample container. Sample homogenization is not required. 10. If volatile organic analysis is to be performed, transfer the sample into an appropriate, labeled sample container with a stainless steel iab spoon, or equivalent and secure the cap tightly. Place the remainder of the sample into a stainless steel, plastic, or other appropriate homogenization container, and mix thoroughly to obtain a homogenous sample representative of the entire sampling interval. Then, either place the sample into appropriate, labeled containers and secure the caps tightly; or, if composite samples are to be collected, place a sample from another sampling interval into the homogenization container and mix thoroughly. When compositing is complete, place the sample into appropriate, labeled containers and secure the caps tightly. U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES ' • PAGSOPE : , 7 201of 123 REV 0.0 DATE 02/18/00' SOIL SAMPLING • 11. If another sample is to be collected in the same hole, but at a greater depth, reattach.the auger bit to the drill and assembly, and follow steps 3 through 11, making sure to decontaminate the auger and tube sampler between samples. 12. Abandon the hole according to applicable state regulations. Generally, shallow holes cari simply be backfilled with the removed soil material. 7-.2.:3 Sampling with a Trier , " , The system consists of a trier, and a "T" handle. The auger is driven into the soil to ' be sampled and used to extract a core sample from the appropriate depth. ./ • The following procedure is used to collect soil samples with a sampling trier: 1. Insert the trier (Figure 2, Appendix A) into the material to be sampled at a 0° to 45° angle from horizontal. This orientation minimizes the spillage of . , - sample. . • ; • . ' ' . ; 2. ' Rotate the trier once or twice to cut a core of material. ,3., Slovyly withdraw the trier, making sure that the slot is facing upward. . .'• 4. If".volatile'organic analyses? are required,' transfer the sample into an appropriate,"labeled sample.; container with a stainless steel lab spoon, or equivalent and secure the cap tightly. • Place the remainder of the sample into a stainless steel, plastic, or other appropriate homogenization container, and mix thoroughly to obtain a homogenous sample representative of the entire sampling interval. Then, either place the sample into appropriate, labeled , cbntainers and secure the caps tightly; or, if composite samples are to be ' collected, place a sample' from' another .sampling interval into the . homogenizatioricontainer arid mix thoroiighly: When compositing is complete, place the'sample into, appropriate, labeled containers and secure the caps tightly. ; 7.2.4. Sampling at Depth vvith a Split Spoon (Barrel) Sampler Split spoon sampling is gerierally used to collect undisturbed soil cores of 18 or 24 •.•. inches in length. -A series of consecutive, cores nfiay be extracted with a split spoon sanipler to give a complete soil column profile; or an auger may be used to drill down to the desired depth for sampiing. The split spoon is then driven to its sampling depth through the bottom of the augured hole and the core extracted. Wheri split spoon sampling is performed to gain geologic information, all work should U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 8 of 13 REV 0.0 DATE 02/18/00 SOIL SAMPLING be performed in accordance with ASTM D1586-98, "Standard Test Method for Penetration Test and Split-Barrel Sampling of Soils". The following procedures are used for collecting soil samples with a split spoon: 1. Assemble the sampler by aligning both sides of barrel and then screwing the drive shoe on the bottom and the head piece on top. 2. Place the sampler in a perpendicular position on the sample material. 3. Using a well ring, drive the tube. Do not drive past the bottom of the head piece or compression of the sample will result. 4. Record in the site logbook or on field data sheets the length of the tube used to penetrate the material being sampled, and the number of blows required to obtain this depth. 5. Withdraw the sampler, and open by unscrewing the bit and head and splitting the barrel. The amount of recovery and soil type should be recorded on the boring log. If a split sample is desired, a cleaned, stainless steel knife should be used to divide the tube contents in half, longitudinally. This sampler is typically available in 2 and 3 1/2 inch diameters. A larger barrel may be necessary to obtain the required sample volume. 6. Without disturbing the core, transfer it to appropriate labeled sample container(s) and seal tightly. 7.2.5 Test Pit/Trench Excavation A backhoe can be used to remove sections of soil, when detailed examination of soil characteristics are required. This is probably the most expensive sampling method because of the relatively high cost of backhoe operation. The following procedures are used for collecting soil samples from test pits or trenches: 1. Prior to any excavation with a backhoe, it is important to erisure that all samplirig locatioris are clear of overhead and buried utilities. 2. Review the site specific Health & Safety plan and ensure that all safety precautions including appropriate monitoririg equipmerit are iristalled as required. U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 9 of 13 REV 0.0 DATE 02/18/00 SOIL SAMPLING 3. Using the backhoe, excavate a trench approximately three feet wide and approximately one foot deep below the cleared sampling location. Place excavated soils on plastic sheets. Trenches greater than five feet deep must be sloped or protected by a shoring system, as required by OSHA regulations. 4. A shovel is used to remove a one to two inch layer of soil from the vertical face of the pit where sampling is to be done. 5. Samples are taken using a trowel, scoop, or coring device at the desired intervals! Be sure to scrape the vertical face at the point of sampling to remove any soil that may have falien from above, and to expose fresh soil for sampling. In many instances, samples can be collected directiy from the backhoe bucket. 6. If volatile organic analyses are required, transfer the sample into an appropriate, labeled sample container with a stainless steel lab spoon, or equivalent and secure the cap tightly. Place the remainder of the sample into a stainless steel, plastic, or other appropriate homogenization container, and mix thoroughly to obtain a homogenous, sample representative of the entire sampling interval. Then, either place the sample into appropriate, labeled containers and secure the caps tightly; or, if composite samples are to be collected, place a sample from another sampling interval into the homogenization container and mix thoroughly. When compositing is complete, place the sample into appropriate, labeled containers and secure the caps tightly. 7. Abandon the pit or excavation accordirig to applicable state regulations. Generally, shallow excavations can simply be backfilled with the removed soil material. 8.0 CALCULATIONS This section is not applicable to this SOP. 9.0 QUALITY ASSURANCE/QUALITY CONTROL There are no speciflc quality assurance (QA) activities which apply to the implementation of these procedures. However, the following QA procedures apply: 1. All data must be documented on field data sheets or within site logbooks. 2. All instrumentation must be operated in accordarice with operating instructioris as supplied by the manufacturer, unless otherwise specified in the work plan. Equipment checkout and calibration U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 10 of 13 REV 0.0 DATE 02/18/00 SOIL SAMPLING activities must occur prior to sampling/operation, and they must be documented. 10.0 DATA VALIDATION This section is not applicable to this SOP. 11.0 HEALTH AND SAFETY When working with potentially hazardous materials, follow U.S. EPA, OHSA and corporate health and safety procedures, in addition to the procedures specified in the site specific Health & Safety Plan.. 12.0 REFERENCES Mason, B.J. 1983. Preparation of Soil Sampling Protocol: Technique and Strategies. EPA-600/4-83-020. Barth, D.S. and B.J. Mason. 1984. Soil Sampling Quality Assurance User's Guide. EPA-600/4-84-043. U.S. Environmental Protection Agency. 1984 Characterization of Hazardous Waste Sites - A Methods Manual: Volume II. Available Sampling Methods, Second Edition. EPA-600/4-84-076. de Vera, E.R., B.P. Sinunons, R.D. Stephen, and D.L. Storm. 1980. Samplers and Sampling Procedures for Hazardous Waste Streams. EPA-600/2-80-018. ASTM D 1586-98, ASTM Committee on Standards, Philadelphia, PA. U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 11 of 13 REV 0.0 DATE 02/18/00 SOIL SAMPLING APPENDIX A Figures SOP #2012 February 2000 U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 12 of 13 REV 0.0 DATE 02/18/00 SOIL SAMPLING FIGURE 1. Sampling Augers ] U. S. EPA ENVIRONMENTAL RESPONSE TEAM STANDARD OPERATING PROCEDURES SOP 2012 PAGE 13 of 13 REV 0.0 DATE 02/18/00 SOIL SAMPLING FIGURE 2. Sampling Trier r d If I V .J L 1J7-2.S4 m O/r-T) SOP#: 2017 WASTE PILE SAMPLING DATE: 11/17/94 REV. #: 0.0 1.0 SCOPE AND APPLICATION Wide mouth glass containers with Teflon lined caps are' typically used for waste pile, samples. Sample The objective ofthis standard operating procedure volume required is a fimction of the analytical (SOP) is to oudine the equipment and methods used in requirements and should be specified in the work plan. collecting representative samples from waste piles, sludges or other solid or liquid waste mixed with soil. 4.0 INTERFERENCES AND POTENTIAL PROBLEMS These are standard (i.e., typically applicable) operating procedures which may be varied or changed There are several variables ' involved in waste as required, dependent on site conditions, equipment sampling, including shape arid size of piles, limitations or other procedure limitations. In all corhpactness, and structure of the waste material. instances, the ultimate procedures employed should be Shape and size of waste material or waste piles vary documented and associated with the final report. greatly in areal extent and height. Since state and federal regulations often require a specified number of Mention of trade names or commercial products does samples per volume of waste, the size and shape must not constitute U.S. EPA endorsement or^ be used to calculate volume and to plan for the correct recommendation for use. number of samples. Shape must also be accounted for when plarming physical access to the sampling point 2.0 METHOD SUMMARY and the equipment necessary to successfully collect the sample at that location. Stainless steel shovels, trowels, or scoops should be used to clear away surface material before samples are Material to be sampled may be homogeneous or collected. For depth samples, a decontaminated auger heterogeneous. Homogeneous material resulting from may be required to advance the hole, then another known situations may not require an extensive decontaminated auger used for sample collection. For sampling protocol. Heterogeneous and unknown a sample core, thin-wall tube samplers • or grai n wastes require more extensive sampling and analysis samplers may be used. Near surfaces, samples can be to ensure the different components (i.e. layers, strata) collected with a clean stainless steel spoon pr trowel. are being represented. All samples collected, except those for volatile The term "representative sample" is commonly used organic analysis, should be placed into a Teflon lined to denote a sample that has the properties and or stainless steel pail and mixed thoroughly before composition of the ^population from which it was transfer to appropriate sample container. < collected and in the same proportions as found in the population. This can be misleading unless one is 3.0 SAMPLE PRESERVATION, dealing with a homogenous waste from which one CONTAINERS, HANDLING, sample can represent the whole population. AND STORAGE The usual options for obtaining the most "representative sample" from waste piles are simpl e Chemical preservation of solids is- generally not random sampling or stratified random sampling. recommended. Refrigeration to 4°C is usually the best Simple random sampling is the method of choice approach, supplemented by a minimal holding time, unless: (1) there are known distinct strata; (2) one depending on contaminants of concem. wants to prove or disprove that there are distinct strata; or (3) one is limited in the number of samples C Canvas or plastic sheet and desires to statistically minimize the size of a "hot C Spade or shovel spot" that could go unsampled. If any of these C Spatula conditions exist, stratified random sampling would be C Scoop the better strategy. C Plastic or stainless steel spoons C Trowel Stratified random sampling can be employed only if C Continuous flight (screw) augers aii points within the pile can be accessed. In such C Bucket auger .cases, the pile should be divided into a three- C Post hole auger dimensional grid system with, the grid cubes should C Extension rods be numbered, and the grid cubes to be sarripled should C T-Handle be chosen by random number tables or generators. C Thin-wall tube sampler with cutting tips The only exceptions to this are situations in which C Sampling trier representative samples cannot be collected safely or C Grain sampler where the investigative team is trying to determine worst case conditions. 6.0 REAGENTS Tf sampling is limited to certain portions of the pile, a No chemical reagents are used for the preservation'of' statistically based sample will be representative only waste pile samples; however, decontamination of that portion, unless the waste is homogenous. solutions may be required. If decontamination of equipment is required, refer to the Sampling 5.0 EQUIPMENT/APPARATUS Equipment Decontamination SOP, and the site specific work plan. Waste pile solids include powdered, granular, or block materials of various sizes, shapes, structure, and 7.0 PROCEDURES compactness. The type of sampler chosen should be compatible with the waste. .Samplers commonly used 7.1 Preparation for waste piles include: stainless steel scoops, shovels, trowels, spoons, and stainless steel hand 1. Review all information available on the augers, sampling triers, and grain samplers. waste pile and expected or unknown contaminants. Waste pile sampling equipment check list: 2. Determine the extent of the sampling effort, C Sampling plan the sampling methods to be employed, and C Maps/plot plan the types and amounts of equipment and C Safety equipment, as specified in the Health supplies required. and Safety Plan C Compass 3. Obtain necessary sampling and monitoring C Tape measure equipment. C Survey stakes or flags C Camera and film 4. Decontaminate or pre-clean equipment, and C Stainless steel, plastic, or other appropriate ensure that it is in working order. homogenization bucket or bowl C Appropriate size sample jars 5. Prepare schedules, and coordinate with staff, C Ziplock plastic bags client, and regulatory agencies, if C Logbook appropriate. C Labels C Chain of Custody records and seals 6. Perform a general site survey prior to site C Field data sheets entry in accordance with the site specific C Cooler(s) Health and Safety Plan.' C Ice C Decontamination supplies/equipment 7. Use stakes or flagging to identify and mark all sampling locations. Specific site factors, caps tightly; or, if composite samples are to including extent .and nature of contaminant I, .. be collected, place a sample from another should be considered when selecting sarnple sampling interval into the homogenization locations. If required, the proposed locations container and mix thoroughly. When may be adjusted based on site access, compositing is complete, place the sample property boundaries, . and surface into appropriate, labeled containers and obstructions.. . , • • , secure the caps tightly. .1.2 Sample Collection 7.2.2 . Sampling with Bucket Aiigers and 7.2.1 Sampling with Shovels and Scoops Thin-Wall Tube Samplers Collection of samples frorn surface portions of the pile, These samplers consist of a series of extensions, a can be accomplished with tools such as spades, "T" handle, and a bucket auger or thin-wall tube shovels, and scoops. Surface material can be removed sampler (Appendix A, Figure L). The auger is used to to the required depth with this equipment, then a bore a hole to a desired sarnpling depth, and is then stainless steel or plastic scoop, or equivalent can be withdrawn. The sample rriay be'collected directly used to collect the sample.'' . • •. , from the bucket auger If a core sample is to be collected, the auger tip is then replaced with a thin- Accurate; representative samples can be collected wall tube sampler. The sampler is then lowered down with this ..procedure depending on the care and the borehole, and driven into the pile to the precision demonstrated'by sample team members. completion depth. The sampler is withdrawn and the Use of a flat, pointed mason trowel to cut a block of core collected from the thin-wall tube sampler. •the desired material can.be helpful when undisturbed profiles are required. A stainless steel scoop, lab Several augers are available. These include: bucket, spoon, plastic spoon, or equivalent will suffice in rnost' continuous flight (screw), and post hole augers. other applicatioris. Care should be exercised to avoicl Bucket augers are better for direct sample recovery the use of devices plated with chrome or other since they provide a large volume bf sample in a short materials. Plating is particularly common with tifne. When continuous flight augers are used, the •implements such as garden trowels. sample can be collected directly from the flights, which are usually at five (5) foot intervals. The The following procedure is usedjto collect the surface continuous flight augers are satisfactory for use when sarnples: a cbrnposite of the complete waste'pile column is desired. Post-hole augers have limited utility for 1. Carefiilly remove the top layer of material to sarnple collection as they are designed to cut through the desired sample depth with a pre-cleaned fibrous, rooted, swampy areas. spade. , : . The following procedure will be used for collecting 2. Using a pre-cleaned stainless steel scoop, waste pile samples With the bucket augers and thin- plastic spoon, trowel, or equivalent remove wall tube,samplers: and discard a thin layer of material from the area which came in contact, with the spade. 1. Attach the auger bit to'a drill rod extension, ahd attach the "T" handle to.the drill rod. 3. If volatile organic analysis is ' to .- be performed, transfer the sample into an 2. Clear the area tp be sampled of any surface appropriate, labeled sample container with a debris. It may be advisable to remove the stainless steel lab spoon, or equivalent, and • - first three to six inches of surface rnaterial ; secure the cap tightly. Place the remainder 1 for an area approxiniately six inches in radius of the sample into.a stainless steel,'plastiCi'or around the drilling loiiation. • . . other appropriate homogenization container, and mix thoroughly to obtain a. homogenous 3. ''Begin augering,.periodically removing and sample representative of the entire sampling depositing accumulated materials onto a interval. Then, either place the sample into plastic sheet spread near the hole. This appropriate,, labeled containers and secure the prevents accidental brushing of loose material back, down the borehole when container and mix thoroughly. When removing the auger or adding drill rod compositing is complete, place the sample extensions. It also facilitates refilling the into appropriate, labeled containers and hole, and avoids possible contamination of secure the caps tightly. the surrounding area. 11. If another sarnple is to be collected in the After reaching the desired depth, slowly and same hole, but at a greater depth, reattach the carefully remove the auger from the bucket auger to the drill and assembly, and borehole. When sampling directly from the follow steps 3 through 11, making sure to auger, collect the sample after the auger is decontaminate the bucket auger and thin-wall removed from the borehole and proceed to tube sampler between samples. Step 10. 7.2.3 Sampling with a Trier Remove auger tip from drill rods and replace with a pre-cleaned thin-wall tube sampler. This sampling device consists of a trier, and a Install proper cutting tip. "T" handle. The trier is driven into the waste pile and used to extract a core sampile from the appropriate Carefully lower the tube sampler down the depth. borehole. Gradually force the tube sampler into the pile. Care should be taken to avoid The following procedure will be used to collect waste scraping the borehole sides. Avoid pile samples with a sampling trier: hammering the drill rod extensions to facilitate coring as the vibrations may cause 1. Insert the trier (Appendix A, Figure 2) into • the borehole walls to collapse. the material to be sampled at a OE to 45E angle from horizontal. This orientation Remove the tube sampler, and unscrew the • minimizes spillage of the sample. Extraction drill rod extensions. of the samples might require tilting of the sample containers. • Remove the cutting tip and the thin-wall tube sampler. 2. Rotate the trier once or twice to cut a core of material. Discard the top of the core (approximately one-inch), as this represents material 3. Slowly withdraw the trier, making sure that collected before penetration of the.layer of. the slot is facing upward. concern. Place the remaining core into the appropriate labeled sample container. 4. If volatile organic analysis is to be Sample homogenization is not required. performed, transfer the sample into an appropriate, labeled sample container with a 10. If volatile organic analysis is to be stainless steel lab spoon, plastic lab spoon, or performed, transfer the sample into an equivalent and secure the cap tightly. Place appropriate, labeled sample container with a the remainder of the sample into a stainless stainless steel lab spoon, or equivalent and steel, plastic, or other appropriate secure the cap tightly. Place the remainder homogenization container, and mix of the sample; into a stainless steel, plastic, or thoroughly to obtain a homogenous sample other appropriate homogenization container, representative of the entire sampling interval. and mix thoroughly to obtain a homogenous Then, either place the sample into sample representative of the entire sampling appropriate, labeled containers and secure the interval. Then, either place the sample into caps tightly; or, if composite samples are appropriate, labeled containers and secure the being collected, place samples from the other caps tightly; or, if composite samples are to sampling intervals into the homogenization be collected, place a sample from another container and mix thoroughly. When sampling interval into the homogenization compositing is complete, place the sample into appropriate, labeled containers and 7. If volatile organic analysis is to be secure the caps tightly. performed, transfer the sample into an appropriate, labeled sample container with a 7.2.4 Sampling with a Grain Sampler stainless steel lab spoon, plastic lab spoon, or equivalent and secure the cap tightly. Place The grain sampler (Appendix A, Figure 3) is used for the remainder of the sample into a stainless sampling powdered or granular wastes or materials in steel, plastic, or other appropriate bags, fiber drums, sacks, similar containers or piles. homogenization container, and mix This sampler is most useful when the solids are no thoroughly to obtain a homogenous sample greater than 0.6 cm (1/4") in diameter. representative of the entire sampling interval. Then, either place the sample into This sampler consists of two slotted telescoping brass appropriate, labeled containers and secure the or stainless steel tubes. The outer tube has a conical, caps tightly; or, if composite samples are to pointed tip at one end that permits the sampler to be collected, place a sample from another penetrate the material being sampled. The sampler is sampling interval into the homogenization opened arid closed by rotating the inner tube. Grai n container and mix thoroughly. When samplers are generally 61 to, 100 cm (24 to 40 in.) compositing is complete, place the sample long by 1.27 to 2.54 cm (1/2 to 1 in.) in diameter and into appropriate, labeled containers and are commercially available at laboratory supply secure the caps tightly. houses. 8.0 CALCULATIONS The following procedures will be used to collect waste pile samples with a grain sampler: This section is not applicable to this SOP. 1. With the sampler in the closed position, 9.0 QUALITYASSURANCE/ insert it into the granular or powdered QUALITY CONTROL material or waste bemg sampled from a point near a top edge or comer, through the center, There are no specific quality assurance activities and to a point diagonally opposite the point which apply to the implementation of these of entry. procedures. However, the following QA procedures apply: 2. Rotate the sampler inner tube into the open position. 1. All data must be documented on field data sheets or within site logbooks. 3. Wiggle the sampler a few times to allow material to enter the open slots. 2. All instrumentation must be operated in accordance with operating instmctions as 4. Place the sampler in the closed position and supplied by the manufacturer, unless withdraw from the material being sampled. otherwise specified in the work plan. Equipment checkout and calibration 5. Place the sampler in a horizontal position activities must occur prior to with the slots facing upward. sampling/operation, and they must be documented. 6. Rotate the outer tube and slide it away from the inner tube. 10.0 DATA VALIDATION 12.0 REFERENCES This section is not applicable to this SOP. Test Methods for Evaluating Solids Waste (SW-846), Third Edition, Vol. II Field Manual U.S. EPA Office 11.0 HEALTH AND SAFETY of Solid Waste and Emergency Response, Washington, D.C. November, 1986. When working with potentially hazardous materials, follow U.S. EPA/OSHA and corporate health and Engineering Support Branch Standard Operating safety procedures. Procedures and Quality Assurance Manual, U.S. Environmental Protection Agency, Region IV, April 1, 1986. Field Sampling Procedures Manual, New Jersey Department of Environmental Protection, Febmary, 1988. APPENDIX A Figures FIGURE.!. Sampling Augers LZ THIN WALL BUCKET TUBE SAMPLER AUGER APPENDIX A (Cont'd) Figures FIGURE 2. Sampling Trier \ A 61-100 cm, (2A.A0") YJ 1.27-2.54 CO (if-1") APPENDIX A (Cont'd) Figures FIGURE 3. Grain Sampler • r • . 61-100 cm, • (2A-A0") i L \ -H 1.27-2.5A cm (%-!••) ENSR Attachment 2 1992 Woodward Clyde Consultants Report April 2007 SURFACE REMEDIAL ACTION REPORT OLD LANDFILL SITE, MILFORD, NJ Prepared for: JAMES RIVER CORPORATION RIEGEL PACKAGING PAPER DIVISION MILFORD, NEW JERSEY Prepared by: WOODWARD-CLYDECONSULTANTS 201 WnXOWBROOKBOULEVABD WAYNE,NJ 07470 91C1450 - 4.3 AUGUST, 1992 TABLE OF CONTENTS Page 1.0 INTRODUCnON 1-1 1.1 OBJECnVES 1-1 1.2 SmE DESCRIPTION 1-2 1.3 PREVIOUS WORK 1- 2 2.0 FIELD PROGRAM 2- 1 2.1 FEELD METHODS 2-1 2.1.1 Dnun Remo>^ 2-1 2.1.2: Reinoval of Off-SpeciiicatioD Foil Backed P^r . 2-3, 2.1.3 Additional Activities 2-4 2.1.4 Distribudon of Oveipacks and Waste-Stream Sampling 2- 4 3.0 WASTE STREAM CONSOUDATIGN AND ANALYTICAL RESULTS 3- 1 3.1 WASTE STREAM CONSOUDATION 3-1 3.2 . ANALYTICAL RESULTS 3-1 3.2.1 TCL Analytical Results 3-1 3-2.2 TCLP Analytical Results 3- 2 4.0 DISPOSAL 4- 1 5.0 UMTTATIONS 5- 1 iinbi*tU>\91cl45(n(l002toe.«5l TABLE OF CONTENTS (continued) UST OF TABLES TABLE l-l SUMMARY OF GROUNDWATER ANALYTICAL RESULTS FROM THE PRELIMINARY STTB INVESTIGATION REPORT TABLE 2-1 SUMMARY OF DRUM SAMPLING TABLE 2-2 DRUM DISTRIBUTION SUMMARY TABLE 3-1 WASTE STREAM CONSOLIDATION SUMMARY TABLE 3-2 TOTAL NUMBER OF DRLFMS PER WASTE STREAM TABUB 3-3 VOLATILB ORGANIC ANALYTICAL RESIJLTS TABLB 3-4 TOXIOTY CHARACTERIST[C LEACHING PROCEDURE RESULTS TABLE 4-1 WASTE STREAM IDENTEFICATION NUMBERS AND WASTE CLASSIFICATION CODES UST OF FIGURES HGURE 1-1 STTE LOCATION PLAN FIGURE 1-2 SURFACE REMOVAL FIELD PROGRAM PLAN UST OF APPl APPENDDC A LABORATORY ANALYTICAL RESULTS PACKAGES APPENDIX B WASTE DISPOSAL MANIFESTS •tni>itUO\91el4j(M0Q2l»e.w5I U 1.0 INTRODUCTION 1.1 OBJECTIVES The objective of the soxfkcc remedial activity perfonned at the James River Riegel Division "Old Landfill Site" in Milford, New Jersey was to remove waste mateiial fiom tbe surface of the landfill using only manual labor. The remedial action was limited because: • there are regulated wetlands on the site which camioC be distuibed by the use of heavy equipment without prior a^roval from the New Jersey Depaitment of Environmental Protection and Energy (NJDEPE). • the New Jersey Administradve Code restricts woifc by heavy eqnq)ment on a landfill until a Disruption Pennit is obtained from NJDEPE which requires an NJDEPE approved woik plan. The surface remedial activity perfonned at the 'Old Landfill" did not include the use of any heavy equqnnent and so did not "disrupt" the landfill or disturb, the wetlands. All activity was limited to hand tools (i.e. shovels, wheel barrows, topes & pulleys, etc.) and all waste staging areas were in unforested poitirais of the site that were outside of the proposed limits of the wetlands. These procedures ware presented to NIDEPB in discussions between Mr. George Butkosky of James River and Ms. June Edwards of tbe SoUd Waste MasageaxnA Divisirai of NJDEPE. Concuneotly, an ^licatkm for a L^ter of Interpretation (LOI) was in preparaticm in anticipation of applyiog for tbe necessary wetlands permits to aUow additional work in or adjacCTt to wetlands. The primary goal was to remove as many surface drums as was safely possibte, including empty, rusted metal 55-gallon drums, partially filled drums, and, in a veiy linuted number of cases, filled dmms. In addition, rolls of foil backed paper and non-foil *ii)biiam91ci45IM0Q2iOI.w51 1-1 backed paper were removed. Also, the riyer front was policed for trash (i.e., cans, botdes, newspapers, etc.). r • ' The removal effort was r«A limited to the James River prqieity. With the pennission of the New Jersey Parks Administration, waste material that was on tbe adjacent park land was also ranoved. This included both the area immediately adjacent to the landfill and a small area several hundred feet south of the landfiU where apparentiy unrelated dumping had occurred. The remainder of Section 1.0 of this report contains a general site description. Section 2.0 describes the field methods used to remove tbe waste material, the amount and type of inaterial renioved, and where it was staged. Section 3.0 discusses tbe methodology for detennining the final numbo' of waste streams for diq)osal and the analytical results from the headq)ace and laboratory analysis of waste stream samples. Finally, Section 4.0 presets infonnation relative to the final disposition di the waste. 1.2 SITE DESCRIPTION The site is an inactive landfill located proximately 1/2 mile south of the James Riv^ Coiporation Riegel Diviskin paper mill on the east bank of the Delaware River in the townshq) of Alexandria, Hunterdon County, New Jersey (Rgtue 1-1). The disposal area is roughly ellii^icid in sh^, measures proximately 1200 x400 ft and covers about ten acres. The site is bonded by an abandoned ntitroad right-of-way on tbe east, the Delaware River on the west, tbe James Riv^ plant pn^ieity on tbe north and New Jersey stale Parkland on the south. Surrounding land use is niral farm excq>t for the papor miU pnqwrty and some ^gle family residences to tttenorth , along Route 619. The topogisq>hy (tf the site is goitiy slewing from d» farmland towards the riverexc ^ for a 20-25 ft drop along part of the westem edge of the fiD area. The disposal area is in the floo<^Iaino f the Delaware River and is rqxmed to contain a variety of fill material including soil, fly ash, bottom ash, wastewater treatment plant shidge, empty and deteriorating 55 gallcm metal drums, some partially Hlled drams, a limited number of filled 55 gallon drums, oft-spedficaticMi foil backed p^, and constiuction dd>ris. >nibi>lkO\91eMS0\dOa2iOI .»5I 1-2 The site was abandoned in 1972, prior to James River's purchase of the Milfoid plant and adjacent propeity which included the Old Landfill. 1J PREVIOUS WORK Woodward-Clyde Consultants (WCC) completed a "Preliminary Site Investigation Rqwit" for die old landfill on Sqrtember 12,1991. This npoit included a reviewo f background infonnation and the result of WCCs preliminary field investigation which inclu • Geophysical surveys indicate tiiat die depth to bedrock oa the eastern poiticm of die site ranges from 19 to 22 ft, and may thin to as little as 5 to 6 ft adjacent to the Delaware River. • Approxunately 800 msted and d^erioiated 55 gallon dmms woe visible on the surface of the site or were paitially buried in the fiU. • A few scattered 55 gallon dmms and rolls of discaitled, ofF-^)ecification m^ foil coated paper were <^rved off-nte on adjacent New Jersey State parkland soutii of the site. • Site reconnaissance observations and geophysical surveys indicated that tbe main disposal area covers ai^roximately ten acres. • The results of the soil gas suiv^ showed diat volatile ozgamc compounds (VOCs) were present at concentrations above background in twenty two of sevKity eight samples. The bigtest concoitrations were attributable to toluene and total volatile hydrocaibcms (TVHQ. One of sbc groundwater samples collected with a hydropunch driven into die alluvial deposits along the Delaware River showed volatile orgsmic compoumis above method detection limits (1 ppb) in shallow groundwatn' downgradioit of the toe of the landfill. The concentiaticm of tbe listed comp(Hinds, toluene (7 ppb) and n^hthakoe (4 ppb), was below the NJDEPE February, 1992 proposed groundwata cleanup standards (Table 1-1). Tentatively identified onnpounds (TICs) were below die 1000 ppb guideline for individual organic contaminants for which thne are no standards (NJAC 7;26D-4.2)and total organic ctnnpounds, listed VOs plus TICs (437 {^b) was well below the 10,000]^ proposed standard for total VOs. •niiiitaO\91ei4S(M 2.1 FEELD METHODS The waste removal activities were performed by Environmental Services, be. (ENSI), a Newark New Jersey based remedial contractor, with foQ-time, on-site inspection by WCC and James River personneL The first portion of the feld program began on Monday, December 14,1991 and continued for two weeks. No site work was performed during the weeks of December 23,1991 and December 30,1991 because of the holidays. The second portion of the program began on Moiiday, January 6, 1992 and was completed on Thursday, January 16, 1992. The major segments of the fieldprogra m included: • removal of 55 gallon drums from|Iiniite d portions of the site with the creation of temporary staging areas; • waste removal activities on adjacent New Jersey park land; • removal of aluminum foil-backed pS-spedfication paper and linuted amounts of other paper products; and, • consolidation of all the temporaiy staging areas into a single sta^g area, including the consohdaition of partially fiDed drums. 2.L1 Drum Removal Fifty five (55) gallon drums were found in discrete piles or scattered about the near shore portions of the landfiU. Because of the rugged tferrain and the Umitation of not using mechanized transport within the wetland areas, consolidating the drums was a time-consuming manuaDy intensive task. The field crews were outfitted iii Tyvek™ suits, rubber gloves and rubber overboots and dust iqaasks for most of the field activities. amlj«IMWcl45 The typical procedure for handling drums was as foUows: • The drum was visually insf>ected and screened with am HNu to determine if there was any material in the drum and if sc, did that material show a resfjonse to the HNu. • If the drum was empty and no response was observed on the HNu, the drum was carried to a centra] area at the base of the toe of the landfiSL • K the drum was not emp^, and there was no response on tbe HNu, the drum typicaUy contained natural soil that had accumulated in tbe dnun over time, as weU as a sinaU amount of material that appeared to be paint sludge and/or dye shidge. If this was the case, the waste material was transferred to a new 55-gaUon drum, and the oM drum was brought to tbe transport area. The new dnuns were not filled to more than 25 percent capacity because of the difficulty in handling fiilly loaded drums without mechanica] equipment. Consolidation took place after the drums had been transported to a central staging area. • If the drum contained a significant amount of material that caused a response on the HNu (either solid or liquid), the drum was transferred to an 85-gaQon overpack drum and sealed. Once aU of the druins were brought to the accumulation area, the drums were moved to a temporary staging area at the top of the toe of the landSQ. This area was both accessible by smaU truck, and outside the wetiand and wetlami buffer zones. The drtnxis aii>bi«lkCr«91cl4S The drum removal activity was started at the northem limit of the landfill. The fiffst puUey transport system was set up at approximately station 15+00 (Figure 2-1). To limit the distance over which drums had to be carried, the drums from a limited area of the landfill were consoUdated at the base of the puUey system and transported to a temporary staging area. Afrer work in that area was completed, the pulky transport system was moved to a more southerly station and the entire drum handhng/transport procedure was repeated. In total, the westem slope of the UtsdSB was divided into four working areas accessed by puUey tmnsport systeins at or near stations 15+00, 11-+00, 8-»-00 and 6+00. Drums from other portions ofthe site (i.e. areas in which a pulley transport system was not required to move the drums up a steep slope) were moved with the same general drum handling procedures as those described above. Heahh and safety procedures were foUowed and temporaiy staging areas were also established. 2.1.2 Removal of Off-Specification Alumlnom FoU Backed Paper Much of the off-specification (off-spec) paper, foil backed or plain was located near the base of the slope or south of the limits of the landfiU. This material was not amenable to the use of the puDey transport system because of its extremely friable nature. The bulk of the off-spec paper was removed by band wfth the aid of shoveb and was transported to a box van using hand carte. Once a box van was filled the contents were emptied at staging area 9 (Figure 2-1). This area was used for the temporaty staging of «mbU»flWcl<3 2.13 Additional Waste Removal Activities Tires and other refuse smaU enough to be manually removed were gathered and staged at the above-mentioned staging areas. Also, the river front was poUced for trash (i.e. botties, cans, wrappers, etc.) which were bagged and disposed with the rest of the solid waste from the plant 2.1.4 Distribution of Overpacks and Waste-Stream Sampling During the course of the field activities, WCC and ENSI, with the help of James River personnel, were able to identify and sample specific waste stieams. For example, with the help of James River personnel, the samples which showed the highest response with the HNu were identified as by-products of a paper coating process. In addition, the quaUty control laboratoiy at the plant was able tp analyze two samples and detennine that the principal volatiles present were tohiene and methyl-etlqrl-ketone (MEK). The single largest waste stream was comprised of partiaUy filled dnuns which contained some soil/sediment mixed with a limited amount of paint or dye sludge (most c^n a piirple or blue color). ' Table 2-1 summarizes ttie samples coUected during the sio&cis remedial activities including the fielddescriptio n of the sample, the number of overpack drums (85 gaUon) and staging area and the number of 55 gaUon dmms represented by the sample. These drums were identified in the field as having similar physica] characteristics or were identified by James River personnel as waste from a spedfic process source. Table 2-2 Usts the number of 55 gaUon drums and overpack (85 gaQon) drums temporarily stored in each staging area. 3lnUaQ(0mcH3C^dOO^(fi^.wSl 2-4 The most easily identified material recovered during the surface remedial activity was soil that was combined with pigments, dyes or paint sludges (21 drums) (sample DW-04) as shown on Table 2-1. The 21 drum total represents the number of fiUed drams that were generated after the material from the partiaUy fiUed drums was consolidated into fuU drums. The waste identified as being generated from the coating process has the largest number of dmms, however, in the field they were divided into a number ofwaste samples on the basis of physical characteristics (e.g. a soft, waxy substance vs. rags and other refuse identified as having been used to dean equipment during or afrer the coating process). The coating process wastes are represented by samples DW-OlJDW-02, DW-03, DW-05, DW-0^ DW-07, and DW-Oa These samples represent a total of thirty three (33) druins. The material or source of the remaining 15 drums are either imidentified, possibly non-hazardous material or appear to contain a hard wax-like substance identified by plant personnel as having been generated from a coating process that did not require solvents or other potentiaUy hazardous materials. The finaldru m total was sixty nine: fourteen overpacks (85 gaUon drums) and fifty five5 5 gallon drums. Table 2-2 shows that the distn'bution of both the overpacks and the total number of consolidated drums is liiglily skewed to the northem end of the site. Ten of the 14 overpacks and thirty eight of fifty five 55 gaUon dnims came from the first two areas in which the surface remedial actions were performed (Figure 2-2). This area includes approximately from station 10+-00 northward to approximatety station 14-hOO, and from the westem slope of the landfiU to the Delaware River. aniW»ntO\91d4JOtf00!2««i»51 2-5 3.0 WASTE STREAM CONSOLIDATION AND ANALYTICALRESULTS 3.1 WASTE STREAM CONSOLIDATION A total of sixty nine drums and seventeen waste stream samples were collected during the field program as descnlsed in Section 2.0. Upon completion of the field effort, headspace analysis using an HNu was performed on the samples to aid in efforts to reduce the number of waste streams for final disposaL Table 3-1 lists the samples, the field descriptions, the results of the headspace analyses, and the number of drums represented by each sample. On the basis of the infonnation presented in Table 3-1, field observations and information from plant personnel, the drums were classified into seven waste sfreams. Table 3-2 lists the seven waste streams, the number of druins per waste sfream (both 55 gaUon and 85 gaUon overpacks), and a brief description of each waste stream (as determmed prior to receipt of laboratoty analytical resuhs). The largest waste sfreams include waste stream no. 4 (pigments and dyes) with twenty one drums, and the three vtraste streams associated with coating processes, waste stream no. 2 (coatings and rags), waste streams no. 5 (originaUy described as a "possibly non- hazardous soUd" but subsequently determined tb be hazardous by VOC analysis) and waste stream number 6, (possibly non-hazardous wax). A brief description of each waste stream is as fbUows: • Waste Sfream 1: Overpacked dnim of Uquid which is reported to have come from the coating operation and suspected to contain solvents. • Waste Stream 2: Rags and other materials identified by James River personnel as having been generated by a coating process. • Waste Stream 3: Waxy substance identified by James River personnel as having been generated by a coating process. James River laboratory analysis indicated Uie presence of MEK and tohiene. • Waste Sfream 4: Sofl containing evidence of pigments, dyes aod possibly paint sludges. Did not show a response on tbe headspace anatyj^ • Waste Sfream 5: Solids that did not show significant response during the headspace analyse and did not exhibit aity solvent or other voktfle-Iike »mbialKWlcl45«M0O2i«J.w51 3-1 odor. VOC analysis showed results in excess of NJDEPE cleanup guideUnes for residential soils, but not for non-residential soils. • Waste Sfream 6: GeneraUy hard, wax-Uke substance that did not show any response during the headspace analysis. • Waste Stream 7: Oil contaminated rags 32 ANALYHCAL RESIJLTS 32.1 Target Compound List Vohitile Oorganics Compoond One sample fromeac h of the four waste streams that consistentiy had elevated head- space readings was submitted for chemical analysis (Table 3-1). The analyses chosen were target Compound List (TGL) Volatile Organics including the next fifteen tentatively identified compounds (TICs) and Toxidty Characteristic Ijeaching Procedure (TCLP). Volatile organic compound (VOC) analyses (Table 3-3) were selected because field observations combined with input on plant procedures indicated that the primaiy contaminants would be VOCs. TCLP (Table 3-4) was perfonioed to determine the waste classification relative to disposal options. The above referenced samples were coUected during the implementatipn of the field program (Sections 1 and 2) which began in mid-December, and finished on Januaiy 16, 1992. Consiequently, the VOC samples exceeded the holding times. The samples were subnu'tted for analysis because the intention of the VOC analysis was to provide infonnation on the specific types of compounds present, not to quantify the material relative to NJDEPE proposed cleanup standards ^ebru^, 1992). The samples were expressty chosen from the material which bad the highest response on the photoionization detector. For example, if a drum contained seventy (70) percent soO and thirty (30) percent waoty material (which caused a significant response on the HNu), onfy the waxy material was submitted for analysis. > The lowest concenfratioii of VOCs were foimd in waste stream 4 (pigments and dyes). The highest levels were found in waste stream 2 (coatings and rags from the paper coating process) and stream 3 (a waxy subst^ce also identified as waste from the coatings process) which had 32,569 ppm VOCs and 51,756 ppm VOCs, respectivefy iiDM«U[091cl45ayKW2tO3L«il 3-2 (Table 3-3). The contaminante found at concentrations over 1,000 ppm inchided toluene (30,000 ppm, waste sfream 2), ethylbenzene (11,000 ppm, waste stream 3) and xylene (14,000 ppm, waste stream 3), aU of -which are non-chlorinated VOCs that are typicaUy used as solvents. 322 TCLP Analytical Results Four analytes were detected at concentrations above method detection Umhs, including chromium (stream 2), lead (streams 2 and 4), copper (streams 2 and 4) and zinc (streams 2,3,4 & 5). Of these, only lead (18.4 ppm, strem 2) exceeded the TCLP regulatory characteristics (5 ppm). There are no TCLP regulatory characteristics for copper and zinc. Two samples exceeded the TCLP physical characteristics of ignitabiUty. The regulatory standard is 149" F. Samples Stream-4 and Stream-5 both showed results greater than 212?F. iiDHalfcmel450V>002i«3.w5I 3-3 4.0 DISPOSAL As was discussed in previous sections, the types of material recovered during the surface remedial action mcluded: rusted, empty 55 gaUon drums; sixty nine fiUed or partially fiUed drums of whkh fourteen were overpacks; off-specification paper, most of which was fofl backed|; rubber tires; and general refuse (botties, wrappers, etc). The general refuse was disposed with the general refuse from the plant operations. Less than 20 rubber tires were foimd during the fieldprogra m Because the local transfer station would not accept mbber tires, they liave been stodcpiled on-site and will be disposed at a later date. The disposal of the remainder of the materials will be discussed in the subsequent sections. 4.1 RUSTED DRUMS Approximately 450 rusted, empty drums were recovered firom the site. The drums were disposed at a drum rei^der. The contractor infonnation is as follows: Contractor: United Cooperage Corporati'oa Address: P.O. Box 22 BerUn, NJ 08009 (609)767-6644 BH»lloO\Sncl4S 42 OFF-SPECIFICATION PAPER Two roll-offs were brought to the site and the off-specification paper products were loaded using a smaU backhoe. A total of approximately 20 tons of mateiial was removed. The material was> fransportedb y Raritan Valley Disposal of Whfte House Station, NJ. The material was disposed at: Contractor: Chambers Waste Systems of New Jersey Address: Hunterdon Transfer Station P.O. Box 670 Petticoat Lane Annandale, NJ 08601 (908) 236-9088 The bflk of lading are included in Appendix B. 43 DRUMIVCED WASTE A total of sbcty nine drums were generated dining the surface remedial activities, fourteen overpacks (85 gaUon drums) and fifty five 55 gaUon druins. Although 17 samples were coUected in the field, one per each waste stream, the total number of waste streams was later reduced to seven on the basis of additional visual exammation of the samples and headspace analysis of the samples. Table 4-1 summarizes the filial waste stream description from the manifest, the dispcsal facflhy's identification number and the waste classification codes for each waste stream *ffliria!kO\91cl4SIM002(04.i>Sl 4-2 The drummed waste was incinerated at: Contractor: ThennaUcem, Ina Address: 2324 Vemesdale Road Rock Hfll, SC 29730 (803) 324-5310 EPA ID number SCD04442333 The waste was transported by Frieehold Cartage, Inc., a licensed hazardous wraste transporter (U.S. EPA ID No. NJD054126164; State Tramporter's ED No. NJDEPES- 2265). The mainfests are inchided in Appendix B. aiiibUl(0\91c]4SOMOO2i The prdgram outlined in the preceding sections was conducted in accordance with the scope of work described in WCCs proposal and subsequent additiom ot changes dfrected by James River personnel, and under the terms and conditioris stated in the Agreement for Professional Services between James River Corporation and WCC No warranty or guarantee conceming the findings and/or condusions of this program is offered or intended. Rather, it is represented that the scope and performance of the professional services rendered are in accordance with the current state ol practice as conducted within the region by similarfy quaUfied practitioners. This report was prepared solely for the use of James River Corporation, and cognizant regulatory agendes. Its use by other parties shaU be solely at such parties risk. MBW»naaWcM5(W0l>2rtS.«51 5-1 Table 1-1 Summary of Groundwater Analytical Results from Preliminary Site Investigation Report Old Landlill Site, Milford, NJ NJDEPE Proposed GW Cleanup Volatile Orgaolcs (ug/l) Standards (2/92) WS-1 WS-2 WS-3 WS-4 WS-5 WS-6 Analytical Method 524.2 Approx Sample Location I+O;F 3+0,F 5+0,F 7 +O.F 9+OJF 11 +O.F Toluene 1000 7 Naphthalene 30 4 Total VOs nd 11 nd nd nd nd Volatile Organics TICs Analytical Method 524.2 Dimethylcyclopentane 1,000 (3) 30 Methylcyclohexane 1,000 (3) 300 Ethyhncthyl(yclohcxane 1,000(3) 7 Unknown Alkane 1,000 (3) 47 Unknown 1.000(3) 42 Total VOTICS nd 426 nd nd nd nd Total V0 +TICs 10,000(4) nd 437 IH) nd nd nd Volatile Organics (ug/l) nd nd Dd nd nd nd Analytical Method 624 Notes: 1) Method 624 used for analyzing for analine, 2-butanone, ethylene glycol and ethyl acetate 2) detection limits for method 52452 was 1 ppb for all target compounds , 3) Assume maximum of 1000 ppb (Ippm) for individual organic contaminant for which there is no standard (7:26D-4.2) 4) Based on Feb, 1992 Proposed Groundwater Standards, 7:26D-4.2 Table M Summary of Waste Materials from Snrface Clean-Up James River CcMrpj Old Landfill SHe: MlUbrd, NJ Sample Field Description (1) Numbei of 85 Number of Total Desigoation Gallon Dnuns 55 Gallon Number Overpacks (2) Drums of Dnuns DW-01 Coating/Liquid Sohrent l(Areal) — 1 DW-02 Coating/Rags l(Area 1) — 1 i D\V-03 Coating/Rags 2(Area 1) 9 12 l(Area2) DW-04 Soil and Pigments/Dyes l(Area2) 20 21 DW-05 Coattng/Liquid Solvent l(Areal) - 1 DW-06 Wax (Hard).SoUd l(An!a7) 2 l(Aiea8) • 1 DW-07 Wax (dinnks) and SoQ l(Are*l) 8 DW-08 MEK contaminated Solids 2(Area:Q 3 5 DW-09 Unknowo-SoUd - 3 3 DW-10 SoO - 5 5 1 DW-ll Unknown-Solid l(Area4) — 1 1 DW-12 Unknown-Solid - 1 1 1 DW-13 Unknowa-SoUd 1 1 1 DW-14 Sofl with Gasoline Odor - 1 1 DW-15 Dirt and Debris • - • - 1 1 DW-16 MEK and Paint Sladge/Semi-SoUd l(Area 3) — 1 DW-17 Oil contaminated Solid - 1 1 TOTALS 14 55 » Notes: 1) Field description is gei»rally a visual description with some input fitom James River personnel as to the source of the waste. This detaiftkm is intended onfy forus e in attempting to visually combine the various types of inaterial found oa the site. Finalwaste dassification is discussed in Sections 3 and 4. 2.) Item in parentheses in column 3 (overpadcs) identifies the temporaiy staging area io which the overpack druins were staged. This information, cmnlnned with Hgure 2-2 gives general d&tribution of dnims requiring oveip^ds aooss the landfiU. mmMUUSMmilK»f'i Table 2-2 Drum Distribution Smnmaiy James River Corp.: Old LandfiU Site: Milford, NJ Staging Area No. 85 Na55 Total No. GaUon Gallon Druxns Drums Drums 6 13 19 2 4 25 29 1 3 4 1 8 9 6 0 1 T 7 1 3 4 8 1 2 3 Totals 14 55 69 ^: 1 *iDtna]k0\91cl45OyttO2t2>>.w3l Table 3-1 Waste Stream ConsoUdation Summary James River Paper Corp.: OU Landfill Site: Milford, NJ — Sample Beld Description (1) Headspace Cbasolidated Total 1 Designation Analysis (3) Waste Stream Number 1 • .... (ppm) Designation (2) of Drams i Coating/Solvent Liquid 10 1 1 DW-01 DW.02 Coating/Rags >150 2 I DW-03 Coating/Rags 11 2 12 1 DW-04 Soii and Pigments/Dyes 1J5 4 21 DW-05 Coating/Solvent >200 1 1 DW-06 Wax (Hard)-Solid 0.6 6 4 DW-07 Wax (chunks) and SoO Bd 6 DW-08 VOC Contaminated SoUds >200 3 5 DW-09 Unknown-Solid 3.5 5 3. DW-10 Sofl a4 5 5 DW-ll Unknown-Solid 0L5 5 1 DW.12 Unnkown-SoUd 03 5 1 DW-13 Unknown-Solid 0.1 5 , 1 1 DW-14 Soil with Gasoline Odor 03 6 1 1 DW-15 Din and Debris QJS 6 1 DW-16 MEK and Paint Shulge/Seinl-SoUd 25 1 1 DW-17 Oil Contaminated Solid IJ) 7 1 TOTALS 69 1 1 Notes: 1) Field description is genmOy a visual descriptkm with some input front James River penonnel as to the potentialsoiucs of the waste. This descriptioa b intended only for use ia attempting to visualty combine the various types of material found on the site. It is nothitendedfor use in quantitattvelyciassifying tbe waste materiaL 2) The Consolidated Waste istream Designationrepreseats theresnhsof combining wastestreams on the basis of visual examination of all samples, head space analysis, field descriptmosdisposal characteristics required by disposal facilities. This represeats professional judgmeat only, without the baaefy of waste dassification aaalysii. 3) The headspace aaalysis was perfonned using aa HNu photoioDization detectoi. The samples were at room temperature uid weie not agitated, 4) od a> not deteaed Tabie 3-2 Total Number of Drums Per Waste Stream James River Paper Corp-: Old LandflO Site: MDfoid, NJ rami iniir irgaaa^aaoa Toud Number of 85 Gallon Total Number Total Number Waste Sucam Waste Stream Drums: of SSOaOon of Designation Description (a) Overpacks Dnmts Flammable Liquids (1) 3 - 3 . 2 Coatings and Rags (2) 4 9 13 3 VO contaminated Wax 2 3 5 Conuminated Soils (3) 4 Pigments and Dyes (4) 1 20 21 5 Possibly Non-Hazardous 1 10 11 Solids (5) Possibly Non- Hazanlous 3 12 15 Wax (6) 7 OU Contaminated Rags 1 1 (7) TOTALS 14 55 69 Notes: (a) Waste Stream Description is based on physical characteristics, knowledge of tbe wastes generated at tbe plant and the headspace analysis. • - Table 3-3 Volatile Orgaaie Analytical Resnlts Old LandfUl Project James River, Milford, NJ Sample Desi^tion Stream-2 Strcam-3 Stream-4 Stream-5 Dilution Factor 500 1000 50 50 Volatile Organks Methylene Chloride •40 JB 17 J 14 J 2-Propaiione . 0 B 10000 200 B 32 JB Carbon Disulfide 0 5100 4-Methy-2-Pentanone 49 1.2-Dicliloroethcne 0 96 J Trichloroethene 43 J Benzene 560 J 5.7 J Tohiene 30000 J , 1100•0 -<140 •. Ethylbenzene 11000 .37 Styrene 680 0 200 Xylene 1800 14000 50 1800 •. ••- • • VOTICs UnknoMHR Alkane 20600 J . 182 J Unknown Alkene 42 J Unknown Hydrocarbon r 13000 J Unknown Cydic 971 Substituted Benzene 26OO0 J 10200 J Unknown Aromatic 9400 J . 