22058_Erwin Mill_AWP_20201013

PCB Waste Assessment
Sampling and Analysis Plan
Erwin Mill
200 North 13t" Street
Erwin, North Carolina
NC Department of Environmental Quality
Brownfields Project No. 22058-18-043
EPA Project ID: NCD986171726
Prepared for:
Erwin Plant, LLC
200 North 13t" Street
Erwin, NC 28339
Prepared by:
Hart & Hickman, PC
3921 Sunset Ridge Road, Suite 301
Raleigh, NC 27607
hart
H&H Job No. BRP-001
October 13, 2020
hickman
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#C-1269 Engineering
#C-245 Geology
2923 South Tryon Street, Suite 100 3921 Sunset Ridge Rd, Suite 307
Charlotte, NC 28203 Raleigh, NC 27607 www.harthickman.com
704.586.0007 main 919.847.4241 main

PCB Waste Assessment
Sampling and Analysis Plan
Erwin Mill
200 North 13" Street
Erwin, North Carolina
H&H Job No. BRP-001
Table of Contents
Tableof Contents........................................................................................................................... i
DistributionList........................................................................................................................... iii
1.0 Introduction.............................................................................................................................1
1.1 Site Description.....................................................................................................................1
1.2 Site History............................................................................................................................1
1.3 Previous PCB Assessment Activities....................................................................................3
1.4 Project Organization..............................................................................................................5
2.0 Project Objectives and Data Quality Objectives..................................................................8
2.1 Project Task and Problem Definition....................................................................................8
2.2 Quality Assurance/Quality Control Objectives.....................................................................8
2.3 Data Management and Documentation.................................................................................9
2.3.1 Field Data........................................................................................................................9
2.3.2 Laboratory Data............................................................................................................11
3.0 Sampling Design and Field Methods...................................................................................12
3.1 Equipment Calibration.........................................................................................................12
3.2 Sampling Activities.............................................................................................................14
3.2.1 Soil Sampling Activities...............................................................................................14
3.2.2 Concrete Sampling Activities.......................................................................................16
3.2.3 Groundwater Sampling Activities.................................................................................17
3.2.4 Surface Water and Sediment Sampling Activities........................................................18
3.2.5 "Tar -like Material" Sampling Activities.......................................................................19
3.3 Decontamination Procedures...............................................................................................19
3.4 Investigative Derived Waste................................................................................................20
4.0 Laboratory Analytical Methods..........................................................................................22
5.0 Quality Assurance/Quality Control.....................................................................................23
5.1 Field Quality Assurance / Quality Control..........................................................................23
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5.2 Laboratory Quality Assurance / Quality Control................................................................26
6.0 Reporting...............................................................................................................................28
List of Tables
Table 1
Summary of Transformer Details
Table 2
Summary of PCB Analytical Data
Table 3
Proposed Sampling Locations and Analyses
List of Figures
Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 PCB Concentration Map
Figure 4 Proposed Sample Location Map
List of Appendices
Appendix A Project Organization Chart
Appendix B Site -Specific Health and Safety Plan
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Distribution List
Mr. Peter Johnson
Erwin Plant LLC Bankruptcy Administrator
USEPA Region 4 Project Officer
Lynn, Smith & Webb, PLLC
PCB & Sustainability Section
44469 Vickers Store