3000 J CIIHIO Aromatic 2570 J Unknown 103 J : 19100 J Notes 1) J - estimated concentration 2) B » compound detected in blank 3) No fleld or trip blanks colleded Table 3-4 Toxicity Characteristic Leaching Procedure Results Old LandfUl Project James River, Milford, NJ Sainple Oesign^)on Regttetory StrMm-2 Stream-3 Strearrv-4 Stream-S levels (PPM) (PPM) (PPM) (PPM) (PPM) TCLP Afsenic 5 NO NO NO NO Barium 100 NO NO NO NO Benzene 0.5 NO NO ND NO Cadnnfun 1 NO ND ND ND Cartxm Tetrechlocid* 5 ND ND ND NO CMordane 0.03 NO ND ND NO CmofokwnzefW 100 NO ND ND ND e NO ND NO NO 5 1.S6 ND NO ND o-Crasol 200 NO ND ND NO m-Cresol 200 ND ND ND NO p-Cresol 200 NO ND ND ND Cresd 200 ND ND ND NO 2,4-0 10 NO ND ND NO 1,4-Oic))lorobenzen* 7.5 ND NO ND NO 1,2-Olchloraelhane v. 0.5 ND ND ND ND t,t-Dichlorciethrytene 0.7 ND NO ND ND 2,4-Oinatrotoiuene 0.13 NO NO ND ND Endrin 0.02 NO ND NO ND O.OOS NO ND NO NO HexacNorobenzcn* 0.13 ND 1 ND NO NO Hexaehlofo-I .a*u«»*ene 0.05 NO ND ND ND HexacNoroelhane 3 NO ND ND ND Lead 5 NO 2.35 NO Lindane 0.4 NO ND ND NO Mercufy 0.2 NO ND ND ND MethoocycMof 10 ND ND ND ND Meihy eOiyl ketone 200 ND ND • NO NO Nrtrobenzen* 2 ND NO ND ND PentacNorophenol 100 ND NO ND NO Pyrtdlnt 5 NO NO NO NO Selenium 1 NO ND ND NO Sliver 5 NO NO NO NO T«traeii pH 2-12.6 5.46 6.79 5.76 6.71 . t^ntabtty. F PM 140 149 77 >tvt m^mmm'mm Corrotivily (in/yr| 0.2S <0.01 <0.01 *0.01 <.01 Rcadivtty (0 Cyanide ipfun) <1 <1 <1 Nodes: 1) NO o rto( delected above metnod detectio-n fimis • n^:Vamcs\sutreptVc4>jd( Table 4-1 Waste Stream IdentiQcatkm Number and Waste CtassiOtaUon Codes James River Papor Corp.: Old LandfiU Site: Milford, NJ Original WCC WasteStream Thermalkem Waste Total Nufflba WasteStream Description from Waste Stream Classificatfon of ' Designation Manifest (a) LD. Na Codes (b) Dnuns 1 Waste Flammable ST.00009^5154 DOOl 3 Liqnid DQ35 P0O3 2 Waste Flammable ST-00009-5155 DOOl 13 Liquid DOOS F0Q3 P0Q5 3 Waste Adhesive, ST-00009-5157 DOOl 5 Flanunabte Liqnid FOGS POOS 4 Hazardous Waste Solid ST-00009-5158 DOOS 21 FOB 5 Hazardous Waste Solid ST-00009-5156 F0O3 11 6 Non-Regulated, Non- ST-00008-7832 7777 15 Hazardous Solid 7 Non-Regulated, Non- ST-O00O8-7833 7777 1 Hazardous Solid 1 TOTALS 69 Notes: (a) Thiswaste stream descriptionnaay differ firom original WCCwaste stream descriptioosbecaiise tlie analytical results (TCIJP and TCX VO) were not available during the fiddprogram , but were available immediately prior to completion of Thennalkem!s waste classification forms. (1)) The waste dassification codes for waste streams one (1) thnmgb five (5) are federal waste classification codes. The codes for waste streams six (S) aod seven (7) are Nonli CaroUna codes fornon-hazardous materials. ENSR AECOM Appendix C Transportation and Disposal Plan (T&D Plan) April 2007 Prepared for: Georgia Pacific Atlanta, GA Transportation & Disposal (T&D) Plan Slope Stabilization Measures Crown Vantage Landfill Site, located in Alexandria Township, New Jersey Revised in Accordance with EPA Letter Dated March 5, 2007 Time Critical Removal Action under EPA Administrative Agreement and Order on Consent, Docket No. CERCLA-02-2005-2017 , ENSR Corporation April 2007 Document No.: 03060-062-304 ENSR AECOM Prepared for: Georgia Pacific Atlanta, GA Transportation & Disposal (T&D) Plan Slope Stabilization Measures Crown Vantage Landfill Site, located in Alexandria Township, New Jersey Revised in Accordance with EPA Letter Dated March 5, 2007 Time Critical Removal Action under EPA Administrative Agreement and Order on Consent, Docket No. CERCLA-02-2005-2017 Prepared By Kathy Whooley Project Specialist Reviewed By Donald P. Hessemer Senior Program Manager ENSR Corporation April 2007 Document No.: 03060-062-304 ENSR AECOM Contents 1.0 Transportation and Disposal Plan 1 -1 1.1 Hazardous and Non-Hazardous Waste Disposal 1-1 1.2 Regulatory levels ' 1 -1 1.3 Site Specific Constituents 1-2 1.4 Sample Shipment Guidelines 1 -2 1.5 EPA Review and Approval of Analytical, Waste Profiles and Manifests 1-2 1.6 Transportation and Disposal Documentation 1-2 1.7 Waste Disposal Contractors/Subcontractors '. 1 -3 1.7.1 Off-site Waste Treatment, Storage, & Disposal Facilities 1 -3 1.7.2 Waste Transporters.... ; 1-3 List of Attachments Attachment 1 Regulatory Levels Attachment 2 Waste Disposal Transfer, Storage, and Disposal Facility Documentation J:\Proiect\Georgia-Pacific\03060-062 Milford CV . I ' April 2007 Landfil^WorkPlan\FINAL-April2007\ENSRTD Plan-FINAL- 4192007.doc 1.0 Transportation and Disposal Plan The transportation and disposal plan (T&D Plan) will be implemented in compliance with the Resource Conservation and Recovery Act ("RCRA"), 42 U.S.C. §§ 6901-6991, and Section 300.440 of the National Contingency Plan (NCP). Upon receipt of waste classification analytical results, waste disposal transportation and disposal services will be contracted based on the disposition of the waste. All disposal facility certifications, approvals and insurance certificates for each facility will be forwarded to the EPA OSC as specified in the AOC. All RCRA waste materials will be sent to a RCRA Permitted and CERCLA approved TSD Facility via a licensed and permitted transporter. All other wastes will be disposed of at an appropriate disposal facility as necessary to comply with land disposal restrictions, CFR 40 Part 268 as conditionally approved by EPA on April 16, 2007. Waste characterization and classification activities must be performed within a reasonable time frame to meet specific RCRA storage requirements to limit storage time on-site of all waste streams. • Copies of all manifests and bill of ladings will be maintained on site. Certificates of Disposal for all waste shipped off site will be submitted to the EPA OSC in the Final Report. All containerized and non-containerized waste, personal protective equipment (PPE), crushed drums and other investigation derived wastes will be • disposed of in accordance with these off-site disposal requirements: 1.1 Hazardous and Non-Hazardous Waste Disposal Hazardous and non-hazardous wastes that are generated on site are anticipated to be categorized into one of seven possible waste streams discussed in the Sampling and Analysis Plan (SAP), based on the categorization into waste streams as described in the August 1992 Woodward Clyde Report. A summary of these seven (7) previously identified waste streams is presented in the SAP and HASP accompanying the Work Plan. Upon completion of field characterization and.drum screening as set forth in the Work Plan and SAP, each drum will be characterized as one of these seven waste streams listed, and appropriate laboratory analyses will be run to complete disposal facility profiling requirements. If the characteristics of a particular drum do match any of the seven waste streams listed, appropriate analyses will be run. Records will.be kept as to the destination of any drum removed from the site. Should drums be bulked in the roll-off, the drum log will reflect its final destination. Empty drums and remnants wilt be collected and sent to a drum reconditioner for recycle or destruction. Drummed waste that contains free liquids or solids that cannot be bulked with other materials will be stored in the salvage drums at the designated waste storage pad as discussed in the Work Plan. Roll-off boxes staged at the waste storage pad will be bulked with like wastes, primarily consisting of 1) empty drums, carcasses and remnants, 2) non-hazardous solid wastes, and 3) other regulated, solid wastes. All roll-off boxes will be equipped with roll type tarps for storage purposes and covered at the end of each work day. 1.2 Regulatory Levels For waste disposal purposes, all hazardous wastes encountered and removed from the landfill will be disposed of off-site in accordance with federal and state requirements forthe shipment of hazardous wastes including all action levels identified in NJAC 7:26 & NJAC 7:26G,and 40 CFR124, 260-266, 268 & 270. The procedures for obtaining representative samples, except for volume less than 900 cubic yards follow a statistical approach outlined in Chapter 7 of the USEPA's guidance document 230/02-89-042 (Methods for Evaluating the Attainment of Cleanup Standards). A table of regulatory levels to be used in waste classification and profiling are provided in Transportation and Disposal Plan Attachment 1, identified as Regulatory Levels. The regulatory levels contained in this T&D Plan were developed to addresses the time critical removal actions as documented in the Work Plan according to the AOC and not intended to serve as a Work Plan for further investigative work to be performed at the Site in support of Site closure activities. J:\Project\Georgia-Pacific\03060-062 MilfordCV 1-1 . ' April 2007 Landfill\WorkPlan\FINAL-April2007\ENSRTD Plan-FINAL- 4192007.doc 1.3 Site Specific Constituents As discussed above under Work Plan Section 3.8.3.1-Waste Management, one sample collected from each waste stream will be analyzed for all constituents (UHC's). Sample collection may be biased to the drummed materials exhibiting the highest field instrument and/or headspace readings. Site specific constituents have been identified based on historic sampling results, and a list of site specific compounds documented at the site was provided in 'Table 1: Summary of Analytical Results from Soil and Waste Samples Collected at the Crown Vantage Landfill on November 12 and 13, 2003" ofthe USEPA Removal Site Evaluation Memorandum dated May 25, 2004. A copy of this document is appended to Work Plan under the tab entitled "EPA Correspondence/Orders." As requested by USEPA, to meet the provisions for all waste steams are to be analyzed for TCL volatiles, semivolatiles, pesticides and PCBs and TAL metals and cyanide as discussed in the SAP to assure that all potential underlying hazardous cdnstituents (UHC's) are properly evaluated. Two herbicides, 2-methyl-4-chlorphenoxyacetic acid [MCPA] and -2-(2-methyl-4-chlorophenoxy)propionic acid [MCPP], will also be analyzed due to their reference in the EPA Removal Site Evaluation memorandum. Once specific drums have been categorized into separate waste streams, based on waste classification and profile sampling for waste disposal facility selection criteria, then a minimum of one (1) sample per waste stream will be collected to adequately characterize TCUTAL compounds, plus MCPA and MCPP, found at the site (refer to SAP for specific analytical methods). The frequency and number of samples collected will be dependent upon one or more of the following site specific conditions encountered in the field (e.g., total number of drums encountered, like consistency of the material encountered between individual drums, field screening results, any other visual or measurable waste characterization that results in the identifying of individual drums with similar inherent characteristics). 1.4 Sample Shipment Guidelines It is anticipated that sample shipment by air and/or over land will be utilized for the shipment of soil, liquid and/or waste samples to laboratories and disposal facilities for waste profiling purposes. As stated in work Plan Section 5.0-"Sampling and Analysis Plan (SAP)," Departnnent of Transportation (DOT) and/or International Air Transport Association (lATA) regulations will be followed for sample shipment. ENSR has a well-defined hazardous materials shipping program and follows lATA requirements for all air shipments of hazardous materials. Based on field screening data, ENSR will determine if the samples are hazardous and if so, the appropriate shipping name to assign to the samples (i.e. environmentally hazardous substance, liquid, n.o.s. or flammable liquid n.o.s.). ENSR will ensure that all applicable package marking and labeling requirements are met and vyill ensure that the proper shipping papers are completed for each shipment. Only ENSR staff that has completed function-specific haz-mat shipping training will be authorized to ship hazardous samples from the site. 1.5 EPA Review and Approval of Analytical,.Waste Profiles and Manifests /~ EPA requires review of all analytical, waste profiles and manifests prior to off-site shipping to a CERCLA approved facility, as per the Order. Written notification will be made to USEPA prior to any off-Site shipment of waste maiterial from the Site to an out-of-state waste management facility in accordance with the Order at least five (5) days prior to shipment. 1.6 Transportation and Disposal Documentation Waste disposal and waste disposal transportation services may be required throughout the duration of wall installation and slope stabilization activities. All RCRA waste materials will be sent to a RCRA Permitted and CERCLA approved TSD Facility via a licensed and permitted transporter. Each waste load generated from the site will receive proper DOT shipping documentation, consisting of either a hazardous waste manifest or J:\Project\Georgia-Pacific\03060-062 Milford CV . , 1 -2 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSRTD Plan-FINAL- 4192007.doc straight bill of lading. Each waste shipment will be documented with appropriate signatures and copies of'. waste disposal records will be retained bn site. As discussed aBove, copies of all manifests and bill of ladings will be maintained on site. Certificates of Disppsal for all waste shipped off site .will, be provided to USEPA . upon receipt and included in the biweekly progress reports as required in the Order. Copies of manifests, bills of lading, and certificates of disposal and destruction will be provided in the Final Report submitted to USEPA. 1.7 Waste Disposal Contractors/Subcontractors United Environ Services, Inc. was previously identified by Fort James to provide waste disposal services for the scope of work presented in this Work Plan. Upon revievy of waste characterization sampling results, all . transporters and disposal facilities'designated to transport and receive such wastes will be identified and a list of alternate transporters and disposal facilities will be provided to EPA prior to the commencerhent of disposal activities in accordance with the AOC. USEPA's certification of all disposal facilities shall be obtained before the waste is shipped in accordance with the Order. EPA Region 11 will perform updated CERCLA off-site compliance cheeks. . • • 1.7.1 Off-site Waste Treatment, Storage, & Disposal Facilities dff-site waste treatment, storage and disposal facilities that have been-identified to receive wastes from the' site include the following:,'•'. Cycle Chem, Inc. - Transfer Facility ' '" Ross Incineration, Inc.- Incineration Ehergis, LLC - Fuel Blending/Solids Dispersion Modern Landfill - Non-Hazardous Waste Patrick J. Kelly Drum Co. - Drum Recycling/Destruction Facility locations, contact information, certification numbers and/or CERCLA certification documentatiori are provided in T&D Plan Attachment 2. Actual dispdsal facility selection wilt be dependent upon waste classification and profiling activities. In addition to those contractors and subcontractors mentioned above. Fort James will notify EPA of the name(s) and qualifications df any other contractors or subcontractors retained to perform work at the site within at least seven (7) days prior to commencement of disposal activities , in accordance with the AOC. / " ' ' . 1.7.2 Waste Transporters Wastes will be transported off-site by either of the following transporters: • . H.M.H.T.T.C; Response, Inc.- Transporter 1 • Clean Venture, inc. - Transporter 2 - , • Transporter locations, coritact information and certification numbers are provided in T&D Plan Attachment 2. Other than those contractors and subcontractors mentioned above, Fort James vyiil notify EPA of the name(s) and qualifications of any other contractors or subcontractors retairied to perform work at the site within at least seven (7) days prior to commencement of such work in accordance with the AOC. J:\Project\Georgia-Pacific\03060-062 MilfordCV •• 1-3 '• • ' ' . April 2007 Landfill\WorkPlan\FINAL-April2007\ENSRTD Plan-FINAL- . ' 4192007.doc '•.., • : I •'•• •• • ENSR Attachment 1 Regulatory Levels J:\Project\Georgia-Pacific\03060-062 Milford CV April 2007 Landfill\WorkPlan\FINAL-April2007\ENSRTD Plan-FINAL- 4192007.doc , TABLE 1 ENSR Regulatory Levels Crown Vantage Landfill - Alexandria Twp., NJ Time-Critical Removal Action EPA Waste No. Parameter i 'Hazardous Level ^^iihemlstry D001 ! Ignitability <= 140 degrees F D002 Corrosivity <= PH2and >=PH 12.5 D003 . Reactive Sulfide 500 ppm (Total) D003 Reactive Cyanide 250 ppm (Total) 'TCLPMenis D004 Arsenic 5.0 D005' Barium 100.0 D006 Cadmium 1.0 D007 Chromium 5.0 D008 Lead 5.0 D009 Mercury 0.2 D010 Selenium 1.0 D011 Silver 5.0 l^!CW^PKv:&c\d^n^M<:^^. D020 Chlordane 0.03 D012 Endrin 0.02 D031 Heptaehlor 0.008 D013 Lindane 0.4 0014 Methoxychlor 10.0 D615 Toxaphene 0.5 D016 2,4-D 10.0 D017 2,4,5-TP 1.0 , D018 Benzene 0.5 D019 Carbon tetrachloride 0.5 D021 Chlorobenzene 100,0 D022 Chloroform 6.0 D028 1,2-Dichloroethane 0.5 D029 1,1-Dichloroethylene 0.7 D035 Methyl ethyl ketone 200.0 D039 Tetrachloroethylene 0.7 D040 Trichloroethylene 0.5 D043 Vinyl chloride 0.2 TCLP Semi-volitiks mg/L D023-D026 o,m,p-(total)Cresol 200.0 D027 1,4-Dichlorobenzene 7.5 D030 2,4-Dinitrotoluene 0.13 D032 Hexachlorobenzene 0.13 D033 Hexachlorobutadiene 0.5 D034 Hexachloroethane 3.0 D036 Nitrobenzene 2.0 D037 Pentachlorophenol 100.0 D038 Pyridine 5.0 D041 2,4,5-Trichlorophenol 400.0 D042 2,4,6-Trichlorophenol 2.0 Regulatory Table.doc 4/10/2007 TABLE 1 ENSR Regulatory Levels Crown Vantage Landfill - Alexandria Twp., NJ Time-Critical Removal Action Listed Wastes - By definition the following specific wastes are hazardous. These lists are organized into three categories: • The F-list (non-specific source wastes) - From common manufacturing and industrial processes, such as solvents that have been used in cleaning or degreasing operations. Because the processes producing these wastes can occur in different sectors of industry, the F-listed wastes are known as wastes from non-specific sources. Wastes included on the F-list can be found in the regulations at 40 CFR j$261.31 . • The K-list (source-specific wastes) - From specific industries, such as petroleum refining or pesticide manufacturing. Certain sludges and wastewaters from treatment and production processes in these industries are examples of source-specific wastes. Wastes included on the K- list can be found in the regulations at 40 CFR !?261.32 , • The P-list and the U-list (discarded commercial chemical products) - These include specific commercial chemical products in an unused form. Some pesticides and some pharmaceutical products become hazardous waste when discarded. Wastes included on the P- and U-lists can be found in the regulations at 40 CFR §261.33 . Regulatory Table.doc 4/10/2007 ENSR Attachment 2 Disposal Transfer, Storage, and Disposal Facility Documentation J:\Project\Georgia-Pacific\03060-062 Milford CV April 2007 Landfil^WorkPlan\FINAL-April2007\ENSRTD Plan-FINAL- 4192007.doc Trauftr Sttdoo: Cytle Chem, Inc. 550lDdustri«lDriv« Lewisbeny. PA. 17339 EPA ID«PAD06709SS22 Incinmtiait: Ross Incinefatioii. Inc. 36790 OOes Road Oraflon, OR 44044 EPAID«OHD04$41S66S Fuel Bleodin^Solids Db^xnioo: EoersbLLC. 2175 Oaiden Bouteyird Holly HiU. SC. 290S9 EPAIIMSCD00336SI91 Noit-HazLaodSl: Modem LaodfiU 4400 MT. Pisgah Road York, PA. 17402 Voa >HK Permit #100113 Dram Recycling/Dcstructioa Psrtnck J. Kelfy Dnun Co. 2109 Howdl Street Camden. N;.0«10S 1-856-963-1795 Certified Analysis: btegiated Analytical Lab. LLC. 273 Ftanldin Road Randolpii^NJ. 07869 l'973.36l-4252 Transpoiter 1: HMJtT.T.C. Response. Inc 333 Linleton Road Parsippany. NJ. 07054 NJDEP 50161 PAAH 0554 Trtospofter 2: Clean Ventine, Inc. 217 South Fust Street Elizabeth. NJ. 07206 NJO000027193 CyCl9Ch0if9 lecycflnKntalnMitSfilipaalef Hazardou June 29,2005 UrttBdEnvko Systems PO BBK 524 Chestwv Dear Mr. Wren; PfMM accept ttMS lc»sr at proof thdt bodi c# our TSO liKttte Cyds Own. Inc. 201Souifini4t9reet BbBbedvNI07«6 Cyde Chem, ihc. ^ SSOIndusfrWMve UMMMfiy, PA 17339 Shoukj /ou have an/ questions or require any additional infbrmatjDrv pieasa do not hesSaie to contact us. Thank yoa -president OC: Tenyl Taclhriicai Account Hepresonutfvo CORPOMTESEM. Nw»*«irT«r. OvpomtOffci: NnmyMniino^ SSERBiBW 2f7SbNtiFMSM«l 20ISM*ftatSltm SSOMUMlDlH ewMtfOwnierf ' fteMvNloRoe BkMk,MflnoS MtMny^WP*!* 1tt-n»MM»wl ^. . . SOe^SMiOO SB»OT5SW yir«»«))N ntmMMMl«7|B MnMon »UC90»>}S»«fi M:9as-IS5^34aS MC7l7«»>»m toHiitme acqKMnpar HuegeanrQw ; wfnfffltniemio/Lcoitk TOTAL P.Bl ENSR Appendix D Health and Safety Plan (HASP) April 2007 Prepared for: Georgia Pacific Atlanta, GA Health & Safety Plan Slope Stabilization Measures Crown Vantage Landfill, located in Alexandria Township, New Jersey Time Critical Removal Action under EPA Administrative Agreement and Order On Consent Docket No. CERCLA 02-2005-2017 Revised in Accordance withi EPA Letter Dated Marchi 5, 2007 ENSR Corporation April 2007 Document No.: 03060-062-300 ENSR AECOM ENSR AECOM Prepared for: Georgia Pacific Atlanta, GA Health & Safety Plan Slope Stabilization Measures Crown Vantage Landfill, located in Alexandria Township, New Jersey Time Critical Removal Action under EPA Administrative Agreement and Order on Consent Docket No. CERCLA 02-2005-2017 Revised in Accordance with EPA Letter Dated March 5, 2007 Prepared By: Kathleen Harvey Regional Health and Safety Manager Reviewed By: Steve Surman Project Manager ENSR Corporation April 2007 Document No.: 03060-062-300 ENSR AECOM ENSR AECOM ENSR Contents 1.0 Introduction... .'..1-1 1.1 HASP Purpose 1-1 1.2 Organization/Responsibilities 1-2 1.2.1 ' Consultant Project Manager 1-2 1.2.2 Consultant Regional Health and Safety Manager 1 -2 1.2.3 Consultant Site Superintendent 1-2 1.2.4 Consultant Site Safety Officer. 1 -3 1.2.5 Consultant Field Personnel 1 -3 1.2.6 Contractors : ; 1-4 1.3 Management of Change/ Modification of the HASP 1-4 1.3.1 • Management of Change 1-4 1.3.2 HASP Modifications ' 1 -4 2.0 Site Description and History 2-1 2.1 SlteLocation : 2-1 2.2 Landfill Operations , : 2-1 2.3 Previous Investigations 2-1 2.3.1 Landfill Investigations and Surface Remediation Action 2-1 2.3.2 Sampling from Western Face of Landfill along Delaware River 2-2 3.0 Scope of Work 3-1 ,3.1 Project Description 3-1 3.2 Barrier Wall Construction : 3-1 3.3 Drum Removal from Landfill Surface 3-1 3.4 Post-Construction Requirements ..3-2 4.0 Chemical Hazard Assessment and Controls 4-1 4.1 Chemical Contaminants of Concern 4-1 4:1.1 Volatile Organic Compounds > 4-1 4.1.2 Polycyclic Aromatic Hydrocarbons : 4-1 .4.1.3 Phthalates ,..:..•.. 4-2 4.1.4 Metals 4-2 4.1.5 Pesticides ;:. ; 4-3 4.1.6 Polychlorinated Biphenyls ..: ...4-3 4.1.7 Waste Stream Characterization 4-6 4.1.8 Hazardous Substances Brought On-Site bythe Consultant and Contractors 4-6 4.2 Chemical Exposure and Control 4-6 4.2.1 Chemical Exposure Potential 4-6 4.2.2 Chemical Hazard Control ' 4-8 J:\Project\Georgia-Pacific\03060-062 tVlilford CV I April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc • . ' ENSR- 5.0 Physical Hazards and Controls i 5-1 5.1 Slip, Trip and Fall Hazards 5-1 5.1.1 Oh-Site Debris., ...::.;.:• 5-1 5.1.2 Good Housekeeping •. 5-1 •5.1.3 Site Illumination :.. , ...... 5-1 5.2 Working in the Delaware River tolhstall Turbidity Curtain 5-1 5.2.1 Working in VVater : ...5-2, . 5.2.2 Useof a Boat.!. : , -....5-2 . 5.2.3 Boat Registration.... ::...: ; ;....: ^ 5-2 5.2.4 Boat Capacity L..; : 5-2 5.2.5 Personal Flotation Devices ...... :; :...:.:....•...... * 5-3 5:2.6 Emergency Equipment :..'.' , ; ....: :.... 5-3. •• 5.2.7 . Warning Boaters ; ! : '. :... 5-3 5.3 On-Site Construction Traffic Hazards :.....' :.:...... : ::...... 5-3 .5.4 Site Clearing Hazards ...:.:...,.•.... :...... !'v:...:...;;:r..:.: ...... :....5-4 5:4.1 Use of Hydraulic Shear . '..'. :.:....: ! , 5-4 5.4.2 Use of a Chain Saw • ..:..': ,...^../:./. : ....5-4 . 5.4.3 Use of Weed Whips ;:::: :...,:.... ,....:..,,.; :..:.;.:...... 5-5 5.4.4 ' Stump Removal ...... ::....5-5 5.4.5 Chipping Operations 5-6 5.5 Utility Hazards /..: ,-. 5-6 5.i5.1 Underground Utility Hazards... 5-6 5.5.2 Overhead Utility Hazards.:,:!.. ..:...... ::....:...... :...... ,:..:•...... :...:....'...... 5-6 5.6 VVell Abandonment - Drilling ..: : ,: ...: :....5-7 • 5.7 Working around Heavy Machinery ....: 5-7 5.8 Excavation Hazards.: ., .' .;....: 5-7 5.9 Equipment Refueling... : ;...:....:..-. : • 5-8 5.10 Drum Handling/Sampling/Storage....: ...:...... '...... '. 5-9 5.10.1 Drum Opening and Sampling Procedures ., :....5-9 5.10.2 Drum Storage/Consolidation... : '. ...5-10 5.10.3 Handling Abandoned Cylinders ....:...• :.... ^.,5-10 5.11 Generator Safety....,...; '. ...5-10 5.11.1 Proper Use of the.Generator ,...5-10 5.11.2 Storage of Gasoline : ..:..... • 5-11 5.12 Noise... :...: ....:: 5-11 5.13 Back Safety...; .:.: '. /...... : ,...::...: : 5-11 5.14 Hand and Power Tool Safety. .-iv...... 5-11 5.14.1 Hand Tools ;.....:! ; : ,.;:! :.: :.5r11 5.14.2 Knives and Cutting Tools 5-12 . ' 5;i4.3 Power Tools..;; :..;...... ; ,...:...:..: :! ./.. ;.: 5-12 ,5.14.4 Electric Tools.;...... :..... 5-12 J:\Proiect\Georgia-Pacific\03060-062 Milford CV' , ' i,' II • " ; " • April 2007 Landfil^WorkPlan\FINAL-April200AENSR-HASP-Final- . . April07.doc, • ... ' . . . ' . . ENSR 5.15 Compressed Gas Safety ;.; .....: .'....5-13 5.16 Thermal Stress ....: 5-13 5.16.1 Heat Stress 5-13 5.16.2 Cold Stress : : ! ,...5-15 5.17 Sun Exposure , 5-16 5.18 Biological hazards 5-16 5.18.1 Poisonous Plants , 5-16 5.18.2 Ticks ; 5-17 5.18.3 Mosquito-Borne Illnesses 5-18 5.18.4 Bees , '. 5-18 5.18.5 Rabid Animals :..: ,....5-18 5.18.6 Snakes 5-19 5.19 Inclement Weather 5-20 6.0 Air Monitoring 6-1 6.1 Direct Reading Instrumentation 6-1 6.2 Ionizing Radiation 6-2 6.3 Personnel Exposure Air Sampling 6-2 6.4 Calibration and Recordkeeping 6-2 7.0 Personal Protective Equipment 7-1 7.1 Mandatory PPE ;.....: 7-1 7.2 Chemical Protective Clothing 7-1' 7.3 Respiratory Protection : 7-1 7.3.1 Barrier Wall Construction Activities 7-2 7.3.2 Drum Handling 7-2 7.3;3 Fit Testing , 7-2 7.4 Other Safety Equipment 7-2 8.0 Site Control 8-1 8.1 Site Access/Egress 8-1 8.2 Designation of Zones : 8-1 8.2.1 Exclusion Zone 8-1 8.2.2 Contamination Reduction Zone 8-2 8.2.3 Support Zone '. 8-2 8.3 Fire Extinguisher Locations 8-3 8.4 General Site Safety Practices 8-3 8.5 Site Communications 8-4 8.6 Off-Site Traffic Control 8-4 J:\ProjecftGeorgia-Pacific\03060-062 Milford CV Ili April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- ' April07.doc ENSR 9.0 Decontamination/Sample Shipment .9-1 9.1 Personal Decontamination ; 9-1 9.2 Large Equipment Decontamination.... '...... :. 9-1 9.3 Sampling Equipment Decontamination 9-1 9.4 Sample Shipment 9-2 10.0 Medical Monitoring and Training Requirements 10-1 10.1 Medical Monitoring 10-1 10.2 Health and Safety Training '. 10-1 10.2.1 HAZWOPER ;.. 10-1 10.2.2 First Aid/CPR , 10:1 10.2.3 Pre-Entry Briefing 10-1 10.3 Visitor Requirements .; : 10-2 11.0 Emergency Response 11-1 11.1 Employee Training : 11-1 11.2 Alarm Systems/Emergency Signals 11 -1 11.3 Escape Routes and Procedures 11-2 11.4 Rescue and Medical Duty Assignments.. 11-2 11.5 Designation of Responsible Parties 11-3 11.6 Employee Accounting Method :.; 11-3 11.7 Accident Reporting and Investigation 11 -3 12.0 Spill Response ; 12-1 12.1 Equipment Refueling 12-1 12.2 Release of Material from Drums/Containers/Pails... 12-1 12.3 Discharge to River 12-1 List of Appendices Attachment A Health and Safety Receipt and Acceptance Form Attachment B Job Hazard Analysis Form Attachment C Health and Safety Pre-Entry Briefing Attendance Form Attachment D Supervisor Accident Investigation Report Form J:\Proiecl\Georgia-Pacific\03060-062 Milford CV • IV • April 2007 LandfiH\WorkPlan\FINAL-April2007\eNSR-HASP-Final- April07.doc ENSR 1.0 Introduction 1.1 HASP Purpose This site-specific Health and Safety Plan (HASP) has been developed by ENSR Corporation (ENSR). It establishes the health and safety procedures required to minimize potential risk to personnel implementing the slope stabilization measures for the Crown Vantage Landfill Site (the Site) located in Alexandria Township, New Jersey. The time-critical actions are being implemented in accordance with the Administrative Agreement and Order on Consent (AOC) for Removal Action, Docket No. CERCLA-02-2005-2017, effective May 26, 2005, for the Site. The time critical actions being implemented include the following: • Stabilizing the face of the landfill to prevent further erosion caused by the flooding of the Delaware River; • Securing the Site against unauthorized access; and • Searching across the surface of the landfill to identify, retrieve, and dispose of any drums/containers/pails and their contents that are present above the ground surface in order to minimize direct contact threats with any drummed materials This HASP has been written to comply with the. requirements of OSHA's Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120). All activities covered by this HASP must be conducted in complete compliance with this HASP and with all applicable federal, state, and local health and safety regulations. All contractors and subcontractors must conform with applicable guidance and regulations, as established by the regulatory agencies in the following documents: • U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), Code of Federal Regulations, Title 29 (29 CFR), Part 1910.120. • U.S. bepartment of Labor, OSHA, 29 CFR, Part 1910.1200. • U.S. Departmentof Labor, OSHA, 29 CFR, Part 1910 and Part 1926. • National Institute for Occupational Safety.and Health (N10SH)/0SHA/U.S. Coast Guard (USCG)/EPA, Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, Publication No. 85- '115,1985. The provisions of this plan apply to The Consultant, ENSR personnel, its subcontractors, and contractors hired by Fort James Operating Company (FJOC) who may potentially be exposed to safety and/or health hazards related to activities described in Section 3.0 of this document. This plan will be distributed to each employee, subcontractor employee, and contractors to FJOC, involved with the proposed time-critical removal actions at the Site. Each employee must sign a copy of the attached health and safety plan sign-off sheet (see Attachment A). Personnel covered by this HASP who cannot or will not comply will be excluded from site activities. This HASP only pertains to the tasks that are listed in Section 3.0. A task specific HASP or addendum to this HASP will be developed at a later date for any other subsequent investigative/remedial activities at the Site. J:\Project\Georgia-Pacific\03060-062 MilfordCV 1-1 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- ' , Aoril07,doc ENSR 1.2 Organization/Responsibilities The Consultant is performing this work on behalf of FJOC. Paul Montney is FJOC's Director of Remediation and is the Project Manager assigned to this Site. The implementation of health and safety at this project location will be the shared responsibility of the Consultant Project Manager (PM), the Consultant Regional Health and Safety Manager (RHSM), the Consultant Project coordinator, the Consultant Project Site Superintendent/ Safety Officer (SSO), Consultant personnel implementing the proposed scope of work, and contractors working for FJOC and with the Consultant to implement the time critical removal actions. 1.2.1 Consultant Project Manager The Consultant PM (Steve Surman/ENSR) is the individual who has the primary responsibility for ensuring that this project specific safety program is effectively implemented for the duration of the project. Some of the PM's . specific responsibilities include: • Assuring that all personnel to whom this HASP applies, including contractors to FJOC, have received a copy of it; • Providing the RHSM with updated information regarding conditions at the Site and the scope of site work; • Providing adequate authority and resources to the on-site SSO to allow for the successful implementation of all necessary safety procedures; • Supporting the decisions made by the SSO and RHSM; • Maintaining regular communications with the SSO and, if necessary, the RHSM; and, • Coordinating the activities of all contractors, on behalf of FJOC, and ensuring that they are aware of the pertinent health and safety requirements for this project. 1.2.2 Consultant Regional Health and Safety Manager The Consultant RHSM (Kathleen Harvey/ENSR) is the individual responsible for the preparation, interpretation and modification pf this HASP. Modifications.to this HASP which may result in less stringent precautions cannot be undertaken by the PM or the SSO without the approval of the RHSM. Specific duties of the RHSM include: Writing, approving and amending the HASP for the time-critical actions; Advising the PM and SSO on matters relating to health and safety for this program; Recommending appropriate personal protective equipment (PPE) and respiratory equipment to protect personnel from potential'site hazards;. Conducting accident investigations; and, Maintaining regular contact with the PM and SSO to evaluate site conditions and new information which might require modifications to the HASP. 1.2.3 Consultant Site Superintendent The Consultant Site Superintendent (Hank Wylam/ENSR) has direct supervision over all on-site personnel for the time critical actions. He will coordinate daily site-specific wprk efforts and will ensure that all activities are conducted in strict compliance with site-specific health and safety plan. J:\Project\Georgia-Pacific\03060-062 MilfordCV 1-2 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR 1.2.4 Consultant Site Safety Officer All Consultant field technicians are responsible for implementing the safety requirements specified in this HASP. However, one field technician will serve as the SSO. For this program, Theresa Willfong/ENSR will serve as the SSO. The SSO will be on site during all activities covered by this HASP. The SSO is responsible for enforcing the requirements of this HASP once work begins. The SSO has the authority to immediately correct all situations where noncompliance with this HASP is noted and to immediately stop work in cases where an immediate danger is perceived. Some of the SSO's specific responsibilities include: Assuring that all personnel to whom this HASP applies, including contractors hired by FJOC, have submitted a completed copy of the HASP receipt and acceptance form; Assuring that all personnel to whom this HASP applies have attended a pre-entry briefing and any subsequent safety meetings that are conducted during the implementation of the program; Maintaining a high level of health and safety consciousness among employees implementing the time critical actions; Procuring and distributing the PPE, respiratory equipment and safety supplies needed for this project for Consultant employees; , Verifying that all PPE and health and safety equipment used by the Consultant is in good working order; Verifying that contractors are prepared with the PPE, respiratory protection and safety equipment required for this program; Notifying the Consultant PM and the EPA On-Scene Coordinators (OSC) of all noncompliance situations and stopping work in the event that an immediate danger situation is perceived; Monitoring and controlling the safety performance of all Consultant and contractor personnel within the established restricted areas to ensure that required safety and health procedures are being followed; Conducting accident/incident investigations and preparing accident/incident investigation reports; Conducting the pre-entry briefing and daily safety meetings, in conjunction with the contractors; and, Initiating emergency response procedures in conjuriction with the contractors. 1.2.5 Consultant Field Personnel All Consultant field personnel covered by this HASP are responsible for following the health and safety procedures specified in this HASP and for perforrning their work in a safe and responsible manner. Some of the specific responsibilities of the field personnel are as follows: • Reading the HASP in its entirety prior to the start of on-site work; • Submitting a completed HASP Acceptance Form to the Consultant SSO prior to the start of work; • Attending the required pre-entry briefing prior to beginning on-site work and any subsequent safety meetings that are conducted during the implementation of the program; • Bringing forth any questions or concerns regarding the content of the HASP to the PM or the SSO prior to the start of work; • Reporting all accidents, injuries and illnesses, regardless of their severity, to the Consultant SSO; and, • . Complying with the requirements of this HASP and the requests of the SSO. J;\Proiect\Georgia-Pacific\03060-062 Milford CV 1-3 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR 1.2.6 Contractors Additionally, the contractors hired by FJOC are responsible for: . Reading the HASP in its entirety pripr td the .start of on-site work; Attending and participating in the required pre-entry briefing prior to beginning on-site work and any ... subsequent safety,meetings that are conducted during the implementation of the program; • Ensuring, via daily inspections, that their equipment is in good vyorking order; ; Operating tHieir eiquipment iri a safe manner;. Appointing an on-site safety coordinator to interface with the Consultant SSO; Providing ,Consultant with copies of material safety data sheets (MSDS) for all hazardous materials brought on-site; and, Providing all the required'PPE, respiratory equipment and safety supplies to their employees. 1.3 Managenient of Change/Modification of the HASP 1.3.1 Management of Change The procedures in this HASP have been .developed based on ENSR's understanding of the potential environmentaMssues at the property and the proposed time critical actions. Every effort has been made to address the, chemical haizards that rriay be encountered during the implementation of the proposed actions. Similarly, this document also discusses the physical hazards associated with the proposed activities. However, unanticipated site-specific coriditions or situations may occur'during the implementation of this project. Also, the Consultant and/or the contractors rnay elect to perforrn certaiin tasks in a manner that is different from what was originally intended due to a change in field conditions. As such, this HASP must be considered a working document that is subject tochange to meet the needs of this dynamic project.. The Consultant and/or the coritractors will complete a,Job Hazard Analysis (JHA) when new tasks 'or different investigative techniques not addressesd in the H/\SP are proposed. The use of new techniques will be • reviewed and if new hazards are associated with the proposed changes, they will be documented on the JHA. • An effective control measijre must also be identified for each new hazard. JHAs vyill be reviewed by the SSO prior to being implemented. Once approved, the JHAs will be reviewed with all field staff.during the daily safety meeting. The Corisultant will also riotify the EPA OSC of any changes in work scope and will prpvide copies of all completed JHAs to the EPA representative. A blank JHA is presented as Attachment B. 1.3.2 HASP Modifications Should significant information become available regarding potential on-site hazards, it may be necessary to modify this HASP. All proposed modifications to this HASP must be reviewed and approved by the Consultant RHSM before such modifications are implemented. Any sigriificant nnodifications rnust be incorporated into the written document as addenda and the HASP must be reissued. The Consultant PM will.ensure that all personnel covered by this HASP receive copies of all issued addenda. Sign-off forms will accompany each addendum and must be signed by all personnel cdvered by the addendum. Sign-off forms will be submitted to the Consultant PM., The HASP addenda should be distributed duririg,the daily safety meeting so that they can be reviewed and discussed. Atfendanbe forms will be collected during the meeting. J:\Project\Georgia-Pacific\03060-062 Milford CV •1-4 April 2007 Landfill\WorkPian\FINAL-April200AENSR-HASP-Final- April07.doc ' , ' ENSR 2.0 Site Description and History 2.1 Site Location The Crown Vantage Landfill is an inactive industrial landfill located off of Milford-Frenchtown Road (County Road 619) in Alexandria Township, Hunterdon County, New Jersey. The landfill vicinity includes the former James River Corporation paper mill plant property to the north and the plant's sewage disposal pond to the northeast; an abandoned railroad right-of-way to the east; New Jersey State park land to the south; and the Lower Delaware River to the west. The site slopes gently from east to west toward the Delaware River except for an approximately 25 foot drop along the western face. Historic and current observations made at the facility indicate that the western face of the landfill is periodically scoured by the river during flooding. There are no flood containment measures present at the facility and the landfilf is uncapped. The landfill encompasses approximately 10 acres within the floodplain of the Delaware River. The landfill is characterized by the deposition of soil, ash, sludge, drums and miscellaneous metal construction debris. Fill material in the landfill is"approximately 20 to 25 feet thick. Vegetation on the uncapped landfill surface consists of a mixture of young and mature hardwood trees, shrubs and grasses. Although the facility is currently fenced, access may be obtained along the Delaware River. 2.2 Landfill Operations Waste deposition activities at the landfill began in the late 1930s and continued until the early 1970s. Background information indicates that the landfill has been inactive since that time. Waste materials deposited at the landfill included those generated by Riegel Paper Co., and other mills owned by Riegel, located at Riegelsville, Hughesville, Warren Glen and Milford, New Jersey and a converting operation in Flemington, New Jersey. Flyash from coat burning and drums containing press roohn wastes (varnish, shellac, methyl ethyl ketone, toluene, inks and dyes) were deposited in the landfill, as well as rolls of paper and aluminum foil-laminated paper; paper fiber sludge from wastewater treatment plant operations; steel and fiber barrels and pallets; construction and demolition debris such-as concrete, duct work, piping and machinery parts; and household garbage and rubbish including appliances and furniture. Reportedly, the landfill was set on fire frequently, usually as a result of the deposition of boiler ash which contained hot embers. In 1955, a large fire was set to destroy flood damaged items from the local community to reduce the risk of epidemic. Background information indicates that burning was a routine method for reducing waste volume. 2.3 Previous Investigations 2.3.1 Landfill Investigations and Surface Remediation Action In June 1991, Woodward-Clyde Consultants conducted a Preliminary Site Investigation at the landfill which included the collection of shallow groundwater samples downgradient of the landfill and adjacent to the river and soil gas samples throughout the site. Soil gas analytical results indicated the presence of chlorinated and non-chlorinated volatile organic compounds (VOCs), including tetrachloroethylene (PCE), trichloroethylene (TCE), trichloroethane (TCA), benzene, toluene and xylenes in the soil gas at depths of 3 to 6 feet. Groundwater sampling indicated the presence of toluene and naphthalene in one of seven samples. In December 1991 and January 1992, Woodward-Clyde conducted a Surface Remediation Action at the landfill that involved the removal, staging and sampling of drums and the consolidation and removal of foil- backed paper and other paper products found on the surface of the landfill. Empty, partially-filled, and full drums, as well as foil-backed and non-foil-backed paper, were removed. A total of seven waste streams were identified, the largest of which consisted of partially-filled drums containing soil/sediment mixed with paint or J:\Proiect\Georgia-Pacific\03060-062 MilfordCV 2-1 April 2007 Landfill\WorkPlan\FINAL-April200AENSR-HASP-Final- April07.doc ENSR dye sludge (most often with a purple or blue color). The next largest waste streams were identified as being generated from the paper coating process and included a soft, waxy substance; rags or other refuse used to clean coating process equipment; and a hard, wax-like substance. Sampling of the drums indicated the highest concentrations pf VOCs were present in the waste stream containing coatings and rags from the paper coating process and the waxy substance identified as being part of the coating process. The lowest concentrations of VOCs were detected in the waste stream consisting of. pigments and dyes. The VOCs detected at concentrations above 1,000 parts per million (ppm) included toluene, ethylbenzene and xylene. . . The presence of VOCs in shallow groundwater was confirmed during a 1994 Preliminary Groundwater Investigation conducted by Woodward-Clyde. Eight monitoring wells were installed throughout the site. Analytical results of the groundwater samples indicated non-detect values for all VOCs except for low, estimated concentrations of toluene. Concentrations of lead and arsenic exceeded the state groundwater quality standard in both upgradient and downgradient wells. 2.3.2 Sampling from Western Face of Landfill along Delaware River In April 2003, Clean Ventures, Inc., on behalf of the New Jersey Department of Environmental Protection (NJDEP) collected 22 surface (0-6 inches) soil samples from^ the exposed face of the landfill adjacent to the Delaware River. Analytical results indicated the presence of polycyclic aromatic hydrocarbons (PAHs), including phthalates. Polychlorinated biphenyls (PCBs, specifically Arochlor 1254) were detected at a maximum concentration of 1,130 ug/kg. Pesticides, including chlordane, 4,4'-DDT, dieldrin, aldrin, endosulfan and lindane, and herbicides including 2,4'-D and Silvex, were detected at low part-per-billion (ppb) concentrations. Metals detected in the soil samples include arsenic, cadmium, chromium, copper, lead, mercury and zinc. Subsequent to the sampling, on June 24 and 15, 2003, EPA observed that the Delaware River was in direct contact with the western face of the landfill during flooding. On November 12, 2003, EPA conducted an on-site reconnaissance of the landfill. EPA toured the western portion of the landfill adjacent to the Delaware River and observed evidence of recent flooding including debris deposited on the upstream side of fence posts, fallen fence posts, standing water and erosion of the landfill surface revealing the presence of drums, paper, foil-backed paper, glass and flyash. Waste flyash samples were collected by the EPA on November 12th and 13th, 2003 from the western face of the landfill where erosion from flooding events occurred. Additionally, surface soil samples were collected downgradient of the landfill and adjacent to the river. Surface water and sediment samples were also collected upstream, downstream and adjacent to the river. Analytical results of surface soil, flyash and sediment samples indicated an observed release of site- attributable contaminants to surface water. Analyses of the surface soil samples indicated the presence of PAHs, including phthalates, PCBs and metals at concentrations significantly above background concentrations. PAHs and metals were detected in the samples of flyash. Analysis of the sediment sample SED-11 indicated the presence of PCBs at a concentration significantly above the background concentration. On June 15, 2004, EPA conducted a follow-up reconnaissance of the landfill. Observations made during the visit included exposed waste on the western face of the landfill and a roll of waxed paper deposited in the Delaware River. EPA conducted an additional site visit on September 20, 2004, after the remnants of Hurricane Ivan resulted in the Delaware River rising well above flood stage. It was determined that the river had crested above the face of the landfill. EPA observed a portion of the landfill face that had experienced some erosion due to the flood waters slough off into the river.'The portion of the landfill that sloughed off had previously been sampled by the EPA and contained elevated levels of PAHs, including phthalates, metals, PCBs and pesticides. As the water level subsided over the next two weeks and'the entire face of the landfill became accessible and visible, additional areas of the landfill face were observed to have suffered significant I sloughing and erosional damage. J:\Project\Georgia-Pacific\03060-062 Milford CV 2-2 April 2007 LandfimWorkPlan\FINAL-April2007\ENSR-HASP-Final- April07,doc ENSR On September 29, 2004, the EPA initiated an emergency removal action to stabilize the Site in the area's along the western landfill face that were impacted by the flooding from the rainfall associated with the remnants of Hurricane Ivan. Rip-rap was placed on these areas to prevent additional releases into the river. In addition, EPA collected some waste material which had been released from the landfill. Due to the past flooding and emergency actions undertaken by USEPA, the topography and vegetative cover have been altered. During the period of April 2-4, 2005, another major flood even occurred which impacted the Crown Vantage Landfill shoreline. EPA mobilized under the existing emergency response action to further stabilize the shoreline. This flood event'was documented to be the third highest within 100 years. On May 26, 2005, an Administrative Agreement and Order on Consent for Removal Action was signed by the USEPA, Region 2 and FJOC. The time critical actions being implemented include the stabilizing of the landfill face in order to eliminate the potential for containers and other waste materials from being released into the Delaware River; the securing of the Site against unauthorized access; and the searching across the surface of the landfill to identify, retrieve, and dispose of any drums/containers/pails and their contents that are present above the ground surface, in order to minimize direct contact threats with these materials. During late June 2006, another flood occurred at the Site, in which the water level crested over the top of the landfill. After the water receded to the toe of the landfill a site inspection was conducted on July 5, 2006 by a representative from ENSR and EPA. Based on the observations made during the inspection there were no indications of significant erosion of the landfill due to the flooding event. J;\Project\Georgia-Pacific\03060-062 Milford CV 2-3 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR 3.0 Scope of Work 3.1 Project Description The time critical action involves two distinct operational goals, including: • Construction of slope stabilization measures by installing a barrier wall at the landfill face along the Delaware River. The proposed slope stabilization design will consist of the following four primary components: - An imported stone aggregate foundation - A geosynthetic reinforced wall containing a stone aggregate backfill reinforced with Geoweb® and Geogrids®, constructed at the toe of the landfill rising to'a maximum height of 128 feet above mean sea level; - Toe scour protection consisting of geotextile fabric and a proper gradation of imported stone aggregate and rip-rap; and - Vegetated facia of the geosynthetic wall system using a blend df topsoil, seed mixture and aggregate for Geoweb® in-fill. • During the construction of the barrier wall, various excavations will be conducted. It is assumed that during excavation operations drums will be encountered. Additionally, the surface of the landfill will be inspected for drums, containers and pails. Any drum's, containers or pails will be removed. 3.2 Barrier Wall Construction \ The construction of the barrier wall includes the following tasks: • Site Preparation - including installation of erosion coriti-ol measures (silt fence around staging area and along the top of the slope of the landfill, and turbidity curtain in River), tree and vegetation removal, temporary road construction and well abandonment • Infra-Structure Construction - including material staging area, fence modifications, temporary haul foads, drum/waste sampling pad and storage pad • Wall Zone Sub-grade Preparation • Geo-Web Reinforced Wall Construction • Installation of Stormwater Control Features • Site Restoration • Demobilization 3.3 Drum Removal from Landfill Surface The entire surface of the landfill will be inspected for drums. Any drums, containers or pails at the surface of the landfill or partially buried drums/containers/pails will be removed from the landfill surface. During the construction of the barrier wall, various excavations will be conducted.' It is assumed that during these excavation operations, drums may be encountered and will also be removed. This HASP addresses drum removal, handling, staging and sampling activities as described in the Work Plan and Sampling and Analysis Plan (SAP). J:\Proiect\Georgia-Pacific\03060-062 MilfordCV 3-1 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc . • . . - ENSR 3.4 Post-Construction Requirements The AOC specifies that provisions for placement of a fence or barrier preventing access onto the landfill along its western edge shall be implemented after the time-critical removal actions have been completed. Periodic inspections and maintenance (quarterly) of all fencing and warning signs will be performed when the time- critical removal actions are completed. As approved in the EDR, signage will be posted along the western edge of the landfill face since evidence from past flood events has shown that any fencing installed along the Delaware River shoreline has been destroyed. The EDR has specific signage along the western edge for this reason. Signage will be installed on trees along the shoreline at a height of 6-feet as indicated in the EDR. Maintenance will consist of repairs of breaches and/or any other type of damage where security is compromised. Inspection and maintenance of the vegetation survival rate will be conducted for a period of two years following completion of landfill stabilization measures. (7 J J:\Proiect\Georgia-Pacific\03060-062 Milford CV 3-2 April 2007 LandfilAWorkPlan\FINAL-April2007\ENSR-HASP-Final- April07,doc - " ' ' :,' ENSR' 4.0 Chemical Hazard Assessment and Controls 4.1 Chemical Contaminants of Concern Flyash from coal burning and drurris containing press room vyastes (varnish, shellac, methyl ethyl ketone, toluene, inks and dyes) were deposited in the laridfilli as well as rolls of paper arid aluminum foil-laminated paper; paper fiber sludge from vyastewater treatment plant operations; steel and fiber barrels and pallets; construction and demolition debris such as concrete, duct w6rk,.piping and machinery parts;-and household garbage and rubbish including appliances and furniture. The primary contaminants of concern associated with these activities include the following:', •'•' '"• ': ' ' , '• • • • . • Volatile orgariic compounds including chlorinated sojvents ,. • • Polycyclic aromatic hydrocarbons • .Phthalates ' ' ' . ; • Metals ' ,.' • ' " • Pesticides' ' : ' ' •':•• • .Polychlorinated Biphenyls , •' , ' Below is a summary of the health hazards associated witfi overexposure to these coritaminarits of concern. This text is followed by Table 1 that summarizespertinent information about each contaminant. In addition, the following reference documents will be readily available for reference on site at the site trailer: • •' Emergency Response Guidebook (latest Version) ' 2006 TVLs and BEIs , • ' NIOSH Pocket Guide to .Chemical Hazards (August 2006 or latesit version) 4.1.1 Volatile Organic Compounds The volatile organic compounds (VOCs) detected in site soils and in the waste streams asspciated with 1992 drum removal program include ethylbenzene, toluene, xylenes and methyl ethyl ketone. Exposure to the vapors of these compounds above their respective OSHA permissible exposure limits (PELs) may produce irritation of the mucous membranes of the upper respiratory tpct, nose and mouth. Overexposure may also result In the depression of the central nervous system. Symptoms,of such exposure include drowsiness, headache, fatigue and "drunken-like" behaviors. Chronic and. prolonged overexposure to the vapors of benzene may cause damage to the blood-form ing organs and is known to cause leukemia in h'umans. Chlorinated solvents, including.tetrachloroethylene (PCE) and trichloroethylene (TCE), have been detected in samples of drunimed materials.-Overexposure to these.chlorinated organic solvents may result in depression of the central nervous system, symptoms of which include, dizziness, headache, giddiness and drunken-like ,.behaviors. Chronic overexposures can result in liver and kidney damage. 4.1.2 Polycyclic Aromatic Hydrocarbons The semi-volatile organic compounds identified in.the fly ash samples and surface soils collected from the exposed face of the landfill are referred to as polycyclic aromatic hydrocarbon (PAH) comppunds. PAH compounds are a family of multiple ring aromatic cbmpounds commonly found in fossil fuels and formed from the incomplete combustion of organic materials. Repeated contact with PAH compounds may cause photosensitizafion of the skin, producing skin burns after subs'equent exposure to ultra-violet light. Certain J:\Project\Georgia-Pacific\03060-062 Milford.CV ' ' 4-1 " ' , . ' April 2007 'Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Firial- . April07,doc , •' •' .. .. ., , • _ ENSR PAHs as a group are considered potential human carcinogens (CaPAH). .OSHA regulates PAHs as coal tar pitch volatiles (CTPV) and has established a PEL for CTPV of 0.2 mg/m3, as an 8-hr TWA. 4.1.3 Phthalates The specific phthalates detected in the fly ash samples and surface soils collected from the exposed face of the landfill include di-n-butyl-phthalate and bis-(2-ethylhexyl) phthalate. Di-n-butyl phthalate is a manufactured chemical that is added to plastics, paint, glue, hairspray and other consumer products. This material has a low toxicity with no reported adverse human health effects. Heayy levels of exposure in animals have resulted in decreased ability to reproduce. The OSHA PEL for di-n-butyl phthalate is 5 mg/m3, as an 8-hr TWA. Bis-(2- ehtylhexyl) phthalate is found in many plastics and is not toxic at low levels. High levels in animals have caused liver and kidney damage. The OSHA PEL is 5 mg/m3, as an 8-hr TWA. 4.1.4 Metals Several metals were detected in flyash samples as well as soil and waste samples. These include lead, chromium, vanadium, nickel, copper, cadmium and beryllium.. In general, the inhalation of metal dusts is irritating to the upper respiratory tract and nasal mucous membranes. Most metal dusts cause dermatitis and/or eye irritation. 4.1.4.1 Lead The early synnptoms of lead poisoning, as a result of overexposure (either through ingestion or inhalation), include fatigue, sleep disturbance, headache, aching bones and muscles, digestive irregularities, abdominal pains, and decreased appetite. Chronic overexposures to lead affect the central nervous system and male and female reproductive systems. Lead has also been identified as a fetotoxin. The OSHA PEL for inorganic lead is 50 [jg/m3, as an 8-hr TWA. 4.1.4.2 Chromium Hexavalent chromium compounds, upon contact with the skin can cause ulceration and possibly an allergic reaction. Inhalation of hexavalent chromium dusts is irritating and corrosive to the mucous membranes of the upper respiratory tract. Chrome ulcers arid chrome dermatitis are common occupational health effects from prolonged and repeated exposure to hexavalent chromium compounds. Acute exposures to hexavalent chromium dusts may cause coughing or wheezing, pain on deep inspiration, tearing, inflammation of the conjunctiva, nasal itch and soreness or ulceration of the nasal septum. Certain forms of hexavalent chromium have been found to cause increased respiratory cancer among workers. Trivalent chromium compounds (chromic oxide) are generally considered to be of lower toxicity, although dermatitis may occur as a result of direct handling. 4.1.4.3 Vanadium Vanadium is irritating to the eyes, skin and respiratory tract. Chronic overexposures may cause pulmonary edema, blood vessel constriction and central nervous system effects. 4.1.4.4 Nickel Skin sensitization is the most frequently seen toxic reaction to nickel and nickel compounds. This often results in chronic eczema known as "nickel itch". Nickel and its compounds are also irritants to the conjunctiva of the eye and mucous membrane of the upper respiratory tract. Studies have shown that chronic overexposures to the dusts of nickel and nickel salts can produce cancers of the lung and nasal passages. 4.1.4.5 Copper The OSHA PEL for copper dust is 1 mg/m3. The inhalation of copper dusts may cause.a feeling of illness similar to the common cold with sensations of chills and stuffiness of the head. Small copper particles may J:\Project\Georgia-Pacific\03060-062 Milford CV 4-2 April 2007 Landfill\WorkPlan\FINAL-April200AENSR-HASP-Final- Aoril07.doc ENSR enter the eye and cause irritation and/or discoloration. Repeated or prolonged contact with copper dusts may cause skin irritation or greenish discoloration of the skin pr hair. Persons with pre-existing Wilson's disease may be more susceptible to, the effects of copper exposure. Although not typically considered a route of exposure in an industrial setting, the ingestion of large quantities of copper may cause stomach and intestine ulceration, jaundice and kidney and liver damage 4.1.4.6 Cadmium Cadmium can cause local skin and eye irritation. The eariy symptoms of overexposure, via inhalation, may include mild irritation of the upper respiratory tract, a sensation of constriction of the throat, a metallic taste and/or a cough. A period of , 1-10 hours may precede the onset of rapidly progressing shortness of breath, chest, pain and flu-like symptoms. Repeated overexposure to cadmium may result in kidney dysfunction/damage and an increased risk of cancer of the lung and pi-ostate. The OSHA Permissible Exposure Limit (PEL) for cadmium is 5 ug/m3. 4.1.4.7 Beryllium Symptoms of acute exposure to beryllium include pain below the sternum, weight loss, nonproductive cough, shortness of breath and irritation of the eyes, respiratory system and skin. Specifically, acute or chronic inhalation of beryllium has caused inflammation of the mucous membranes, trachea and bronchi and lungs. Symptoms of chronic exposure include cough, pain in the joints, general weakness, weight loss, clubbing of the fingers; shortness of breath, cyanosis and allergic contact dermatitis. Chronic exposures can cause enlargement of the liver, spleen and heart; multiple granulomas of the lung, spleen, liver and lymph nodes; and lung cancer. The OSHA PEL for beryllium is 2 ug/m3. 4.1.5 Pesticides 4.1.5.1 Chlorinated Pesticides Chlorinated hydrocarbons, such as DDT, chlordane, lindane, aldrin and dieldrin, are highly stable and valued for their residual action against insects. They are also stored in the body fat of mammals and are eliminated very slowly. These pesticides affect the central nervous system. Symptoms of poisoning include tremors and convulsions. Chronic effects associated with organochlorine pesticide poisoning include liver damage. Many of the chlorinated hydrocarbon pesticides are directly absorbed through the skin to cause systemic effects. 4.1.5.2 Chlorophenoxy-herbicides The chlorophenoxy herbicides, 2-methyl-4-chlorophenoxyacetic acid (MCPA) and 2- (2—methyl-4 chloro phenoxy)propionic acid (MCPP), were detected in sediment and waste samples collected from the site MCPA and MCPP are selective herbicides. Contact with MCPA or MCPP powder or spray is corrosive to the eyes and skin and may cause redness Upon inhalation, a burning sensation may be experiences. These symptoms are due to the acidic nature of MCPP. As a group, chlorophenoxy herbicides are considered potential human carcinogens. 4.1.6 Polychlorinated Biphenyls Polychlorinated biphenyls (PCBs) are a series of technical mixtures consisting of many isomers and compounds that vary from mobile oily liquids to white crystalline solids to hard noncrystalline resins. PCB containing fluids were commonly used as the coolant in heavy duty transformers and capacitors. Since pure PCBs are highly viscous, they were typically mixed with an organic solvent to allow the transformer fluid to flow. Depending upon the age of the transformer, the PCB concentration in transformer fluids can range from a few ppm to many hundreds of ppm. PCBs are generally considered to be of moderate to low toxicity. The higher the chlorine content of the PCBs, the greater the toxicity is likely to be. Exposure to PCBs can cause liver damage at high concentrations. J:\Proiect\Georgia-Pacific\03060-062 Milford CV ' 4-3 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- Aoril07.doc , ENSR Prolonged exposure to large doses of PCBs has been shown to cause cancer in laboratory animals. However, no strong evidence indicates that PCBs are human carcinogens. Dermal contact with liquid PCBs may produce skin irritation or a rash, often referred to as "chloracne." Eye contact with PCB fluids is likely to produce eye irritation. The OSHA PEL for PCBs (54% chlorine content) is 0.5 mg/m3, as an 8-hr TWA. J:\Projecl\Georgia-Pacific\03060-062 Milford CV 4-4 April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR Table 1 Summary Table of Contaminants and Associated Exposure Limits Contaminant of Concern OSHA PEL/ACGIH TLV as 8-hr TWA Toluene 200 ppm/50 ppm Xylene 100 ppm MEK 2Q0 ppm Ethylbenzene 100 ppm Tetrachloroethylene 100 ppm/25ppm Trichloroethylene 100ppm/50ppm PCBs (Arochlor 1254) 0.5 mg/m3 PAHs (as CTPV) 0.2 mg/m3 di-n-butyl-phthalate , • 5 mg/m3 bis-(2-ethylhexyl) phthalate 5 mg/m3 Lead 0.050 mg/m3 Arsenic 0.010 mg/m3 Cadmium 0.005 mg/m3/0.01 mg/m3 . Chromium 0.5 mg/m3 Copper 1 mg/m3 Nickel 1 mg/m3/1.5 mg/m3 • Vanadium (as ferrovanadium dust) 1nig/m3 Beryllium 0.025 mg/m3/0.002mg/m3 MCPA No exposure limits established MCPP No exposure limits established . DDT 1 mg/m3 Chlordane 0.5 mg/m3 Lindane No PEL established/0.5 mg/m3 Aldrin 0.25 mg/m3 Dieldrin 0.25 mg/m3 2'4-D No PEL established/10 mg/m3 Endosulfan No PEL established/ 0.1 mg/m3 J:\Project\Georgia-Pacific\03060-062 Milford CV 4-5 April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doo ENSR 4.1.7 Waste Stream Characterization Upon completion of field characterization and drum screening, each removed drum will be categorized into a waste stream as described in the Woodward Clyde Consultants report dated August 1992. The seven streams include: Waste Stream '- Drummed Flammable Liquids from Coating Operations Waste Stream Waste Stream Waste Stream Waste Stream Waste Stream Waste Stream Although the above information suggests that the types of wastes that may be encountered in the landfill are defined, drums encountered throughout the course of this project will be treated as unknowns, requiring the use of Level B protective equipment. 4.1.8 Hazardous Substances Brought On-Site by the Consultant and Contractors A material safety data sheet (MSDS) must be available for each hazardous substance that the Consultant or the contractors bring on the property. This includes solutions/chemicals that will be used to decontaminate sampling equipment, fuels for construction equipment and calibration gases for air monitoring equipment. All containers of hazardous materials must be properly labeled in accordance with OSHA's Hazard Communication Standard. Either the original manufacturer's label or an NFPA 704M label specific for the material (as shown at the ^ right) is considered to be an acceptable label. Additionally, the Consultant will also provide MSDSs for the contaminants of concern. For ease of review and general accessibility, these MSDSs and the sheets for the decontamination solutions and calibration gases will be maintained on site in a separate binder rather than appended to this HASP. A chemical inventory list is provided as Table 2. MSDSs for these chemicals will be on site. If additional materials are brought on-site, the Consultant will secure MSDSs for those chemicals, add them to the binder and review them with the field team during the morning site-safety meeting before the materials are used on site 4.2 Chemical Exposure and Control 4.2.1 Chemical Exposure Potential The potential for exposure to the contaminants of concern during the time critical actions is considered to be moderate to high, with the higher potential fqr exposure occurring during drum recovery, handling and sampling activities. This is due to the confining nature of a drum and higher concentrations of contaminants found in drums. J:\Project\Georgia-Pacific\03060-062 Milford CV 4-6 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc " ^ ENSR Based on previous data, it is more likely that the primary corntaminants of coricern during the excavation activities ass.qciated with the construction of the reinforced wall will be PAHs and metals present in the fly ash. " ' Table 2 Chemical Inventory List Contaminant of Concern Chemicals .. Toluene Isobutylene in Air calibration gas , Xylene Methane in Air calibration gas MEK j Diesel fuel . Ethylbenzene Gasoline Tetrachloroethylene Te'st Kit Reagents Trichloroethylene Nitric acid solution '•: PCBs (Arochlor 1254) Acetone r . , PAHs (as CTPV) , Hexane ' ' '•^•' di-n-butyl-phthalate Alconox bis-(2-ethylhexyl) phthalate Lead , , • Arsenic • '. . Cadrnium ' Chromiuni' •' Copper Nickel Vanadium (as ferrovanadium dust) Beryllium ' MCPA ' ' ' -, , MCPP : DDT Chlordarie , • .', Lindane -.'] Aldrin Dieldrin • 2'4-D Endosulfan J:\Proiect\Georgia-Pacific\03060-062 Milford CV 4-7 April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- Aoril07.doc ' • ENSR However, exposure to PAH and metal-containing dusts is expected to be minimal due to the wet nature of the area where the work is being conducted. Exposure to VOCs is more likely to be a concern during drum handling/sampling operations. Exposure will be highest if drums containing liquid wastes are encountered. During the sampling of the drums, there is also the potential for direct dermal contact/splash hazard with drummed materials. Dermal contact with flyash and impacted soils may alsd occur during the construction of the retaining wall especially when manual techniques are used. 4.2.2 Chemical Hazard Control The chemical hazards associated with the proposed time critical actions can be controlled in several ways, including: • The Consultant will perform air monitoring (Section 6.1) in the worker's breathing zone to determine exposure to VOC vapors and total dusts during the installation of the retaining wall as well as during drum removal/handling and sampling activities. If exposures exceed the action levels, respiratory protection as discussed in Section 7.2, will be donned. • Although significant amounts of dust are not anticipated to be generated during the wall construction due to the wet nature of the work area, if necessary, applying a fine mist of water over the surface soils during wall construction activities will minimize the potential for dust generation. • To avoid direct dermal contact with contaminated media, protective clothing, as described in Section 7.1, will be required when handling drums and decontaminating sampling equipment or machinery. • Although highly unlikely, exposure to all of the contaminants of concern may occur via ingestion (hand-to-mouth transfer). The decontamination procedures described in Section 9.0 address personal hygiene issues that will limit the potential for contaminant ingestion. J:\Projecl\Georgia-Pacific\0306C-062MilfordCV 4-8 April 2007 LandfiH\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR 5.0 Physical Hazards and Controls There are numerous physical hazards associated with existing site conditions as well as the nature of the work being conducted at the Site. It should be noted, that for purposes of implementing the proposed remedial actions, no confined space entry will be performed. If confined spaces are identified on site and it is determined that such spaces must be entered, the RHSM will be contacted to ensure that this HASP is properly revised to address the hazards of confined space entry. 5.1 Slip, Trip and Fall Hazards 5.1.1 On-Site Debris A significant amount of drums and other debris were removed from the surface of the landfill during the December 1991 and January 1992, Surface Remediation Action. However, buried and semi-buried materials are still present at the landfill and pose a potential slip, trip and fall hazard to the field team. Additionally, the site is heavily vegetated and the terrain is uneven. Further, field operations include site clearing activities which may or may not include stump grinding. Fallen trees and remaining stumps will also present a tripping hazard to the field team. • • To the extent possible, team members should walk on established roadways within the site to access their work areas versus cutting through the landfill proper. During the landfill reconnaissance for drums, employees should walk-around objects that are in the way rather than jumping over debris. 5.1.2 Good Housekeeping Maintaining a work environment that is free from accumulated debris is the key.to preventing slip, trip and fall hazards at construction sites. Essential elements of good housekeeping include: • Orderiy placement of materials, tools and equipment; • Placing trash receptacles at appropriate locations for the disposal of miscellaneous rubbish; • Prompt removal and secure storage of items that are not needed to perform the immediate task at hand; and, • Awareness on the part of all employees to walk around, not over or on, equipment that may have been stored in the work area. ' 5.1.3 Site Illumination It is anticipated that two portable, light towers will be on-site. These light towers will be available in the event of an emergency where work activities must be implemented during low-light hours. 5.2 Working in the Delaware River to install Turbidity Curtain Erosion control measures include the installation of a turbidity curtain in the Delaware River along the western edge of the landfill. The turbidity curtain system will consist of two main elements: 1. For river flow diversion, a silt-dam constructed of an adjustable and permeable turbidity curtain measuring 7' deep, complete with 6" closed cell foam buoys and ballast chain, will be installed at the upstream end of the project area. 2. For containment, an adjustable and impermeable turbidity curtain measuring 7' deep, complete with 6" closed cell foam buoys and ballast chain, will be installed along the entire project area. J:\Project\Georgia-Pacific\03060-062 Milford CV 5-1 April 2007 La^dfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR Steel'T' posts will be driven into the river bottom every 20'. Pipe, measuring 2" in diameter and approximately 8' long, will be placed on the steel'T' posts. A 5/16" stainless steel cable will be run through the curtains. Stainless steel 'snap clips' will secure the curtain to the pipes. Upstream and downstream of the turbidity curtains marker buoys will be placed. These buoys will be held in place with a fluke style river anchor and 7' of chain. 5.2.1 Working in Water The initial step in turbidity curtain installation will be the placement of the marker buoys upstream and downstream of the wdrk location. These buoys iwill be manually placed by personnel equipped with waders and a Coast Guard approved Type 111 personal flotation device (PFD). The steel'T' posts will be driven into the river bottom using a pneumatic driver. Personnel will enter the river in waders to deploy the 'T' posts. Should the depth of the river prohibit this operation, a pontoon boat will be brought to the site, thereby allowing personnel to stand on the deck and drive the posts. When working in or on the river, the buddy system will be followed at all times. Additionally,, a throw ring will be available in the event of an emergency. 5.2.2 Use of a Boat Based on the current, depth to water, and river conditions at the time, a boat may be utilized for turbidity curtain and marker buoy deployment. It is anticipated that the contractor would use a 16' fiberglass trihull boat if needed. Before the boat is placed in service, it will be inspected and determined to be in safe operating condition before use. A pre-use inspection of the watercraft must also be performed by the operator before each daily use. Watercraft found in an unsafe condition shall be taken out of service and its use prohibited until unsafe conditions have been corrected. 5.2.3 Boat Registration All watercraft must meet USCG or state watercraft registration and numbering requirements. The US Coast Guard requires that all motorized watercraft be numbered in the state,of principal use. A valid certificate showing the numbers issued to the watercraft is required to be on board the watercraft whenever the watercraft is in use. Watercraft registration numbers are required to be painted or permanently attached to each side of the fonward half of the watercraft. Watercraft registration must be updated as the governing laws require. i 5.2.4 Boat Capacity Small watercraft shall not be loaded (passengers and gear) beyond the weight capacity printed on the USCG ,.information plate attached to the stern. If there is no capacity label, use the following formula to determine the safe loading capacity: • # People = (length of boat X width)-^15 Watercraft shall have sufficient room, freeboard, and stability to safely carry the cargo and number of passengers allowed with consideration given to the weather, and water conditions in which it will be operated. Once on board, distribute the load (people and equipment) evenly and secure all equipment to prevent it from shifting. J:\Project\Georgia-Pacific\03060-062 Milford CV 5-2 April 2007 LandfimWorkPlan\FINAL-April2007\ENSR-HASP-Final- April07,doc ENSR 5.2.5 Personal Flotation Devices Employees working over or near water, where the danger of drowning exists, shall wear a USCG-approved personal flotation device (PFD). When selecting the appropriate type and style of PFD, the type of activity being conducted and the required mobility of the user must be considered, because some activities may require a PFD which is less restrictive. Project team employees will be required to wear a USCG-approved Type 111 personal flotation device (PFD). Although not as effective as a Type I in turning an unconscious wearer face-up, a Type 111 PFD is-generally less bulky and restrictive, and is typically the PFD of choice in a marine work environment. The use of inflatable PFDs is discouraged due to questionable reliability and maintenance requirements. Prior to and after each use, each PFD shall be inspected for defects which would alter their strength or buoyancy. Defective units shall not be used. 5.2.6 Emergency Equipment All personnel working on boat(s) are to be informed of the locations of all safety equipment on the boat, including first-aid kit, fire extinguishers and throw-ring, as applicable to the specific boat being used. 5.2.7 Warning Boaters The Delaware River is used for a variety of recreational purposes. In accordance with USEPA letter dated March 5, 2007,"the appropriate river authorities must be notified before installation of the turbidity curtain and marker buoys," The Site Superintendent will be provided with the specific contact information for proper notification of turbidity curtain installation activities. The information to be provided will include at a minimum, the location, installation dates and duration of turbidity installation, including marker buoys. The identification and notification of "river authorities" will be coordinated with EPA and will include public notification of local fishing, boating and canoe clubs and/or other river agencies, Additionally, to warn boaters of the presence of the turbidity curtain in the river, buoys will be manually placed into the river at upstream and downstream locations. Each buoy will be equipped with a hazard warning sign and light. Along the curtain, white, flashing photosensitive marker lights will be installed every 75 feet. 5.3 On-Site Construction Traffic Hazards A significant amount of heavy machinery will be used on site to create haul roads and staging areas, remove trees and other vegetation, excavate soils and deliver retaining wall materials and to excavate, transport and package any removed drums/containers/pails. The use of such equipment poses a potential hazard to the support crew working around the equipment. To ensure that all pedestrians at the site are visible to equipment operators, all employees at the site will don ANSI-approved Class II traffic vests. Additionally, employees should follow the designated roadways that lead to the work areas. This is where equipment operators will expect to find pedestrians walking. Do not take short cuts through the woods that lead to on-site access roads as equipment operators/drivers will not anticipate employees exiting from these locations. J:\Project\Georgia-Pacific\03060-062 Milford CV 5-3 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07,doc ENSR 5.4 Site Clearing Hazards Site clearing operations consist of tree and brush removal as well as vegetation removal. Tree removal will be conducted using a hydraulic shear attached to an excavator as well as chain saws. Once on the ground, the trees will be cut into manageable lengths for removal from the work area. Large trunks, limbs and branches will be transported to a staging area where they will be chipped using a tub-grinder. Smaller limbs will be chipped in the immediate area of clearing using an 18" chipper. In order to perform the landfill surface drum reconnaissance, vegetation must be cut down. Weed whips will be used to cut non-woody vegetation from the landfill surface in order to expose any surface drums. As this operation is conducted, personnel will stake and flag any exposed or partially exposed drums. 5.4.1 Use of Hydraulic Shear Tree removal may be cbnducted using a hydraulic shear attached to an excavator as well as chain saws. Both pieces of machinery present significant hazards to the user and should be operated only be employees who are trained and familiar with their operation. When operating the shear, the following safety procedures will be implemented: , • Carefully survey the ground, timber and stand conditions before starting tree felling operations. Be alert to overhead hazards such as dead snags and large limbs which may fall unexpectedly during felling operations. Do not operate equipment during' adverse weather conditions. Maintain safe operating distances from all ground workers and other tree clearing operations of at least two tree lengths. Do not exceed the designed capacity of the shear attachment. If the diameter of the tree to be cut exceeds the design of the attachment, use an alternate way to remove the tree. • Do not leave a, hung tree. Safely use the attachment to push a hung tree to the ground. Falling tree limbs or branches can enter the operator's area. Given the likelihood of being hit while . cutting trees, the operator station must be protected from all sides with heavy gage metal screen or a similar barrier. Typical equipment cabs protect the operator from the top, back and both sides but not the front due to the need for easy access to the cab. In tree shear operation, the equipment must have a protective door made of heavy metal screen or other durable material. • Working on sloping or rough grade involves a potential overturn hazard. Using a shear attachment in a raised position creates additional hazards because the attachment and the weight of the tree being cut raise the center of gravity. Keep the load low for machine stability. • When operating on a slope, work only up and down the slope. Do not cut trees at an angle. • When stopped, lower attachment to the ground. 5.4.2 Use of a Chain Saw Chain saws will be used in addition to the hydraulic shear to remove trees from the proposed work areas. The following safety procedures and all of the provisions of 29 CFR 1910.266 will be implemented when operating a chain saw: • Chain saws must be inspected daily to assure that all handles and guards are in place and tight, that . all controls function properly and that the muffler is operative and equipped with a spark arrestor. • All chain saw controls function properly. This includes having saw equipped with a safety throttle which shuts off power after pressure on the throttle is released. J:\Project\Georgia-Pacific\03060-062 Milford CV 5-4 April 2007 Landfil^WorkPlan\FINAL-April200AENSR-HASP-Final- April07.doc ENSR • The cutting chain is properiy adjusted, and that the saw chain will,not continue to be driven after the throttle is released. • Chain brakes and all other manufacturers'safety features remain operational. • Chain saws without all safety devices operational or in need of repair or parts or otherwise not safe for use shall immediately be tagged out and marked "out of service". • Start the saw only on the ground of when ptherwise firmly supported. • Clear brush which might interfere with clear footing before starting to cut. • Shut off the saw when carrying it for a distance greater than from tree to tree or when surface is slippery or heavy with underbrush, the saw must be' at idle speed-when carried short distances. • Do not use the saw to cut directly overhead or a distance at which the operator no longer has a safe grip on the saw. Always use two hands to operate the saw. • Safety glasses with permanently attached sideshields will be'worn underneath a steel mesh faceshield which will attach to standard hard hats. The brush shield is designed to protect the head and face from debris created by using a chain saw. ' • Employees will wear Kevlar gloves and Kevlar chain saw chaps to protect hands and legs from accidental contact with the saw. The leg protection shall cover the fuH length of the thigh to the top of the boot on each leg to protect against contact with a moving chain saw. • ''• Ear muffs dr ear plugs with a minimum NRR of 24 dB must also be worn. 5.4.3 Use of Weed Whips Weed whips are used to clear areas of succulent,vegetation such as grass, light brush, briars and tree seedlings. The L-shaped weed whip.cuts grass and weeds but is unstable for use on larger growth; the triangular-frame weed whip cuts briars and woody stems up to a half-inch in diameter. A suwanee sling is a heavy duty weed whip that also has an axe b)lade. It does the same work as a weed whip, but can also cut through large materials. The heavier weight of this tool allows it to more easily cut off larger material than a weed whip.,- •. "..-'.•-. When using weed whips, employees should follow these safety procedures: Select the correct tool for the types aind size of vegetation present across the landfill. Employees will wear leather gloves when using weed whips. Weed whips are meant to be swung back and forth with both hands. Avoid using a golf swing. The tool should be swung no higher than an employee's sideJ Strong swings should be made to prevent the blade frorn bouncing or glancing off springy growth. Screws hold the serrated double-edge blade in place. These screws can work loose so check them before each use. , • ' , .. . ' ' At the end of the day, irispect the whips for damage. Clean, sharpen, and pil as necessary and store with a sheath in place. 5.4.4 Stump Removal Stump removal operations will be conducted using, an excavator and dozer (where required). Once removed, the stumps will be transport:ed to a staging area where large tree trunks/limbs/branches are staged for subsequent tub grinding. In other cases, where the topography is favorable and root masses will not impede wall construction, the stumps will be ground in place. J:\Project\Georgia-Pacific\03060-062 Milford CV 5-5 April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc . • ENSR 5.4.5 Chipping Operations ; A tub-grinder is being used to chip larger trees and stumps and a 18" chipper will be used to chip smaller branches and limbs'. When operating chippers: Do not open the access covers or doors until the drum or disk is at a complete stop. Verify that infeed and discharge ports are designed to prevent personnel contact with disc, knives or blower blades. All employees feeding brush into chippers shall wear eye protection in the form of a faceshield over safety glasses with sideshields. Loose clothing, gauntlet-type gloves, rings and watches shall not be worn by workers feeding the chipper. Materials such as stones, nails, sweepings, etc. shall not be fed into brush chippers. Detached chippers must be chocked during usage on any slope when movement of the chipper is reasonably foreseeable. As with other mobile equipment that is intended to be operated from a stationary position, the unexpected movement of the equipment can endanger employees who are either operating the equipment or in the path of the equipment when it moves. The vibration caused by the operation of the equipment can enhance the potential for unintended equipment movement. Chocking of mobile equipment to prevent movement is recognized throughout industry as a necessary and appropriate means to prevent unintended movement. 5.5 Utility Hazards 5.5.1 Underground Utility Hazards New Jersey law requires that a utility clearance be performed at least three (3) days prior to initiation of any subsurface work. Terra will contact New Jersey One Call (1-800-272-1000) to request a mark-out of natural gas, electric, telephone, cable television, water and sewer lines iri the proposed work locations. Work will not begin until the required utility clearances have been performed. Public utility clearance organizations typically do not mark-out underground utility lines that are located on private property. As such, the contractor must exercise due diligence and try to identify the location of any private utilities on the property being investigated. The contractor can fulfill this requirement in several ways, including: Obtaining as-built drawings for the areas being investigated from the property owner; Visually reviewing each proposed soil boring/well installation locatipns with the property owner or knowledgeable site representative; Performing a geophysical survey to locate utilities; Hiring a private line locating firm to determine the location of utility lines that are present at the property; Identifying a no-dig zone; or Hand digging in those proposed locations if insufficient data is available to accurately determine the location of the utility lines. 5.5.2 Overhead Utility Hazards Be particularly aware of overhead power lines in the work area. Any vehicle or mechanical equipment capable of having parts of its structure elevated (drill rig, crane etc.) near energized overhead lines shall be operated so J:\Project\Georgia-Pacific\03060-062 Milford CV 5-6 April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR that a clearance of at least 10 feet is maintained. If the voltage is higher than 50kV, the clearance shall be increased 4 inches for every lOkV over that voltage. 5.6 Well Abandonment - Drilling Select monitoring well and piezometers will be abandoned by a well driller licensed in the State of New Jersey prior to the start of.wall construction activities in accordance with NJAC 7:9D as specified ori Figure 3A, Sheet 4 of 13 of the Site Preparation Plan provided in the Engineering Design Report (EDR). A well driller licensed in the State of New Jersey will abandon select groundwater monitoring wells and piezometers prior to the start of the wall construction activities. All well and piezometer abandonment activities will be conducted in accordance with applicable NJDEP requirements.. No overdrilling is anticipated, in general an attempt will be made to pull out the casing. In the event that the casing can not be removed then the casing will be cut at the ground surface and grouted to the surface.. For this program, it is anticipated that the well materials will be pulled out using an ATV hollow stem auger drill rig with the holes being grouted from the bottom up. Well materials will be consolidated into roll-off containers for disposal. 5.7 Working around Heavy Machinery A significant amount of heavy machinery will be used on site to create haul roads and staging areas, remove trees and other vegetation, excavate soils and deliver retaining wall materials and to excavate, transport and package any removed drums/containers/pails. The use of such equipment poses a potential hazard to the support crew working around the equipment. Use of heavy equipment at the site requires all employees working in the exclusion zone to wear ANSI-approved hard hats, steel-toed safety shoes/boots, safety glasses and hearing protection. Operators will inspect the equipment daily before use to ensure safe operating conditions and to determine that the brakes arid operating systems are in proper working condition and that all required safety devices are in place and functional (i.e. reverse gear alarms are working properly). When working around heavy equipment, employees should: Make sure that the operator is aware of your presence/activities; Stay in the operator's line of sight, don't work in his/her blind spot; Approach areas where equipment is operating from a direction visible to the operator; Be aware of the swing radius of equipment that rotates such as excavators; and. Develop a series of hand signals to facilitate communication with the operator. 5.8 Excavation Hazards Excavation/trench depths during this project may vary from several inches to over 5 feet. The summary of cave-in prevention actions listed below is brief and is meant to remind employees of the significant hazards associated with entering an unshored excavation/trench. It is the sole responsibility of the excavation contractor to ensure compliance with OSHA's Excavation Standard (29 CFRI926.650) and to provide a person competent in identifying excavation hazards to the project. Open excavations will be inspected daily by the contractor's competent person. A stairway, ladder, ramp or other similar means of egress must be located in trench excavations greater than 4 feet in depth so as to require no more than 25 feet of lateral travel for employees in the trench excavation. Remember that more than one means of egress may be required. J:\Proiect\Georgia-Pacific\03060-062 Milford CV 5-7 April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR • The excavation must be free of accumulated water before entry is allowed. • No person shall enter an excavation greater than 5 feet in depth unless: - the walls of the excavation have been sloped back to an angle not steeper than one and half horizontal to one vertical (1.5H:1V) {i.e., 34 degrees from the horizontal) as specified in 1926.652(b) - Example - An excavation that was planned to be 5 feet deep and 3 feet wide at the base would have to be sloped back so that it was 18 feet wide at the top. - the walls of the excavation have been shored in accordance with the requirements specified in 29 CFR 1926.652(c), (d), and (e) or - the work in the excavation is to be performed within the confines of an approved shield system (e.g., trench box) that has been constructed and is used in accordance with the requirements of 1926.652(g) • A stand-by employee must be present at all times when employees are in the excavation. • All materials, including spoils, shall be placed at least 2 feet from the edge of the excavation to prevent the material from rolling into the excavation. All personnel should remain 2 feet away from the edge of the excavation while personnel are in the excavation. Aside from the inherent cave-in hazards associated with excavation and trenches, there is also the potential at this Site to uncover buried drums during excavation activities. In order to carefully expose buried drums, all excavation operations will be conducted in 6" lifts. Should a drum become exposed, a second excavator equipped with a barrel grapple will remove the drum from the excavation area and handle it as specified in the Work Plan and Sampling and Analysis Plan. 5.9 Equipment Refueling A double-walled fuel tank will be placed at the staging area and will be contained within a lined berm. Some equipment will fuel at this tank (e.g. loaders, off-road dump trucks) while excavators and dozers will have the fuel brought to them. Portable fuel tanks to fuel heavy equipment will be used at the'Site. These portable tanks will be normally in the bed of a pickup truck or in an off-road type vehicle capable.of carrying a fuel tank. These vehicles will travel from a designated fuel transfer location to where the heavy earth moving equipment is being used in the exclusion zone. On-site refueling will be a two person task. One person will control the fueling nozzle and the other will serve as a look-out for leaks in the hose and will also operate the electrical shut off switch for the fuel pump, if necessary. During on-site refueling, the following safety precautions will be implemented: All personnel fueling equipment must in control of the fueling nozzle at aH time. Fuel levels in the machinery can be checked visually to prevent run over. Maximum fill heights will not be achieved to prevent any spillage from overflow. The fuel pump will be immediately shut off if a leak in the hose is observed or if the fueling nozzle can not be shut off due to equipment malfunction A containment tub will be put down under the piece of equipment that is being fueled prior to fueling it. This precaution will prevent fuel from spilling on to the ground. When fueling is required, the equipment will be moved as far away from the river as possible and positioned so that the fueling port is turned toward the river. Portable fueling trucks will carry sorbent materials such as oil dry and sorbent pads. A fire extinguisher must be located within a 50-foot radius of the fueling area. J:\Project\Georgia-Pacific\03060-062 Milford CV 5-8 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.dOG ENSR 5.10 Drum Handling/Sampling/Storage Any drum recovered whole, or partial drums with material contained within them, will be placed directly into a salvage drum. S^alvage drums will be then be transported to the drum sampling pad using a skid steer or end loader. Drum remnants and empty drums vyill be stockpiled close to the excavation area and subsequently transported to the drum staging area for off-site disposal/recycling. This same technique will be used to handle surface drums found during the landfill reconnaissance. Following field characterization and laboratory -. analysis of the waste samples, drums will be removed from salvage drums and bulked with like wastes or remain in salvage drums. The potential physical and chemical hazards associated with the drum removal, drum handling and drum sampling tasks are significant. Aside from the potential for inhaling vapors and being splashed with drum contents, there are significant physical hazards associated with handling drums including: Being struck by drum parts (removable heads, rings and bungs) thrown by pressurized release of drum contents; Being struck by falling drums; Contact with sharp metal parts (chimes, rings, etc); Strain and overexertion due to inappropriate lifting techniques; and. Being caught between drums when loading damaged drums into salvage or overpack drums and when manually moving drums next to one another: The following safety precautions will be implemented during these efforts to reduce the potential for injury. 5.10.1 Drum Opening and Sampling Procedures All drums to be characterized for off-site disposal will be moved to the drum sarnpling and storage pad. Drum sampling operations will be monitored using a Pl.D and combustible gas detector. In the event that the lower explosive limit (LEL) reaches or exceeds 10%, drum sampling operations will be suspended. Drums with removable heads (open tops) will have the tops removed. This operation should be conducted with caution as rings that become disfigured can spring from the drums when they are released. Non-bulging, non-removable head drums with bungs will be opened slowly by removing the smaller of the bungs. Should a pressure release be detected, employees will step back and let the drum vent prior to completing the opening. Manual drum opening will be performed with a bung wrench that is made of non sparking materials such as brass or a bronze-beryllium alloy. If the bung on a non-bulging drum can not be removed, the drum will be moved into a segregated area and opened by means of a non-sparking drum punch. Bulging drums could have contained frozen materials, could have been pressurized at one time or another or are/have been under pressure due to chemical reaction. Bulging drums present a unique hazard and as such, will be placed behind a blast shield and opened using a remote drum opener. All solid samples will be collected using a stainless steel trowel or dedicated disposable scoop/spatula. Liquid samples will be collected using a dedicated glass drum sample thief. When collecting samples, employees will not stand on or work from drums or containers and will not stand over or place hands and arms over a drum.. J:\Proiect\Georgia-Pacific\03060-062MilfordCV 5-9 . April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- Aoril07.doc ENSR 5.10.2 Drum Storage/Consolidation Following drum field characterization/screening and sampling, each drum will be categorized into a waste, stream as described below for purposes of bulking materials of similar composition and compatibility for off-site disposal: ': Waste Stream 1 Drummed Flammable Liquids from Coating Operations Waste Streani 2 • Rags and other Materials Generated by the Coatings Process Waste Stream 3 • Waxy Substance from Coating Operations Containing MEK Waste Stream 4 • Soil Containing Pigments, Dyes arid/or Paint Sludges Waste Stream 5 • General Solids with no VOC Headspace Readings , Waste Stream 6 • Hard, Waxy Solid with no VOC Headspace Readings Waste Stream 7 Oil Contaminated Rags Once categorized, drurns will be .1) removed frorii salvage drums and bulked with like wastes; or 2) remain in the salvage drums, be nuhibered and placed on the drum storage pad. The drums will be placed in rows no more than two. wide with the labels and identifying marks turned toward the aisle. Aisles will be wide enough to allow for uninterrupted egress and movement of drum handling equipment (i.e. skid steer). Up to three (3) roll- off boxes will also be placed on the waste storage pad. The boxes will be used to bulk like wastes. 5.10.3 Handling Abandoned Cylinders Abandoned cylinders (that are intact) w/ill be flagged and located via GPS during the drum reconnaissance pperations. A sub-contractor specializing in reactive/explosive wastes and gas cylinders will be contracted to remove said materials. Various techniques are employed in dealing with such wastes including on-site treatment. A cylinder with unknown contents and/or at an unknown pressure presents a variety of hazards including, but. not limited to: compressed gas, flammable, corrosive, oxidizer, pyrophoric, toxic. These hazards result in: high pressure release, fire, explosion, fuming gas, release of toxic gas. If it is determined, by a trained technician, that it would be unsafe to manually operate the main cylinder valve, it will be necessary to perform a remote cylinder opening. Safe distance for cylinder handling will be dependent upon the cylinder contents and/or size and the site condition. Appropriate measures for dealing witfi abandoned cylinders are included in the Work Plan Appendix containing-.the SOPs. PPE will be determined by cylinder contents or if contents are unknown, will be based on the highest possible hazards, as will be dictated by the SSO. 5.11 Generator Safety 5.11.1 Proper Use of the Generator VVhen using a generator on site, follow these safety guidelines:. Verify that the wattage of tfie generator being used is sufficient for your project needs. ' Verify that the voltage rating ofthe generator rinatches the rating of the equipment you need to operate. . Properly ground the generator Keep water away from the generator; Protect it from rain., Use a heavy-duty, three-prong, grounded extension cord. J:\Project\Georgia-Pacific\03060-062 Milford CV 5-10 April 2007 Landfil[\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc • ;'-: ,.;-;''.^.;v...... ' "^'y' • -^ENSR^ , • Gasoline and its vapors nnay ignite if they come in.contact vyith,,hot conhppne^ Tijrn the.generator off and make sure it has cooled down'(i.e. 10-rninute,s) before re-fueH^ 5.11.2 Storage of Gasolinie i .-/- .':" •"•.' Gasoline must be stored in an approved container or tank. A;Type 11 galvariized,steel safety can is • recommended for storing gasoline'that will.be used to refuel the generator or other small engine equiprrient being used ort site. Storage iri ,anything other than an 'approyed container is strictly prohibited. ' Gasoline is a flammable liquid arid should be stdred at room temperature, away fronri potential heat sources such as the suri,and away frorn any on-site, ignition sources^ f. • 5.12-.,,; Noise .-,/'.• •-...'--.' The use of heavy equipment to implement the. various'site preparation and construction activities associated with'the time critical actions may expose the field-team to noise levels that exceed the OSHA PEL of 90 dB fpr an 8-hour day. Exposure to noise can result'in tfie fbllowing: .' '-, . ' • • Temporary hearing losses where normal hearing returns after a rest period;: - ; • ' • , Interfefence with.speech communication and.the perceptiori of auditory signals; : . — . .• interference with the performance of complicate.d tasks; and,': Permanent hearing loss due to repeated exposure, resulting in nerve destructiori in the hearing organ. • "• Since personal noise rnonitoring will not be conducted duririgJfhe proposed activities,,employees must follow . this' general rule of thumb: If the noise levels are such that ydu must shout at .spmeone 5 feet away from you, you need to be wearing hearing prptectidn-- Employees can vyear either disposable eiarplugs or earmuffs but all hearing protection must have a minimum noise reduction'rating (NRR) of 27 dB^' 5.13 Back Safety ",''.•'.•'•"."• ^ ^^' ••"''..••••'''/",, • '•''-•'•": Using the proper techniques to lift and rnoVe heavy pieces ofjequipment is important to reduce the potential foi". ' back injury. The following precautioris should be implemerited when lifting.pr moving heayy objects: Use mechanic^kldevices to m.dve objects that are too heavy to be moved manually , If mechariical devices are not available, ask another person to assist you. ' . Bend at the knees,'not the waist. Let your legs do the lifting. Do not twist while lifting " . Bring the load as close to you as possible before lifting • " - Be sijre the path you are taking while carrying a heavy object is.f ree of obstructions arid slip, trip, and fall hazards. . ' '•''...."'' .' --•-•-• • ' • 5.14 Hand and Power Tool Safety A variety of hand and power tools may be used during'the proposed site activities. The use of each can pose serious safety hazards to.the user: , ,.; • .. '.' 5.14.1 Hand Tools the greatest hazards posed by'hand tools result from misuse and improper mairitenance. J:\ProjecftGeorgia-Pacific\03060-062 Milford CV,' .-.. .5-11 .-. • : • , '' April 2007 La.ndfill\WorkPlan\F"lNAL-April2007\ENSR:HASP-f^irial- . •• - ' , i" ,:.', ';' ;. - 'April07.doc, , v!v . ' ENSR • When using hand tools be sure you have selected the right tool for the job. If a chisel is used as a screwdriver, the tip of the chisel may break or fly off, hitting the user or others. • Inspect tools for damage such as mushroomed chisel heads or broken hammer handles. If jaws of a wrench are sprung, the wrench may slip. If a wooden handle is loose, splintered or cracked, the head of the tool may fly off. • Do not use damaged tools. • Be sure you know how to use the tool you are working with. 5.14.2 Knives and Cutting Tools There is the potential for employees to cut themselves when using knives, handsaws and blades that may be used to cut materials. To prevent the potential for cuts and lacerations, employees will wear either leather work gloves or Kevlari I gloves. When using knives or blades for these activities, follow the safety precautions listed below: Keep your free hand out of the way Secure your work if cutting through thick material Use only sharp blades; dull blades require more force which results in less knife control Pull the knife toward you; pulling motions are easier to manage Don't put your knife in your pocket Use a self-retracting blade Wear leather or Kevlari I gloves when using knives or blades. 5.14.3 Power Tools To prevent hazards associated with the use of power tools, workers should observe the following general precautions: Never carry a tool by the cord or hose. Never yank the cord or the hose to disconnect it from the receptacle. Keep cords away from heat, oil and sharp edges. Disconnect tools when not using them, before servicing or cleaning them and when changing accessories such as blades, bits and cutters. Secure work with clamps or vise, freeing up both hands to operate the tool. Avoid accidental starting. Do not hold fingers on the switch button when carrying a plugged-in tool. Keep tools sharp and clean for best performance. Wear appropriate clothing. Loose clothing or jewelry can become caught in moving parts. Keep all guards in place. 5.14.4 Electric Tools A variety of power tools may also be used during the proposed activities. When using portable tools that are electrically powered, follow the safety precautions listed below: • Check to see that electrical outlets used to supply power during field operations is of the three wire grounding type. J:\Project\Georgia-Pacific\03060-062 Milford CV 5-12 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR • Extension cords used for field operations should be pf the three wire grounding type and designed for hard or extra-hard usage. This type of cord uses insulated wires within an inner insulated sleeve and will be marked S, ST, STO, SJ, SJO or SJTO. • NEVER remove the ground plug blade to accommodate ungrounded outlets. • Do not use extension cords as a substitute for fixed or permanent wiring. Do not run extension cords through openings in walls, ceilings or floors. • Protect the cord from becoming damaged if the cord is run through doorways, windows or across pinch points. •' Examine extension and equipment cords and plugs prior to each use. Damaged cords with frayed insulation or exposed wiring and damaged plugs with missing ground blades MUST BE REMOVED from service immediately. • When working in flammable atmospheres, be sure that the electrical equipment being used is approved for use in Class 1, Division 1 atmospheres. • Do not touch a victirri who is still in contact with current. Separate the victim from the source using a dry, nonmetallic item such as a broomstick or cardboard box. Be sure your hands are dry and you are standing on a dry surface. Turn off the main electrical power switch and then begin rescue efforts. 5.15 Compressed Gas Safety Compressed air cylinders will be used to supply air-line respirators. Follow the compressed gas handling procedures as outlined below: Inspect all cylinders upon delivery and verify that they are properiy labeled. Breathing air cylinders shall be legibly identified with the word AIR. Compressed air used for respiration shall meet, as a minimum, the requirements of the specification for Grade D breathing air as described by the Compressed Gas Association. Do not store cylinders in direct sunlight (increase in temperature will increase pressure) Use a cylinder dolly to move the cylinders. Keep cylinder valves closed at all times (except when in use). Open valves slowly and away from people. Close the valve and relieve the pressure before removing the regulator. Always keep the valve cap over the valve assembly when not jn use (break in valve will cause cylinder to become a projectile). Cylinders must be stored in the uprigtit position and must be secured by a chain or rope. Segregate empty cylinders from full cylinders. 5.16 Thermal Stress It is anticipated that site operations will begin in the eariy spring of 2007 and continue through the summer and fall of 2007. As such, the hazards of both heat and cold stress are presented inthis HASP. 5.16.1 Heat Stress Types of Heat Stress J;\ProjecRGeorgia-Pacific\03060-062 Milford cv 5-13 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR Heat related problems include heat rash, fainting, heat cramps, heat exhaustion and heat stroke. Heat rasfi can occur when sweat is not allowed to evaporate, leaving the skin wet most of the time and making it subject to irritation. Fainting may occur when blood pools to lower parts of the body and as a result, does not return to the heart to be pumped to the brain. Heat related fainting often occurs during activities that require standing erect and immobile in the heat for long periods of time. Heat cramps are painful spasms of the muscles due to excessive salt loss associated with profuse sweating. Heat exhaustion results from the loss of large amounts of fluid and excessive loss of salt from profuse sweating. The skin will be clammy and moist and the affected individual may exhibit giddiness, nausea, and headache. Heat stroke occurs when the body's temperature regulatory system has failed. The skin is hot, dry, red and spotted. The affected person may be mentally confused and :delirious. Convulsions could occur. EARLY RECOGNITION AND TREATMENT OF HEAT STROKE ARE THE ONLY MEANS OF PREVENTING BRAIN DAMAGE OR DEATH. A person exhibiting signs of heat stroke should be removed from the work area to a shaded area. The person should be soaked with water to promote evaporation. Fan the person's body to increase cooling. Eariy Symptoms of Heat-Related Health Problems: • decline in task performance • excessive fatigue • lack of coordination • reduced vigilance • decline in alertness , • muscle cramps • unsteady walk • dizziness Susceptibility to Heat-Stress Increases due to: • lack of physical fitness, • Obesity • lack of acclimation . • drug or alcohol use • increased age • sunburn • dehydration • infection People unaccustomed to heat are particularly susceptible to heat fatigue. First timers in PPE need to gradually adjust to the heat. The Effect of Personal Protective Equipment Sweating normally cools the body as moisture is removed from the skin by evaporation. However, the wearing of certain personal protective equipment (PPE), particularly chemical protective coveralls (e.g., Tyvek), reduces the body's ability to evaporate sweat and thereby regulate heat buildup. The body's efforts to maintain an acceptable temperature can therefore become significantly impaired by the wearing of PPE. Measures to Avoid Heat Stress: • The following guidelines should be adhered to when working in hot environments: • Establish work-rest cycles (short and frequent are more beneficial than long and seldom). • Identify a shaded, cool rest area. • Rotate personnel, alternative job functions. J:\Proiect\Georgia-Pacific\03060-062 MilfordCV 5-14 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- Aoril07.doc ENSR • Water intake should be equal to the sweat produced. Most workers exposed to hot conditions drink less fluid than needed because of an insufficient thirst. DO NOT DEPEND ON THIRST TO SIGNAL WHEN AND HOW MUCH TO DRINK. For an 8-hour workday, 50 ounces of fluids should be drunk. • Eat lightly salted foods or drink salted drinks such as Gatorade to replace lost salt. • Save most strenuous tasks for non-peak heat hours such as the eariy morning or at night. • Avoid alcohol during prolonged periods of heat. Alcohol will cause additional dehydration. • Avoid double shifts and/or overtime. The implementation and enforcement of the above nrientioned measures will be the joint responsibility of the project manager, on-site field coordinator, and health and safety officer. Potable water and fruit juices should be made available each day for the field team. Heat Stress Monitorinq Techniques Site personnel should regulariy monitor their heart rate as an indicator of heat strain by the following method: Check radial pulse rates by using fore-and middle fingers and applying light pressure to the pulse in the wrist for one minute at the beginning of each rest cycle. If the pulse rate exceeds 110 beat/minute, shorten the next work cycle by one-third and keep the rest period the same. If, after the next rest period, the pulse rate still exceeds 110 beats/minute, shorten the work cycle by one-third. The procedure is continued until the rate is maintained below 110 beats/minute. 5.16.2 Cold Stress Types of Cold Stress Cold injury is classified as either localized, as in frostbite, frostnip or chilblain; or generalized, as in hypothermia. The main factors contributing to cold injury are exposure to humidity and high winds, contact with wetness and inadequate clothing. The likelihood of developing frostbite occurs when the face or extremities are exposed to a cold wind in addition to cold temperatures. The freezing point of the skin is about 30o F. When fluids around the cells of the body tissue freeze, skin turns white. This freezing is due to exposure to extremely low temperatures. As wind velocity increases, heat loss is greater and frostbite will occur more rapidly. Svmptoms of Cold Stress The first symptom of frostbite is usually an uncomfortable serisation of coldness, followed by numbness. There may be a tingling, stinging or aching feeling in the effected area'. The most vulnerable parts of the body are the nose, cheeks, ears, fingers and toes. Symptoms of hypothermia, a condition of abnormally low body temperature, include uncontrollable shivering and sensations of cold. The heartbeat slows and rnay become irregular, the pulse weakens and the blood pressure changes. Pain in the extremities and severe shivering can be the first warning of dangerous exposure to cold. Maximum severe shivering develops when the body temperature has fallen to 95o F. Productive physical and mental work is limited when severe shivering occurs. Shivering is a serious sign of danger. Immediately remove any person who is shivering from the cold. .J:\Proi6ct\Georgia-Pacific\03060-062MilfordCV 5-15 . April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07,doc ' • ENSR Methods to Prevent Cold Stress When the ambient temperature, or a wind chill equivalent, falls to below 40o F (Anrierican Conference of Governmental Industrial Hygienists recommendation), site personnel who must remain outdoors should wear insulated coveralls, insulated boot liners, hard hat helmet liners and insulated hand protection. Wool mittens , are more efficient insulators than gloves. Keeping the head covered is very important, since 40% of body heat can be lost when the head is exposed. If it is not necessary to wear a hard hat, a wool knit cap provides the best head protection. A facennask may also be worn. Persons should dress in several layers rather than one single heavy outer garment. The outer piece of clothing should ideally be wind and waterproof. Clothing made of thin cotton fabric or synthetic fabrics such as polypropylene is ideal since it helps to evaporate sweat. Polypropylene is best at wicking away moisture while still retaining its insulating properties. Loosely fitting clothing also aids in sweat evaporation. Denim is not a good protective fabric. It is loosely woven which allows moisture to penetrate. Socks with a high wool content are best. If two pairs of socks are worn, the inner sock should be smaller and made of cotton, polypropylene or similar types of synthetic material that wick away moisture. If clothing becomes wet, it should be taken off immediately and a dry set of clothing put on. If wind conditions become severe, it may become necessary to shield the work area temporarily. The SSO and the PM will determine if this type of action is necessary. Heated break trailers or a designated area that is heated should be available if work is performed continuously in the cold at temperatures, or equivalent wind chill temperatures, of 20o F. • Dehydration occurs in the cold environment and may increase the susceptibility of the worker to cold injury due to significant change in blood flow to the extremities. Drink plenty of fluids, but limit the intake of caffeine. Workinq on the Water in Cold Environments If water temperatures are below 50°F, an insulated Mustang flotation suit shall be worn to protect against thermal shock and/or hypothermia. 5.17 Sun Exposure Employees are encouraged to liberally apply sunscreen, with a minimum sun protection factor (SPF) of 15, when working outdoors to avoid sunburn and potential skin cancer, which is associated with excessive sun exposure to unprotected skin. Additionally, employees should wear safety glasses that offer protection from UVA/UVBrays. 5.18 Biological hazards The time critical actions are being implemented in the early spring and will end in late fall. The hazards associated with poisonous plants and insects will be a concern due to the vegetative growth present at the site, and the fact that a significant amount of trees and other vegetation is being removed tp enhance access to the river. The site provides animal habitat so there is a remote chance the wild animals, perhaps rabid, would be encountered. 5.18.1 Poisonous Plants Persons working on the site should be aware of the possible presence of poisonous plants and insects. Poison ivy is a climbing plant with leaves that consist of three glossy, greenish leaflets. Poison ivy has conspicuous red foliage in the fall. Small yellowish-white flowers appear in IVlay through July at the lower leaf axils of the plant. White berries appear from August through November. Poison ivy is typically found east of the Rockies. Poison oak is similar to poison ivy but its leaves are oak-like in form. Poison oak occurs mainly in the south and southwest. Poison sumac typically occurs as a small tree or shrub and may be 6-20 feet in height. The J:\Proiect\Georgia-Pacific\0306'o-062 Milford cv 5-16 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR bark is smooth, dark and speckled with darker sfDots. Poison sumac is typically found in swampy areas and "; east of the Mississippi. The leaves have 7-13, smooth-edged leaflets and drooping clusters of ivory-white berries appear in August and last through spring, • The leaves, roots, stems and fruit of these poisonous plants contain urushiol: Contact with the irritating oil ' causes an intensely itching skin rash and characteristic, blister-like lesions. The oil can be transmitted on soot particles when burned and rriay be carried on the fur of animals, equipment and apparel. Proper identification of these plants is the key to pre'i/enting contact and subsequent ddrrhatitis. Wear lorig sleeves and pants when working'in wooded areas. In areas of. kriown infestation, wear Tyvek coveralls and gloves. Oils are easily transferred from one surface to another. If you come in contact with these poisonous ' plants, wash all exposed areas immediately with coorwater to remove the oils. Some connmercial products such as Tecnu's Poison Oak-n-lvy Cleanser claim to further help with the removal of oils. 5.18.2 Ticks Ticks are bloodsuckers, attaching themselves to warm-blooded vertebrates .to feed. Deer ticks; are associated with the transmission the bacteria that causes Lyme disease. Female deer ticks are about one-quarter inch in length and are black and brick red in color. Males are smaller and all black. If a tick is not removed, or if the tick is allowed to remain for days feeding on human blood, a condition known as tick paralysis can develop. This is due to a neurotdxiq, which the tick apparently injects while engorging. This neurotoxin acts upon the spinal cord causing lack of coordination, weakness and paralysis. . - " ' The early stages of Lyme disease, which can develop within a week to a-few weeks ofthe tick bite, are usually marked by one or more of these signs and symptoms: Tiredness v Chills and fever' Headache , . Muscle and/or joint pain. ' ' , , ' ' Swollen lynnph glands • • • Characteristic skin rash (i.e. bulls eye rash) Tick season lasts from April through October; peak season is May through July. Y,ou can reduce your risk by taking these Precautions: • During outside activities, wear long sleeves and long pants tucked into socks;. Wear a hat, and tie hair back. . " • • • . • Use insecticides to repel or kill ticks. Repellents containing the compound DEET can be used on exposed skin except for the face, but they do not kill ticks and are not 100% effective in discouraging ticks from biting. Products containing permethrin kill ticks, but they cannot be used on the skin - only on clothing. When using any of these cherinicals, follow label directions carefully. • After outdoor activities, perform a tick check. Check body areas where ticks are commonly found: behind the knees, between the fingers and toes, under the'arms, in and behind the ears, and on the neck, hairline, and top of the head. Check places where clothing presses on the skin. • Remove attached ticks promptly. Removing a tick before it has been attached for more than 24 hours greatly reduces the risk of infection. Use tweezers, and grab as closely to the skin as possible. Do . .not try to remove ticks by squeezing them, coating them with.iDetroleum jelly, or burning them with a ' match. '::/' '-. " J:\Project\Georgia-Pacific\03060-062 Milford CV 5-17 April 2007 Landfill\WorkPlan\FINAL-April200AENSR-HASP-Final- Apriip7.doc '. , ' ENSR • Report any of the above symptoms and all tick bites to the SSO for evaluation. 5.18.3 Mosquito-Borne Illnesses 5.18.3.1 Eastern Equine Encephalitis Eastern equine encephalitis is a rare disease that is spread to horses and humans by infected mosquitoes. It is among the most serious of a group of mosquito-borne virus diseases that can affect the central nervous system and cause severe complications and even death. Although relatively small outbreaks of human disease have occurred in the United States, the frequency of this disease is increasing with most cases reported from the eastern seaboard states, the Gulf Coast, and some inland mid-western areas. After infection, the virus invades the central nervous system, including the spinal cord and brain. Most people have no symptoms; others get only a mild flu-like illness with fever, headache, and sore throat. For people with infection of the central nervous system, a sudden fever and severe headache can be followed quickly by seizures and coma. About half of these patients die from the disease. Of those who survive, many suffer permanent brain damage and require lifetime institutional care. Symptoms usually appear 4 to 10 days after the bite of an infected mosquito. Confirming diagnosis is based on tests of blood or spinal fluid. 5.18.3.2 West Nile Virus West Nile encephalitis is an infection of the brain caused bythe West Nile virus, which is transmitted by infected mosquitoes. Following transmission from an infected mosquito. West Nile virus multiplies in the person's blood system and crosses the blood-brain barrier to reach the brain. The virus interferes with normal central nervous system functioning and causes inflammation of the brain tissue. However, most infections are mild and symptoms include fever, headache and body aches. More severe infections may be marked by headache, high fever, neck stiffness, stupor, disorientation, coma, tremors, convulsions, muscle weakness, paralysis and rarely, death. Persons over the age of 50 have the highest risk of severe disease. Prevention centers on public health action to control mosquitoes and on individual action to avoid mosquito bites. To avoid being bitten by the mosquitoes that cause the disease, use the following control measures: • If possible, stay inside between dusk and dark. This is when mosquitoes are most active. • When outside between dusk and dark, wear long pants and long-sleeved shirts. • Spray exposed skin with an insect repellent, preferably containing DEET. 5.18.4 Bees Wasps (hornets and yellow-jackets) and bees (honeybees and bumblebees) are common insects that may pose a potential hazard to the field team if work is performed during spring, summer or fall. Bees normally build their nests in the soil. However, they use other natural holes such as abandoned rodent nests or tree hollows. Wasps make a football-shaped, paper-like nest either below or above the ground. Yellow-jackets tend to build their nests in the ground but hornets tend to build their nests in trees and shrubbery. Bees are generally more mild-mannered than wasps and are less likely to sting. Bees can only sting once while wasps sting multiple times because their stinger is barbless. Wasps sting when they feel threatened. By remaining calm and not annoying wasps by swatting, you lessen the chance of being stung. When a wasp stings, it injects a venomous fluid under the skin. The venom causes a painful swelling that may last for several days. If the stinger is still present, carefully remove it with tweezers. Some people may develop an allergic reaction (i.e. anaphylactic shock) to a wasp or bee sting. If such a reaction develops, seek medical attention at once. 5.18.5 Rabid Animals The site provides animal habitat so there is a remote chance the wild animals, perhaps rabid, would be encountered. Rabies is a viral disease of the brain and spinal cord that affects warm blooded animals, such as J:\Project\Georgia-Pacific\03060-062MilfordCV 5-18 April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR dogs, cats, horses, cattle and wild animals like deer, raccoons and skunks. Raccoons remain the most frequently reported rabid animal in the United States especially in the northeastern, mid-Atlantic and southeastern states. : ' The rabies virus causes the affected animal to become very aggressive and feariess. Behaviors exhibited by rabid animals include: • , • Daytime activity in animals normally active only at night: • Aimless roaming during which the animal becomes very irritable, often biting at anything that moves. • Excessive saliva ardurid the mouth that looks like it is-foaming around the mouth"; • Staggering, weakness and paralysis. Do not approach a rapid animal; Walk away quickly from the animal and go to a protected place where you can contact the local animal control officer. Do not try to trap trie animal yourself. 5.18.6 Snakes ^ There are nunrierous non-poisonous snakes that are. present in Hunterdon County with two species of poisonous snakes known to live in the area of the site. These include: • Northern Copperhead • Timber Rattlesnake The Northern Copperhead favors rotting woodpiles in rocky, wooded areas that are usually mountainous. They are active from May through October. The copperhead is 24"^36" long. It is red-brown in coloration with darker hourglass bands. This snake is easily camouflaged in the leaf litter of the forest floor. Small, dark spots are frequently present between the crossbands and dark, rounded spots can be seen at the sides of its belly. The timber rattlesnake ranges from 36" to 60" in length. In northern New Jersey, the timber rattlesnake is found in rocky, wooded ledges where they den in south-facing slopes. They are active from May through October. There are two color variations of this snake in New Jersey: the yellow variation and the black variation. The yellow variation is characterized with black or dark brown crossbands on a ground color of yellow or brown witfi the crossbands being V-shaped that break up into spots down its back. The black variation is characterized by a heavy stippling of black or very dark brown that hides the much lighter pigment. Rattlesnakes and copperheads belong to the family of pit vipers. The venom of these snakes affects the circulatory system. The bite of a pit viper is characterized by extreme pain, rapid swelling, one or more puncture wounds created by the fangs, and is marked by a general discoloration of the skin. Manifestations of envenomation include general weakness, rapid pulse, nausea and vomiting, shortness of breath, dimness of vision of shock. , • To reduce the chances of being bitten by a snake, the following procedures should be followed: • Never bend down to ttie ground or sit on the ground before checking your surroundings for the preserice of snakes • Never put your unprotected hand or foot into a closed space that you cannot check for the presence of hidden snakes. • Wear knee-high boots or leggings to help protect from snake bites. - J:\Project\Georgia-'Pacific\03060-062 IVlilford cv ,. .; 5-19 April 2007 Landfill\WorkPlan\FINAL-April200AENSR-HASP-Final-. . , April07.ddc ENSR 5.19 Inclement Weather Work is expected to begin in the spring of 2007 and proceed through the fall of 2007. It is therefore important to have a response plan in place that dictates what actions site employees will take in the event of severe weather, specifically severe thunderstorms. . ' When a severe thunderstorm is approaching, employees will only have a short amount of time to make important decisions. Employees do not have access to consistent and current news information via the television or radio when working in the field. To ensure the field team is alerted to the onset of severe weather, the project team will be issued a battery-operated National Oceanic and Atmospheric Administration (NOAA) weather radio. The radio will be equipped with an alarm that will automatically broadcast any pertinent information from NOAA's National Weather Service. Via the radio, the team will be aware of any severe thunderstorm and/or tornado watches or warnings that have been issued for their work area by the National Weather Service. It is important for field team members to understand the difference between a "watch" and a "warning". If a severe thunderstorm watch is issued for your work or travel area, it nieans that a severe thunderstorm is possible. If a severe thunderstorm warningjs issued, it means that a severe thunderstorm has actually been spotted or is strongly indicated on radar and it is time to seek safe shelter immediately. Weather broadcasts are typically issued for specific counties, not individual towns. The project site is located in Hunterdon County. Additionally, employees should become familiar with the names of the counties through which they must travel when mobilizing/demobilizing from their assigned work location, in the event that a broadcast is issued for those counties. If a severe thunderstorm watch is issued, employees must remain alert for approaching storms and review the procedures for seeking refuge in the event that a warning is issued. If a severe thunderstorm warning is issued, employees will take the following measures: • If you hear thunder, you are close enough to a storni to be struck by lightning. Cease all work and seek shelter, either a sturdy building or car, immediately. Do not take shelter in small sheds, under isolated tress or in convertible automobiles. Avoid trees as they are targets for lightning. If in.a car, keep the windows up. • If you are caught outside during a thunderstorm and no shelter is available, find a low spot away from trees, fences and poles. Squat low to the ground on the balls of your feet, place your hands on your knees with head between them. Make yourself the smallest target possible and minimize your contact with the ground. • J:\Proiect\Georgia-Pacific\03060-062 Milford CV 5-20 April 2007 LandfiH\WorkPlan\FINAL-April2007\ENSR-HASP-Final- Aoril07.doc ENSR 6.0 Air Monitoring The primary contaminants of concern during the excavation activities associated with the construction of the reinforced wall will be PAHs and metals. However, exposure to PAH and metal-containing dusts is expected to be minimal due to the wet nature of the area where, the work is being conducted. Exposure to VOCs is more likely to be a concern during drum handling/samplirig operations with exposure being highest if drums • containing liquid wastes are encountered. 6.1 Direct Reading Instrumentation Instrument 1 - RaeSystems Mini-Rae 2000 F'lD with a 10.6 ev lamp ; Although exposures to VOCs are not anticipated during the construction of the retaining w'all, a RaeSystems Mini-Rae 2000 PID with a 10.6 ev lamp will be used to monitdr the breathing zone of personnel during this work as well as the drum handling and sampling operations where exposure to VOCs is expected to be more of a concern.' If the PID indicates sustained (15 minute) breathing zone vapor concentratioris in excess of 5 uhits or more above background, respiratory protection, as described in Section 7.2 of this document, will be donned- This- action level is based on EPA protocol and is'not a site-specific action limit. In accordance yvith EPA protocol, if total VOC concentrations in the breathing zorie exceed 25 units above background, as indicated on the PID, the level of respiratory protection required will be raised. This action limit is based dn EPA protocol and is not a site-specific action limit. Instrument 2 - MIE Data-Ram total dust monitor, or its equivalent, MIE Data-Ram total dust monitor, or its equivalent, will be used to determine when engineering coritrols are required to control dust, to determine the efficacy of thosfe measures and to determine if respiratory protection is required in addition to implementing engineering controls. The total dust monitor will be used to determine that total diist levels within the established work areas are maintained below the action level. The readings will be taken at the locations within the restricted area,.and during the time periods, which are likely to represent worst case conditions. The determination of worst case will be made by the SSO and will be dependent upon such variables as the type of .wot'k being performed and number of personnel or level of activity in the zone If total dust levels are sustained (15 minutes) in the worker's breathing zone at levels exceeding 1mq/m3, the contractor will be instructed to implement engineering controls. This iricludbs applying a water spray from a water truck or temporary water storage tank to minimize dust levels. If engineering Controls are unsuccessful at reducing dust levels below the action limit of 1 mg/m3. Level C respiratory protection will be donned. If dust levels should be sustained at levels above 5 mg/m3. in the worker's breathing zone, additional engineering controls, such as the application of additional water, placement of additional stone or tracking pads (where applicable) will be implemented. If these additional measures are not adequate to reduce dust levels to below 5 mg/m3, Level B respiratory protection will be required. The total dust action limits of l mg/m3 and 5 mg/m3 are in accordance with EPA protocol arid are not site-specific action limits. Instrument 3 - Combination Oxyqen/Combustible Gas Indicator . , The Consultant will monitor the drum.storage and.drum sampling areas for the presence of flammable and potentially explosive atmospheres using a combination oxygen/combustible gas indicator. If the meter detects J:\Project\Georgia-Pacific\03060-062 MilfordCV •• 6-1 April 2007 Landfill\WorkPlan\FINAL-April200AENSR-HASP-Final- . . . April07.doc • • ENSR a flammable atmosphere (greater than 10% of the lower explosive limit) in these areas, drum sampling will cease until the SSO and RHSM can confer on how to safely proceed with the sampling operations. 6.2 Ionizing Radiation At the request of the EPA, the Consultant will screen the work areas for ionizing radiation. The Consultant will screen work areas using a Ludlum Model 19 MicroR survey meter or.equivalent gamma scintillation detector survey meter which is used for low level uR gamma surveys. In the unlikely event that radiation levels are detected at 5 milllRem (mR) above background, work will be temporarily suspended until the SSO and RHSM can evaluate the survey data and determine if existing site safety protocols are adequate or if additional survey/screening needs to be completed. 6.3 Personnel Exposure Air Sampling The Consultant is using direct reading air monitoring instrumentation to screen employee breathing zones for the presence of total VOCs and total dust throughout the program. If the data generated during this monitoring suggesits that employees are being consistently exposed to site contaminants above the established action limits, the Consultant may elect to perform personnel exposure monitoring for those employees at highest risk of exposure. The SSO and RHSM will make this determination and will inform the EPA On-Scene Coordinator if, and when, personnel exposure monitoring will be conducted. If such monitoring is conducted, appropriate NIOSH analytical methods will be used to collect and analyze the samples - . 6.4 Calibration and Recordkeeping Equipment used by the Consultant will be calibrated in accordance with the Consultant's standard operating procedures and/or the manufacturer's recommendations. All SOPS which include calibration procedures will ' be maintained on site in a dedicated binder to allow for easy assess by field staff. The SSO will maintain daily logs of PID, total dust, and CGI readings and radiological screening in a dedicated air monitoring field notebook. Daily calibration information will also be recorded in this field notebook. J:\Project\Georgia-Pacific\03060-062 Milford CV 6-2 April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR 7.0 Personal Protective Ecjuipment 7.1 Mandatory PPE The following safety gear will,be worn once employee leave the support zone: • Hard hat • • Safety glasses with sideshields • ANSI-approved Class 11 traffic vest • Steel-toed boots 7.2 Chemical Protective Clpthing Erosion Turbidity , Drum Control • Curtain . Well: Infrastructure Tree Barrier Wall Handling PPE Item Installation Installation Abandonrnent Construction Removal . Construction ' Sarnpling Hard hat ' . :"' • • • : ..V ./ • ' - , • Steel Toed • y ' • • Disposable Shoes - ' booties over or rubbersteel- toed boots Safety y • • . Glasses Steel-mesh- faceshield Faceshield Traffic Vest ' ^, '. ' ^ .t Hip Vyaders ^. (, PFD .V • Chain saw chaps Kevlar gloves • • • Chemically- resistant -. • ' ^'. gloves Polycoated • • tyvek • • -'; • " ,. •. . v ./ ••' Hearing Protection / • • ' 7.3 Respiratory Protection The primary contaminants of concern during the excavation activities associated with the construction of the retaining wall will be PAHs and metals. However, exposure to PAH and metal-containing dtists is expected to be minimal due to the wet nature of the area where the work is being conducted. Exposure to VOCs is more likely to be a concern during drum handling/sampling operations on/from the top of the landfill. Exposure will •be highest if drums containing liquid w/astes.are ericountered. J:\Project\Georgia-Pacific\03060-062 Milford CV . . 7-1 ' April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASF'-Final- April07.doc ENSR 7.3.1 Barrier Wall Construction Activities The Consultant will perform air monitoring in the worker's breathing zone to determine exposure to VOC vapors during fhe wall construction activities. In accordance with EPA protocol, if fhe PID indicates sustained (15 minutes) breathing zone concentrations of 5-25 units. Level C respirators will be donned. If total dust levels are sustained (15 minutes) in the worker's breathing zone at levels exceedinq 1mq/m3, the contractor will be instructed to implement enqineerinq controls. This includes applying a water spray from a water truck or temporary water storage tank to minimize dust levels. If engineering controls are unsuccessful at reducing dust levels below the action limit of 1 mg/m3. Level C respiratory protection will be donned Level C Specification: Half-mask air-purifying respirator with combination organic vapor cartridges and P-100 filters. In accordance with EPA protocol, if total VOC concentrations in the breathing zone exceed 25 units above background, as indicated on the PID, Level B respiratory protection will be required. If dust levels should be sustained at levels above 5 mg/m3 in the worker's breathing zone, additional engineering controls, such as the application of additional water,, placement of additional stone or tracking pads (where applicable) will be implemented. If these additidnal measures are not adequate to reduce dust levels to below 5 mg/m3. Level B respiratory protection will be required. The type of Level B respiratory equipment to be used is provided in the discussion below regarding drum handling. 7.3.2 Drum Handling Although information from previous drum removal efforts suggests that the types of waste streams that may be encountered in the landfill are defined, drums encountered throughout the course of this project will be treated as unknowns, requiring the use of Level B protective equipment. For this program, a supplied air-line system (cascade system) that can be transported across the site as drums are uncovered, will be used. This system will be used by the ground crews that are supporting the equipment operators. Additionally, each equipment operator participating in the drum removal activities will have a dedicated airline system attached to the equipment. Operators will immediately don respiratory protection when a drum is uncovered and has been determined by the ground crew to be intact. A dedicated airline system will also be established at the drum sampling pad to support drum sampling and waste bulking operations. Each system will be the pressure-demand type and each operator will be equipped with an emergency escape bottle. Care will be taken as to the positioning of the system to ensure that vehicular traffic will not cross over or stop on the air supply lines leading from the breathing air bottle bank to the manifold. Additionally, the length of hose from the bottle bank to the manifold will be limited to 300 feet. All air hoses used through the landfill will be placed in a protective/disposal covers. 7.3.3 Fit Testing Employees who are expected to don respirators must have successfully passed a fit-test within the past year for the brand, model and size respirator they plan to wear on this program. 7.4 Other Safety Equipment The following additional safety items should be available at the site and located in the site trailer, contamination reduction zone (CRZ) or at individual work locations if appropriate: • Portable, hand-held eyewash bottles J:\Project\Georgia-Pacific\03060-062 Milford CV 7-2 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR First aid kit Insect repellant Sunscreen with SPF 15 Type A-B:C fire extinguisher (on machinery and in drum storage area) Spill response supplies Air horns Portable phones/radios J;\Project\Georgia-Pacific\03060-062 Milford CV 7-3 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-'Final- April07.doc . ENSR 8.0 Site Control 8.1 Site Access/Egress The primary access/egress to the landfill is via a gated entrance (Gate # 1) approximately 0.5 mile down a dirt road located immediately off of Milford-Frenchtown Rd. The Consultant's construction trailer is located immediately within the gated area (i.e. Support Zone). All site personnel must sign in and out at the project trailer on a daily basis. Once on site, a dirt/stone road leads directly to the river. Additionally, there is an access road that gradually leads from the top of the landfill to the toe of the slope of the landfill. The existing construction road is being augmented to provide access for construction and material handling equipment in the northern section of the landfill! A second access/egress point is available at Gate 2,. which is located just north of Gate 1 or at Gate 3 which is located at the northern most section of the landfill. The Consultant will post signs at the entrances to the site that warn of the hazards associated with site operations and that access to the site is limited to authorized personnel only. Additional signs directing visitors to the site trailer will also be erected at the entrance to the site. All visitors must sign in and out at the project trailer. Any unauthorized visitors will be reported to the site superintendent. In general site hours of operation during implementation of the Work Plan may extend from 0600 hours to 2000 hours. During non-operational hours the access gate to the Support Zone will be secured (locked). Road access to the site will be chained and/or posted as "Closed". All equipment will be staged in the designated staging area. Road access to the site will be chained and/or posted as "Closed". 8.2 Designation of Zones To prevent both exposure of unprotected personnel and migration of contamination due to tracking by personnel or equipment, hazardous work areas will be cleariy identified and decontamination procedures will be required for personnel and equipment leaving those areas. The Consultant designates work areas or zones as suggested in the "Occupational Safety and Health' Guidance Manual for Hazardous Waste Site Activities," NIOSH/OSHA/USCG/EPA, November 1985. They recommend that the areas surrounding each of the work areas to be divided into three zones: • Exclusion or "Hot" Zone • Contamination Reduction Zone (CRZ) • Support Zone 8.2.1 Exclusion Zone 8.2.1.1 General . Access to the site is gained via Gate 1. The support zone, located immediately inside the gate, includes the trailer area and the proposed material staging area. Immediately adjacent to the material staging area is the decontamination area. The exclusion zone for this program includes all the landfill areas located beyond the proposed decontamination pad as well as the riverfront. Signs will be installed at the main entrance of the exclusion zone to alert personnel of PPE and training requirements. All personnel entering an exclusion zone J:\Project\Georgia-Pacific\03060-062 MilfordCV 8-1 April 2007 Landfill\WorkPlan\FINAL;April2007\ENSR-HASP-Final- April07.doc ENSR must wear the prescribed level of personal protective equipment and meet the training and medical requirements as oijtlined in Section 10 of this HASP. ' 8.2.1.2 Drum/Waste Storage and Sampling Pads An approximately 7,500 square foot area will be prepared fdr drum storage and sampling;-A one-foot berm will be constructed around the perimeter of the drum storage pad': Geotextile fabric will be placed over the prepared subgrade and perimeter berm with a 40-mil liner being placed over the geotextile fabric. A second layer of geotextile will be placed over the liner. Six inches of cushion sand will be placed over'the fabric and a six-inch layer of road gravel will be placed over the cushion. The actual dimensions of the drum storage and sampling pad will be dictated by site conditions. 8.2.2 Contamination Reductipn Zone _ A formal decontamination zone is being established adjacent to the material staging area. This area will include a personnel decpntamination area and an equipment decontamination area. The details of both decon areas as provided in Section 9.0 of this HASP. Due to the size of the site, it rriay be necessary to establish mini-decon areas especially within the immediate drum handling areas in the event that employees need to remove contaminated PPE immediately as a result of the release of material from a drum or container. 8.2.3 Support Zone The support zone consists of the command post trailer area, sanitation facilities and a materials staging area. 8.2.3.1 Command Post Trailer The main access to the site will be via Gate 1. All employees,.agency representatives and visitors to the site will use this gate to gain access to the site. Immediately upon entering the site, employees, agency representatives and visitors to the site, as well as all delivery personnel, will report to the construction trailer,. Everyone will be required to sign the log-in book located in the trailer and participate in a site safety briefing with the SSO before leaving trte support zone and entering any active work area. Based on the amount of. construction activity that is taking place at the site, all employees, agency representative and visitors to the site who want to access yvork areas must minimally dpn the following safety gear once they have left the support zone of the site: • Hard hat " • Safety glasses with sideshields • * ., • ANSI-approved Class 11 traffic vest or equivalent • Steel-toed boots . A first aid station will-be located inside the site trailer. The station will include a wall-mounted 25-person first aid kit and a gravity fed eyewash station capable of 15-minute flushing, Smaller first aid kits and portable eye wash bottles will be co-located with the fire extinguishers as discussed in Section 8.3. Minimally, the SSO will be first.aid and CPR trained. The SSO.is ailso trained in accordance with OSHA's Control of Exposure to Bloodborne Pathogens standard 8.2.3.2 Sanitation Facilities Sanitation facilities will be located within the support zone. Potable water will be available within the site trailer via a water cooler. Potable water will be delivered to tfie trailer as needed. Liquid soap and towels will also be available in the trailer.' •J:\Pfoject\Georgia-Pacific\03060-062 Milford CV 8-2 April 2007 Landfil!\WorkPlan\FINAL-April2007\ENSR-HASP-Final-' April07.doc J • ENSR 8.2.3.3 Materials Staging Area A material staging area is being constructed directly south of the current location of the site trailer. This area will encompass approximately 1 acre. Once grubbing operatipns jn this area are complete, a geotextile fabric will be placed on the prepared sub-grade. The fabric will thenibe covered with puarry stone.' Truck traffic will be routed into the riortheast corner of the nevyly constructed material staging area. Materials will be dropped in this area and stockpiled for subsequent movement into the site. Equipment working in the materials staging area will remain in this clean zone throughout materials loading operations. A gate will be installed in the site fence near the northwest corner of the material staging area. This will allow materials . transportation equipment to remain in the exclusion zone'and not have to enter the materials staging area which is a designated clean zone, this operation will eliminate the need to decontaminate material transportation equipment that would otherwise have to enter the material staging area during loading operations. 8.3 Fire Extinguisher Locations Minimally, portable. Type A-B:C fire extinguishers will be located in the following areas: Each active work area including eacfi drum opening area Drum/waste storage area Decontamination Zone Material staging area and equipment refueling area Site Trailer , 8.4 General Site Safety Practices The following measures are designed to augment the specific health and safety guidelines provided in this plan.. . - • All work will be conducted under the buddy system. • Eating, drinkirig, chewing gum or tobacco, smoking or any practice that increases the probability of hand-to-mouth transfer and ingestion of materials is prohibited in the immediate work area and the decontamination zone. Due to the significant issues related to heat stress, there will be a designated areas within the work zone set up as a drinking station. A cooler with a closed top and a closed top cup dispenser will be made available to employees. Smoking is prohibited in all work areas. Matches and lighters are not allowed. There' be one designated smoking area located at the site trailer within the Support Zone. Hands and face must be thoroughly washed upon leaving the work area and before eating, drinking or any other activities. , • • Beards or other facial hair that interfere with respirator fit are prohibited. The use of alcohol or illicit drugs is prohibited during the conduct of field operations. All equipment must be decontaminated or properly discarded before leaving the site in accordance with the project work plan. J:\Project\Georgia-Pacific\03060-062 Milford CV 8-3 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final-. April07.doc ENSR 8.5 Site Communications in addition to cellular phones to facilitate contact with local emergency providers and the Consultant and/or . FJOC Project Managers, the Consultant team will be equipped with portable radios to enhance on-site communications with each other and with EPA's on-site representatives. This is important as line-of-sight contact can not be maintained between the on-site trailer and the bank of the river. Additionally, the construction foreman, SSO and SS will carry air horns that will be used to signal an emergency to the rest of the field team: The signals to be used in the everit of an emergency are discussesd in more detail in Section 11.2. - - • ,;'":•• • •, 8.6 Off-Site Traffic Control During on-site mobilization', the Consultant will meet with local officials to deterniirie what type of traffic coritrol should be implemented during periods of peak construction traffic from the niain road into the site. This'may include the use of a flagger and/or the placement of DOT-approved signs to warn motorists, of constructiori. traffic, Agreed upon control Pleasures will be added to this. HASP . J:\Pro)ect\Georgia-Pacific\03060-062 Milford:CV • 8-4 - - -;' ' April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- • , ' April07.doc ' . •, ., • . • ENSR Detawae River J:\Projecl\Georgia-Pacific\03060-062 Milford CV 8-5 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR 9.0 Decontamination/Sample Shipment 9.1 Personal Decontamination During all field operations, personnel will pass through the contamination reduction zone while entering or exiting the exclusion zone. The CRZ may include tfie following components: ( .• Trash containers for disposal of PPE • Decontamination tubs consisting of: - A pre-rinse tub containing water - A cleaning tub containing water and cleaning detergent - A post cleaning rinse tub containing water • Long-handled scrub brushes • A table for safety equipment and accessories The CRZ will be cordoned off with orange, temporary security fence and underiain with road gravel. Decontamination procedures will include: Remove overboots prior to entering CRZ, or discard disposable booties or wash/rinse outer boots Remove and discard outer PPE such as Tyvek coveralls Remove and discard outer glove Remove respirator, if worn, and dispose of cartridges as applicable . Wasti/rinse respirator and hang to air dry Remove hard hat Remove and dispose of inner gloves All disposable PPE will be containerized and disposed of off-site in the same manner as all investigation- derived wastes (IDW). Waste disposal practices are discussed in further detail in the Transportation and Disposal Plan. This plan is Appendix 3 in the Work Plan for the slope stabilization measures program. 9.2 Large Equipment Decontamination An equipment decontamination pad will be constructed within the exclusion zone. The pad will be approximately 20' x 20' in size with a sump constructed in one corner of the pad. The prepared sub-grade will be covered with a 40 ml HDPE liner. A six-inch layer of sand will be placed over the liner. Timbers will placed on the pad so tracked equipment can move in and across the pad. Equipment to be decontaminated will enter the pad from the gravel access road and cross over the timbers. Once on the pad, the equipment will be decontaminated using a steam cleaner. All water collected in the sump will be pumped into 55-gallon, USDOT approved drums and shipped off site for disposal following waste characterization analysis. 9.3 Sampling Equipment Decontamination On-site decontamination of sampling equipment may include the following: • Wash with non-phosphate detergent solution J:\Proiect\Georgia-Pacific\03060-062 MilfordCV 9-1 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR Rinse with tap water Rinse with distilled/deionized water Rinse with 10% nitric acid solution (if analyzed for metals) Rinse with distilled/deionized water Solvent rinse with acetone or hexane (pesticide grade), or other solvent, if analyzed for VOCs Allow to air dry completely Rinse again with distilled/deionized water 9.4 Sample Shipment It is anticipated that sample shipment by air and/or over land will be utilized for the shipment of soil, liquid and/or waste samples to laboratories and disposal facilities for waste profiling purposes. As discussed in the SAP under Section 3.11-"Sample Shipment," Department of Transportation (DOT) and/or International Air Transport Association (lATA) regulations will be followed for sample shipment. The Consultant has a well- defined hazardous materials shipping program and follows lATA requirements for all air shipments of hazardous materials. Based on field screening data, the Consultant will determine if the samples are hazardous and if so, the appropriate shipping name to assign to the samples (i.e. environmentally hazardous substance, liquid, n.o.s. or flammable liquid n.o.s.). The Consultant will ensure that all applicable package marking and labeling requirements are met and will ensure that the proper shipping papers are completed for each shipment. Only staff that has completed function-specific haz-mat shipping training will be authorized to ship hazardous samples from the site. J:\Project\Georgia-Pacific\03060-062 Miltord CV . 9-2 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR 10.0 Medical Monitoring and Training Requirements 10.1 Medical Monitoring All personnel performing activities covered by this HASP must be active participants in a medical monitoring program that complies with 29 CFR 1910.120(f). Each individual must have completed an annuaf surveillance examination and/or an initial baseline examination within the last year prior to performing any work on the site covered by this HASP. No site specific monitoring is required for the proposed time critical removal action program. All employees directly involved with the time critical actions must be prepared to provide the Consultant SSO with a copy of their annual medical clearance letter which clearly indicates that they have been medically cleared to wear respiratory protection. 10.2 Health and Safety Training 10.2.1 HAZWOPER All personnel performing activities covered by this HASP must have completed the appropriate training requirements specified in 29 CFR 1910.120 (e). Each individual must have completed an annual 8-hour refresher training course and/or initial 40-hour training course withiri the last year prior to performing any work on the sites covered by this HASP. One of the Consultant employee assigned to supervisory role during the proposed removal actions will be required to have successfully participated in the 8-hr supervisor training course. All employees directly involved with the time critical actions must be prepared to provide the Consultant SSO with copies of their HAZWOPER training certificates upon their arrival to the site. 10.2.2 First Aid/CPR At least one member of the construction crew must be currently certified in First Aid and CPR. Additionally, the Consultant's SSO will also be currently certified in First Aid and CPR. Copies of the contractors certificates must be provided to the Consultant SSO upon arrival to the site. 10.2.3 Pre-Entry Briefing Prior to the commencement of on-site activities, a pre-entry briefing will be conducted by the SSO to review the specific requirements of this HASP. Attendance of the pre-entry meetirig is mandatory for all personnel covered by this HASP and must be documented on the attendance form provided in Attachment C. HASP sign-off sheets should also be collected at the time of the pre-entry briefing. All documentation should be maintained in the project file. Specific topics that will be discussed during the.pre-entry briefing include: Discussion of site history Discussion of work scope Review of the potential hazards associated with contaminants of concern and how these potential hazards will be controlled Review of air monitoring requirements and action limits Review of PPE and engineering control requirements J:\Project\Georgia-Pacific\03060-062 Milford CV 10-1 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR • Discussion of the potential physical hazards associated with implementing scope of work • Review of emergency egress and hospital location/direction • Spill Response Procedures • Review of decontamination procedures The pre-entry briefing must be completed for each new employee before they begin work at the site. Contractors must notify the Consultant SSO, at least one day in advance, of any new employees that are being rotated into the project. This will ensure that the SSO is available to review the new employee's training paperwork and to conduct the required pre-entry safety briefing before the new employee gains access to the work areas. Short safety refresher meetings will be conducted, as needed, throughout the duration of the project. These safety meetings will likely be conducted in conjunction with the daily work schedule/progress meetings conducted by the contractor. 10.3 Visitor Requirements All visitors will sign in at the construction trailer. Visitors who do not have the requisite training and/or medical clearance information will be allowed into the work areas. However, these visitors will be escorted the Consultant's representative at all times and will at no time be permitted to enter a work area where respiratory protection is deemed necessary. As stated above, all employees, agency representative and visitors to the site who want to access work areas must minimally don the following safety gear once they have left the support zone of the site: • • Hard hat • Safety glasses with sideshields • ANSI-approved Class 11 traffic vest or equivalent • Steel-toed boots J:\Project\Georgia-Pacific\03060-062 Milford CV 10-2 ' April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR: 11.0 Emergency Response OSHA defines emergency resppnse as any "resppnse effort by ernplpyefes from outside the immediate release' area or by other designated.responders (i.e.,,mutual-aid groups, Idpal fire departments, etc.)„to an occurrence , which results, or is' likely to result iri an uncoritrolled release of,a hazardous substance." The Consultant personnel shall not participate in any emergency response where there are, potential safety or health hazards ' (i.e.,"fire; explosion, or chemical exposure). Tfi'e Consultant response actioris will.be linriited to, evacuation and medical/first aid as described vvithiri this sectiori below- As such this section is written to comply with the: requirementsof 29 CFR 1910:38(3);:-~ ^ . \ . V' ; The basic elennents of an. emergency evacuation plan include: ' . , Employee training, .• ' • ' Alarm systerns, ' •'.• •, . i . Escape roijtes. ' Escape procedures,'! Critical operationspr eqliipnient, . Rescue and medical duty assignments, •- ''',._ .Designation'of responsible parties, - , = Erriergency repdrting procedures and '•' ' Methods'to account for all eniployees after evacuation. 11^1 Empiloyee Training Employees must be instrijcted in the site-specific aspects of emergency evacuation. On-site refresh'er or' • update training is required anytime escape routes or procedures are modified or personnel assignrnents are ^changed. . , ',''•...;- :•:•-'','•, ''-'.: , - ' • 'V' ' , ' , • 11.2 Alarm Systems/Emergency Signals An emergency cpmmunication .system musf be iri.eff ect at-all sites. The most simple and effective emergency.' communication systern iri'many situations will be direct verbdlicommunications. Each site must be assessed at the time of initial site activity apd periodically as„the work progresses,,'Verbal communications must be , supplemented anytime voices cain not be clearly pet-ceived above ambient noise levels (i.e., noise from heavy -equipment; drilling rigs. backhpes, etc.) and anytime a clear-lirie-of-sight can not be easily maintained amongst all the Consultant personnel because'pf distance, terrain or other b^^ : In addition to cellular phones to facilitate;contact with local emergency providers and the Consultant and/or • FJOC Project Managers, the Consultant team will tie,equipped with'portable radios to enhance on-site communications with each other,and yvith EPA's on-site representatives. Due to expected high noise levels, verbal communications may not be adequate to warri employees of; hazards associated with the immediate work area. Verbal communications'will therefore be supplemented. The construction foreman, SSO arid'SS will carry air fiorns that ,will be used-to signal an emergency,to the rest of the field tearh below. These'signals will be reviewed with all staff during.the pre-entry briefing., • . J:\Project\Georgia-Pacific\03060-062 Milford CV., ''., 11-1 April 2007, LaridfimWorkPlari\FINAL-Ap'ril2067\ENSR-HASP-Final- April07,doc'. .. '' • . '- , ENSR • ONE HORN BLAST: GENERAL WARNING One horn blast is used to signal relatively minor, yet important events on-site. An example of this type of event would be a minor chemical spill where there is no immediate danger to life or health yet personnel working on- site should be aware of the situation so unnecessary problems can be avoided. If one horn blast is sounded, personnel must stop all activity and equipment on-site and await further instructions from the SSO. • TWO HORN BLASTS: MEDICAL EMERGENCY Two horn blasts are used to signal a medical emergency where immediate first aid or emergency medical care is required. If two horn blasts are sounded, all first-aid and/or CPR trained personnel should respond as appropriate, all other activity and equipment should stop and personnel should await further instructions from the SSO. - . THREE HORN BLASTS FOLLOWED BY ONE CONTINUOUS BLAST: IMMEDIATE DANGER TO LIFE OR HEALTH Three horn blasts followed by another extended or continuous horn blast signals a situation that could present an immediate danger to the life or health (IDLH) of all personnel on-site. Examples of possible IDLH situations could include fires, explosions, hazardous chemical spills or releases, hurricanes, tornadoes, or floods. If three horn blasts followed by a continuous blast are sounded, all activity and equipment must stop, all personnel must evacuate the site to an appropriately designated site located outside the site gate or further off-site if , necessary. (Note: Unless otherwise specified, all decontamination procedures must be implemented). 11.3 . Escape Routes and Procedures The escape route from the property will be via landfill access roads to Gate # 1 located in the southeast portion of the site near the command post trailer/support zone or Gate # 3 at the northwest corner of the site. Both gates lead to the dirt road that leads to Milford-Frenchtown Rd. The escape routes and assembly areas will be reviewed during the pre-entry briefing. All personnel on site are responsible for knowing the escape route from the site and where to assemble after evacuation. If site evacuation is required, the SSO will serve as the Site Marshall. The SSO will use the daily site sign- in/sign-out book to verify that all site occupants have successfully evacuated the site and have been accounted for at the assembly point. The SSO will be the primary contact with emergency responders who arrive on the scene and will report the results of the evacuation/headcount to the chief agency coordinating the response effort. 11.4 Rescue and Medical Duty Assignments The SSO and SS are properiy trained to respond to minor chemical emergencies. If such an emergency arises on site, the SSO and SS will don self-contained breathing apparatus (SCBA) and Level B protective clothing to enter the emergency area, assess the situation via the use of direct-reading air monitdring instrumentation that is being used on site and cordon off the area as necessary. J:\Project\Georgia-Pacific\03060-062 Milford CV 11-2. April 2007 Landfill\WorkPlan\FINAL-April2007\EI^SR-HASP-Final- April07.doc ENSR Two full-charged 45-minute SCBAs will be available in the support zone for response to minor chemical emergencies. Additional response gear, including Saranax suits and nitrile gloves will also be kept on site. This equipment will be located in the site trailer. Additionally, the Consultant plans to meet with local emergency responders as part of our site mobilization effort, to determine their ability to respond to an on-site emergency that may involve exposure to chemicals. If il is determined that local resporiders can not assist on-site responders during such an emergency, the Consultant will contact other local town and/or country response teams. If no local responders have the capability to respond to a chemical emergency, the Consultant will contract additional emergency response services to an outside firm with tfie requisite training and equipment. The phone, numbers of the police and fire departments, ambulance service, local hospital, and the Consultant representatives are provided in the emergency reference sheet. This sheet will be posted in the site trailer located in the support zone of the site. In the event an injury or illness requires more than first aid treatment, the SSO will accompany the injured person to the medical facility and will remain with the person until release or admittance is determined. The escort will relay all appropriate medical information to the on-site project manager and the RHSM. If the injured employee can be moved from the accident area, he or she will be brought to the CRZ where their PPE will be removed. If the person is suffering from a back or neck injury the person will not be moved and the requirements for decontamination dp not apply. The SSO must familiarize the responding emergency personnel about the nature of the site and the injury. If the responder feels that the PPE can be cut away from the injured person's body, this will be done on-site. If this not feasible, decontamination vvill be performed after the injured person has been stabilized. 11.5 Designation of Responsible Parties The SSO is responsible for initiating emergency response, In the event the SSO can not fulfill this duty, the alternate SSO will take charge. 11.6 Employee Accounting Method The SSO is responsible for identifying all personnel on site'at all times. This will be done via the daily site sign-in/sign-out book that will be located in the Site Trailer. If site evacuation is required, the SSO will use the daily site sign-in/sign-out book to verify that all site occupants have successfully evacuated the site and have been accounted for at the assembly point. 11.7 Accident Reporting and Investigation Any incident (other than minor first aid treatment) resulting in injury, illness or property damage requires an accident investigation and report. The investigation should be conducted as soon as emergency conditions are under control. The purpose of the investigation is not to attribute blame but to determine the pertinent facts so that repeat or similar occurrences can be avoided. An'accident investigation form is presented in Attachment E of this HASP. The injured Consultant employee's supervisor and the RHSM should be notified immediately of the injury. If a subcontractor is injured, s/he should report to their supervisor immediately who must report the injury to the Consultant SSO. (3 J:\Project\Georgia-Pacific\03060-062.MilfordCV 11-3 April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc . ENSR EMERGENCY REFERENCES Ambulance: 911 Fire: 911 Police: 911 Medical Services: 908-859-6700 Warren Hospital 185 Roseberry St - Phillipsburg Directions to Hospital: Head northwest on CO Hwy 619. Go 0.9 miles and then go straight onto CO Hwy 519. Go 6.0 miles and go right to stay on CO Hwy 519. Go 0.3 miles and turn right onto CO Hwy 639. Go less than 0.1 mile and turn left onto unnamed street. Go less than 0.1 miles and go straight on County Rd 519. Go 3.4 miles and turn left onto Highway 122. Go 0.2 miles and turn right onto CO Hwy 519. Go 0.8 miles and turn left to get onto US-22 heading northwest. Go 2.1 miles and turn right onto an unnamed street: Go 0.1 miles and turn right onto Roseberry Street. Follow for 0.2 miles to hospital. Additional Medical Services: 610-250-4000 ' Easton Hospital ' 250 South 21 ^' Street - Easton, PA Directions to Easton Hospital: Head northwest on CO Hwy 619. Go 0.9 miles and then go straight onto CO Hwy 519. Go 6.0 miles and go right to stay on CO Hwy 519. Go 0.3 miles and turn right onto CO Hwy 639. Go less than 0.1 mile and turn left onto unnamed street. Go less than 0.1 miles and go straight on County Rd 519. Go 3.4 miles and turn left onto Highway 122. Go 3.3 miles and go right to stay on Highway 122. Go less than 0.1 mile and turn right to get onto US-22 W. Go 0.5 miles an d take exit towards Easton. Go 0.1 miles and go straight onto Snyder Street. Go 0.2 miles and turn left onto N Bank St. Go less than 0.1 miles and turn right onto Bushkill St. Go less than 0.1 miles and turn left onto N 4* St. Go 0.2 miles and turn right onto Northhampton St. Go 1.8 miles and turn left onto S 22"" St. Go 0.2 miles and turn left onto Lehigh St. GO 0.1 miles and turn right onto S 21^' St. Follow to hospital On Site Telephone: Property is unoccupied. Bring portable communications. Underground Utility Location Service: (800)272-1000 J;\Proiect\Georgia-Pacific\03060-062 Milford CV 11-4 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR ENSR Project Representatives: ENSRAA/estford, MA (978)589-3000 -Kathy Harvey (RHSM) x 3325 ENSR/Piscataway, NJ 732-981-0200 -Don Hessemer Cell 732-233-2197 -Steve Surman .. Cell (732) 713-4625 -Steve Kostage . Ceir(978) 337-1519 Fort James Operating Cornpany Representatives: - Paul A Montney (PM) 973-465-4646, Cell # 908-672-4008 EPA Representatives: - Lou DiGuardia (On Scene Coordinator) , , 732-906-6927 -' . 908-420-1776 J:\Project\Georgia-Pacific\03060-062 Milford CV 11-5 April 2007 Landfill\WorkPlan\FINAl;-April2007\ENSR-HASP^Final- , ' '• . - April07.doc . - ENSR Map from Landfill to Warren Hospital 185 Roseberry Street - Phillipsburg PAN BV <• FULL SCREEN ^ t HALF SCREEN - t 1. * ' 4 0 Ml, I CENTER -75 13098 40 63002 . ^' titap by Mf.ps On Ui (R) ©198+-2005 TeleAtla.5 N.Am.; switcfiboard. Use subject to LiCEt'jSE. J:\Proiect\Georgia-Pacific\03060-062 Milford CV 11-6 April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR Map fronri Landfill to Easton Hospital 250 S 21?' Street - Easton, Pa PANBV J " ' \FULL SCREEN • t ' 2Qm-^ j CENTER -75 16389 40 62817 \ \>v fiif.p-; On Us (R) ©1984-2005 leleAtlSiS N.Am.. Switchboard. Use subject to LlCEf'lSE. J:\Proiect\Georgia-Pacific\03060-062, Milford CV 11-7 April 2007 Landfill\WorkPlan\FINAL-April20,07\ENSR-HASP-Fina!7 April07.doc • • ENSR 12.0 Spill Response All incidental spills due to the spilling or leaking of drummed contents, or improper refueling of site equipment is anticipated to be limited in quantity and capable of being contained on-site prior to reaching any nearby waterways, the river or any off-site areas (outside the landfill limits. Emergency response equipment, including but not limited to, spill kits, absorbent pads, sorbent materials, drums, shovels, sand bags, and other materials to contain small spills will be made readily available and staged in a centrally localized area of the site for easy access. In the event of a spill or discharge of a hazardous material or oil, immediate steps must be taken to minimize the migration of the material on the lands or into the water, unless there is an imminent threat to health. The information below addresses the two most significant activities that could result in a spill of hazardous material or oil at the Site. 12.1 Equipment Refueling As discussed in Section 5.9, equipment will be refueled on site. Proper procedures for preventing fuel spills were addressed in this section. In the unlikely event of a fuel spill, any one or more of the following procedures may be implemented: • Apply oil dry or other sorbent materials on the spill • Use a vacuum tanker to remove any ponded/pooled products • Deploy an oil boom in the case of a spill that impacts a body or water followed by deployment of absorbent pads as well as the operation of the vacuum tanker Pprtable fueling trucks will carry sorbent materials such as oil dry and sorbent pads. In addition, a 20 lb. fire extinguisher will be located within a 50 foot radius of the fueling ^rea. The initial response to any spill will consist of eliminating the cause of the spill. Impacted cleanup materials, as well as impacted soils and water, will be managed for off-site disposal similar to the management and disposal of IDW., 12.2 Release of Materiai from Drums/Containers/Pails The drum and waste storage and sampling pad will consist of an approximate 150' x 50' area, constructed of several liners with a sand layer and topped with a 6" layer of gravel. A 1-foot high berm will also be constructed around the perimeter of the drum sampling area. If drum contents are spilled, a similar program of applying sorbent materials and pads will be implemented. If necessary, a vacuum tanker will be used to remove any ponded or pooled products. Impacted cleanup materials, as well as impacted soils and water, will be managed for off-site disposal similar to the program established for drum disposal. 12.3 Discharge to River To address discharges to the river, floating booms will be installed in the river, in similar fashion to the turbidity curtain, for the purpose of containing any potential releases to the river. As a precaution, an 8" sorbent boom can be placed within the curtain at the time of deployment of the curtain and maintained throughout the project. Small spills, 100 gallons or less, that reach the river but are contained within the curtain can be managed by the Contractor. In addition to the spill kits, a small, portable vacuum tanker mounted on a tractor can be provided to readily clean-up small spills where sorbents are not efficient. In the case of a small water borne J:\Project\Georgia-Pacific\03060-062MilfordCV 12-1 April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR spill. Contractor can deploy this equipment for small skimming operations; Vacuum tanker service is within 2 hours if required through a local vendor. Larger spills that i-each the river, outside the curtain, will require the enlistmerit of a spill response contractor. Any large releases to the water surface will be remediated in a timely fashion by a contractor that specializes in cleaning up spills on water. FJOC has a national contract with a spill response company for emergency response with an estimated response time of 1-hour (1-.5- to 2-hours on the weekend). A list of the specific 24- hour emergency response cleanup contractors that specialize in the cleanup of spills on water surfaces covered under this contract can be provided., i I J:\Project\Georgia-Pacific\03060-062 Milford CV • 12-2 ' April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- . April07.doc '' ' - . ' . ~ ' . , ENSR Attachment A Health and Safety Receipt and Acceptance Form J:\Project\Georgia-Pacific\03060-062 Milford CV - , April 2007 Landfill\WorkPlan\FINAL-Aprii2007\ENSR-HASP-Final- April07.doc • 4 ENSR Health and Safety Plan Receipt and Acceptance Form Slope Stabilization Measure Crown Vantage Landfill Alexandria Township, Hunterdon County, New Jersey Time Critical Removal Action under EPA Administrative Agreement and Order on Consent Docket No. CERCLA-02-2005-2017 1 have received a copy of the Health and Safety Plan prepared for the above-referenced site and activities. 1 have read and understood its contents and 1 agree that 1 will abide by its requirements. Name Signature Date Representing J:\Proiect\Georgia-Pacific\03060-062 Milford CV • April 2007 Landfil^WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc ENSR Attachment B Job Hazard Analysis Form J:\ProjecfiGeorgia-Pacific\03060-062 Miltord ,CV . • April 2007 LandfiH\WorkPlan\FINAL-April2007\ENSR-HASP-Final- • , April07.doc , ENSI Job Analysis Form; PRINCIPAL POTENTIAL STEPS HAZARDS RECOMMENDED CONTROLS - ". "-. - • • ; '•' '/ ':'•-'- ••:-'^" - •'• ' "<• ' ' •' ' '- / - ' '• .' ' /:'- SAFETY EQUIPMENT INSPECTION REQUIREMENT TRAINING REQUIREMENTS - .. '-' • '••-'' .',.. ,- '. '•-' ; - • ': -. .'• • - . - • . • " J:\Project\Georgia-Pacific\03060-062 Milford CV April 2007 Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc Attachment C Health and Safety Pre-Entry Briefing Attendance Form J:\Projec1NGeorgia-Pacific\03060-062 Milford CV Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc Health and Safety Plan Pre-Entry Briefing Attendance Form Slope Stabilization Measure Crown Vantage Landfill Alexandria Township, Hunterdon County, New Jersey Time Critical Removal Action under EPA Administrative Agreement and Order on Consent Docket No. CERCLA-02-2005-2017 • Briefing Conducted By: Date Performed: Printed Name Signature Representing r J:\Project\Georgia-Pacific\03060-062 Milford CV LandfiII\WorkPlan\FINAL-April2007\ENSR-HASP-Final- April07.doc Attachment D Supervisor Accident Investigation Report Form J:\Proiect\Georgia-Pacific\03060-062 Milford CV Landfill\WorkPlan\FINAL-April2D07\ENSR-HASP-Final- April07.doc .. -. H&S SOP No. 4:2 SUPERVISOR'S ACCIDENT/INCIDENT INVESTIGATION REPORT To ba complcitfjf.l witl-iin J days of th& occutrenc-o olirio accidcii'il/inciderit tjy trie EWSR iuper-^isoi' who wa's in control of tho woiti at ir time Insiructions lor cornpleling tho form car-i be found on the next page Use it-is TAB key to move betvje&n field's Date of Accident/Incident Location of accident/incident. Time of Accident/Incident (Be specific if not at an ENSR CSC) Date reported Witnesses to the incident/accident. ( Property damage Describe incurred? • Yes DNO Injury Incurred? Injured Job Employee's Title • Yes • NO Name Home Office Department Nature of injury (be specific) Treatment provided, if known (be specific) What task was the employee engaged in when Injured? Has the employee lost time ' On what date If the employee has beyond the date of the injury? did the lost returned to work, on time begin? what date did this • Yes • No occur? How did the accident occur? Why did the acddent occur? What could be done to prevent recurrence ofthe accident? What actions have you taken thusfkrto prevent recurrience? Supervisor's Date of Name Completion Afterthe fomi has been completed, seiecl File on the main Word menu, and then Send To, and Mail Recipient (as Attachment) V;tien the ne-iv e-mail rtith attachment is open, address it to your RHSNrI and send it. J:\Proiect\Georgia-Pacific\03060-062 Milford CV Landfill\WorkPlan\FINAL-April2007\ENSR-HASP-Final-- April07.doc ENSR Appendix E Quality Assurance Project Plan (QAPP) April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN for REMOVAL ACTIONS at CROWN VANTAGE LANDFILL SITE Alexandria Township, NJ April 2007 Revision 2 Prepared by: ENSR Corporation 20 New England Avenue Piscataway, NJ 08854 Prepared for: Georgia-Pacific Corporation / Atlanta, GA ///^ 4/26/07 Fort James Operating Company Project Manager Date John Harrod - Georgia-Pacific Senior Environmental 4/19/07 Consultant Project Manager Date Steve Surman - ENSR \p:f^ I,, ^uwvervw 4/19/07 Consultant Project Quality Assurance Officer Debra Simmons - ENSR Date U.S. EPA Region 2 On Scene Coordinator Lou DiGuardia ' Date QUALITY ASSURANCE/QUALITY CONTROL PLAN for REMOVAL ACTIONS at CROWN VANTAGE LANDFILL SITE Alexandria Township, NJ I April 2007 Revision 2 Prepared by: ENSR Corporation 20 New England Avenue Piscataway, NJ 08854 Prepared for: Georgia-Pacific Corporation Atlanta, GA Fort James Operating Company Project Manager Date John Harrod - Georgia-Pacific Senior Environmental 4/19/07 Consultant Project Manager Date Steve Surman - ENSR 4/19/07 Consultant Project Quality Assurance Officer Date Debra Simmons - ENSR U.S. EPA Region 2 On Scene Coordinator Date Lou DiGuardia Section: Distribution Date: April 2007 OUALITY ASSURANCE/QUAUTY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 1 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 1 of 1 DISTRIBUTION LIST U.S. EPA Region 2, Removal Action Brancli, EOSC, Lou DiGuardia Fort James Operating Company Project Manager, John Harrod - Georgia-Pacific Senior Environmental Engineer ' Consultant Project Manager, Steve Surman - ENSR Consultant Project QA Officer, Debra Simmons - ENSR Accutest Laboratory Project Manager, Tammy McCloskey Section: Contents Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page i of lii CONTENTS A .0 PROJECT MANAGEMENT. A.1 Introduction A.2 Project Schedule A.3 Distribution List A.4 Project/Task Organization A.4.1 Management Responsibilities A.4.2 QualityAssurance Responsibilities 3 A.4.3 Laboratory Responsibilities 3 A.4.4 Field Responsibilities 5 A.5 Problem Definition and Background 6 A.5.1 Site Background and Description 6 A.5.2 Problem Definition : 6 A.6 Project/Task Description ....7 A.7 Quality Objectives and Criteria for Measurement Data 8 A.7.1 Project Quality Objectives 8 A.7.2 Task Objectives 8 A.7.3 Data Quality Objectives for Measurement Data 8 A.8 Special Training/Certification 10 , A.8.1 Training ^ : ; : 10 A.8.2 Certifications 10 A.S Documents and Records 10 A.9.1 Project Files 10 A.9.2 Field Records 11 A.9.3 Laboratory Records and Deliverables 12 A.10 References ....: 12 B .0 MEASUREMENT/DATA ACQUISITION , B.1 Sampling Methods , B.1.1 Field Measurements B.1.2 Sampling Procedures B.1.3 QC Sample Collection B.1.4 Equipment Decontamination. Section: Contents Date: March 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page ii of iii B.2 Sample Handling and Custody 2 B.2.1 Sample Containers, Preservation, and Holding Times 2 B.2.2 Sample Labeling 2 B.2.3 Custody Procedures 3 B.3 Analytical Methods 6 B.4 Quality Control 6 B.4.1 Field 6 B.4.2 Laboratory 6 B.5 Instrument/Equipment Testing, Inspection, and Maintenance 7 B.6 Instrument/Equipment Calibration and Frequency 7 B.7 Inspection/Acceptance of Supplies and Consumables 7 B.8 Non-Direct Measurements 8 B.9 Data Management 8 C .0 ASSESSMENT/OVERSIGHT 1 C. 1 Assessment and Response Actions 1 0.1.1 Assessments 1 C.l.2 Response Actions 2 C.2 Reports to Management 3 D .0 DATA VALIDATION/DATA USABILITY. D.I Data Review, Verification, and Validation D.1.1 Field Data D.1.2 Internal Laboratory Review D.I .3 Validation of Analytical Data D.2 Verification and Validation Methods D.2.1 Field Data Verification D.2.2 Laboratory Data Verification 2 D.2.3 Validation of Analytical Deliverables 3 ' D.2.4 Verification during Data Management 4 D.3 Reconciliation with User Requirements 4 D.3.1 Comparison to Measurement Objectives 4 D.3.2 Comparison to Project Objectives 6 • Section: Contents ; • Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVAL ACTION Revision: 2 CROWN VANTAGE LANDFILL SITE; ALEXANDRIA TOWNSHIP, NJ Page iil of iii LIST OF TABLES Table B-1 Sample Container, Preservation, and Holding Time Requirements..: 5 Table B-2 Analytical Methodologies .3 LIST OF FIGURES Figure B-1 Example of Chain-of-Custody Record 1 Figure B-2 Example of Custody Seal ,. :..... 2 , . Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 1 of 13 A.O PROJECT MANAGEMENT A.1 Introduction This Quality Assurance/Quality Controi Plan (QA/QC Plan) presents the organization, objectives, planned activities, and specific Q/VQC procedures associated with the Removal Action activities to be conducted at the Crown Vantage Landfill Site (the "Site"), Alexandria Township, New Jersey. Specific protocols for sampling, sample handling and storage, chain-of-custody, and laboratory and field analyses will be described. All Q/VQC procedures will be structured in accordance with applicable technical standards, U.S. EPA's requirements, regulations, guidance, and technical standards. This Q/VQC PLAN has been prepared in accordance with the U.S. EPA QAPP policy as presented in EPA Requirements for Quality Assurance Project Plans (EPA Q/VR-5, March 2001). Additional guidance used in preparing this Q/VQC Plan is presented in Section A.10. An Administrative Agreement and Order on Consent (AOC) for Removal Action was executed on May 26, 2005 between the United States Environmental Protection Agency (USEPA), Region 2 and Fort James Operating Company (FJOC). The Agreement requires the preparation of a Work Plan, consisting of a Sampling and Analysis Plan (SAP), Health and Safety Plan, and a Q/VQC Plan. This Q/VQC Plan has been prepared in conjunction with the other documents and incorporates them by reference. A.2 Project Schedule The project schedule is discussed in Section 10 of the Work Plan. A.S Distribution List The Q/VQC Plan, and any subsequent revisions, will be distributed to the personnel shown on the Distribution List that immediately follows the approval page. A.4 Project/Task Organization The responsibilities of key personnel are described below. A.4.1 Management Responsibilities U.S. EPA Region 2 On-Scene Coordinator (EOSC) The U.S. EPA Region 2 EOSC, Lou DiGuardia, has the overall responsibility for all phases of the investigation. Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION ' Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 2 of 13 Fort James Operating Company Proiect Manaaer The FJOC Project Manager, Mr.John Harrod, Georgia-Pacific Senior Environmental Engineer, is primarily responsible for project direction and decisions concerning technical issues and strategies, budget, subcontractor procurement and schedule. Consultant Proiect Manager The Consultant Project Manager, Mr. Steve Surman - ENSR, has responsibility for technical and scheduling matters. Other duties, as necessary, include: • Orientation of the project staff to the specific needs and requirements of the project, • Ensuring that data assessment activities are conducted in accordance with the Q/VQC Plan, • Approval of project-specific procedures and internally prepared plans, drawings, and reports, • Serving as the focus for coordination of all field and laboratory task activities, communications, reports, and technical reviews, and other support functions, and facilitating site activities with the technical requirements of the project, and • Maintenance of the project files. Consultant Proiect Engineer The Consultant Project Engineer, Mr. Steve Surman - ENSR, provides technical assistance to the Consultant Resident Engineers. Consultant Proiect Coordinator The Consultant Project Coordinator, Mr, Steve Kostage - ENSR, is responsible for the onsite day-to day activities, as implemented by the Consultant Site Superintendent and sampling staff. The Consultant Project Coordinator is also responsible for coordinating with the subcontractor project managers. Subcontractor Proiect Managers The Subcontractor Project Managers for Terra Contracting and United Enviro are responsible for the overseeing the day-to-day activities implemented by their respective staffs and for communicating any problems, delays, etc. to the Consultant Project Coordinator. Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN , Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 3 of 13 A.4.2 Quality Assurance Responsibilities Consultant Proiect QA Officer The Consultant Project QA Officer, Ms. Debra Simmons - ENSR, has overall responsibility quality assurance oversight. The Consultant Project QA Officer communicates directly to the Consultant Project Manager. Specific responsibilities include: • Preparing the Q/VQC Plan, • Reviewing and approving QA procedures, including any modifications to existing approved procedures, • Ensuring that QA audits of the various phases of the project are conducted as required, • Providing QA technical assistance to project staff, and • Reporting on the adequacy, status, and effectiveness of the QA program to the Consultant Project Manager. Consultant Data Validator The Consultant Data Validator (ENSR) works under the direction of the Consultant Project QA Officer. The Consultant Data Validator is responsible for validating the analytical data in accordance with the QA/QC Plan. A.4.3 Laboratory Responsibilities Integrated Analytical Laboratories LLC (IAL) in Randolph, New Jersey was previously approved to perform the analyses of all samples collected at the site. Analytical services will be provided by a Contract Laboratory Program (CLP) certified laboratory or by a non-CLP laboratory that meets the requirements of the Administrative Agreement and Order on Consent. All laboratories contracted to perform under this work plan will be identified and the laboratory qualifications will be provided to EPA prior to performing laboratory services in accordance with the AOC. Accutest Laboratories, in Dayton, NJ, is the proposed laboratory for the analytical program associated with the slope stabilization measures. Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 4 of 13 Laboratory Manager The Laboratory Manager is ultimately responsible for the data produced by the laboratory. Specific responsibilities include: • Implementing and adhering to the laboratory QA nnanual and all corporate policies and procedures within the laboratory, • Approving the standard operating procedures (SOPs), • Maintaining adequate staffing documented on organization charts • Implementing internal/external audit findings corrective actions Laboratorv QA Coordinator The Laboratory QA Coordinator reports to the Laboratory Manager. Specific responsibilities include: • Approving SOPs, • Assessing and maintaining the laboratory QA manual implementation within the facility operations, • Recommending resolutions for ongoing or recurrent nonconformances within the laboratory, • Performing QA assessments, • Reviewing and approving corrective action plans for nonconformances, tracking trends of nonconformances to detect systematic problems, and initiating additional corrective actions as needed. Laboraton/ Proiect Manager The Accutest Laboratory Project Manager, Tammy McCloskey, is the primary point of contact between the laboratory and Consultant Project Manager. Specific responsibilities of the Laboratory Project Manager include: • Monitoring analytical and QA project requirements for a specified project, • Acting as a liaison between the client and the laboratory staff. Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 5 of 13 • Ensuring review of project data packages for completeness and compliance to client needs, and • Monitoring, reviewing, and evaluating the progress and performance of projects. A.4.4 Field Responsibilities Consultant Site Superintendent The Consultant Site Superintendent, Hank Wylam - ENSR, has overall responsibility for completion of all field activities in accordance with Work Plan, SAP, and the Q/VQC Plan and is the communication link between project management and the field team. Specific responsibilities of the Consultant Site Superintendent include: • Coordinating activities at the site, • Assigning specific duties to field team members, • Mobilizing and demobilizing of the field team and subcontractors to and from the site, • Directing the activities of subcontractors on site, • Resolving any logistical problems that could potentially hinder field activities, such as equipment malfunctions or availability, personnel conflicts, or weather dependent working conditions, and • Implementing field QC including issuance and tracking of measurement and test equipment; the proper labeling, handling, storage, shipping, and chain-of-custody procedures used at the time of sampling; and control and collection of all field documentation. Sampling Personnel The Consultant sampling team reports directly to the Consultant Site Superintendent. The responsibilities of the sampling team include: • Collecting samples, conducting field measurements, and decontaminating equipment according to documented procedures stated in the Work Plan and Q/VQC Plan, Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 6 of 13 • Ensuring that field instruments are properly operated, calibrated, and maintained, and that adequate documentation is kept for all instruments, • Collecting the required QC samples and thoroughly documenting QC sample collection, • Ensuring that field documentation and data are complete and accurate, and • Communicating any nonconformance or potential data quality issues to the Field Superintendent. o A.s Problem Definition and Background " A.5.1 Site Background and Description Section 1.0 of the Work Plan contains a description of the Site. In addition. Section 1.0 and Section 2.0 of the July 2006 Engineering Design Report (EDR) contains a description of background and landfill characteristics, respectively. A.5.2 Problem Definition 'The time-critical actions to be implemented generally include,the stabilization of the landfill face in order to eliminate the potential for containers and other waste materials from being released into the Delaware River; immediately securing the Site against unauthorized access; and a search across the entire surface of the landfill to identify, retrieve, and dispose of any drums/containers/pails and their contents that are present above the ground surface, in order to minimize direct contact threats with these materials." The project involves two distinct operational goals to be implemented to comply with the United States Environmental Protection Agency (USEPA), Region 2, Administrative Agreement and Order on Consent for Removal Action executed on May 26, 2005 between the USEPA and FJOC: • Construction of a barrier wall along the southwestern face of the Crown Vantage Landfill abutting the Delaware River shoreline. During the construction of the barrier wall various excavations will be conducted. It is assumed that during excavation operations drums may be encountered. • The removal of surface drums, containers, and pails throughout the entire landfill area. The entire surface of the landfill will be inspected. Any drums, containers or pails (collectively referred to in this Plan as "drums") found at the surface or partially buried will be removed. This Q/VQC Plan addresses the sampling and analysis procedures to be implemented during the drum removal activities in order to identify and properly characterize drums and other containers and their Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 7 of 13 contents removed from the landfill surface for ultimate off-site disposal at an appropriate disposal facility capable of accepting CERCI_A wastes. A.6 Project/Task Description To accomplish the above objectives, the following tasks will be implemented: • Inspection of the landfill for drums. • Sampling of materials encountered during the drum removal activities for characterization purposes. a • Screening of samples in the field using a PiD, pH strips (or meter), and reactivity and PCB test kits. Haz-cat screening kits may be used for drum screening evaluation. A gas combustible meter and radiation meter will be used for health and safety screening purpose. Sample locations will be recorded using a global positioning system (GPS) unit. • Waste classification and the categorizing of waste streams will be based on prior analysis and site experience with previously established waste streams. The waste designated for off-site disposal will be broken into previously established waste streams, as identified in the 1992 Woodward Clyde Consultants (WCC) report. A copy of the 1992 WCC report is provided in Attachment 2 of the SAP. Each waste stream will be sampled in accordance with the established protocols of previous investigations based on site conditions and subject to disposal facility acceptance criteria. • Analysis of the samples by a fixed-based laboratory. Analyses may include ignitability, reactivity, corrosivity, PCBs, and Toxicity Characteristic Leaching Procedure (TCLP) parameters, depending on the results of field screening and visual observations. Once specific drums have been categorized into separate waste streams, based on waste classification and profile sampling for waste disposal facility selection criteria, a minimum of one (1) sample per waste stream will be collected to adequately characterize underlying hazardous constituents (UHCs). These samples will be analyzed for the CLP Statement of Work (SOW) OLM04.3 Target Compound List (TCL) and the ILM05.3/5.4 Target Analyte List (TAL) list of parameters. These samples will also be analyzed for the herbicides 2-methyl-4-chlorophenoxyacetic acid (MCPA) and 2-(2-methyl-4- chlorophenoxpropionic acid (MCPP). This analyte list (TCL/TAL plus MCPA and MCPP), presented as Table A-1, covers all previous constituents detected at the site as presented in Table 1 of the EPA Removal Site Evaluation Memorandum, dated May 25, 2004 Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVAL ACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 8 of 13 • In the event that analytical methods may change from what is presented in the SAP and Q/VQC Plan, the Q/VQC Plan will be amended as necessary and EPA will be notified of tfie modification in writing prior to implementation of alternative methods or protocols. A.7 Quality Objectives and Criteria for Measurement Data A.7.1 Project Ouality Objectives The sampling program will consist of preparatory activities, sampling of materials as identified in Section A.6, and analysis of samples by a fixed-base laboratory. A.7.2 Task Objectives Tasks that will be implemented include the collection of materials, laboratory analysis, and a comparison to appiicable regulatory limits. A.7.3 Data Quality Objectives for Measurement Data Precision Precision is a measure of the degree to which two or more measurements are in agreement. Field precision is assessed through the collection and measurement of field duplicates at a rate of one duplicate per 20 samples. Precision will be measured through the calculation of relative percent difference (RPD). The objectives for field precision RPDs are 30% for aqueous samples and 50% for solid samples. Precision in the laboratory is assessed through the calculation of RPD for duplicate samples, either as matrix spike/matrix spike duplicates (MS/MSDs) or as laboratory duplicates, depending on the method. For this program, statistical control limits, as generated by the laboratory and current at the time of analyses, will be utilized as the precision objectives. Accuracv Accuracy is the degree of agreement between the observed value and an accepted reference or true value. Accuracy in the field is assessed through the use of trip blanks and the adherence to all sample handling, preservation, and holding time requirements. Trip blanks should contain no target analytes above the reporting limit Sampling preservation and holding time requirements are discussed in Section 8.3.1. Section: A.O * Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION / Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 9 of 13 Laboratory accuracy is assessed through the analysis of MS/MSDs, laboratory control samples (LCSs), and surrogate compounds, and the subsequent determination of percent recoveries (%Rs). . For this program, accuracy objectives will be the statistical control limits generated by the laboratory and current at the time of analyses. Completeness Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under normal conditions. "Normal conditions" are defined as the conditions expected if the sampling plan was implemented as planned. Field completeness is a measure of the amount of valid samples obtained during all sampling for the project. The field completeness objective is greater than 90 percent. Laboratory completeness is a measure of the amount of valid measurements obtained from all the ^measurements taken in the project. The laboratory completeness objective is greater than 95 percent. Sensitivity Sensitivity of analytical data, is demonstrated by the laboratory detection limits (laboratory-specific MDLs and reporting limits). Reporting limits for the actual samples may be affected by analytical dilutions, sample volume, or sample matrix. Target detection limits are presented in Table A-1. Comparability Comparability expresses the confidence with which one data set can be compared to another. Comparability is dependent upon the proper design of the sampling program and will be satisfied by ensuring that the work plans and SOPs are followed and that proper sampling techniques are used. Planned analytical data will be comparable when similar sampling and analytical methods are used as documented in the Q/VQC Plan. Representativeness Representativeness expresses the degree to which data accurately and precisely represents a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition within a defined spatial and/or temporal boundary. Representativeness is ensured through the design of the sampling program and will be satisfied by ensuring that the Work Plan, SAP, SOPs, and Q/VQC Plan are followed and that proper sampling techniques are used. Within the laboratory, representativeness will be ensured by the use of Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 10 of 13 appropriate methods, conformance to the approved analytical procedures, and adherence to sample holding times. The sampling network was designed to provide data representative of the areas of concern. During development of this network, consideration was given to past facility processes, existing analytical data, physical setting and processes, and media of concern. The rationale of the sampling network is discussed in detail in the Work Plan. A.8 Special Training/Certification A.8.1 Training The training and H&S requirements necessary for field sampling activities are addressed in the Work Plan and H&S Plan. Prior to starting work, personnel will be given instruction specific to the project, covering the following areas: Organization and lines of communication and authority, Overview of the Work Plan, SAP, and Q/VQC Plan, Q/VQC requirements. Documentation requirements, and Health and safety requirements. Instructions will be provided by the Consultant and subcontractor management personnel. A.8.2 Certifications Laboratories utilized for analyses will hold current, applicable certifications for the parameters being analyzed. A.9 Documents and Records A.9.1 Project Files The project files will be the central repository for all documents which constitute evidence relevant to sampling and analysis activities as described in this Q/VQC Plan. The Consultant is the custodian of the project files and will maintain the contents of the project files for the investigation, including all relevant records, reports, logs, field notebooks, pictures, subcontractor reports, and data reviews in a secured, limited access area and under custody of the Consultant Project Manager. The project files will include at a minimum: • Field logbooks. Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 11 of 13 Field data and data deliverables. Photographs, Drawings, Sample collection logs. Laboratory data deliverables. Data review or assessment reports, A copy of the final Work Plan (with attachments, including the Q/VQC Plan), The project HASP, Progress reports, QA reports, interim project reports, etc.. All custody documentation (tags, forms, airbills, etc.) Records will be retained until the completion of the requirements under the Administrative Agreement and Order on Consent for Removal Action. A.9.2 Field Records Field logbooks will provide the means of recording the data collecting activities performed during the investigation. As such, entries will be described in as much detail as possible so that persons going to the facility could reconstruct a particular situation without reliance on memory. Field logbooks will be bound field survey books or notebooks. Logbooks will be assigned to field personnel, but will be stored in the project files when not in use. Each logbook will be identified by the project-specific document number. The title page of each logbook will contain the following: • Person to whom the logbook is assigned, • The logbook number, • Project name and number, • Project start date, and • End date. Entries into the logbook will contain a variety of information. At the beginning of each entry, the date, start time, weather, names of all sampling team members present, and the signature of the person making the entry will be entered. The names of visitors to the site, field sampling or investigation team personnel, and the purpose of their visit, will also be recorded in the field logbook. Field logbooks will be supplemented by standardized field measurement and sample collection forms. All measurements made and samples collected will be recorded. All entries will be made in permanent Section: A.O Date: April 2007 QUALITY ASSURANCE/QUAUTY CONTROL PLAN Number; 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 12 of 13 ink, signed, and dated and no erasures or obliterations will be made. If an incorrect entry is made, the information will be crossed out with a single strike mark which is initialed and dated by the sampler. Whenever a sample is collected, or a measurement is made, a detailed description of the sampling location, which includes compass and distance measul'ements, or, latitude and longitude information (e.g., obtained by using a global positioning system) will be recorded. The number of photographs taken of the sampling location, if any, will be noted. Equipment used to make measurements will be identified, along with the date of calibration. A.9.3 Laboratory Records and Deliverables Laboratory data reduction procedures will be performed according to the following protocol. All information related to analysis will be documented in controlled laboratory logbooks, instrument printouts, or other approved forms. All entries that are not generated by an automated data system will be made neatly and legibly in permanent, waterproof ink. Information will not be erased or obliterated. Corrections will be made by drawing a single line through the error and entering the correct information adjacent to the cross-out. All changes will be initialed, dated, and, if appropriate, accompanied by a brief explanation. Unused pages or portions of pages will be crossed out to prevent future data entry. Analytical laboratory records will be reviewed by the supervisory personnel on a regular basis and by the Laboratory QA Coordinator periodically, to verify adherence to documentation requirements. Results of analyses will be provided within standard turnaround time (not to exceed three weeks). The laboratory will provide at least one hard copy report and one copy of an electronic data deliverable (EDD). The EDD will be provided in an EQulS format (four-file). The hard copy data package will consist of a Level 3 data deliverable, i.e., will include sample results, a case narrative describing any anomalies or nonconformanceis, dates of extraction and analysis, and QC summary sheets for method blanks, surrogate recoveries, MS/MSD recoveries and RPDs, LCS recoveries, laboratory duplicates, serial dilution results, and ICP interference check sample results,. A.10 References This Q/VQC Plan was prepared using the following documents: United States Environmental Protection Agency, Quality Staff. EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5. EP/V240/B-01/003. March 2001. United States Environmental Protection Agency. EPA Removal Site Evaluation. May 25, 2004. Section: A.O Date: April 2007 QUALITY ASSURANCE/QUAUTY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 13 of 13 United States Environmental Protection Agency. US EPA Region 2 Guidance for the Development of Quality Assurance Project Plans for Environmental Monitoring Projects. April 2004. United States Environmental Protection Agency, Quality Staff. Guidance for the Data Quality Objective Process, EPA QA/G-5. EPA/600/R-96/055. August 2000. United States Environmental Protection Agency, Quality Staff. EPA Guidance for Quality Assurance Project Plans, EPA QA/G-5. EPA/240/R-02/009. December 2002. United States Environmental Protection Agency. Test Methods for Evaluating Solid Waste, Physical/Chemical raethods, SW-846. Third Edition. May 1986, revised June 1997. United States Environmental Protection Agency. EPA NEIC Policies and Procedures Manual. EPA 330/9-78-001-R. Revised August 1991. United States Environmental Protection Agency. OSWER Directive No. 9360.4-01, QA/QC Control Guidance for Removal Activities: Sampling Q/VQC Plan and Data Validation Procedures. April 1990. Section: B.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 1 of 9 B.O MEASUREMENT/DATA ACQUISITION B.1 Sampling Methods B.1.1 Field Measurements Field measurements may include measurement of total volatile organic compounds (VOCs) in air using a photoionization detector (PID), measurement of the lower explosive limit (LEL) using a gas combustible meter, measurements of ionizing radiation using a radiation meter, PCB and reactivity measurements by field test kits (Chlor-n-Oil Test Kit and Chemets Screening Kit, respectively), and pH measurements of liquids using pH paper (or a pH meter): Locational data will be acquired using a GPS unit (Trimble handheld Geo XT 2005 or equivalent). Haz-cat screening kits may be used for drum screening evaluation. Field measurements will be conducted as described in the SAP, following the manufacturer's instructions. Copies of all pertinent manufacturer's instructions will be maintained on site and will be accessible to personnel performing the measurements. B.1.2 Sampling Procedures Samples will be collected using one or more of the following SOPs: USEPA ERT SOP 2009 - Drum Sampling USEPA ERT SOP 2012 - Soil Sampling USEPA ERT SOP 2017 -Waste Pile Sampling Copies of these SOPs are included in Appendix A of the SAP. B.1.3 QC Sample Collection QC samples for laboratory analyses will include trip blanks, field duplicates, MS/MSDs, and temperature blanks. These samples will be collected as described below: Trip blanks - Trip blanks will be prepared by the laboratory and will accompany the seimple containers to the field, where they will remain unopened. The trip blanks will then be shipped with the samples to the laboratory. Trip blanks will be analyzed for volatile organic compounds (VOCs) only. Field duplicates - Field duplicates will be collected a frequency of one field duplicate per 20 samples per matrix. Field duplicates will be collected by alternately filling two sets of identical sample containers from the interim container used to collect the sample. All field duplicates will be analyzed for the same parameters as their associated samples. Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 2 of 9 MS/MSDs - MS/MSD samples will be collected at a frequency of one for every 20 or less investigative samples. For those samples designated as MS/MSDs, sufficient additional volume (based on the individual laboratory's requirements) will be collected. Temperature blanks - Temperature blanks will be included in each cooler, allowing the laboratory to determine the temperature of the shipment without disturbing the field samples. Temperature blanks will be prepared in the laboratory by filling a plastic or glass vial with water. B.1.4 Equipment Decontamination Decontamination of equipment in the field will be conducted as described in Section 3.6 of the SAP. These equipment decontamination procedures will be used for any non-disposable or non-dedicated sampling equipment. B.2 Sample Handling and Custody B.2.1 Sample Containers, Preservation, and Holding Times •) Sample bottles and chemical preservatives will be provided by the laboratory. EnCore® or equivalent samplers to be used for VOC sample collection may be obtained from the laboratory or directly from the vendor. The containers will be cleaned by the manufacturer to meet or exceed all analyte specifications established in the latest U.S. EPA's Specifications and Guidance for Contaminant-Free Sample Containers. Certificates of analysis will be provided with each lot of containers and maintained on file at the laboratory to document conformance to EPA specifications. A summary of sample container, presen/ation, and holding time requirements is presented in Table B-1. B.2.2 Sample Labeling Immediately upon collection, each sample will be labeled with an adhesive label. Samples will be assigned unique sample identifications as described below: • The first character will identify if the material is drummed (D) or a bulk sample (B). • The next character will represent the sample matrix (S = solid, L = liquid, and M = mixed waste). • The next two numbers will correspond to the double-digit drum number (01 through 99), which will be assigned during sampling operations. Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 3 of 9 • The next set of characters will represent the nearest station number (00 through 1500). Samples being designated for MS/MSD analysis will not include an identifier as part of the sample code, but will be identified on the chain-of-custody form. Field duplicates will be assigned a unique sample number that does not allow the laboratory to recognize the associated field sampie. The cross reference between the field duplicate and its associated field sample will be recorded in the field records. B.2.3 Custody Procedures Custody is one of several factors that are necessary for the admissibility of environmental data as evidence in a court of law. Custody procedures help to satisfy the two major requirements for admissibility: relevance and authenticity. Sample custody is addressed in two parts: field sample collection and laboratory analysis. A sample is considered to be under a person's custody if • the item is in the actual possession of a person; • the item is in the view of the person after being in actual possession of the person; • the item was in the actual physical possession of the person but is locked up to prevent tampering; • the item is in a designated and identified secure area. Field Custodv Procedures The field sampler is personally responsible for the care and custody of the samples until they are transferred or dispatched properly. Field procedures have been designed such that as few people as possible will handle the samples. All sample containers will be identified by the use of sample labels with sample numbers, sampling locations, date/time of collection, and type of analysis. The sample numbering system is presented in Section B.2.2 of the Q/VQC Plan. Sample labels will be completed for each sample using waterproof ink unless prohibited by weather conditions. For example, a logbook notation would explain that a pencil was used to fill out the sample tag because the pen would not function in freezing weather. Samples will be accompanied by a properly completed chain-of-custody form. The sample numbers and locations will be listed on the chain-of-custody form. When transferring the possession of Section: A.O Date: April 2007 QUALITY ASSURANCE/QUAUTY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHjP, NJ Page 4 of 9 samples, the individuals relinquishing and receiving will sign, date, and note the time on the record. This record documents the transfer of custody of samples from the sampler to another person, to a mobile laboratory, to the permanent laboratory, or to/from a secure storage location. An example chain-of-custody form is presented as Figure B-1. EPA retains the right to collect split samples of all materials removed as part of this action. If split samples are collocated with a government agency, a separate sample receipt will be prepared for those samples and marked to indicate with whom the samples are being collocated. The person relinquishing the samples to the facility or agency should obtain the representative's signature acknowledging sample receipt. If the representative is unavailable or refuses to sign, this is noted in the "Received By" space. » All sample shipments will be accompanied by the chain-of-custody record identifying the contents. The original record and second copy will accompany the shipment, and the back copy will be retained by the sampler and placed in the project files. Samples will be properly packaged on ice at 4°C for shipment and dispatched to the appropriate laboratory for analysis, with a separate signed custody record enclosed in and secured to the inside top of each sample box or cooler. Shipping containers will be secured with strapping tape and custody seals for shipment to the laboratory. The custody seals will be attached to the front and back of the cooler and covered with clear plastic tape after being signed by field personnel. An example custody seal is shown in Figure B-2. The cooler will be strapped shut with strapping tape in at least two locations. If the samples are sent by common carrier, the waybill will be used. Waybills will be retained as part of the permanent documentation. Commercial carriers are not required to sign off on the custody forms since the custody forms will be sealed inside the sarnple cooler and the custody seals will remain intact. Laboratorv Custodv Procedures Samples will be received and logged in by a designated sample custodian or his/her designee. Upon sample receipt, the sample custodian will • Examine the shipping containers to verify that the custody tape is intact, • Examine all sample containers for damage. Section: A:0 Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 5 of 9 Determine if the temperature required for the requested testing program has been maintained during shipment and document the temperature on the chain-of-custody form or in the sample receipt records. Compare samples received against those listed on the chain-of-custody, Verify that sample holding times have not been exceeded, Examine all shipping records for accuracy and completeness. Determine sample pH (if applicable) and record on chain-of-custody or in the sample receipt records. Sign and date the chain-of-custody immediately (if shipment is accepted), Note any problems associated with the coolers and/or samples on the cooler receipt^ form and notify the Laboratory Project Manager, who will be responsible for contacting the client, Attach labdratory sample container labels with unique laboratory identification and test. Place the samples in the proper laboratory storage. Following receipt, samples will be logged in according to the following procedure: . • The samples will be entered into the laboratory information management system (LIMS). At a minimum, the following information will be entered: project name or identification, unique sample numbers (both client and internal laboi'atory, type of sample, required tests, date and time of laboratory receipt of samples, and field ID provided by field personnel. • The appropriate laboratory personnel will be notified of sample arrival. • The completed chain-of-custody, waybills, and any additional documentation will be placed in the project file. Specific details of laboratory custody procedures for sample receiving, sample identification, sample control, and record retention are described in the Laboratory QA Manual and laboratory SOPs. Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 6 of 9 B.3 Analytical Methods Samples collected for off-site analysis during the program will be analyzed by a laboratory that participates in the USEPA CLP or a non-CLP labbratory that meets the requirements of the Administrative Agreement and Order on Consent. Accutest Laboratories in Dayton, NJ is the proposed laboratory. Samples will be analyzed according to the analytical methods listed in Table B-2. Laboratory turnaround time will be three weeks (15 business days) for the hard copy report and EDD. B.4 Quality Control B.4.1 Field Field QC samples will be collected during sampling to assess the accuracy and precision of the data. These samples will include trip blanks, field duplicates, and MS/MSDs. The collection of QC samples is described in Section B.1. The frequency of collection and acceptance criteria are described in Section A.7. B.4.2 Laboratory The laboratory has a QC program in place to ensure the reliability and validity of the analysis performed at the laboratory. All analytical procedures are documented in writing as SOPs and each SOP includes the minimum requirements for the procedure. The internal QC checks differ slightly for each individual procedure but in general the QC requirements include the following: Blanks (method, reagent/preparation, instrument) MS/MSDs Surrogate spikes Laboratory duplicates LCSs Second column confirmations (GC/ECD analysis) Interference checks (ICP analysis) Serial dilutions (ICP analysis) The frequency of the QC checks will be consistent with the analytical methods. Acceptance criteria will be the current limits generated by the laboratory. Section: A.O , Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 7 of 9 B.S Instrument/Equipment Testing, Inspection, and Maintenance The field equipment for this project will include a PID, LEL meter, radiation meter, test kits for PCBs and reactivity, GPS, and pH paper or meter. Haz-cat screening kitsmay be used.for drum screening evaluation. Consultant field personnel will be responsible for ensuring that instruments are properly functioning. At a minimum, this will entail checking the instrument prior to shipment to the field and performing daily operational checks and calibration as described in Section B.6. Routine maintenance and trouble-shooting procedures will be performed as described in the manufacturer's instructions, which will be available on site. Spare parts will be readily available on site or from the vendor. Routine testing and preventive maintenance is performed by the laboratory as part of their QA program. Details on the type of checks, frequencies, and corrective actions are included in the Laboratory QA Manual. B.6 Instrument/Equipment Calibration and Frequency The field instrumentation will include a PID, LEL meter, radiation meter, GPS, and pH paper or meter. Calibration of the meters will be performed according to the manufacturer's instrument-specific instructions and will occur prior to use on each day of use. Calibrations will be checked periodically throughout the day and at the end of the sampling day. The radiation meter will be factory calibrated and source checked in the field according to the manufacturer's instructions. Calibrations associated with test kits will be conducted according to manufacturer's instructions and recommended frequency. All calibration procedures will be documented in the field records. Calibration records will include the date/time of calibration, name of the person performing the calibration, reference standard used, and the results of the calibration. Calibration procedures for laboratory instruments will consist of initial calibrations, initial calibration verifications, and continuing calibration verification. The SOP for each analysis performed in the laboratory describes the calibration procedures, their frequency, acceptance criteria, and the conditions that will require recalibration. The laboratory maintains documentation for each instrument which includes the following information: instrument identification, serial number, date of calibration, analyst, calibration solutions, and the samples associated with these calibrations. B.7 Inspection/Acceptance of Supplies and Consumables For this project, critical supplies for field activities Will be tracked through Consultant's system in the following manner. Section: A.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVAL ACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 8 of 9 Critical Supplies and Inspection Requirements Responsible Consumables and Acceptance Criteria Individual Sample containers Visually inspected upon receipt for cracks, Consultant Site breakage, and cleanliness Superintendent Chemicals and reagents Visually inspected for proper labeling, Consultant Site expiration dates, appropriate grade Superintendent Field measurement Functional checks to ensure proper Consultant Site equipment calibration and operating capacity Superintendent Sampling equipment Visually inspected for obvious defects, Consultant Site damage, and contamination Superintendent Field test kits Inspected for completeness Consultant Site Superintendent Supplies and consumables not meeting acceptance criteria will initiate the appropriate corrective action. Corrective measures may include repair or replacement of measurement equipment, and/or notification of vendor arid subsequent replacement of defective or inappropriate materials. All actions will be documented in the project files. The laboratory system of inspection and acceptance of supplies and consumable is documented in the Laboratory QA Manual. B.B, Non-Direct Measurements The use of non-direct data (i.e., historical reports, maps, literature searches) will be limited to the design of the sampling and analysis program and will not be used for characterization purposes. B.9 Data Management Data management operations include data recording, validation, transformation, transmittal, reduction, analysis, tracking, storage and retrieval. All data will be entered into a database system. As data is loaded into the system, a variety of quality checks are performed to ensure data integrity. These checks include Audits to ensure that laboratories reported all requested analyses; Checks that all analytes are consistently and correctly identified; Reviews to ensure that units of measurement are provided and are consistent; Queries to determine that any codes used in the database are documented properly; Reports to review sample definitions (depths, dates, locations); Proofing manually entered data against the hard-copy original, and Reports to review groupings of sampling locations and coordinate systems. Section: A.O Date: April 2007 QUAUTY ASSURANCE/QUAUTY CONTROL PLAN Number: 03060-062-303 REMOVAL ACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 9 of 9 At a minimum, the database will contain the following fields: Sample identifier Sample location Sample media type Sampling date Analysis date Laboratory analysis identifier Analyte name Concentration value ^ Measurement units Data qualifiers Once all data quality checks are performed, the data will be exported to a variety of formats to meet project needs. The project database will be maintained on a secure network drive which is backed up regularly. Access to the database will be limited to authorized users and will be controlled by password access. Data will be retained in accordance with the requirements stated in Section A.9.1 of this Q/VQC Plan. Section: CO Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 1 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 1 of 4 CO ASSESSMENT/OVERSIGHT C.l Assessment and Response Actions C.l .1 Assessments The types of planned assessments pertinent to this program include technical surveillance audits (TSAs) of field and laboratory activities. Field Activity TSA A TSA of field activities may be conducted by the Consultant Project QA Officer or his/her designate. The TSA includes an examination of field sampling records, field measurement results, field instrument operating and calibration records, sample collection, handling, and packaging procedures, QA procedures, chain-of-custody, sample documentation, etc. If significant deficiencies are noted, follow- up audits will be conducted. During the audit, the auditor will keep detailed notes of audit findings. Preliminary results of the audit will be reviewed with the Consultant Site Manager while on site to ensure that deficiencies adversely affecting data quality are immediately identified and corrective measures initiated. Upon completion of the audit, the Consultant Project QA Officer will prepare a written audit report, which summarizes the audit findings, identifies deficiencies and recommends corrective actions. This report will be submitted to the Consultant Project Manager, who will be responsible for ensuring that corrective measures are implemented and documented (Section C.l.2). The results of the audit process will be included in the QA reports to management, as described in Section C.2, and will be made available to EPA upon request. Laboratorv TSA Laboratory TSAs are conducted periodically by the Consultant's QA staff as part of their analytical subcontractor monitoring program. The laboratory TSA includes a review of the following areas: QA organization and procedures. Personnel training and qualifications. Sample log-in procedures. Sample storage facilities, Analyst technique Adherence to laboratory SOPs and project Q/VQC Plan, Compliance with Q/VQC objectives. Instrument calibration and maintenance. Data recording, reduction, review, and reporting, and Section: CO Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 1 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 2 of 4 • Cleanliness and housekeeping. Preliminary results of the systems audit will be discussed with the Laboratory Manager, Laboratory Project Manager, and Laboratory QA Coordinator. A written report that summarizes audit findings and recommends corrective actions will be prepared and submitted to the Laboratory Manager for response, and to the Consultant Project Manager. The results of the audit, including resolution of any deficiencies, will be included in the QA reports'to management, as described in Section C.2. If issues are noted during the laboratory systems audit that could potentially affect the quality of the data generated for the removal actiori, these issues will be communicated to EPA. C.l.2 Response Actions Corrective action is the process of identifying, recommending, approving, and implementing measures to counter unacceptable procedures or out-of-limit QC performance that can affect data quality. Corrective action can occur during field activities, laboratory analyses, data review, and data assessment. All corrective action proposed and implemented should be documented in the QA reports to management (Section C.2). Corrective action should only be implemented after approval by the Consultant Project Manager, or his designee. The U.S. EPA Region 2 OSC will be notified of significant issues that potentially impact the achievement of the project objectives. Field Corrective Action Corrective action in the field may be needed when the sample network is changed (i.e., more/less samples, sampling locations other than those specified in the Q/VQC Plan, etc.), or when sampling procedures and/or field analytical procedures require modification, etc. due to unexpected conditions. The field team may identify the need for corrective action. The Consultant Site Superintendent will approve the corrective action and notify the Consultant Project Manager. The Consultant Project Manager, in consultation with the Consultant Project QA Officer, will approve the corrective measure. The Consultant Site Superintendent will ensure that the corrective measure is implemented by the field team. Corrective action resulting from internal field audits will be implemented immediately if data may be adversely affected due to unapproved or improper use of approved methods. The Consultant Project QA Officer will identify deficiencies and recommend corrective action to the Consultant Project Manager. Implernentation of corrective actions vvill be performed by the Consultant Site Superintendent and field team. Corrective action will be documented in QA reports to the project managementteam (Section C.2). Section: CO Date: April 2007 QUALITY ASSURANCE/QUAUTY CONTROL PLAN Number: 03060-062-303 REMOVAL ACTION Revision: 1 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 3 of 4 Corrective actions will be implemented and documented in the field record book. Documentation will include: • A description of the circumstances that initiated the corrective action, • The action taken in response, • The final resolution, and • Any necessary approvals. No staff member will initiate corrective action without prior communication of findings through the proper channels. Laboratorv Corrective Action Corrective action in the laboratory may occur prior to, during, and after initial analyses. A number of conditions such as broken sample containers, multiple phases, low/high pH readings, and potentially high concentration sarriples may be identified during sample log-in or analysis. Following consultation with laboratory analysts and supen/isory personnel, it may be necessary for the Laboratory OA Coordinator to approve the implementation of corrective action. If the nonconformance causes project objectives not to be achieved, the Consultant QA Officer will be notified. These corrective actions are performed prior to release of the data from the laboratory. The corrective action will be documented in both the laboratory's corrective action files, and in the narrative data report sent from the laboratory to the Consultant. If the corrective action does not rectify the situation, the laboratory will contact the Consultant QA Officer, who will determine the action to be taken and inform the appropriate personnel. Corrective Action During Data Review and Data Assessment The need for corrective action may be identified during either data review or data assessment. Potential types of corrective action may include resampling by the field team or reinjection/reanalysis of samples by the laboratory. These actions are dependent upon the ability to mobilize the field team and whether the data to be collected is necessary to meet the required QA objectives. If the Consultant data reviewer or data assessor identifies a corrective action situation, the Consultant Project Manager will be responsible for informing the appropriate personnel. C.2 Reports to Management QA reports will be submitted to the Consultant Project Manager to ensure that any problems identified during the sampling and analysis programs are investigated and the proper corrective measures taken in response. The QA reports will include: Section: CO Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 1 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 4 of 4 • All results of field and laboratory audits, • A summary of revisions to the Q/VQC Plan, • Results of any performance evaluation (PE) or split samples, • Problems noted during data validation and assessment, and • Significant QA/QC problems, recommended corrective actions, and the outcome of corrective actions. QA reports will be prepared by the Consultant Project QA Officer and submitted on an as-needed basis. Section: D.O Date: April 2007 QUALITY ASSURANCE/QUAUTY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 1 of 7 D.O DATA VALIDATION/DATA USABILITY D.I Data Review, Verification, and Validation All data generated through field activities, or through the analytical program, will be reduced and validated prior to reporting. No data will be disseminated by Consultant or its subcontractors until it has been subjected to the procedures summarized below. D.1.1 Field Data Field data will be reviewed daily by the Consultant Site Manager or Resident Engineer to ensure that the records are complete, accurate, and legible and to verify that the sampling procedures are in accordance with the protocols specified in the SAP, SOPs, and Q/VQC Plan. D.I .2 Internal Laboratory Review Prior to the release of any data from the laboratory, the data will be reviewed and approved by laboratory personnel. The review will consist of a tiered approach that will include reviews by the person performing the work, by a qualified peer, and by supen/isory and/or QA personnel. D.I .3 Validation of Analytical Data Validation of the laboratory data packages will be performed by the Consultant. Validation procedures are described in Section D.2.3. D.2 Verification and Validation Methods D.2.1 Field Data Verification Field records will be reviewed by the Consultant Site Manager to ensure that: • Logbooks and standardized forms have been filled out completely and that the information recorded accurately reflects the activities that were performed. • Records are legible and in accordance with good recordkeeping practices, i.e., entries are signed and dated, data are not obliterated, changes are initialed, dated, and explained. • Sample collection, handling, presen/ation, and storage procedures were conducted in accordance with the protocols described in the QA/QC Plan, and that any deviations were documented and approved by the appropriate personnel. Section: D.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVAL ACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 2 of 7 D.2.2 Laboratory Data Verification Prior to being released as final, laboratory data will proceed through a tiered review process. Data verification starts with the analyst who performs a 100 percent review of the data to ensure the work was done correctly the first time. The data reduction and initial verification process must ensure that: Sample preparation and analysis information is correct and complete. Analytical results are correct and complete. The appropriate SOPs have been followed and are identified in the project records. Proper documentation procedures have been followed, and All nonconformances have been documented. Following the completion of the initial verification by the analyst performing the data reduction, a systematic check of the data will be performed by an experienced peer or supen/isor. This check will be performed to ensure that initial review has been completed correctly and thoroughly and will include a review of Adherence to the requested analytical method SOP, Correct interpretation of chromatograms, mass spectra, etc.. Correctness of numerical input when computer programs are used (checked randomly). Correct identification and quantification of constituents with appropriate qualifiers. Numerical correctness of calculations and formulas (checked randomly) Acceptability of QC data. Documentation that instruments were operating according to method specifications (calibrations, performance checks, etc.). Documentation of dilution factors, standard concentrations, etc.. Sample holding time assessment. Section: D.O Date: April 2007 QUALITY ASSURANCE/QUAUTY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 3 of 7 A third-level review will be performed by designated laboratory personnel before results are submitted to clients. This review serves to verify the completeness of the data report and to ensure that project requirements are met for the analyses performed. A narrative will accompany the final report. D.2.3 Validation of Analytical Deliverables Validation of analytical deliverables will consist of two approaches. Upon receipt of the laboratory data packages reporting the results of waste disposal profiling parameters (TCLP, ignitability, corrosivity, PCBs, and cyanide) the Consultant will review the case narrative to identify any significant data quality issues. Any deviations from approved procedures, nonconformances to method or laboratory QC criteria, or matrix effects will be investigated to determine the impact on the project data. Significant data quality issues will be communicated to the Consultant Project Manager. Data packages that contain the results of the all UHCs (TCUTAL plus MCPA and MCPP) will be subjected to a more extensive validation. The validation of these data deliverables will consist of a review of the following elements (as applicable to the methods), as presented on summary forms within the package: • Holding times and sample preservation, • Laboratory blanks and trip blanks (other field blanks are not applicable to this program), • Surrogates, . LCSs, . MS/MSDs, • Laboratory duplicates, • Serial dilutions, and • Inductively Coupled Plasma (ICP) Interference Check Solution (ICS) AB. Validation will be performed using the applicable EPA Region 2 validation SOPs as guidance: • Validating Chlorinated Herbicides by Gas Chromatography (HW-17, Revision 1.3), • Validating Volatile Organic Compounds by SW-846 Method 8260B (HW-24, Revision 1), • Validating Semivolatile Organic Compounds by SW-846 Method 8270 (HW-22, Revision 2), • Validating Pesticide/PCB Compounds by SW-846 Method 8080A (HW-23, Revision 0), . Validating PCB Compounds by SW-846 Method 8082 (HW-23B, Revision 1.0), and • Evaluation of Metals Data for the CLP Program (HW-2, Revision 13) [note that this SOP will be adapted for the SW-846 methods to be utilized for this program]. Data failing to meet the acceptance criteria established in this QA/QC Plan will be flagged as estimated, rejected, or accepteci without qualification using actions outlined in the Region 2 SOPs. Section: D.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 4 of 7 Upon completion of the validation, a brief report will be prepared. This report will summarize the samples reviewed, elements reviewed, any nonconformances with the established criteria, and validation actions (including application of data qualifiers). Data qualifiers will be consistent with the U.S. EPA guidelines as shown below: J - The result is an estimated quantity; the associated numerical value is the approximate concentration of the analyte in the sample. : Jt - the result is an estimated quantity, but the result may be biased high (this qualifier will be used only for metals data). J- - The result is an estimated quantity, but the result may be biased low (this qualifier will be used only for metals data). UJ - The analyte was not detected above the sample reporting limit; and the reporting limit is approximate. U - The sample was analyzed for, but was not detected above the sample reporting limit. R - The data are unusable. The sample result is rejected due to serious deficiencies. The presence or absence of the analyte cannot be verified. D.2.4 Verification during Data Management All manually entered data (e.g., field data) will be proofed 100 percent against the original. Electronic data will be checked 100 percent after loading against laboratory data sheets for completeness and spot checked for accuracy. " . ' D.3 Reconciliation with User Requirements ' D.3.1 Comparison to Measurement Objectives The field and laboratory data collected during this investigation will be used to achieve the objectives identified in Section A.7 of this QA/QC Plan. The QC results associated with each analytical parameter for each matrix will be compared to the measurement objectives presented in Section A.7.2 of this Q/VQC Plan. Only data generated in association with QC results meeting the stated acceptance criteria (i.e., data determined to be valid) will be considered usable for decision making purposes. Section: D.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 5 of 7 D.3.1.1 Accuracy Assessment One measure of accuracy will be percent recovery (%Rs), which is calculated for matrix spikes, surrogates, and laboratory control samples (LCSs). Percent recoveries for MS/MSD results will be determined according to the following equation: (Amount in Spiked Sample - Amoimt in Sample) /oR — A:10U Known /anount Added Percent recoveries for LCS and surrogate compound results will be determined according to the following equation: ^ ^ _ Experimental Concentration ^ JQQ Known Amount Added An additional measure of accuracy is blank contamination. The blanks associated with this project are limited to laboratory method blanks; field blanks (e.g., equipment rinsate blanks, trip blanks) are not applicable. The results of the laboratory blanks will be compared to the objectives in stated Section A.7.2 of the Q/VQC Plan. Failure to meet these objectives may indicate a systematic laboratory problem that should be investigated and resolved immediately. Associated data may be qualified and limitations placed on its use, depending on the magnitude of the problem. D.3.1.2 Precision Assessment The RPD between the matrix spike and matrix spike duplicate and field duplicate pair is calculated to compare to precision objectives (Section A.7.2 of this QA/QC Plan). The RPD will be calculated according to the following formula. r,r^r-. {Amount In SttmpU \ - AMOunt In SaMpU 2) RPD = : xlOO 0.5 {Amount in Sample 1 -I- Amount in Sample 2) D.3.1.3 Completeness Assessment Completeness is the ratio of the number of valid sample results' to the total number of samples analyzed with a specific matrix and/or analysis. Following completion' of the analytical testing, the percent completeness will be calculated by the following equation: ^ , (number of valid measurements) Completeness = jcl 00 (number of measurements planned) Section: D.O Date: April 2007 QUAUTY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 6 of 7 Failure to meet the completeness objective will require an assessment to determine if the missing or invalid data are critical to achieving the project objectives. Corrective actions may include resampling or re-analysis, depending on the type of problem, logistical constraints, etc. D.3.2 Comparison to Project Objectives In addition to the comparison described in Section D.3.1, the data obtained will be both qualitatively and quantitatively assessed on a project-wide, matrix-specific, and parameter-specific basis. Factors to be considered in this assessment of field and laboratory data will include, but not necessarily be limited to, the following. • Conformance to the field methodologies and SOPs proposed in the Work Plan and QA/QC Plan, • Conformance to the analytical methodologies provided in the QA/QC Plan, • ; Adherence to proposed sanipling strategy, • Presence of elevated detection limits due to matrix interferences or contaminants present at high concentrations, • Unusable data sets based on the data review-results, • Data sets identified as usable for limited purposes (estimated data) based on the data review results, and • Status of all issues requiring corrective action, as presented in the QA reports to management The effect of nonconformance (procedures or requirements) or noncompliant data on project objectives will be evaluated. Minor deviations from approved field and laboratory procedures and sampling approach will likely not affect the adequacy of the data as a whole in meeting the project objectives. Data that are estimated during the review process will generally be considered usable, although any instances of extreme bias will be evaluated on a case-by-case basis to determine the limitations, if any, of the data usability. Missing or rejected data will be reviewed to determine whether the data is critical to attaining the project objectives. The assessment will also entail the identification of any remaining data gaps and need to reevaluate project decision rules. Section: D.O Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVALACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 7 of 7 This assessment will be performed, by the Consultant technical team, in conjunction with the Consultant Project QA Officer, and the results presented and discussed in detail in the final report. Section; Tables Date: April 2007 QUALITY ASSURANCE/QUAUTY CONTROL PLAN Number: 03060-062-303 REMOVAL ACTION Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 1 of 6 Table A-1 Target Compounds for Additional Waste Stream Characterization Parameters Laboratory Laboratory Project Method Reporting Action Detection Limit Limit Level Metals by SW-846 Method 601 OB (mg/kg) Aluminum 2.2 20 NS Antimony 0,72 2.0 NS Arsenic 0.54 2,0 NS Barium 0.28 20 NS Beryllium 0,02 1,0 NS Cadmium 0.14 0.5 NS Calcium 11 500 NS Chromium 0.17 1.0 NS Cobalt 0.12 5.0 NS Copper 0,24 2.5 NS Iron 4.2 10 NS Lead 0.43 2.0 NS Magnesium 0.6 500 NS Manganese 0,03 1.5 NS Meroury 0.011 0.040 NS Nickel 0.52 4.0 NS Potassium 6.7 500 NS Selenium 0.75 2.0 NS Silver 0.15 1.0 NS Sodium 76 500 NS Thallium 0.8 • 1.0 NS Vanadium 0.13 5.0 NS Zinc 0.4 2.0 NS Cyanide by SW-846 Method 9014 (mg/kg) 0.01 0.24 NS VOCs by SW-846 Method 8260B (iiglkg) Acetone 2.9 10 NS Benzene 0.48 1 NS Bromodichloromethane 0.46 5 NS Bromoform 0.43 5 NS Bromomethane 0.37 5 , NS 2-Butanone (MEK) 2.7 10 NS Carbon disulfide 0.55 5 NS Cartxin tetrachloride 0.95 5 NS Chlorobenzene 0.43 5 NS Chloroethane 1.7 5 NS Chloroform 0.58 5 NS Chloromethane 0.46 5 NS Cyclohexane 1.3 5 NS 1,2-Dibromo-3-chloropropane 2.2 10 NS Dibromochloromethane 0.55 5 NS 1,2-Dibromoethane 0.57 1 NS 1,2-Dichlorobenzene 0.46 5 NS 1,3-Dichlorobenzene 0.49 5 NS Section: Tables Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number; 03060-062-303 REMOVAL ACTION Revision; 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 2 of 6 Parameters Laboratory Laboratory Project Method Reporting Action Detection Limit Limit Level 1,4-Dichlorobenzene 0,46 5 NS Dichlorodifluoromethane 0.79 5 NS 1,1-Dichloroethane 0.48 5 NS 1,2-Dichloroethane 0.54 1 NS 1,1-Dichloroethene 0,69 5 NS cis-1,2-Dlchloroethene 0.67 5 NS trans 1,2-Dichloroethene 0.68 5 NS 1,2-Dichloropropane 0.55 5 NS cis 1,3-Dichloropropene 0.41 5 NS trans 1,3-Dichloropropene 0,39 5 NS Ethylbenzene 0.45 1 NS Freon 113 0.86 5 NS 2-Hexanone 1.4 5 NS Isopropylbenzene 0.47 5 NS Methyl acetate 1.4 5 NS Methylcyclohexane 0,64 5 NS Methyl tert butyl ether (MTBE) 0.56 1 NS 4-Methyl-2-pentanone (MIBK) 2.0 5 NS Methylene chloride 0.69 5 NS Styrene 0.33 5 NS 1,1,2,2-Tetrachloroethane 0.57 5 NS Tetrachloroethene 0.82 5 NS Toluene \ 0.54 1 NS 1,2,4-Trichlorobenzene 0.35 5 NS 1,1,1-Trichloroethane 0.59 5 NS 1,1,2-Trichloroethane 0.54 5 NS Trichloroethene 0.52 5 NS Trich lorof 1 uorom ethane 0.73 5 NS Vinyl chloride 0.65 5 NS m,p-Xylene 0,88 2 NS o-Xylene 0.49 1 NS Xylene (total) 0,49 1 NS SVOCs by SW-846 Method 8270C (^g/kg) 2-Chlorophenol 29 170 NS 4-Chloro-3-methylphenol 42 170 NS 2,4-Dichlorophenol 56 170 NS 2,4-Dlmethylphenol 85 170 NS 2,4-Dinitrophenol 51 670 NS 4,6-Dinitro-o-cresol 29 670 NS 2-Methylphenol 33 170 NS 3&4-Methylphenol 48 170 NS 2-Nitrophenol 41 670 NS 4-Nitrophenol 45 170 NS 2,4,5-Trichlorphenol 50 170 NS 2,4,6-Trichlorophenol 28 170 NS Acenaphthene 17 67 NS Section; Tables Date; April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number: 03060-062-303 REMOVAL ACTION ^ Revision: 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 3 of 6 Parameters Laboratory Laboratory Project Method Reporting Action Detection Limit Limit Level Acenaphthylene 13 67 . NS Acetophenone 21 170 NS Anthracene 13 . 67 NS Atrazine 29 170 NS Benzo(a)anthracene 16 . 67 NS Benzo(a)pyrene 12 67 , NS- Benzo(b)fluoranthene 15 67 NS Benzo(g,h,i)perylene 18 67 NS Benzo(k)fluoranthene 25 67 NS 4-Bromophenyl phenyl ether 17 67 NS Butylbenzylphthalate 25 67 NS 1,1-Biphenyl 16 67 NS Benzaldehyde 37 170 NS 2-Chloronaphthalene 47 67 NS 4-Chloroaniline 21 170 , NS Caprolactam 32 67 • • NS Carbazole 13 67 NS Chrysene 12 67 NS Bis(2-Chloroethoxy)methane 21 67 NS Bis(2-Chloroethyl)ether ' 17 67 , NS Bis(2-Chloroisopropyl)ether 25 .67 NS 4-Chlorophenylphenyl ether 16 67 NS 2,4-Dlnltrotoluene 39 67 NS 2,6-Dinitrotoluene 38 67 NS 3,3'-Dichlorobenzidine 32 170 NS Dibenzo(a,h)anthracene 17 67 NS Dibenzofuran 15 67 NS Di-n-butylphthalate . 21 67 NS Di-n-octylphthalate 28 67 NS Diethylphthalate 14 67 NS Dimethylphthalate 14 67 NS Bis(2-Ethylhexyl)phthalate 43 67 NS Fluoranthene 12 67 NS Fluorene 13 67 NS Hexachlorobenzene 19 67 NS Hexachlorobutadiene 22 67 NS Hexachlorocyclopentadiene 24 670 NS Hexachloroethane 17 170 • NS lndeno(1,2,3-c,d)pyrene 21 67 NS Isophorone 17 67 NS 2-Methylnaphthalene 22 67 NS 2-Nitroaniline 21 170 NS 3-Nitroaniline 26 170 . NS 4-Nitroaniline 23 170 NS Naphthalene 19 67 NS Nitrobenzene 23 67 NS Section; Tables Date; April 2007 QUAUTY ASSURANCE/QUALITY CONTROL PLAN Number; 03060-062-303 REMOVAL ACTION Revision; 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 4 of 6 Parameters Laboratory Laboratory Project Method Reporting Action Detection Limit Limit Level N-Nitroso-di-n-propylamine 21 67 NS N-Nitrosodiphenylamine 14 170 NS Phenanthrene 15 67 NS Pyrene 11 • 67 NS Pentachlorophenol 37 670 NS Phenol 41 170 NS Pesticides by SW-846 8081A ((ig/kg) Aldrin 0.30 1.3 NS alpha-BHC 0.25 1.3 NS beta-BHC 0.29 1.3 NS delta-BHC 0.49 1.3 , NS gamma-BHC (Lindane) 0,27 1.3 NS alpha-Chlordane 0.36 1.3 NS gamma- Chlordane 0.36 1.3 NS Dieldrin 0.34 1.3 NS 4,4'-DDD 0.32 1.3 NS 4,4'-DDE 0.33 1.3 NS 4,4'-DDT 0.41 1.3 NS Endrin 0.33 1.3 NS Endosulfan sulfate 0.36 1.3 NS Endrin aldehyde 0.32 1.3 NS Endosulfan 1 0.36 1.3 Endosulfan II 0.36 1.3 Heptaehlor 0.35 1.3 Heptaehlor epoxide , 0,37 1.3 Methoxychlor 0,45 3.4 Endrin ketone 0.37 3.4 Toxaphene 6.4 17 PCBs by SW-846 Method 8082 (\iglkg) Arochlor-1016 6.4 34 NS Arochlor-1221 20 34 NS Arochlor-1232 18 34 NS Arochlor-1242 11 34 NS Arochlor-1248 12 34 NS Arochlor-1254 16 34 NS Arochlor-1260 6,8 34 NS Herbicides by SW-846 8151A ()ig/kg) MCPA (2-methyl-4-chlorophenoxyacetic acid) 830 3400 NS MCPP (2-(2-methyl-4-chlorophenoxy)propionic acid) 560 3400 NS NS - None specified Method detection limits (MDLs) are updated periodically. The MDLs reported will be the current ones at the time of analyses. Reporting limits are estimated. Actual reporting limits will be adjusted for sample-specific factors (e.g., percent moisture, sample volume). Reporting limits and MDLs for VOCs are based on low-level analyses. Medium-level reporting limits and MDLs are lOOx higher. Section; Tables Date; April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number; 03060-062-303 REMOVAL ACTION Revision; 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 5 of 6 Table B-1 Sample Container, Preservation, and Holding Time Requirements Parameter Container^ Preservation Holding Time ^ PCBs (total) 1 -500-mL wide-mouth Cool 4°C 14 days to extraction, 40 days glass with Teflon-lined from extraction to analysis lid TCLP VOCs^ 1-125 mL wide-mouth Cool 4°G, minimal 14 days to TCLP extraction, 14 glass headspace days from TCLP extraction to analysis TCLP SVOCs, 1-500 mL wide-mouth Cool 4°C 14daystoTCLPexti'action, 7 pesticides, herbicides^ glass days to SW-846 extraction, 40 days from SW-846 extraction to analysis (SVOCs, pesticides, herbicides) TCLP Metals, ignitability, 1-500 mL wide-mouth Cool 4''C 180 days to TCLP extraction; 180 corrosivity, reactivity glass days to analysis (metals); 28 days (Hg); 7 days (reactivity), 2 days (corrosivity); 14 days (ignitability) Cyanide 1-500 mL wide-moutti Cool 4°C 14 days to analysis glass Sulfide 1-500 mL wide-mouth Cool 4°C 7 days to analysis glass Total Metals" 1 -500 mL wide-mouth Cool 4°C 180 days to analysis (28 days for glass Hg) VOCs" 3 EnCores (low-level) • Cool 4°C 48 hours to preservation; 14 days and 1 EnCore (medium from collection to analysis level) SVOCs" 1-500 mL wide-mouth Cool 4°C 14 days to extraction; 40 days giass from extraction to analysis Pesticides" 1 -500 rnL wide-mouth Cool4°C 14 days to extraction; 40 days glass from extraction to analysis PCBs" 1-500 mL wide-mouth Cool 4°C 14 days to extraction; 40 days glass from extraction to analysis Herbicides" 1 -500 mL wide-mouth Cool 4°C 14 days to extraction; 40 days glass from extraction to analysis ^ Laboratory may provide alternate containers as long as the containers meet the requirements of the method and allow the collection of sufficient volume to perform the analyses. ^ Holding time begins from date of sample collection. ^ May be combined into one container. * Refer to Tabie A-1 of the QA/QC Plan for the specific analyte list associated with each analysis. Section; Tables Date: April 2007 QUAUTY ASSURANCE/QUALITY CONTROL PLAN Number; 03060-062-303 REMOVAL ACTION Revision; 2 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 6 of 6 Table B-2 Analytical Methodologies Parameter Methodology PCB Aroclors (total' or per Table 1^) SW-846 Method 8082 TCLP VOCs, SVOCs, herbicides\ SW-846 Methods 1311/8260B/8270C/8081 A/8151 A/6010B/7470A pesticides', metals Ignitability, corrosivity, reactivity' SW-846 Chapter 7 Cyanide^ SW-846 Methods 9012B or 9014 Sulfide^ SW-846 Methods 9030B/9034 Metals^ SW-846 Method 601 OB VOCs^ SW-846 Method 8260B SVOCs^ SW-846 Method 8270C Pesticides^ SW-846 Method 8081A Herbicides^ SW-846 8151A >i ' PCBs (total), TCLP herbicides, TCLF* pesticides, and reactivity will be analyzed only if field screening results indicate positive results for these parameters. ^ Refer to Table A-1 of the QA/QC Plan for the specific analyte list associated with each analysis. ^ Total cyanide and total sulfide may be substituted for reactive cyanide and reactive sulfide. Section; Figures Date: April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number; 03060-062-303 REMOVAL ACTION Revision; 1 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 1 of 2 Figure B-1 Example of Chaln-of-Custody Record CHAIN OF CUSTODY RECORD ENSR Page o) CHent/Projed Name: Projed Location: Analysts Reguested P - V\»a,\< 1 - HCl 4' * - */nt>* Gtai» 2 - H2S0* * G - Clear GUM 3 . MN03 4- Preyed Number; Field Logbook No.: V-VOAV.tf 4-M»OH.4 5-N(OH/tTAc 4 E-EnCW» 6-Ka2SI03 4- 7-4- Sampler (Print Name)/(Affitiat)on): Chain ot Custody Tape Nos: Mqbu CfOm DW - Dftf^^^ig WB»( S - SCI VViV ' WcnlMaw St. ' S uJge Signature Send Results/Repofi to: TAT: GW - GrounO'al*' SO - S«<]vn«ri SW - StilBCB WMr SO - SoM Sr-SKitmWa*»i A-*if W - Wntw L - LnjuW P- PtTXJua G C Sarrpte 0 R Pietd Lab Field Sampla No /Idenbfication Dau Time Con tame* Malru Pieiefv Remwha M A Ftltefed ID P B -A Relinquished by: IPTT* \*9vn^m^xiti) Received by: (Pmi MomeyjA/w^honi Analytical Laboratory (Destination): Date: Dale: Time: Time: Signature: Signature: Retir>quished by. iPm tanww(AfliHcon» Received by: iPfm N«m«>iAff*iB«>on) Dale: Date: Time: Time; Stg nature: Signalure: Relinquished by: (Pmt N»n«yiAA6Mnn) Received by: iPm NjmaKAItiWion) Oate: Date: Sample Shipped Via: Temp blank Time: Tme: Signature: Signature: UPS FedEx Courier Other Yes r Serial No. Section; Figures Date; April 2007 QUALITY ASSURANCE/QUALITY CONTROL PLAN Number; 03060-062-303 REMOVAL ACTION Revision; 1 CROWN VANTAGE LANDFILL SITE, ALEXANDRIA TOWNSHIP, NJ Page 2 of 2 Figure B-2 Example of Custody Seal O u LU < to z LU s ts CO Q ENSR Appendix F Well Abandonment Procedures April 2007 NEW JERSEY • STATE • REGULATIONS TITLE 7 - DEPARTMENT OF ENVIRONMENTAL PROTECTION Chapter 9D - Well Construction and Mamtenance; Sealing of Abandoned Wells g—* Reverse t_B Links Table of Contents Subchapter 1. GENERAL REQUIREMENTS FOR PERMITTING OF WELLS, AND FOR LICENSING OF WELL... ' Section 1. Scope Section 2. Construction Section 3. Applicability Section 4. Severability Section 5. Definitions Section 6. General provisions Section 7. General provisions for well driller licenses ofthe proper class, pump ... Section 8. Application and licensing examination procedures and requirements for well... Section 9. Licensing examination application fees, licensing fees and renewal ... Section 10. State Well Drillers and Pump Installers Examining and Advisory Board Section 11. Well pennits Section 12. Provisions for issuance of emergency well drilling permits Section 13. Provisions for issuance of expedited well drilling pennits ^^^ion 14. Provisions for denial, revocation or cancellation of well permits ^IRion 15. Well record requirements Section 16. Fees for permit to drill well Subchapter 2. REQUIREMENTS AND PROCEDURES FOR THE CONSTRUCTION, INSTALLATION, ... Section 1. Well categories Section 2. General construction requirements for all wells Section 3. Specific requirements for the construction of Category 1 and Category 2 wells Section 4.. Requirements for the construction and maintenance ofall Category 3 wells Section 5. Requirements for the installation of Category 4 wells Section 6. Specific requirements for the instaUation of Category 5 geoteclinical borings Section 7. Minimum distance requirements Section 8. Deviation frora construction standards Section 9. Required materials for sealing the annular space of any well Section 10. Required procedures for sealing the annular space of any well Section 11. Well development and well redevelopment SUBCHAPTER 3. REQUIREMENTS AND PROCEDURES FOR THE DECOMMISSIONING OF WELLS Section 1. General requirements for the decommissioning of all wells Section 2. Specific requirements for the decommissioning of dewatering wells and ... Section 3. Specific requirements for the decommissioning of hand dug wells Section 4. Specific requirements for the decommissioning of Category 5 wells-gcotechnical... pter 4. CIVIL ADMINISTRATIVE PENALTIES; INJUNCTIVE RELIEF; DENIAL, SUSPENSION. Section 1. Purpose Section 2. General provisions Section 3. Administrative orders Section 4. Civil administrative penalties Section 5. Basis for denial of license Section 6. Basis for suspension or revocation of license Section 7. Procedures for civil administrative orders, jassessment of civil... Section 8. Procedures to request an adjudicatory hearing to contest an administrative ... SUBCHAPTER 1. GENERAL REQUIREMENTS FOR PERMITTING OF WELLS, AND FOR LICENSING OF WELL DRILLERS AND PUMP INSTALLERS, PROCEDURES AND PRACTICES OF THE STATE WELL DRILLERS AND PUMP INSTALLERS EXAMINING AND ADVISORY BOARD Top ^ 7:9D-1.1 Scope Unless Otherwise provided by rule or statute, this subchapter shall constitute the rules governing the requirements and standards forthe permitting, construction and decommissioning of wells, the standards and requirements for the licensing ofall well drillers ofthe proper class and pump installers in accordance with N.J.S.A. 58:4A-4.1 etseq., and the activities, duties, procedures and practices of the State Well Drillers and Pump Installers Examining and Advisory Board. Top ^ V 7:9D-1.2 Construction 21^11 rules shall be liberally construed to permit the Department and the Board to discharge their r-^Pbry functions under the "New Jersey Subsurface and Percolating Waters Act," N.J.S.A. 58:4A-4.1 etseq. Top ^ V 7:9D-1.3 ApplicabUity %^(a) This chapter applies to any person, well drilling companies, partnerships, corporations or other entities engaged in pump installation, well or well pump repair, well drilling, well construction and decommissioning of wells and to any person licensed under this chapter, or seeking a license as a well driller or pump installer of the proper class. %i^(b) Nothing in this chapter shall be construed as applying to the drilling of blast holes in quarries or mines or to persons licensed pursuant to, and acting in accordance with The State Plumbing License Law of 1968, P.L. 1968, c.382 (N.J.S.A. 45:140-1 et seq.); or to excavations and certain activities that do not endanger or threaten subsurface or percolating waters or endanger life. Top 7:9D-1.4 Severability If ^^section, subsection, provision, clause or portion ofthis chapter Is adjudged unconstitutional or by a court of competent jurisdiction, the remainder of these rules shall not be affected thereby. Top ^ 7:9D-1.5 Defmitions As used in this chapter, the following words and terms shall have the following meanings unless the context clearly indicates otherwise: ""i^ldoned well" means any well as defined in this section which is not in use, is not properiy I, ^Brained, or no longer serves its intended use as demonstrated by the permit issued for its construction, or any well which endangers or threatens the subsurface and percolating waters by the intrusion of salt water or from any other cause, or endangers life. "Act" means the New Jersey Subsurface and Percolating Waters Act, N.J.S.A. 58:4A-4.1 et seq., as amended. "Administrative authority" means the local board of health having jurisdiction. When water systems serve county. State, or Federal facilities the administrative authority shall mean the Bureau of Safe Drinking Water in the Department. "Annular space" means the space between the well casing/well screen and the wall of the borehole or, in the case ofa multiple cased well, all space(s) between casing(s) and all space between the outer casing and the wall of the borehole. "Apprentice well driller" means any person registered by the Board to work under the supervision of a licensed well driller of the proper class for the specific purpose of training in the practice of well drilling. "Aquifer" means a water-bearing layer of natural earth materials that will yield water in a usable quantity to a well or spring. "Bojrd" means the State Well Drillers and Pump Installers Examining and Advisory Board established mt to the Subsurface and Percolating Waters Act, N.J.S.A. 58:4A-4.1 et seq. "Borehole" means the hole made by driving, jetting, coring drilling, augering or other means into the ground for the purpose of constructing a well pursuant to this chapter. "Boring" or "soil boring" means any hole, any temporarily cased hole or any other such installation using direct-push methods which do not exceed a duration of 48 hours. "Boring log" means a description of the boring including, but not limited to, the depth and nature ofthe material that has been penetrated, water zones and any other data or information required by the Department under this chapter. "Building sewer line" means the pipe extending from the outer wall of a building to a septic tank or approved place of disposal including a public sewer, and the lines to all parts ofthe subsurface sewage disposal system, except those classified as distribution lines. "Casing" means a pipe or tubing installed into a borehole during or after drilling to support the sides of the holes and prevent caving or the entrance of water, gas or other fluid into the hole. "Cesspool" means a covered pit with open-jointed lining into which untreated sewage is discharged, the liquid portion ofwhich Is disposed of by leaching into the surrounding soil, the solids or sludge being retained within the pit. : ^Vd loop geothermal well" means a well or a borehole drilled to a specific depth either singly or in a se^^ wherein a continuous closed loop of pipe is inserted from one well to another for the purpose of non-contact thermal energy transfer from a fluid in the loop to or from the earth. "Commissioner" means the Commissioner of the Department of Environmental Protection. "Confining layer" means a layer of natural earth riiaterials having very low hydraulic conductivity that inhibits the movement of water into and out of an aquifer. "'^•lolidated formation" means a geologic formation where the sands, gravels, clays or other similar • ^Wials have been lithified. These rock formations will cornmonly remain stable around an open borehole without caving. "Coring" means drilling with a hollow bit and core barrel in order to obtain a representative sample of the geologic formation. "Decommissioning" means the permanent closure or sealing of any well in accordance with the procedures set forth in N.J.A.C. 7:9D-3. "Department" means the Department of Environmental Protection. "Dewatering system permit" means a permit to drill well(s) for the installation, operation and abandonment ofa dewatering well or dewatering well point system for temporary construction dewatering projects only. "Dewatering well driller" means a person possessing a New Jersey dewatering well driller's license who has at least three years of experience under the supervision of a New Jersey licensed master or journeyman well driller or dewatering well driller with concentration In the practical construction of only dewatering wells or dewatering wellpoints or who satisfies equivalent experience and other requirements of N.J.A.C. 7:9D-1.7 "Dewatering well" or "dewatering wellpoint" means a well or wellpoint installed for the removal of i_^^d water with the intent of temporarily lowering the water table or aquifer level during construction Oi^^tions. "Disposal field" means a disposal bed or a group of one or more disposal trenches. The perimeter of the disposal field corresponds to the perimeter ofthe disposal bed, or a line circumscribing the outermost edges ofthe outermost disposal trenches and including the area between the disposal trenches. "Distribution box" means a watertight structure which receives sanitary sewage effluent from a septic tank and distributes such sewage effluent in equal portions to two or more pipelines leading to the disposal field. "Domestic well" means a Category 1 well as described in N.J.A C. 7:9D-2.1(a)1, that is used primarily to supply drinking and sanitary water supply for an individual dwelling unit. "Driving" means the pounding of the well casing into the ground. "Dry well" means a covered pit with open-jointed lining through which drainage from roofs, basement floors or area-ways may seep or leach into the surrounding soil. "Geologic log" means a description ofthe materials and drilling conditions encountered during the drilling of a well or boring. hysical log" means the graphic or electronic record of certain physical properties of material, nay include, but are not limited to, measurement of spontaneous potential, resistivity, electro magneti» c response, natural gamma radiation, temperature, caliper, water flow, velocity (sonic) and induced nuclear methods such as gamma and neutron logs. "Ground vyater" nneans water below the land surf'ace in a zone of saturation. "Grout" means any material approved by the Department for use in sealing the annular space of a well during construction, or fbr sealing a well during decommissioning. dug well" means a manually excavated well of permanent nature installed for water supply. "Immediate on-site supervision" means that a New Jersey licensed well driller of the proper class is present on-site during each entire well drilling operation to oversee the. work and perfprmance of any person engaging in or assisting with the operation of the well drilling machine or the construction of any well. On site supervision does not include mobilization and de-mobilization of the well drilling equipment. "Injection well" means a well through which liquid or gas is injected, under pressure or gravity flow, into the ground for the purpose of disposing wastes, maintaining formation pressure, recharging the aquifer, or environmental remediation. "Jetting" means the use of a high pressure stream of air or water to mobilize earth material in advance of penetrating, driving or lowering pf well casing into an aquifer. • "Journeyman well driller"*means a vvell driller possessing a New Jersey journeyman well driller's license who has at least three years of experience under the supervision of a ,Nevv Jersey licensed master or journeyman well driller in the trade, business, or calling of well drilling, with concentration in the practical construction of wells, and the installation and repair of well, pumping equipment and appurtenances thereto, or who satisfies equivalent experierice and other requirements pursuant to N.J.A.C. 7:9D-1.7. ise of the proper class" or "license" means a document issued to a person pursuant to N.J.S.A. \-4.1 et seq. authorizing the individual to engage and perform work in the trade, business, or calling of well drilling, or the installation of well pumping equipment and appurtenances thereto, or the decommissioning of wells. ' . "Maintenance casing" means an inner casing which can be removed to repair or replace the screen which is attached to it. "Master well driller" means a well driller possessing a New Jersey master well driller's license who has at least five years experiencie in the trade, business, or calling of well drillirig, including at least two years of experience as a licensed journeyman well driller in this State, skilled in the planning, superintending, and practical construction of wells, and the installation and repair of well pumping equipment and appurtenances thereto, or who satisfies equivalent experience and other requirements pursuant to N.J.A.C. 7:9D-1.7. • "Monitoring well" means a well used to obserye the elevation ofthe water table or potentipmetric surface, or to measure the. water quality of a water-bearing zone. . , "Monitoring well driller" means a well driller possessing a.New Jersey monitoring well driller's license who has at least three years of experience under the supervision of a New Jersey licensed rriaster, journeyman, or monitoring well driller in the trade; business, or calling of well drilling, with concentration in the practical construction of wells,, or who satisfies equivalent experience and other requirements purayan)UmUc t to N.J.A.C, 7:9D-1.7. ' J^openn loop geothermal well" means a well desigried and installed specifically for use of the earth as a source for heat extraction/rejection. "Oversized borehole" means a borehole which is at least four inches greater than the inside diameter of the casing which is to be inserted. "Pitless well adapter" means a manufactured device designed for attachment to one or more openings through a well casing, and constructed so as to prevent the entry ofcontamination into the well, to r ^^ct water from the well, to protect the water from freezing or extremes of temperature, and to ^ ^Boe access to water system components within the well. "Pitless well unit".means a preassembled device which extends the upper end of a well casing to above grade, provided with a pitless well cap, and constructed so as to prevent the entry of contamination into the well, to conduct water from the well, to protect the water from freezing or extremes of temperature, and to provide access to the well and to the water system components within the well. "Pitless well cap" means a gasketed, watertight, sanitary device that covers and encloses the upper termination of a pitless well unit or the well casing, and is provided with watertight connections for electrical power lines and well vent. "Potable water" means water of a bacteriological and chemical quality conforming to applicable standards and free from impurities in such amounts sufficient to cause disease or harmful physiological effects. "Pump" means mechanical equipment or a device used to remove or emplace fluids from or into a well. "Pump installer" means a person possessing a New Jersey license as a pump installer who has at least one year experience under the supervision of a New Jersey licensed master or journeyman well driller or a New Jersey licensed pump installer, and is qualified to engage in the installation, removal, alteration, and repair of well pumping equipment and appurtenances thereto In connection with any weH, including connecting lines between a well and storage tank or appurtenances thereto, or who ies equivalent experience and other requirements pursuant to N.J.A.C. 7:9D-1.7 of these rules. "Sanitary well seal" means a manufactured device or approved arrangement which is used to cap a well or to establish or maintain a watertight junction between the well casing and the piping or equipment installed therein. "Seepage pit" means a covered pit with open-jointed lining material through which septic tank effluent may seep or leach into the surrounding soil. "Septic tank" means a watertight receptacle which receives the discharge of sanitary sewage from a building sewer or part thereof, and is designed and constructed so as to permit settling of settleable solids from the liquid, partial digestion ofthe organic matter, and discharge of the liquid portion into a disposal field or seepage pit "Service line" means a pipe for the transmission or conveyance of potable water under pressure either from an individual well or from a distribution main to a single realty improvement. "Site-wide permit" means a permit to drill well which allows for the construction of an undetermined number of closed-loop geothermal wells or cathodic protection wells or geotechnical borings or dewatering wells or dewatering wellpoints or other types of wells as determined by the Department, restricted to a single lot and block or an easement right-of-way within a single municipality, or a contiguous property of common ownership consisting of multiple lots or blocks within a single municipality. o^n)orer" means a person possessing a New Jersey soil borer's license who has at least three years of experience under the supervision of only a New Jersey licensed master or journeyman well driller or soil borer or monitoring well driller with concentrations in the practical construction of borings, or who satisfies equivalent experience and other requirements pursuant to N.J.A.C. 7:9D-1.7. "Sub-account" means a special dedicated non-lapsing account established pursuant to N.J.S.A. 58:4A- 14.1(b) that may be used by a licensed well driller or licensed pump installer to cover permit or license renewal fees. \on line" means a pipe which conveys water at less than atmospheric pressure from a well to a pump. . " • , "Test well" means any well which is drilled, bored, cored, or othenwise constructed for temporary use in obtaining data for engineering or for geophysical or geological exploration or evaluating aquifer potential or quality for a specific use. "Unconsolidated formation" means a geologic formation where the sands, gravels, clays or other similar materials are loosely arranged. These formations will commonly not remain stable around an open borehole. ^ "Undersized borehole" means a borehole which is no larger than the inside diameter of the well casing and is constructed for emplacement of a well. .V "Well" means a hole or excavation larger than four inches in diameter or a hole or excavation deeper than 10 feet in depth that is drilled, bored, cored, driven, jetted, dug, or othenA/ise constructed for the purpose of removal or emplacement of, or investigation of, or exploration for, fluids, water, oil, gas, minerals, soil, or rock, or for the installation of an elevator shaft. "Well driller" means a person possessing a New Jersey license as a well driller ofthe proper class who engages in drilling, digging, driving, boring, coring, jetting, or other construction or repair of any well, andjn the installation, removal, alteration, and repair of well pumping equipment and appurtenances |o in connection with any well, including connecting lines between a well and a storage tank or tenances thereto. "Well drilling" means any operation or activity involving the drilling, constructing, installing, repairing, replacing, modifying, stimulating or sealing of any well. "Well permit" means a written approval issued by the Department to a licensed well driller and a property owner which, authorizes a licensed well driller of the proper class to construct a well or wells. "Well pit" means a below ground chamber or vault for the purpose of enclosing and providing access to a wellhead which terminates below grade. "Well record" means the form to be completed by the well driller, depicting the construction details of any well provided by the Department at the time of well permit issuance. "Well stimulation" means the stimulation of a well to increase its productivity. Stimulation techniques include, but are not limited to, blasting, hydro-fracturing, chemical treatment, surging, and dry-icing. "Well water system" means a system which derives water from a well to supply potable or non-potable water for any purpose. Top ^ .6 General provisions %)-s,(a) No person shall drill, construct, install, repair, replace, modify, stimulate or decommission any well or engage in such business without possessing a valid New Jersey well driller's license ofthe proper class unless that activity Is performed under the direct and immediate on-site supervision of a New Jersey licensed well driller of the proper class issued by the Department. %i^(b) No person shall drill, construct, install, or replace a well without first having obtained a well permit pursuant to this chapter, except in the case of an emergency under N.J.A.C. 7:9D-1.12. ^|l) No person shall install, repair or replace a well pump or well pumping equipment or engage in such business without being or employing a New Jersey licensed pump installer or a New Jersey licensed well driller of the proper class. %i^(d) No person shall conduct any operation involving the drilling, coring, boring, driving, jetting, digging or other construction or repair of any well pursuant to N.J.A.C. 7:9D:-1.11 without the immediate on-site supervision of a licensed well driller of the proper class. The name of the well drilling company shall be displayed on the equipment used by such driller. 1. There shall be one licensed well driller of the proper class on site for each well drilling rig on site. %i^(e) No well driller shall perform any well drilling operation without maintaining the area surrounding the operation in a sanitary condition and providing proper containment of all materials and surface drainage away from the well. Top ^ ^ i?B 7:9D-1.7 General provisions for well driller licenses of the proper class, pump installer licenses and apprentice registrations |) Well driller licenses are classified as master well driller licenses, journeyman well driller ' 3S, monitoring well driller licenses, dewatering well driller licenses, and soil borer licenses. The Department may establish other license categories of the proper class as deemed necessary by recommendation ofthe Board. The authority to conduct the well drilling activities for each license ofthe proper class is established as follows: %^ 1. A master well driller is authorized to: %i^i. Drill, construct, install, repair, replace, modify, stimulate, or disconnect a well of any category; Install or replace well pumping equipment and appurtenances, storage tanks and appurtenances and connecting lines between a well and storage tank; iii. Perform yield and drawdown testing of wells; ^ lii^, iv. Supervise three or more journeyman well drillers and apprentice well drillers and sponsor apprentice well drillers; %^v. Certify public non-community and non-public well water systems where the mains are less than four inches in diameter; %i^vi. Certify that a well has been drilled, constructed, installed, repaired, replaced, modified, or stimulated in conformance with all applicable State and well drilling and pump installation standards; %^vii. Qualify as a candidate to be appointed to the Board; %^ viii. Perform field observations to verify qualifications of applicants for all licenses covered by this chapter; and %^ix. Seal and decommission any well in compliance with N.J.A.C. 7:9D-3. 2. A journeyman well, driller is authorized to: %^i. Drill, construct, install, repair, replace, modify, stimulate, or disconnect a well of any category except public community supply wells; %i.ji. Install or replace well pumping equipment and appurtenances, storage tanks and appurtenances and connecting lines between a well and storage tank; %^iii. Perform yield and drawdown testing of wells; %^iv. Seal and decommission any well in compliance with N.J.A.C. 7:9D-3; %.^v. Qualify as a candidate for apppintment to the Board; and %^vi. Sponsor apprentice well drillers. %^ 3. A journeyman (Class B) well driller is authorized to: %^i. Drill, construct, install, repair, replace, modify, stimulate, or disconnect a well of any . category except public community supply wells and Category 3 wells; %^ii. Install or replace well pumping equipment and appurtenances, storage tanks and appurtenances and connecting lines between a well and storage tank; %)^ iii. Perform yield and drawdown testing of wells; %i^iv. Seal and decommission any well, except Category 3 wells, in compliance with N.J.A.C. 7:9D-3; %^v. Qualify as a candidate for appointment to the Board; and %]^vi. Sponsor apprentice well drillers. %]„4. A dewatering well driller is authorized to: %^i. Drill, construct, install, replace, modify, stimulate or disconnect any dewatering well or dewatering wellpoint which does not penetrate a confined aquifer; ii. Seal and decommission only dewatering wells or dewatering wellpoints which have not penetrated any confining layers; iiiiii. Qualify as a candidate for appointment to the Board; and iv. Sponsor apprentice well drillers. 0^5. A soil borer is authorized to:. ii^i. Drill and install any Category 5 well; ii. Seal and decommission only Category 5 wells in compliance N.J.A.C. 7:9D-3; iii. Qualify as a candidate for appointment to the Board; and iv. Sponsor apprentice well drillers. 6. A monitoring well driller is authorized to: %^i. Drill, construct, install, repair, replace, modify, stimulate, or disconnect any Category 3 and Category 5 well which does not require permanent well pumping equipment; %^ ii. Seal and decommission any Category 3 and Category 5 well in compliance with N.J.A.C. 7:9D-3; %i^iii. Qualify as a candidate for appointment to the Board; and lii^iv. Sponsor apprentice well drillers. %^(b) An apprentice well driller is authorized to perform well drilling work as a well driller only under the immediate on-site supervision of a master or journeyman well driller, or well driller of the proper class. %-s.(c) A pump installer Is authorized to: %^ 1. Install or replace well pumping equipment and appurtenances, storage tanks and appurtenances and connecting lines between a well and storage tank; '"^^^i^ 2. Perform yield and drawdown testing of wells; and 3. Qualify as a candidate for appointment to the Board. %^(d) A licensed well driller of the proper class or a pump installer shall at all times during any operation have in her or his possession the valid license ofthe proper class. Top ^ TT- 7:9D-1.8 Application and licensing examination procedures and requirements for well driller licenses of the proper class, pump installer licenses, and apprentice registrations %i^(a) An applicant for a New Jersey master well drilling license shall: 1. Submit a complete application on the form prescribed by the Department pursuant to (1) below and satisfy all experience and other requirements specified by this subchapter and provide evidence of the following: %^i. Five years of well drilling experience, ofwhich two years must be as a licensed New Jersey journeyman well driller; and ii. That he or she has resolved any revocation or suspension of a previously issued well drilling license or settled any outstanding violation or fine pursuant to the Act; 2. Obtain a passing grade of at least 80 percent on each portion of the written examination for the master well driller license administered; and %)^3. Satisfy all licensing requirements as set forth in this chapter. %^(b) An applicant for a New Jersey journeyman well drilling license shall: 1%^ 1. Submit a completed application on the form pr^eschbed by the .Department pursuant to (1) below and satisfy all experience and other requirements specified by this subchapter and provide evidence of the following: : %^ i. Three years of well drilling experience as an apprentice well driller under the supervision of a master or journeyman well driller. This informatipn shall be submitted on the Department's apprentice work log form and shall specify dates arid descriptions of work and the name of the supervising master or journeyman well driller; li^ ii. A written recommendation of the master or journeyman well driller who has agreed to sponsor the applicant; Infill. A high school diploma or G.E.D.; •IE^ iv. That he or she has resolved any revocation or suspension of a previously issued well drilling license or of any outstanding violation orifine pursuant to the Act; arid %..v. Any applicant that does not possess the required experience in the State of New Jersey shall submit evidence that he or she Is in possession of a valid National Ground Water Association Certification (NGWA) in the appropriate well drilling category, evidence of three years of drilling experience in any,other state, and any other requirements deemed necessary by the Board for such applicants; . %^2. Obtain a passing grade of at least 80 percent on each portion ofthe written examination for the journeyman well driller license administered; and %^.3. Satisfy alMicensing requirements as set forth in this chapter. . ^ %^ (c) An applicant for a New Jersey dewatering well drilling license shall: %^ 1. Submit a cbmpleted application on the form prescribed by the Department pursuant to (1) below and satisfy all experience and other requirements specified by this subchapter and provide evidence of the follovvirig: %^i. Three years of experience drillirig and sealing dewatering well or dewatering wellpoints as an apprentice vvell driller under the supervision of either a master or journeynrian well driller or licensed dewatering well driHer; %i.Ji. A high school diploma or G.E.D ; and %i^iil. That he or she has, resolved any revocation or suspension of a previously issued license of the proper class or any outstanding violation Pr fine pursuant to the Act; li^ 2. Obtain a passing grade of at least 80 percent on each portion of the written examination for the dewatering well drillers license administered; and fc.;, 3. Satisfy all licensing requirements as set forth in this chapter. %)^(d) An applicant for a New Jersey soil borer license shall: , 1. Submit a completed application on the form prescribed by the Department pursuant to (1) below and satisfy all experience and other requirements specified by this subchapter and provide evidence of the following: Three years of experience drilling and sealing borings as an apprentice well driller under the supervision of either a master or journeyman well driller, licensed soil borer or monitoring well driller; %^ ii. A high school diploma or G.E.D.; and iii. That he or she has resolved any revocation or suspension of a previously issued license of the proper class or any outstanding violation or fine pursuant to the Act; %i^2. Obtain a passing grade of at least 80 percent on each portion of the written examination for the soil borer license administered; and 3. Satisfy all licensing requirements as set forth in this chapter. (e) An applicant for a New Jersey monitoring well drilling license shall: 1. Submit a completed application on the form prescribed by the Department pursuant to (1) below and satisfy all experience and other requirements specified by this subchapter and provide evidence of the following: i. Three years of well drilling experience as an apprentice well driller under the supervision ofa master or journeyman well driller or a monitoring well driller. This information shall be submitted on the Department's apprentice work log form and shall specify dates and descriptions of work and the name of the supervising master or journeyman well driller or monitoring well driller; ii. A written recommendation of the master or journeyman well driller or monitoring well driller who has agreed to sponsor the applicant; iii. A high school diploma or G.E.D.; iv. That he or she has resolved any revocation or suspension of a previously issued well drilling license or of any outstanding violation or fine pursuant to the Act; and %v^v. All applicants that do not possess the required experience in the State of New Jersey shall submit evidence that he or she is in possession of valid National Ground Water Association Certification (NGWA) in the appropriate well drilling category, evidence of three years of drilling experience in any other state, and any other requirements deemed necessary by the Board for such applicants; %i^2. Obtain a passing grade of at least 80 percent ori each portion ofthe written examination for the monitoring well driller license administered; and %^ 3. Satisfy all licensing requirements as set forth in this chapter. An applicant for a New Jersey apprentice well driller registration shall: 1. Submit a completed general application on the form prescribed by the Department pursuant to (1) below and provide evidence of the following: i. Proof that the applicant is at least 18 years of age; and tn^ ii. A signed statement by a New Jersey licensed well driller of the proper class stating her or his willingness to sponsor the apprentice's training in the appropriate well drilling category. (g) An applicant for a New Jersey pump installers license shall: 1. Submit a completed application on the form prescribed by the Department pursuant to (1) below and satisfy all experience and other requirements specified by this subchapter and provide evidence of the following: %^ i. One year of experience in the installation, removal, alteration and repair of well pumping equipment and appurtenances under the supervision of either a master or [ journeyman well driller or New Jersey licensed pump installer; %i^ii. A high school diploma or G.E.D.; and %^ iii. That he or she has resolved any revocation or suspension of a previously issued license of the proper class or any outstanding violation or fine pursuant to the State Act; %i^2. Obtain a passing grade of at least 80 percent on each portion ofthe written examination for the pump installer's license administered; and 3. Satisfy all licensing requirements as set forth in these rules. J^jjb) The Department shall review each application upon receipt of all the information required in (1) r^Pp and either notify the applicant of any deficiencies or notify the applicant of her or his eligibility to take the appropriate examination. Applicants for apprentice registration will be notified ofthe sufficiency or insufficiency of their applications. 1. The Department shall grade all examinations and submit the results to the State Well Drillers and Pump Installers Examining and Advisory Board. 2. The Board shall review the results of each examination at the next regulariy scheduled meeting and certify the findings to the Commissioner or designee. %i^(i) The Department shall notify all applicants ofthe results of their examination. %i^(j) The Department shall issue the appropriate license to successful applicants upon full payment of the appropriate initial license fee in N.J.A.C. 7:9D-1.9. %i^(k) An unsuccessful applicant may review his or her examination at the Department during normal working hours for a period of 30 days from the date of written receipt of their examination results. %i^(l) Applications for a license under this section shall be submitted on a form prescribed by the Department and shall Include the following: %^ 1. Name, address, age, and daytime or work telephone number; 0^2. Social security number; i. Under the New Jersey Child Support Act, N.J.S.A. 2A:4-30 et seq., disclosure of applicant's social security number is mandatory. The social security number shall be used solely for the purpose of an internal unique identifier; 3. Education; tu-s, 4. Work experience; v, , 5. Verification of work experience; and %E-^6. A signed and notarized Oath of Applicant stating as follows: "I certify under penalty of law that the information provided in this document is true, accurate and complete. I am aware that there are significant civil and criminal penalties for submitting false, inaccurate or incomplete information, including fines and/or imprisonment." If, at anytime, the Department finds information or evidence that an applicant obtained a license under false pretenses, such findings shall render the license null and void. (m) All applicants for a well drillers license, other than those applying for a master well driller license or those who satisfy out-of-State experience requirements, shall meet the apprentice well driller experience requirement. This requirement shall not apply to any applicant who applies for said examination from September 4, 2001 through September 4, 200,4 provided the applicant has satisfied all other requirements as set forth in this subchapter. Top ^ 7:9D-1.9 Licensing examination application fees, licensing fees and renewal requirements for all well driller licenses of the proper class and pump installer licenses and apprentice registrations, and establishment of special dedicated non-lapsing account %i.4a) All classes of well driller licenses and pump installer licenses shall be renewed once every three vQ^lon a schedule which applies to all licensees. Renewals shall be made by submitting the renewal •"^provided by the Department and the renewal fee prior to June 30. %i^(b) A non-refundable $35.00 application fee is required with all applications made for any licensing examination and shall be made by check or money order payable to "Treasurer, State of New Jersey" and submitted to the Department. %i^(c) The initial and renewal fees for all licenses of the proper class and fees for apprentice registrations and late renewals are as follows: 1. Master well driller's license $75.00 2. Journeyman well driller's license $75.00 3. Dewatering well driller's license $75.00 4. Soil borer's license $75.00 5. Monitoring well driller's license $75.00 6. Pump installer's license $75.00 ^^pprentice registration $30.00 8. Late renewal fee $10.00 %^(d) A licensee whb fails to renew his or her license prior to the June 30 renewal payment deadline may have his or her license renewed by payment, of the appropriate renewal fee and late payment fee within six months following the renewal date of the license. .^^) A licensee who fails to renew his or her license within six months following the renewal date of the license shall not have the license reinstated until he or she successfully passes the written examination prescribed by the Department for applicants for a new license of the proper class. %^(f) A special dedicated non-lapsing account is established by the Division of Budget and Finance within the Department into which any licensed individual may deposit funds to cover well permit and license renewal fees. Sub-accounts shall be established for each individual licensee or company, if specifically requested. Upon authorization of the licensee, the Department shall withdraw well permit application fees or license renewal application fees from the appropriate sub-account. Top ^ 7:9D-1.10 State Well Drillers and Pump Installers Examining and Advisory Board %^ (a) The nine members of the State VVell Drillers and Pump Installers Examining and Advisory Board are appointed by the Commissioner or his or her designee. %i-i,(b) The Board shall be composed ofthe following: 1. Three master well drillers whose collective experience represents each geologic area of the State and each drilling method allowed under this chapter; ^2. One member who is a well driller in any classification established by the Department; 3. One member not employed by the State and who has no pecuniary involvement in well drilling or pump Installing; , %^4. Three representatives of the Department; and %^ 5. One licensed pump installer. %i^(c) All Board members shall be appointed for a term of three years with three members appointed or reappointed each year. 1. A Board member may be removed by the Commissioner upon a determination that the Board member exhibited misconduct, incompetence, neglect of duty or for other good cause shown. %..,(d) Board members, except for those vvho are Department employees, shall receive reimbursement for travel expenses in accordance with departmental policies and procedures which the Department determines are necessary and Incident to the position. %i-.,(e) At least once each year, the Commissioner shall call for meetings ofthe Board, having a quorum of five or more members of which at least three shall be licensees. '\m^ The duties of the Board shall include, but not be limited to, the following: 1. Examining the qualifications and experience of all persons applying for any well driller license of the proper class, pump installer license or apprentice registration; %i^2. Certifying all applicants scheduled for a license examination and certifying the results of any examinations administered pursuant to N.J.A.C. 7:9D-1.8 to the Commissioner; 3. Recommending to the Commissioner appropriate new rules or amendments to this hapter; 4. Advising the Department regarding any enforcement actions or any complaints against licensed well drillers, licensed pump installers, apprentice well drillers, or any person pursuant to this chapter; and %^ 5. Periodically reviewing and modifying the contents of the examinations administered pursuant to N.J.A.C. 7:9D-1.8. Top ^ 7:9D-1.11 Well permits %^(a) Except where the emergency procedures set forth in N.J.A.C. 7:9D-1.12 apply, the owner or authorized agent ofthe land on which the well drilling activity is conducted and the New Jersey licensed well driller of the proper class shall sign and obtain a valid New Jersey well permit from the Department prior to drilling, constructing. Installing, physically altering, or redesignating the use of any well. (b) The use of a well may not be redesignated pursuant to (a) above unless the well driller is able to verity that the well to be redesignated satisfies all applicable construction standards established for the new use of the well. r) A licensed well driller may obtain a site-wide permit when installing dewatering well point systems, closed-loop geothermal well systems, cathodic protection wells, or soil borings. %^(d) Well permits are valid for a period of one year from the date of issuance except for well permits issued for domestic use which are valid for a period of two years. ^ li^ 1. If the well is not constructed within the appropriate period, a new well permit shall be obtained from the Department prior to the start of any well drilling activity. %^(e) Original State well permits or copies thereof shall be available on-site af all times for inspection by any authorized local and/or State representative. %^(0 A State well permit shall be required prior to the construction of all wells as described in N.J.A.C. 7:9D-2, regardless of well diameter and total well depth except for those wells described in (g) and (h) below. 1 . All wells requiring a permit to drill shall be completed on the forms prescribed by the Department giving the owner's name and address, name of facility, well driller's name and address, the proposed diameter, the proposed depth, the proposed pumping capacity, the type of well, the proposed location of well in relation to any building structure and potential sources of contamination, the date of application, the signature of owner, signature of well driller and registration number of the well driller who has submitted the application form. ) As provided by N.J.S.A. 58:4A-14a(2), the following activities may be conducted by a well driller without an individual permit issued by the Departmerit: 1. The repair of any well to include redevelopment or in kind well screen replacements; %^ 2. The installation of pitless well, adapters; 1.' Pitless well adapters may also be installed by licensed pump installers without an individual permit. '%i-s,3. Test borings and any Category 5 wells which are 50 feet or less in total depth and 8.5 inches or less in borehole diameter; %]^4. Cathodic protection wells vvhich are 50 feet .br less in total depth and six inches, or less.in borehole diameter; and %i„5. Dewatering wells or dewatering wellpoints which are 25 feet or less in tptal depth and six inches or less in borehole diameter. %^(h) Any activity performed pursuant to (g) above shall tje performed and cornpleted by a licensed well driller of the proper class and any resulting well shall be decommissioned in accordance with N.J.A.C, 7:9D-3 except that no well abandonment report shall be required, %^(i) Where appropriate, the Department shall, as a condition of a well permit, require that a well driller comply with one or more of the following cpnditions: ; ' 1. Limit or modify the depth, screened interval or open hole Interval, design, well location and/or specify special or alternative cpnstruction methods used; %^2. Provide advanced notice of drilling in prder to allow for the inspection of the well site by authorized representatives and/or provide for the taking of geophysical logs, geologic or water samples as necessary; and/or %^3. Any requirement deemed necessary by the Departnient to protect public health and/or the subsurface and percolating waters of the State., %^G) The owner of the property on which a vvell is drilled shall be responsible for ensuring that all information provided on the well permit application is true, accurate and complete. In cases where the licensed well driller or pther authorized agent signs for the owner, he or she shall assume the owner's responsibility for the information on the permit application. ' (k) The well permit application shall be returned without review to the licensed well driller if the Department determines that: %^ 1. The application Is incomplete, contains inaccurate information, lacks sufficient information or is illegible; %)^2. The application is not accompanied by a check or money order made payable to the "Treasurer, State of New Jersey"; or 3. Insufficient funds are available in the specified sub-account authorized for well permit application fee payment. . %^(1) Any request for deviation from standards pursuant to N.J.A.C. 7:9D-2.8 shall be submitted to the Department <5Q.^ Top ^ "V 7: 9D-1.12 Provisions for issuance of emergency well drilling permits %i-s,(a) The Department may issue an emergency well permit to minimize actual or avert potential harm to human health, the environment, or property. ''']^k) A licensed well driller requesting an emel-gency well permit under this section shall contact the I. ^Bfftment on the day of the emergency or, when the emergency occurs after business hours, on a weekend or on a holiday, the next working day thereafter. The Department must receive a completed well permit application from the well driller. 1. Within five business days of the emergency well permit number issuance, the licensed well driller shall submit to the Department a completed well permit application. %^ 2. The application shall include a clear and concise factual description of the nature and scope of the emergency and verification upon request by the Department. %i.s,(c) The Department, upon issuance of an emergency permit, shall assign to the licensed well driller an emergency well drilling permit number and specify the date of approval. The licensed well driller shall make the permit number and approval date available for any on-site inspection by any authorized local. State or Federal representative. Top ^ 7:9D-1.13 Provisions for issuance of expedited well drilling permits %iT.(a) The Department may issue an expedited well permit for those well permit applications initially received via telefax machines or other electronic media. The expedited permit processing service can'^ b^l^ized only in conjunction with the special dedicated non-lapsing account established under ^~^Pc. 7:9D-1.9(f) or any other Department-approved payment method. %^(b) A licensed well driller requesting an expedited well permit under this section shall properiy complete the appropriate well permit application forni and send a copy to the Department via telefax machine or other electronic media. %i-a(c) Upon receipt of a properiy completed permit application via electronic media, the Department shall verify that sufficient funds exist in the driller's sub-account to cover the appropriate well permit fee and the additional fee forthe expedited service as per N.J.A.C. 7:9D-1.16(b). Upon this finding, the Department shall transmit an approved copy ofthe well permit to the licensed driller via telefax machine or other electronic media. %)^(d) The well driller shall submit the completed well permit application form (hard copy) to the Department within five business days ofthe expedited well permit number issuance. The well driller shall assure that the assigned well permit number is properiy noted on the application form. %i'Si(e) An expedited well permit approval may be issued for a public community supply well only in those cases where the Bureau of Safe Drinking Water has issued Its apprdval to construct the well. Top ^ "V 7:9D-1.14 Provisions for denial, revocation or cancellation of well permits ) The Department shall deny the issuance of a well permit upon a determination of the following: 1. The well driller has failed to pay the required initial or renewal licensing fee, pursuant to these rules or the Subsurface and Percolating Waters Act. Such action taken by the Department to deny such well permit applications shall not restrict or prohibit the property owner from securing the services of another New Jersey licensed well driller to obtain a permit to drill well; or 1ii^2. The site where the well is to be drilled is designated by the Department as an area where wells may not be constructed. Including, but not limited to, contaminated aquifers, areas of salt ^water intrusion, and other areas where environmental remediation may be adversely affected by ^1h e construction and/or operation of wells. %^(b) The Department may revoke a well permit upon a determination ofthe following: 1. The permit application contained false or inaccurate information; or %i^2. The owner, well driller or both failed to comply with any requirement of the State Act or this subchapter or has not complied with one or more conditions of the State well permit issued for the particular well. %i„(c) The well driller shall be responsible for cancellation of all approved State well permits which have either expired or In those instances where the well construction was never initiated. All cancellations shall be made by the New Jersey licensed well driller using the fornis prescribed by the Department. ^^ Top ^ ^ 7:9D-1.15 Well record requirements %^(a) All well records shall be maintained as follows: 1. A licensed well driller shall, within 90 days of completion of the drilling, constructing, nstalling, repairing, replacing or modifying any well requiring a permit to drill, file a completed well record on the forms provided by the Department. ,i. A well is completed when all drilling and the physical construction ofthe well has been completed by the well driller. %i^ii. All well records shall be signed by the well driller who actually performed the construction of the well, or provided the on-site supervision of the well construction; %i^2. Where a well is equipped with a pump having a capacity in excess of 70 gallons per minute (gpm) and the equipment is installed afterthe well record has been submitted, the well record shall be amended by the licensed well driller or pump installer and resubmitted to the Department within 90 days of installation of the pumping equipment; and %^3. Well records shall be accurate, complete and legible using the forms prescribed by the Department giving the geologic log (that is, description of materials penetrated during well drilling), the location ofthe well, the date of well construction and date well completed, the size and depth of the well, the diameter of the borehole and well casing installed, the length of well casing, the length of any well screen or open hole interval, a description of all equipment and materials used to construct the well, the static water level and yield ofthe well, information on any permanent well pumping equipment installed by the well driller or pump Installer, name and registration number of the well driller who constructed the well and other such information ertaining to the construction of the well. %i^(b) Where a site-wide permitis issued, one well record form shall be submitted for all wells that are the subject of that permit. '"^^) Non-refundable payment of well permit fees is requii-ed fbr any well requiring a permit to drill p^^iant to the State Act and these rules. Payment shall be made by check or money order, payable to "Treasurer, State of New Jersey" and submitted with the appropriate permit application to the Department. %T,(b) Well permit fees are assessed as follows: %^ 1. Each permit application for any well other than those described in (b)2 below shall be accompanied by a fee of $50.00; %^ 2. Each permit application for a well equipped with a pump capable of producing 70 gallons per minute or more shall be accompanied by a fee of $125.00;. 3. Each site-wide permit application for borings, cathodic protection wells, closed loop geothermal well systems or dewatering well systems shall be accompanied by a fee of $500.00. A site-wide permit shall allow for the construction of 10 or more borings, cathodic protection wells, closed loop geothermal wells, or dewatering wells or dewatering wellpoints for each project area. Where less than 10 borings, cathodic protection wells, closed loop geothermal wells, or dewatering wells or dewatering wellpoints are proposed to be drilled at a site. Individual well permits shall be applied for pursuant to (a)1 above. %^(c) The Department shall annually publish a list of acceptable electronic media for expedited permit pragfissing and the associated additional fee for each individual permit shall be $25.00. SUBCHAPTER 2. REQUIREMENTS AND PROCEDURES FOR THE CONSTRUCTION, INSTALLATION, OPERATION AND MAINTENANCE OF WELLS Top ^ 7:9D-2,1 Well categories lE^(a) The following well categories are forthe purposes of establishing general and specific well construction standards: %^ 1. Category 1 Potable Water Supply Wells: domestic, non-public, public community supply, and public non-community wells; • %^2. Category 2 Non-Potable Water Supply Wells: fire protection, irrigation, test, industrial, livestock, open loop geothermal and injection or recharge wells; %^3. Category 3 Resource Evaluation Wells: monitoring wells, air sparging wells, soil vapor extraction wells, recovery wells, and wells or wellpoints installed for environmental remediation projects; • %^4. Category 4 Special Use Wells: methane gas extraction wells, closed-loop geothermal wells, dewatering wells or dewatering wellpoints, cathodic protection wells, oil and gas exploration wells, elevator shafts and any other such well which may, in the discretion ofthe Department require a permit pursuant to the State Act and N.J.A.C. 7:9D-1.11; and %^5. Category 5 Geotechnicar Wells: test borings, probe holes, uncased holes drilled or othenA/ise constructed for the purpose of obtaining data for engineering and/or geophysical, ^hydrological or geological purposes and borings involving the use of direct-push technologies. Top 7:9D-2.2 General construction requirements for all wells %^(a) The following general construction requirements shall apply to the construction of all categories of wells pursuant to the State Act: 1. A New Jersey licensed vvell driller shall be on-site and directly supervise each well drilling operation, and there shall be one licensed well driller of the proper class on site for each well drilling rig on site; %i^ 2. All water used in the construction, alteration, repair or decommissioning of any well shall be of potable quality; %^3. All well drilling rigs, tools, pipe and other drilling equipment shall be maintained in a clean and operational state to prevent contamination to the well or work site; %]^4. The Department may prohibit for use in the construction or maintenance of any well any material or equipment that may pose a significant hazard to public health, safe drinking water or ground water; %i.^5. Any hazardous waste, including, but not limited to, contaminated casing, cuttings, sediment, displaced water, or free product. generated during the drilling procedure shall be handled in accordance with N.J.A.C. 7:26G; %)^6. No new Category 1 or Category 2 well shall be located or enclosed in a basement or cellar of a building; %^i. No existing well shall be built over by any realty improvement that would inhibit access to the well for any repair, replacement or decommissioning; %)^7. When permanent casing is to be driven into an undersized borehole, the borehole diameter shall be less than the inside diameter of the casing; %^ 8. A drive shoe shall be placed on casing that is to be driven; %)-.,9. When casing is to be installed into an oversized borehole, the borehole diameter shall be at least four inches greater than the inside diameter of the well casing to be installed; %i^10. Where applicable, all annular space between well casings, and the annular space between any casing and borehole, shall be sealed immediately following the setting ofthe well casing, but no later than 24 hours after the well casing has been set in place; (lii^ 11. A temporary outer casing of the same inner diameter as the oversized borehole may be Installed to prevent cave-in provided the temporary casing is removed, If possible, during the sealing of the annular space; 12. A well shall not be screened or gravel packed in more than one water bearing unit or across a confining unit without prior written approval by the Department; %^ 13. Adequate protection shall be provided fbr the top of the borehole and/or the top of the well casing to prevent surface contamination from entering the well during the drilling operation and hen the driller is not at the drilling site; 14. When the drilling of a borehole for any well is temporarily suspended and the rig moves away from the drilling site, the borehole shall be considered abandoned and subject to the decommissioning requirements In N.J.A.C. 7:9D-3; 1ii^15. Once the well has been installed, the well casing shall be securely capped until the pump is installed and/or the well is placed in service or until the well is properiy decommissioned. The cap shall be threaded onto the casing, or be a friction type device which locks onto the outside of the casing, or a blank sanitary well seal, or any other equivalent type of cap as may be approved by the Department; 16. All flowing wells shall be equipped with a water-tight cap which is threaded, slip-on or welded, and a control valve or necessary appurtenances to protect the integrity ofthe well construction and/or wellhead. i. There shall be no overflow of water from the well which may become a public nuisance or violate any other New Jersey State law or regulation; 17. Unsuitable or non-productive wells that cannot be used for their intended purpose shall be decommissioned in accordance with N.J.A.C. 7:9D-3. These include, but are not limited to, wells which are abandoned during construction, are contaminated, exhibit a loss of supply or are damaged; 18. If the Department determines that any well water system, or any appurtenance thereto, is not being properiy maintained, or has deteriorated to such an extent that contamination might enter the well or enter the ground water or constitute a physical hazard, the Department may order work to be performed on the well or appurtenances thereto as is deemed necessary to prevent contamination of the ground water or mitigate the physical hazard; %^ 19. When permanerit well pumping equipment Is required for any well, all installation or replacement work shall be performed by a New Jersey licensed pump installer or New Jersey licensed master or journeyman well driller. All such work shall conform with the standards set forth in N.J.A.C. 5:23-3.16 and 13:31-1.18(a). %i-s,20. Any portion of a well borehole which is drilled into a confining layer or through a confining layer where the deeper aquifer will not be used, shall be considered abandoned and that portion of the well borehole shall be decommissioned and sealed prior to the completion of the well in accordancewith N.J.A.C. 7:9D-3. %^(b) Any well installed in an area of known contamination or salt water intrusion may be required to have double-cased well construction as follows: %^ 1. The outer-most well casing shall be constructed into the first significant confining layer which separates the water supply from any such contamination. This casing shall extend at least 0 feet into the confining layer or to the base of the confining layer; %^2. The annular space between the casing and borehole shall be sealed in accordance with N.J.A.C. 7:9D-2.9 and 2.10. The annular space between all subsequent well casings installed shall also be permanently sealed to protect all underlying aquifers as well as the water supply; and %^3. All wells with casing that extends through salt vyater into fresh water shall be doOble-cased. i53^_ Top ^ ' ^^^.3 Specific requirements for the construction of Category 1 and Category 2 wells %„(a) In addition to the well permitting requirements'in N.J.A.C. 7:9D-1 and the well construction standards in N.J.A.C. 7:9D-2.2, the following requirements shall also apply to all Category 1 wells: %^ 1. All parts ofthe well water systern shall be tested, installed, designed, located, and constructed in accordance with all applicable sections of N.J.A.C. 7:10-12 or 11; %i^2. All wells shall be disinfected pursuant to the applicable requirements of N.J A.C. 7:10-12 or 11; : .. ; . . .. ; ^ . •'• / • , //.,.: ; ; %^ 3. Fpr potable water supply wells installed in unconsolidated formations: * %^ i. All well casing shall be no less than four inches in inner diahieter and no less than 50 feet in depth; ii. The diameter of any well screen shall not be less than two inches; and iii. All wells shall have a minimurn length of 50 feet of grout seal extending from the top of the gravel pack or top of the vveH screen to grade. %^ 4. For potable water supply wells installed in consolidated formations: i. All well casing shall not be less than six inches in inner diameter; li-s, ii. Each well shall have a rriinimum of 50 feet of casing and be constructed with a minimum of 20 feet of casing set into ,unweathered rock; and iii. All wells shall have.a hninimum length of 50 feet of grout seal extending from the bottom of the casing described in (a)4ii above to grade; and %^ 5. All well water systems which may require water treatment pursuant to (a)1 above shall conform with all applicable requirenients set forth in N.J.A.C. 7:10-12 or 11. %^(b) In addition to the well permitting requirements in N.J.A.C. 7:9D-1 and the well construction standards in N.J A.C. 7:9D^2:2, the foilowing requirements shall also apply to all Category 1 and 2 wells: %^ 1. All well casings shall extend a minimum of 12 inches above grade arid shall be equipped with pitless adapters or pitless well units.. The pitless adapter or pitless well unit requirement does not apply to wells equipped with a turbine pump. Exceptions tb this 12 inch requirement are those well casings located in a well pit or pump house where adequate protection from surface drainage or contamination is provided and those located in driveways as flush mount installations provided with a watertight lid; >%^2. All wells shall be equipped with a, down facing casing vent Ipcated at least 12 inches above the flood level. All vents shall be screened to prevent^the entry of Insects; 1E^ 3. Any repairs made to existing wells or pump systeins, where the well head terminates below ground, shall include extending the well casing above the land surface and installing a pitless adapter. Extending the well casing above grade shall be accomplished by either welding additional casing on the existing casing, or the use of a gasketed, water-tight casing adapter which complies with the Pitless Adapter Standard-1997 (PAS-97) Performance Standards document set forth at (a)6ii below; ^%)T.4. The annular space between the casing and the oversized borehole shall be sealed in accordance with the requirements set forth in N.J.A.C. 7:9D-2.9and 2.10; %i^5. All annular space between any well casings shall be sealed, excluding the annular space between a maintenance casing and any permanent casing; and %i^6. All permanent well pumping equipnient, well pump controls, pitless well adapters and pitless well units for Category 1 and 2 wells shall be Installed as follows: %i^i. A pitless well installation shall consist of either a pitless well unit or pitless well adapter, and a pitless well cap or a sanitary well seal; %^,ii. Pitless well units, pitless well adapters and pitless well caps shall be manufactured and installed in accordance with the Pitless Adapter Standard-1997 (PAS-97) Performance Standards ofthe Water Systems Council, incorporated herein by reference, as amended and supplemented. The standard may be obtained from the Water Systems Council, 800 Roosevelt Road, Building C, Suite 20, Glen Ellyn, IL 60137; %iT,iii. The lateral discharge line from the well shall be covered with a minimum of 3.0 feet of earth. In northern portions ofthe State (that is, Passaic, Sussex and Warren counties), additional earth cover to prevent freezing may be necessary; %^iv. The hole used to install the lateral discharge line into the well casing shall be made in such a manner as to provide a watertight connection; 'ta^v. The exterior connection between the adapter and the well casing shall be a water tight seal either welded, threaded, or of a clamp-on gasket type. A clamp-on gasketed adapter shall be installed only on a well casing with a smooth, clean surface; vi. At the point of attachment to the well casing, a pitless well unit shall be field-welded, threaded, or ofthe slip-on type with "O-ring" gasket, and shall be of watertight construction; %^vii. Ifthe connection is by means ofa field-weld, the pitless well unit shall be ofa type specifically desigried for a welded connection; %^viii. Ifthe connection is of the slip-on type with "O-ring" gasket, the surface ofthe well casing shall be smooth and clean; %i.Jx. The field connection between the pitless well unit and the lateral discharge line shall be either threaded, flanged or a mechanical joint, and shall be constructed and Installed so as to be watertight; %^x. Well pumps and appurtenant equipment shall be designed and installed to ensure adequate protection of the water supply and protection against freezing of the water; %^xi. Each well pump shall have a foot-valve or a check valve; %^xil. In a screened well, the well pump setting and suction inlet shall be located so that the pumping level of the water cannot be drawn below the top of the screen; %^xiii. Any well with a yield of less than five gallons per minute (gpm) shall be equipped with a low water level cut-off device; %T,xlv. Any well with a pump capacity greater than the yield of the well shall be equipped with a low water level cut-off device; %i^xv. Whenever possible, pumping equipment shall be designed and located so as to avoid the need for a pump pit. A pump pit, if used, shall be of watertight construction and shall have a drainage system or sump pump installed to prevent flooding; %^xvi. The pumping equipment shall be located so as to permit convenient access for the removal and repair of the pump and related appurtenances; %i^xvii. Each pump shall be mounted so as to minimize vibration and noise and to minimize damage to the pump; %ivxviii; A pressure switch and a thermal overioad switch shall be included on all pump installations; ln^xix. A pressure relief valve is required on all positive displacement pumping systems; and %i^xx. Pump controls or accessories shall either be housed in a secured building or be enclosed in a weather-proof, locked cabinet. %]^(c) All wells installed in unconsolidated formations shall be constructed as follows: IE^ 1. When used, all well screens shall be properly sized to produce water free of sand and silt at the well head to the extent that the sand and silt will not interfere with the intended use and operation of the well water system. %^(d) All wells installed in consolidated formations shall be constructed as follows: %^1. All well casing shall be steel and shall conform to the minimum specifications and requirements set forth in Table 1 of(e)4 below; %^2. All wells shall have a minimum of 50 feet of casing, with a minimum of 20 feet of casing set irito unweathered rock; and %)^3. If broken rock, mud seams, etc., are encountered when drilling below the base ofthe permanent casing, the driller shall pull out the permanent casing, ream the hole to below the problem zone and reinstall the ^ell casing. In those instances or situations where the well driller is unable to remove the permanent well casing, a deviation from the construction standards shall be requested in accordance with N.J.A.C. 7:9D-2.8. %)^(e) All materials used for the maintenance, replacement, repair, or modification of any Category 1 or 2 well shall meet the following requirements: _ %^ 1. All well casing shall be approved for its intended use by the National Sanitation Foundation ^^NSF) and either the American Water Works Association (AVVWA) or the American Society for ^^Testing and Materials (ASTM); lii^2. Outer caslngis and liners shall be ofthe same yvelght and thickness as the permanent casings; %i,a3. Plastic well casing shall conform to the following requirements: %^i. Plastic well casing shall be limited to use in unconsolidated formations; lE^li. Plastic weH casing or screen shall not be driven; ln^ iii. Plastic well casing shall meet the requirements specified in the American Society for Testing and Materials (ASTM) Standard F480-91, "Standard Specification for Thermoplastic Well Casing Pipe and Couplings Made in Standard Dimension Ratios (SDR), SCH 40 and SCH 80," Incorporated herein by reference, as amended and supplemented. The Society's address is 1916 Race Street, Philadelphia, PA 19013; %^iv. ABS casing shall meet the requirements specified in the American Society for Testing and Materials Standard D1527, "Standard Specifications for Acrylonitrile-Butadiene- Styrene (ABS) Plastic Pipe, Schedules 40 and 80," incorporated herein by reference, as amended and supplemented. The Society's address is 1916 Race Street, Philadelphia, PA 19013; %i^v. Plastic well casing shall also meet the requirements ofthe National Sanitation Foundation Standard Number 14; "Plastic Piping System Components and Related Materials," incorporated herein by reference, as amended and supplemented. The Foundation's address is P.O. Box 130140, 789 Dixboro Road, Ann Arbor, Ml 48113-0140; %i^vi. Each length of plastic casing shall be marked in accordance with the ASTM marking specifications noted In ASTM Standard F480 (see (c)3ili above); and %i^vii. Plastic vyell casing may be joined by solvent welding or mechanically joined by threads or other means depending on the type of material and its fabrication. Solvent cement used for solvent welding shall meet the specifications for the type of plastic well casing being used. Solvent cement shall be applied in accordance with the instructions of the solvent and casing mariufacturer; '^.A- Standard steel casing shall be manufactured and installed to conform to ASTM designation A-53 or A-120, or American Petroleum Institute (API) standard Specifications 5A or 5L, incorporated herein by reference, as amended and supplemented. The latter are available from API, Division of Production, 300 Corrigan Tower Building, Dallas, TX 75201. All steel casing shall be manufactured to conform to the American National Standards Institute (ANSI) dimensions and shall conform to the minimum specifications and requirements listed in Table 1 below: TABLE 1 Minimum Steel Casing Pipe Weights and Dimensions Weight (lb. Per foot) Nominal Plain end Threads & Threads Thickness Diameter (inches) Size couplings reamed/ (inches) (Inches) recessed & drifted Outside Inside couplings 10.79 10.89 11.00 .237 4.500 4.026 5 14.62 14.81 15.00 .258 5.563 5.047 6 18.97 19.18 19.45 .280 6.625 6.065 24.70 25.55 .277 8.625 8.071 10 40.48 41.85 .365 10.750 10.020 12 43.77 45.45 .330 12.750 12.090 14 54.57 57.00 .375 14.000 13.250 16 62.58 65.30 .375 16.000 15.250 18 70.59 73.00 .375 18.000 17.250 20 78.60 . 81.00 .375 20.000 19.250 Nominal weight based on length of 20 feet including coupling. %i^,5. Well screens other than those commercially manufactured shall be constructed by creating slots or openings in approved casing materials as specified at (e) above. %i^(f) All gravel or filter packs installed in Category 1 or 2 wells shall conform to the following requirements: 1. All gravel or filter pack placed between the borehole and the well screen shall be clean, washed, and disinfected priorto emplacement, or provisions made for performing disinfection in place. Gravel pack may be disinfected by introducing granular chlorine or chlorine tablets during the gravel pack operation; %i^2. The grain size and gradation ofthe filter material shall be selected to stabilize the aquifer material during well development; %i^3. The gravel pack shall not extend into any confining layer above the screen: 1. For well screens less than or equal to 20 feet In length, the filter pack shall not extend more than 10 feet above the top of the well screen; %^ ii. For well screens greater than 20 feet in length, the filter pack shall not extend more than 50 percent of the length of the well screen itself above the top of the well screen. The filter pack shall not extend more than 50 feet above the top of any well screen; %^4. Gravel refill pipes may be installed if they terminate above the ground surface, are sealed In place, are provided with water tight caps and the well casings are eight inches or greater in diameter; and ,5. The filter-pack or gravel shall be placed around each screen in a manner that will enhance 'well production and assist in preventing sand and silt infiltration through the well screen following well development. Filter materials may be introduced into a well provided that: fe-s, 1. For gravity placement, the filter material shall be poured into the annular space around the screen at a measured and uniform rate; and %^ii. For tremie pipe placement, the filter material shall be placed through a tremie pipe that has been lowered to the bottom ofthe well. %^(g) In addition to the general well permitting requirements in N.J.A.C. 7:9D-1 and the construction r'^jBirements in N.J.A.C. 7:9D-2.2 and 2.3, the following specific requirements shall apply to all open Jeothermal wells constructed for heating and cooling: 1. Unless otherwise approved by the Department, all return water shall be through a return well to the originating aquifer; %)^.,2. All water returned to the originating aquifer shall, except for a difference in temperature and oxygen content, have the same physical and chemical characteristics as were present prior to withdrawal. No corrosion inhibitors, water softeners or other additives shall be added to water that will be returned to the originating aquifer; %-si3. The annular space between the casing and the oversized borehole shall be sealed in accordance with the requirements in N.J.A.C. 7:9D-2.9 and 2.10;and 'tB^A. Wells that also provide a potable water supply shall be constructed according to the requirements specified for Category 1 wells. ijj^^ Top ' 7:9D-2.4 Requirements for the construction and maintenance of all Category 3 wells %..,(a) In addition to the well permitting requirements in N.J.A.C. 7:9D-1 and the general construction snagificatlons in N.J.A.C. 7:9D-2.2, the following specific requirements shall apply to all Category 3 1. The State well permit number shall be prominently displayed and permanently affixed to each well in addition to the site-specific well identification number set forth on. the approved well permit application (for example, MW-1); %i^2. Copies ofthe site-specific well construction requirements shall be maintained at the drilling site by the well driller; %^3. All annular space between the casing and the oversized borehole shall be sealed in accordance with the requirements in N.J.A.C. 7:9D-2.9 and 2.10; ' %)^4. For all monitoring wells, except those used for aquifer pump tests, no more than 25 feet total of well screen shall be Installed and no more than five feet of filter pack shall be placed above the top of the well screen. For all monitoring wells constructed without a screen, except those used for aquifer pump tests, there shall be no more than 25 feet total of open borehole; %i^5. Protective steel casing shall be installed to a minimum depth of three feet below grade, equipped with a steel locking cap and securely set in concrete. This requirement shall only apply to all above grade well installations; %i^6. All flush-mounted monitoring wells shall be constructed with manholes, locking caps, and ^^ealsto prevent leakage of surface water Into the well; and. %^7. Below-grade installations of monitoring wells shall be in accordance with the Department's Field Sampling Procedures Manual, May, 1992, as amended and supplemented. %i^ (b) Category 3 wells in consolidated formations shall be constructed in accordance with the following: I. The borehole drilled to case off the overburden shall extend a minimum of lO.feet into ^^ompetent bedrock; and ' %^ 2. If a well screen and riser pipe are to be installed,,applicable well specifications for wells shall be adhered to pursuant to N.J.A.C. 7:9D-2.2. %^(c) Category 3 wells in unconsolidated aquifers where a confining layer(s) exist shall be constructed, in accordance with the following: %^ 1. The screened interval or the filter pack shall riot extend across the interface of a confining layer and an aquifer. Top ^ TT- 7:9D-2.5 Requirements for the installation of Category 4 wells %^{a) In addition to the well ppr-mitting requirements in N.J.A.C. 7:9D-1 and the well construction requirements in N.J.A.C. 7:9D-2.2, the folloy\/lng requirements apply to all vertical closed loop geothermal wells: , %^ 1. The vertical closed loop geothermal well shall be constructed using a borehole with sufficient diameter to allow for.proper grouting; %^2. The tremie or grout pipe shall be installed with the closed loop upon completion of the borehole. The entire annular space betyveen the clpsed loop and the uncased bprehole shall only be sealed under pressure in accordance with N.J.A.C. 7:9D-2.9 and.2.10 using the following materials: iD^i. High grade bentonite, cementitipus thermally enhanced grout or Thermal Grout 85™ or equal for wells constructed into unconsolidated formations; and ii. Cenrientitious thermally enhanced grotit for wells constructed into corisolidated fornriations; %i^3. The circulating fluids utilized in the closed loop system shall be potable water or an appropriate mixture of potable water with one of the following aritifreeze solutiPns: %i^i. Calcium Chloride; %.ji. Ethanol; %^ iii. Potassium Acetate; %)-jv. Potassium Carbonate; • V. Propylene Glycol; or Vfe^vi. Sodium Chloride; %i^4. Pipe material for the, underground buried pprtion of the heat exchanger shall be 160 psi polyethylene pipe as specified below: ln^i. Polyethylene-All material shall maintain a 1600 psi hydrostatic design basis at 73.4 degrees F per ASTMD-2837, and shall be listed In PPI TR4 as a PE3408 piping formulation. The material shall be a high density, polyethylene extrusion compound having a cell classification of PE345434C or PE355434C with a UV stabilizer of C, D or E as specified in ASTM D-3350 with the following exception: this material shall exhibit zero failures (FO) when tested for 192 or more hours under ASTM D-1693, condition C, as required in ASTM D-3350; . %v5. Buried pipe systems shall be joined so that the resultant assembly is leak-proof using one of the following methods: %]^i. The heat fusion process in accordance with the pipe manufacturer's specifications; or %i>JI. Those joined using the International Ground Source Heat Pump Association (IGSHPA) approved mechanical stab fittings. %^(b) In addition to the well permitting requirements in N.J.A.C. 7:9D-1 and the well construction standards in N.J.A.C. 7:9D-2.2, the following requirements shall apply to all dewatering wells or dewatering wellpoints: %^ 1. Any dewatering well or dewatering wellpoint installed pursuant to N.J.A.C. ]7:9D-1.11(g) or that requires an individual or site-wide well permit shall be installed by a New Jersey licensed well driller of the proper class; %)^2. A dewatering well which penetrates a confined aquifer shall be installed by a New Jersey licensed master or journeyman well driller and constructed in accordance with the requirements In N.J.A.C. 7:9D-2.2; 1i^3. The owner ofthe project requiring a dewatering system is responsible for obtaining all other necessary permits and for the hiring of a licensed dewatering well driller or a New Jersey licensed well driller of the proper class to install and properiy decommission all dewatering wells or dewatering wellpoints; %-s,4. A permit is required prior to the installation of any dewatering well or dewatering wellpoint in accordance with N.J.A.C. 7:9D-1; %i^5. The location and construction specifications for dewatering wells shall be as follows: %i^i. A dewatering well shall be located to facilitate temporary dewatering operations and shall be constructed and maintained to prevent surface flow or any other source of pollution from entering the well; %x,ji. Temporary erosion control measures shall be employed to reduce erosion caused by groundwater diversion including, but not limited to, berms, dikes, drains, soil stabilization matting, diversion channels, baled hay or straw, silt fences or sedimentation basins. All soil erosion control shall be in accordance with Standards for Soil Erosion and Sediment Control in New Jersey (see N.J.A.C. 2:90-1.3); %^ iii. The owner of the project where dewatering is taking place shall be responsible for the repair or replacement of any potable water well system which becomes contaminated, damaged, has reduced capacity, reduced water quality or is otherwise rendered unusable as a potable water well system as a result ofthe dewatering operation. All work shall be in accordance with this subchapter and N.J.A.C. 7:10-12, or N.J.A.C. 7:10-11; and %^6. The requirements forthe installation of dewatering well casings and screens are as follows: i. The wall thickness of the dewatering well casing shall be selected to withstand the forces exerted on the well casing during both installation and removal; %^ii. The dewatering well casing shall extend not less than 12 inches above the working grade of the well, except where the operation is under a vacuum and closed piping is maintained to prevent surface contamination from entering the well; %^iii. The top ofthe dewatering well casing shall be capped with either a sanitary well seal, a metal plate welded into place or a threaded cap from date of installation until it is taken out of service and properly decommissioned. The device shall be constructed so as to prevent pollution or physical injury; iv. The material used between the borehole and the dewatering well casing shall be clean and free of harmful material. Above grade, the material shall be placed around the well casing in a mound to divert surface waters away from the well casing; %i^v. When a gravel pack is not used, any annular space between the well casing and the wall of the borehole shall be sealed from the top of the screen or base of the casing pursuant to N.J.A.C. 7:9D-2.9 and 2.10; %i^vi. Dewatering well screens shall be sufficiently strong and durable to ensure that they may be removed intact from the dewatering well; and %i..vii. The screening ofa dewatering well in more than one aquifer is prohibited. %^(c) In addition to the general well drilling and well permitting requirements in N.J.A.C. 7:9D-1 and 2.^yie following requirements shall apply to the construction of all cathodic protection wells: 1. The borehole shall be at least four inches larger than the diameter of the anode, cathode, or casing to be used; %i^2. The top of a cathodic protection well casing shall be fitted with watertight caps, covers, "U" bends, or equivalent devices or housings to prevent entry of surface water and pollutants. All such covers shall allow venting of gases from the well; and %^3. The annular space between the casing and the oversized borehole shall be sealed in accordance with the requirements in N.J.A.C. 7:9D-2.9 and 2.10. %)^(d) In addition to the general well drilling and well permitting requirements in N.J.A.C. 7:9D-1 and 7:9D-2.2, the following requirements shall apply to the construction of all elevator shafts: 1. Wells constructed or boreholes drilled for the installation of elevator shafts or hydraulic cylinders shall be cased, sealed and maintained in a manner to prevent the vertical movement of water as a source of contamination to any aquifer; %^2. Casing shall either be driven into an undersized borehole or Installed using the oversized borehole method. Ifthe oversized borehole method is used, the borehole shall be at least four inches larger than the casing to be installed; j %i^3. The annular space between the casing and the oversized borehole shall be sealed in '^accordance with the requirements set forth in N.J.A.C. 7:9D-2.9 and 2.10; and %i^4. To prevent any contaminants from entering the ground water at the bottom of the casing, the bottom of the casing shall be: ^ %i^i. Permanently capped prior to installation; or ii. A neat cement plug at least two feet thick shall be Installed at the bottom of the casing in accordance with N.J.A.C. 7:9D-2.9 after it is installed. In addition to the general well drilling and well permitting requirements in N.J.A.C. 7:9D-1 and 2.2, all oil and gas exploration wells shall conform to the installation and reporting requirements pursuant to N.J.S.A. 13:1 M-1 et seq. . Top ^ ^ 7:9D-2.6 Specific requirements for the installation of Category 5 geotechnical borings %i^(a) In addition to the general well permitting requirements in N.J.A.C. 7:9D-1 and any applicable construction requirements in N.J.A.C. 7:9D-2.2, the following specific requirements shall apply to all test borings and borings using direct-push technologies: 1. The driller or borer may request up to 10 individual borings on one permit to drill well application. In this case, a separate well permit number shall be issued for each boring specified on the application," up to 10 well permit numbers per application; or %^ 2. The driller or borer may request any number of borings on one permit to drill well application. In this case, a single site-wide well permit number shall be issued for all borings specified on the application; and %^3. Geotechnical borings involving the use of direct-push technologies shall be installed so as to provide an effective means of decommissioning the borehole in accordance with N.J.A.C. ' :9D-3. 'Sil^ Top ^ TT- 7:9D-2.7 Minimum distance requirements %^(a) All new Category 1 and Category 2 wells shall be located at least five feet horizontally from a building or any portion thereof, except for a pumphouse. %-s,(b) All Category 1 wells and components shall be located no less than the minimum distances prescribed as follows (all distances are in feet): Component Buildingsewer Septic Distribution Disposal Seepage Dry' Cesspool Fuel tank box field pit well Storage tank Well 25 50 50 100 150/100 50 150 25 Suction line 25 50 50 100 100 50 150 - Water 5 10 10 10 10 _ 25 line Note: The 150 foot minimum distance between a well and a seepage pit system shall apply only in those Instances where a new well is being installed in conjunction with a new seepage pit system pursuant to N.J.A.C. 7:9A-4.3. 1. Where gravel, limestone, or fractured, creviced or fissured rock formations are encountered and may pose a threat to the water supply, the local administrative authority may require a greater distance of a well from a subsurface sewage disposal system; 2. A well shall not be drilled within 20 feet of a wood frame building. (c) All Category 2 wells^ shall be located no less than 25 feet from a fuel storage tank. %^(d) Additional minimum distance requirements for any well may be required by the Department as necessary to protect ground water supplies in areas of known contamination. %i^(e) The Department may modify the minimum distances in this section for individual well installations where it has determined that additional controls are necessary to protect water supplies. ' Top ^ ^ III 7:9D-2.8 Deviation from construction standards %^(a) Where unusual conditions occur at a well site and compliance with this subchapter shall not result in a satisfactory well or protection of the water supply, the New Jersey licensed well driller shall request that special standards be prescribed for the particular well. All deviations from standards shall be requested pursuant to N.J.A.C. 7:9D-1.11, shall be in writing, and shall include as appropriate: 1. The purpose of the well construction; %^ 2. The location of the well to include a site plan; ln^ 3. The name, address, and telephone number of the owner; 1l^4. The name, address, and telephone number of the driller; %^5. The unusual conditions existing at the well site; % „6. The reasons that compliance to the rules for minimum standards will not result in a satisfactory well; 7. The proposed method of construction that the well contractor believes shall be adequate for each well; and %^8. A diagram showing the pertinent features of the proposed well design and construction. %^(b) The Department shall provide the driller with written approval ofthe deviation which may include special requirements, or with written denial ofthe deviation citing specific reasons forthe denial. Top -v 7:9D-2.9 Required materials for sealing the annular space of any well ^^) Except with the approval of the Department, pnly the follovying materials shall be acceptable for the sealing of the annular space between the casing and the oversized borehole or between casing(s) of multiple cased wells: %^ 1. Portland Neat Cement in accordance vyith Table 1 below; %^2. Portland Cement and High Grade Bentonite in accordance with Table 2 below; %^ 3. High-Grade Bentonite in accordance with Table 3 below; ^1i^4. Cementitious Thermally Enhanced Grout in accordance with Table 4 below; %^.5. Thermal Grout 85™ or equal in accordance with Table 5 below. Table 1 Portland Cement Type Of Pounds Gallons Target Acceptable Density Range lbs/gal Water/Cement Cement of of Water Density Ratio Cement lbs/gal l&ll 94 5.2 15.6 15.0 to 16.3 0.46 III 94 6.3 14.8 14.2 to 15.5 0.56 Table 2 Portland Cement and High Grade Bentonite; Use Portland Cement Types I or II Only Percent Pounds of Pounds of Gallons of Target Acceptable Water/ P^^iite Bentonite Cement Water Density Density/Range Cement - lbs/gal lbs/gal Ratio 5.3 5.0 94 8.3 13.9 13.4 to 14.5 0.74 Table 3 High Grade Bentonite (Figures Based on 15 to 30 Percent Solids by Weight) Pounds of Target Gallons of Acceptable Target Density Acceptable Bentonite of Water Range Water Density Range (gallons) lbs/gal lbs/gal 50 18 14-34 9.8 9.2 to 10.2 Table 4 Cementitious of Cement Thermally Enhanced Grout Pounds Amount of Pounds of Pounds to Target Target Density of (Type Superplasticizer Dried (Silica 200 Mesh Gallons pf I, II or V) (Sulfonated Sand Sodium Water lbs/gal Napthalene) Conforming to Bentonite • the Sieve Analysis 94 21 ounces per 200 104 6.19 18.2 bag of 200 1.04 cement (not to exceed 29 ounces) S..^^No. Percent Passing (%) (Size, um) ^ 8(2360) ioo; • V" - ••-• 16(1180) 95-100 30(595) , .55-80 • - 50(297) • 30-55 • ' ' 100(149) 10-30 200 (75) 0-10 ; Table5; -.• ^ • • , ^•;/,. .•"•• .- ' ' Thermal Grout 85™ or equai-(Figures based on 63.5 percent solids by weight) Pounds of Pounds of Target Gallons of Acceptable Target EL^^ite Thermal Water Range of Densltylb/gal ^ Enhancement Water Compound . Density (gallons) 54 200 175 . : 17-18 ' 13.1 Cpmpound shall be washed, dried siliCa sand which is graded and shall have less than 20 percent by weight retained on a U.S. Sieve #50,and shall have AFS GFN (American Foundrymen's, Society Grain Fineness Number) between 55.0 and 75.0. The silica content (SI02) shall be greater than 99 percent. %^ (b) All materials shall be accurately measured prior to mixing. The grout material shall have a maximum permeability of 1 x 10'^ centimeters per second yvhen prepared In accordance with manufacturer's specifications. (c) Bentonite products and additives shall be mixed In accordance with manufacturer's specificatlpns. %^ (d) Bentonlte-based grout materials listed in Table 3 and Table 5 shall not be used for sealing any annular space in consolidated formations or in those instances where it will corne in contact with ground water of a pH of less than 5.0 or a total dissolved solids content in excess of 1,000 ppm. ''^^) Where the grout material extends through zones of salt yvater, a salt-water resistant grout ..IK-ial shall be used. ]^ Top ^ ^ 7:9D-2.10 Required procedures for sealing the annular space of any well (a) The annular space within any well shall be sealed in accordance with one of the following methods: For the pressure method, the grout shall be pumped through a tremie pipe installed into the annular space of the well in one continuous operation from the bottom to the top of the annular space unless the depth, resulting pressures, or subsurface conditions necessitate that the grout be installed in lifts; %^i. The tremie pipe shall be slowly raised as the grout is being placed, keeping the discharge end ofthe pipe submerged in the grout at all times until the sealing ofthe annular space is completed; %^ii. When pressure sealing the annular space directly above a filter or gravel pack, the grout shall be discharged from the tremie pipe so as not to disturb the top ofthe gravel pack; %^2. For the inner string method, the grout shall be pumped through a tremie pipe and float shoe installed inside the casing ofthe well in one continuous operation so as to completely fill the annular space; %)^3. The displacement method shall be used only for wells in consolidated formations. A sufficient quantity of grout shall be pumped under pressure through a tremie pipe into the oversized borehole to ensure that the annular space will be completely filled with grout after the emplacement of a plugged casing Into the borehole; pr i%^4. For the casing method (Haliburton Method), the grout shall be forced from the Inside ofthe casing into the annular space utilizing a series of plugs. %^(b) For wells in unconsolidated formations, when the casing is driven into an undersized hole, the provision for sealing shall be waived. %-i,(c) The following procedures shall be followed when sealing the annular space of any well: %^ 1. All water used for the mixing of grout shall be of potable quality; %i^2. All grout mixtures shall be weighed with a mud balance or othenA/ise verified by the well driller of the proper class so as to conform with the requirements in N.J.A.C. 7:9D-2.9; %i^3. The grout mixture shall be brought up to ground level to displace all water and materials in the annular space. Regrouting of a well is acceptable and shall be performed as follows: i. Any settlement of the grout less than 10 feet from the ground surface shall be regrouted and completed by the gravity or pressure method; %^ ii. The driller shall return to the well no sooner than 24 hours nor later than 72 hours and fill all settling; ln^iii. Any settlement of 10 feet or greater shall be regrouted using the pressure method; and li^ iv. The finished level of the grout seal shall be at the level of the pitless well adapter or other connection; and %^4. The grout being discharged from all annular space shall be weighed with a mud balance or otherwise verified by the well driller so as to comply with the requirements in N.J.A.C. 7:9D-2.9. 7.^^2.11 WeU development and well redevelopment %^(a) A well permit is not required for performing any well development or well redevelopment. %^(b) All well development or redevelopment work shall be performed by a well driller licensed In accordance with this chapter. . %^(c) All well development or well redevelopment shall be performed with care so as not to damage the well structure or cause adverse subsurface conditions that may destroy the natural barriers which prevent the movement of poor quality water or contaminants. %)^(d) Acceptable well development/redevelopment methods include: %i^1. Overpumping; 2. Mechanical surging; %^ 3. Air surging; %^ 4. Jetting; 5. Chemical treatment: i. Detergents, chlorine, acids, or other chemicals may be used for the purpose of Increasing or restoring well yield; %^ii. All acids must be specifically designed for use in water well rehabilitation, and shall be used in accordance with the manufacturer's specifications; and iii. The well shall be thoroughly pumped after the completion of development/redevelopment operations to remove such chemical agents or residues; %^6. Explosives: The use of explosives shall be limited to wells constructed in consolidated formations; %^ii. Explosives shall be used by a person licensed pursuant to N.J.A.C. 12:190 by the New Jersey Department of Labor, Office of Safety Compliance Explosive Regulations and only after approval is obtained from the Department; %f ill. The well shall be thoroughly pumped after the completion of development/redevelopment operations to remove such explosive agents or residues; iv. The well to be treated must be a minimum of 150 feet from the nearest wells; and V. The well site owner or the licensed well driller who will conduct the well development/redevelopment, shall notify the owner(s) of any property adjacent to the well site of the development/redevelopment procedure no less than 24 hours prior to the procedure; and %)^7. Hydrofracturing: The use of hydrofracturing technologies shall be limited to wells constructed in consolidated formations; %]^ii. The well to be treated shall be a minimum of 150 feet from the nearest wells; iii. A packer shall be set no less than 50 feet below the bottom of the well casing; and iv. The well site owner or by the licensed well driller who shall conduct the well development/redevelopment shall notify the owner(s) of any property adjacent to the well site of the development/redevelopment procedure np less than 24 hours prior to the procedure. %i^(e) All water used during any selected method or process shall be of potable quality. %i-,(f) All wells which have been subjected to development or redevelopnient shall be free of sand or silt upon completion of development/redevelopment operations. SUBCHAPTER 3. REQUIREMENTS AND PROCEDURES FOR THE DECOMMISSIONING OF WELLS Top ^ 1 General requirements for the decommissioning of all wells %i^(a) The Department may order the decommissioning of any well which: %^ 1. Is abandoned as defined in this chapter; %),^2. Has been constructed in violation of N.J.S.A. 58:4A-4.1 et seq.; %)^3. Has not been maintained in a condition that ensures protection from contamination forthe subsurface and percolating waters of the State; %i^4. Is damaged; lu^ 5. Has been replaced by another well; li^6. Is contaminated; %v, 7. Has salt water intrusion; or ) • %^ 8. Is non-productive. %^) The Department may require or allow a well to be decommissioned by a method other than as ^vth In this subchapter where unusual circumstances are encountered which would prevent aororence with the standard sealing requirements. %^(c) All wells shall be decommissioned by, or under the constant on-site supervision of, a New Jersey licensed well driller of the proper class. %^(d) The well driller shall obtain all applicable well records prior to sealing the well in order to verify the depth and diameter of the well. .'^^^) The Department may require additional information about a well prior to the well being i c ^Pimissioned. Such information may include, but is not limited to, data gathered via geophysical : logging or downhole televising. %^ (f) Any hazardous waste (that is, contaminated casing, cuttings, sediment, displaced water, or free ; product) generated during the sealing shall be handled in accordance with N.J.A.C. 7:26G. i ;%i^(g) The following types of wells shall not be decommissioned until the driller proposing to seal the I: well has obtained approval from the Department: • [ - ' 1. Wells, other than hand dug wells, for which no well record can be obtained; j %^ 2. Wells.that are contaminated with hazardous waste; \ 3. Wells that are affected by salt water intrusion; %^4. Wells installed in unconsolidated formations that are screened in more than one aquifer; 5. Wells which cannot be cleared of all obstructions throughout the entire length and diameter of the well; 6. Multiple cased wells; or 1%^ 7. Elevator shafts. %^(h) All other wells shall be decommissioned as follows: 1. The well shall be cleared of pump, pipe, debris, and all other obstructions; %)^2. Ifthe well has been overdrilied to remove the entire casing, screen, and gravel pack, the resulting borehole shall be constructed to, and maintained at, the original depth of the well until this borehole is properiy sealed in accordance with this subchapter; %i^3. Adequate protection shall be provided for the top of the borehole and/or the top of the well casing to prevent surface contamination from entering the well during the sealing operatiori and when the driller is not at the sealing site; %^4. If it is known that an unsealed annular space exists between the outermost casing and the borehole, the casing shall be perforated, ripped, or removed to insure that this space is sealed; and %i,.,5. All water used in the sealing process shall be of potable quality. %i^(i) The materials specified In N.J.A.C. 7:9D-2.9 shall also be used to seal and decommission wells: 1. Portland Cement in accordance with Table 1 below; %^2. Portland Cement and High Grade Bentonite In accordance with Table 2 below; %^ 3. High Grade Bentonite in accordance with Table 3 below; %-s,4. Cementitious Thermally Enhanced Grout in accordance with Table 4 below; %T.5. Thermal Grout 85™ or equal in accordance with Table 5 below; >%i^ 6. The Department may approve alternate or additional sealing materials; %-s.7. Only those materials or additives specifically designed for well sealing by the manufacturer and approved by the Department shall be used to decommission wells. The material shall have a maximum permeability of 1 x IO''' centimeters per second when prepared in accordance with manufacturer's specifications; %i^8. Bentonlte-based grout materials listed in Table 3 and Table 5 below shall not be used as a sealing material in consolidated formations or in those instances where it will come in contact with groundwater of a pH of less than 5.0 or a Total Dissolved Solids content in excess of 1,000 ppm. Table 1 Portland Cement Type of Pounds of Gallons of Target Density Acceptable Water/Cement Cement Cement Water lbs/gal Density Range Ratio lbs/gal l&ll 94 5.2 15.6 15.0 to 16.3 0.46 94 6.3 14.8 14.2 to 15.5 0.-56 Table 2 Portland Cement/High Grade Bentonite; Use Portland Cement Types I or II Only Percent Pounds of Pounds of Gallons of Target Acceptable Water/ Bentonite Bentonite Cement Water Density Density/Range Cement lbs/gal lbs/gal Ratio 5.3 5.0 94 8.3 13.9 13.4 to 14.5 0.74 Table 3 High Grade Bentonite (Figures Based on 15 to 30 Percent Solids by Weight) Pounds of Target Gallons of Acceptable Target Density Acceptable Bentonite Water Range of Water lbs/gal Density Range (gallons) lbs/gal 50 18 14-34 9.8 9.2 to 10.2 ,9k A Cementitious Thermally Enhanced Grout Pounds of Amount of Pounds of Dried Pounds of 200 Target . Target Cement (Type Superplasticizer Silica Sand Mesh Sodium Gallons of Density I, II or V) (Sulfonated Conforming to the Bentonite Water lbs/gal Napthalene) Sieve Analysis 21 ounces per 1.04 6.19 18.2 bag of cement (not to exceed, 29 ounces) ' Sieve Np. (Size, um) Percent Passing (%) 8(2360) 100 16(1180) 95-100 30(595) 55-80 ^ 50 {297) 30-55 - . 'l6b(149) 10-30 200(75) 0-10 Table 5 .Ti^^al Grout 85™ or equal-(Figures based on 63.5 percent solids by vveight) Pounds of Pounds of Thermal . Target Gallons Acceptable Range Target Density Bentonite Enhancement Compound of Water of VVater (gallons) lb/gal 54 200 17.5 17-18 13.1 Compound shall be washed, dried silica sand which is graded and shall have less than 20 percent by weight retained on a U.S. Sieve #50 and shall have AFS GFN (American Foundryiiien's Society Grain Fineness Number) between 55.0 and 75.0. The silica content (Si02) shall be greater than 99 percent. %i^(j) Sealing materials shall be pumped into the well under pressure through a treniie pipe which discharges at the bottom of the well. If an annular space is being sealed, the material shall discharge at the bottom ofthe annular space. During sealing, the tremie pipe may be raised from the bottom ofthe space being filled in a manner which insures that the discharge end of the tremie pipe is constantly submerged within the column of undiluted sealing niaterial in the well. V . . %^(k) The sealing material shall be pumped into the well until all water has been displaced from the well and until the sealing material overflowing the well has a density within the acceptable'density range for that niaterial. 1%^ 1. Any settlement of the sealing material less than 10 feet from the ground surface shall be resealed by the gravity pr pressure method: %^2. The driller who seals .the well shall, return to the wel| no sooner than 24 hours nor later than 72 hours arid fill all settling in the well with concrete. Additional concrete shall be poured to form a slab which shall encompass the top ofthe casing. This slab shall be located at or below grade. %^ 3. Any settlement of 10 feet or greater shall be resealed using pressure method, prior to placement of the concrete slabs pursuant to (k)2 above. %^(1) The driller who decommissioned the well shall submit a complete, legible Well Abandonment Report on the form prescribed by the Department giving the location and date the well was sealed, the permit number (if applicable) of the well sealed, the property owner name, address, lot and block, the total well depth, the well diameter and well casing materials, a cross-section of the sealed well and a description of the materials used to decommission the well, and the signature, name and registration number of the driller who sealed the well. The Well Abandonment Report shall be submitted with a copy of all applicable well records to the Department within 90 days of the completion of sealing. %^(m) The driller shall obtain Departmental approval prior to deviating from the methods set forth in this subchapter. nS^^ Top ^ 7:9D-3.2 Specific requirements for the decommissioning of dewatering wells and dewatering wellpoints %i^(a) Any dewatering well constructed into confined aquifers shall be decommissioned only by a New Jersey master or journeyman well driller in accordance with N.J.A.C. 7:9D-3.1. %i's,(b) Decommissioning ofall other dewatering wells and dewatering wellpoints shall be performed by the licensed well driller ofthe proper class and shall be completed within five business days afterthe de^tering well or dewatering wellpoint is taken out of service. y^p) The well sealer shall obtain approval from the bepartment prior to instituting any modification in the decommissioning procedures. ' %-s,(d) For all dewatering wells 25 feet or less in depth, that have not penetrated a confining layer, decommissioning shall be completed by employing one of the following methods: 1. If backfilling of the borehole is utilized: 'IE^ i. Backfilling the hole with clean native materials; ii. Tamping the backfill materials in layers to within several feet below proposed finished grade; iii. Placing a minimum of a three foot concrete plug; and %^iv. Backfilling the remaining portion ofthe hole with top soil or native soil materials; or %i^2. If decommissioning with an approved grout material, the decommissioning of the dewatering well or dewatering wellpoint shall be completed in accordance with N.J.A.C. 7:9D-3.1. %^^(e) Ifthe casing and screen are completely removed from a dewatering well which is greaterthan "M||pt in depth but has not intersected a confining layer, the top 25 feet ofthe original borehole shall u^^ared of all obstructions or drilled out to allow for the placement ofa grout plug In accordance with N.J.A.C. 7:9D-3. %i.^1. . . %^(f) Ifthe casing and screen are left in place in a dewatering well greaterthan 25 feet in depth which has not penetrated a confining layer, the enfire well/hole shall be sealed by pumping grout through a tremie pipe from the bottom of the well to the top in accordance with N.J.A.C. 7:9D-3. 1. In order to prevent surface contamination from entering any annular space which has been ^Pgravel packed, the top 25 feet of the gravel pack and casing shall be removed to allow for the placement of a grout plug in accordance with N.J.A.C. 7:9D-3.1. %^(g) Dewatering wells penetrating bedrock shall have that part ofthe well drilled into the bedrock formation sealed with neat cement grout. The balance of the hole shall be sealed in accordance with N.J.A.C. 7:9D-3.1, as applicable. ^31^ Top ^ . 7:9D-3.3 Specific requirements for the decommissioning of hand dug wells %^ (a) Water shall be pumped from the well in order to ensure that no debris lies at the bottom of the well and to minimize settlement of the fill material. %i^(b) The total depth ofthe well shall be sealed using one ofthe following methods: %]^1. The entire well shall be sealed in accordance with N.J.A.C. 7:9D-3.1 using only cement- based sealing materials; or %^2. The well shall be filled with sand or gravel to three feet from the land surface. The sand or gravel shall be thoroughly tamped. The remainder ofthe well shall be filled in with top soil. Additional top soil shall be mounded over the well to allow for settlement. Top ^ "V 7:9D-3.4 Specific requirements for the decommissioning of Category 5 wells-geotechnical borings (a) All borings shall be decommissioned within 48 hours of complefion. %i^(b) Borings less than 25 feet in depth may be decommissioned by backfilling with cuttings and then tamping in order to restore to the maximum extent possible the natural conditions of the site that existed prior to drilling the borings. %^(c) All borings 25 feet or greater in depth shall be decommissioned using an approved sealing material in accordance with N.J.A.C. 7:9D-3.1. (d) The decommissioning of borings installed by direct-push technologies shall be In accordance with this subchapter except as follows: %^ 1. The drive casing may be used as a tremie pipe provided the drive point is ofthe sacrificial type, or the casing is equipped with a grout shoe and is withdrawn as the sealing material Is pumped Into the driven borehole; %.^2. The direct-push device may be removed and a second casing of equal diameter to the kJrive casing may be used as a tremie pipe provided the casing is equipped with a sacrificial ti| 'plug, and is reinserted Into the same hole to the boring's original depth; %i,,3. If an outer casing is simultaneously driven with the direct-push device and inner drive casing and the cone and inner casing are retrieved, the outer casing may be used as tremie pipe; or %1T.4. If the direct-push device and drive casing are retrieved, the borehole may be overdrilied using a hollow stem auger and decommissioned in accordance with this subchapter. SUBCHAPTER 4. CIVIL ADMINISTRATIVE PENALTIES; INJUNCTIVE RELIEF; DENIAL, SUSPENSION AND REVOCATION OF LICENSES; AND REQUESTS FOR ADJUDICATORY HEARINGS Top ^ -TT- 7:9D-4.1 Purpose This subchapter establishes the procedures governing the issuance of civil administrative orders, the assessment of civil administrative penalties and the suspension or revocation of any license issued pursuant to the Act. This subchapter also governs the procedures for the submittal and review and grant or denial of any requests for adjudicatory hearings on appeal from any contested case arising from the implementation of any provision of this chapter. • Top 7:9D-4.2 General provisions %^(a) The Department or the Board may invesfigate any possible violafion of any provision of the Act o^^j^ provision of any rule, permit, license or administrafive order promulgated or issued pursuant '"^Bo including, but not limited to, obtaining a license or permit through error or fraud, exhibiting gross negl^ence, incompetence or misconduct in the practice of well drilling or pump installafion pursuant to this chapter and the Department may take one or more of the following acfions: %^ 1. Suspend a well driller's license or pump installer's license for a period not to exceed one year; %^ 2. Revoke a well driller's license or pump installer's license; %^3. Issue an administrative order; or 4. Assess an administrative penalty. %i^(b) The Department or the Board will also take action against any person who has aided or abetted a violation as set forth in (a) above. Top rr 7:9D-4.3 Administrative orders 1 The Department may issue an administrafive order against any persPn who has violated any pr^^ion ofthis chapter, or any provision of the Act pursuant to which this chapter has been ^mlgated, for one or more of the following purposes: li^ 1. To direct any person to cease violation of any provision of this chapter; %i^,2. To assess a civil administrative penalty pursuant to this subchapter; or %i^3. To suspend or revoke a permit pursuant to this subchapter. "^^^ Top ^ ^ : T ^^|t.4 Civil administrative penalties ; %)^(a) The Department may, in accordance with (d) below, assess a civil" administrative penalty pf not • more than $5,000 per day for each violafion of any provision of the Act or any provision of any rule, ; license or administrative order promulgated or issued pursuant thereto. %i^(b) The authority to assess a civil administrative penalty pursuant to (a) above is in addition to any other reniedies available to the Department pursuant to law. i . • , ' . ' -. ' ' ' . I (c) The Department may consider each violation of any provision of the Act, br any rule, license or I administrafive order Issued pursuant thereto, as a separate and disfinct violation. Each day during I which a viplation confinues may constitute an additional, separate and disfinct offense subjecfing the \ violator to the penalfies in accordance with this subchapter. \ %i^(d) The Departmerit may assess a civil administrafive penalty for each violation of any provision of ; the Act, any provision of this chapter, Pr any provision of a license or an administrafive order i promulgated or issued pursuant thereto in an arnount as follows; %^ 1. For any violafion not related tb the construction of a well, the penalty shall be at the midpoint of the range as follows unless adjusted pursuant to (g) below: i SERIOUSNESS . , Major Moderate Minor Major $800-$ 1,000 $550-$750 i $400-$500 CONDUCT Moderate $550-$750 $400-$500 $250-$350 Minor. $400-$500 $250-$350 , $100-$200 %)^ 2. For any violation directly related to the construcfion of a well, the penalty shall be at the midpoint of the range as follows unless adjusted pursuant to (g) below: SERIOUSNESS Major Moderate Minor Major $4,000-$5,000 $2,750-$3,750 $2,000-$2,500 • CONDUCT Moderate $2,750-$3,750 $2,000-$2,500 $1,250-$1,750 ^ Minpr $2,006-$2,500 $1,250-$ 1,750 $500-$ 1,000 %^(e) The Department shall determine the seriousness of the violation as major, moderate or minor as set forth in (e)1 through 3 below. %^ 1. Major violations shall be determined as follows: %^i. Major violations not related to well construcfion shall include engaging in any regulated acfivity pursuant to this chapter without obtaining a license or permit or with a revoked or suspended license. - ii. Major violations related to the construcfion of a well shall include drilling or installing a well in violafion of the provisions of this chapter or in violation of a permit condifion imposed pursuant to thi(s chapter .; • • • ' . • . •, , ' • 2. Moderate violations shall be determined as follows: %^i. Moderate violations not related tp well construcfion shall include engaging in any regulated activity pursuant to this chapter with an expired license or permit li. Moderate vioJafions related to well construction shall include the installation of any pump or appurtenance Pr the decommissioning of any well in a manner that viPlates the provisions of this chapter or a condition ofa permit issued pursuant to this chapter. %^ 3. Minor violations shall be determined as follows: j . %.J. Minor violafioris nPt related to well construction shall include violations of any provisions of this chapter or a condition of a pemjiit issued pursuant to this chapter involving record keeping, failure to submit information to the Department or the submission of inaccurate or incomplete informafion, failure to notify the Department priorto drilling. %i.Ji. Minor violafions related to well construction shall include anything not included in (e) lii or 211, above. %^(f) The Department shall determine the conduct of the viblator as major, moderate or rpinor as follows: %)^1. Major, conduct shall include any intentional, deliberate, purposeful, knowing or willful actor omission by the violator; ' 2. Moderate conduct shall include any unintenfional but foreseeable act dr omission by the , violator; and %^3. Minor conduct shall include any other conduct not identified in (f)1 br 2 above. iD^(g) The Department shall Increase or reduce the amount determined pursuant to (d) above, and in accordance with applicable law, to an amount no greater than the top nor less than the Bottom of each ; applicable range, on the basis of the following factors: 1 . The compliance history of the violator; 2. The nature, timing and effectiveness of any measures taken by the violator to mitigate the ^^pffects of the violation for which the penalty is being assessed; %^ 3. The nature, timing and effectiveness bf any measures taken by the violator to prevent future similar violafions; %^i. Implerinentation of measures that can reasonably be expected to prevent a recurrence ofthe same type of violation will result in a reduction equal to the bottoni of the range; %-^4. Any unusual or extraordinary costs or impacts direcfiy orindirecfiy imposed on the public or ^he environment as a result of the violation; and/or %^5. Other specific circuinstahces of the violator or violation determined oh an individual case basis... -'^ %^ (hj The Department may settle any civil administrafive penalty assessed pursuant to this section according to the following factors: %^ 1. Mifigafing or extenuafing circumstances not previously considered in the notice of civil administrative penalty assessment; , . %i^2. The timely implementafion by the violator of measures leading to compliance not previously considered in the penalty assessment; 3. The nature, timing and effectiveness of measures taken to mitigate the effects of the violation or prevent future similar violations nbt previPUsly considered in the penalty assessment; %^ 4. The compliance history of the violator not previously considered in the penalty assessment; %^5. The deterrent effect ofthe penalty not previPusly considered in the penalty assessment; and/or ' % ,.6. Any other terms or conditions acceptable to the Departrnent. Top "V ; 7:9D-4.5 Basis for denial of license %^(a) The Department may deny issuance of a well drilling license of the proper class or pump installer license upon a deterniination that: tu^l. The applicant has failed the examination admiriistered pursuant to N.J.A.C.7:9D-1.12; fe^ 2. The applicant has provided false or inaccurate informafion in the applicatiori; pr 3. The applicant has one or more outstanding violafions of any provision of the Subsurface and Percolating Waters Act. ijgj^ Top A. •v . '-'• 7:9D-4.6 Basis for suspension or revocation of license %!^(a) The Department may take or the Board may recomhiend to the Commissioner that the Department take action to suspend or revoke, on an Individual case basis, any license when any of the fo^iping circumstances are evident: li^ 1. That a licensee has been found guilty of fraud or deceit In obtairiing his or her license; %)^2. That a licensee has been found guilty of one or more construcfion related violation(s); %)„3. That a licensee has been found guilty of repeated non-construcfion related violations; %i^4. That a licensee has been found guilty of gross neglect, incompetence or misconduct in the business of well drilling or pump installation or repair in the State of New Jersey; 5. That a licensee has violated any provision of the Subsurface and Percolafing Waters Act or any other State Act relafing to the installafion or repair of wells and well pumping equipment; %^6. That the licensee has failed to respond to efforts by the Department to resolve or correct a violafion; or %i^7. That the licensee has been found guilty ofa violafion determined to cause, or tend to cause, substantial harm to public health, safety and yvelfare. m.^ Top rr 7:9D-4.7 Procedures for civil administrative orders, assessment of civil administrative penalties and suspension or revocation of license and adjudicatory hearings %i^(a) Any order, nofice of civil administrafive penalty assessment, nofice of suspension of license or notice of revocation of license issued pursuant to this subchapter shall: 1. Be served by certified mail, return receipt requested upon the person or persons who are the subject of the order or nofice; Where certified mail has been attempted by the Department and returned, service shall be by first class mail; li]^2. Identify the person or persons claimed by the Department to have committed the violation described in the order or nofice; 3. Describe the acfivity or activities which are in violafion; %^ 4. Identify the specific provision or provisions of the Act, rule, license or order, which have been violated; %£^5. Describe the remedial or other action which must be implemented or caused to be implemented by the violator and the time periods within which such implementation shall commence and be completed; %^ 6. Identify the office within the Department to which any required reply or other correspondence must be directed; %-s,7. Advise the person or persons named in the order ofthe right to request an adjudicatory hearing pursuant to the provisions of N.J^A.C. 7:10A-2.8 and 7:9D-4.8; %i^8. In the case of a civil administrafive penalty assessment, specify the amount ofthe civil administrative penalty to be imposed; h^Q. In the case ofa suspension or revocation of a license, a descripfion ofthe specific grounds 'for the suspension or revocafion; and 10. In the case of a suspension of license, the length of fime for which a suspension shall remain in effect. %iT,(b) If a civil administrative penalty is assessed against more than one person for the same violation or violafions, each shall be jointly and severally liable for the penalty assessed. %^(c) Suspension or revocation of license shall commence and payment of a civil administrative p^MUy Is due upon receipt by the violator of a final order of the Department in a contested case , ^^ding or when the nofice of suspension or revocation of license or nofice of civil administrative penalty assessment becomes a final order as follows: %i^1. Ifno hearing is requested pursuant to N.J.A.C. 7:9D-4.8, a notice of civil administrative penalty assessment becomes a final order on the 21st day following receipt ofthe notice of civil administrative penalty assessment by the violator; %^2. Ifthe Department denies a hearing request, a nofice of civil administrative penalty assessment becomes a final order upon receipt by the violator of the notice of denial; %^3. If a hearing request is submitted by the violator and subsequenfiy withdrawn, the notice of civil administrative penalty assessment becomes a final order upon such withdrawal unless the violator and the Department have executed an administrafive consent order or comparable instrument providing otherwise. 7:9D-4.8 Procedures to request an adjudicatory hearing to contest an administrative order, administrative penalty assessment, suspension of license or revocation of license ' J - %!^(a) Any person (hereinafter "petitioner") requesfing an adjudicatory hearing to contest an administrafive order, civil administrafive penalty assessment, denial, suspension or revocafion of a ^•^^ or permit or to challenge any permit or license condifion, or who believes himself or herself to be aggrieved with respect to decisions made by the Department, shall: %^ 1. Submit the original request in wrifing to: Attention: Adjudicatory Hearing Requests Office of Legal Affairs Department of Environmental Protection PO Box 402 Trenton, New Jersey 08625-0402 %i^2. Submit a copy ofthe request to the offices indicated in the enforcement document. %i^(b) All written requests for an adjudicatory hearing must be received by the Department within 20 calendar days after receipt by the petifioner of notice of the Department's acfion being contested. If the Department does not receive a hearing request within the allotted fime, it shall deny the hearing request. ) Any written request for an adjudicatory hearing shall include the following: % ^ 1. The name, address and telephone number of the petitioner and of its legal or authorized representafive; . %^ 2. An admission or denial of each of the Department's findings of fact; %^i. If the petitioner lacks sufficient knowledge or information to form-a belief as to the truth of a finding, the petifioner shall so state and this shall have the effect of a denial. %^ii. A denial shall fairiy meet the substance ofthe findings denied. When the petitioner intends, in good faith to deny only part or a qualification of a finding, the petitioner shall specify so much of it as is true and material and deny only the remainder. iii. The petitioner may not generally deny all of the findings, but shall make all denials as specific denials of designated findings. %^ iv. For each finding the pefifioner denies, the petifioner shall allege the fact or facts as the petifioner believes it or them to be; %i^3. A description of any facts or issues which the petifioner believes constitute a defense to the allegafions made by the Department; %^4. Information supporting the hearing request and specific reference to, or copies of, other written documents relied upon to support the request; %"s,5. An esfimate ofthe time required for the hearing (in days or hours); and %i^6. A request, if necessary, for a barrier-free hearing locafion for physically disabled persons. %^(d) Ifthe petitioner fails to provide all ofthe informafion required by (c) above, the Department may deny the hearing request. ^) All adjudicatory hearings shall be conducted in accordance with the Administrafive Procedure J.S.A. 52:14B-1 et seq., and the Uniform Administrative Procedure Rules, N.J.A.C. 1: b-i,1. %^,(f) No permit or license which Is the subject of an order of suspension or revocafion shall be valid during the pendency of any action on appeal from that order. Top I Home I States | NEW JERSEY | STATE | REGULATIONS | TITLE 7 | Top j License terms • Privacy policy Click here for copyright © information.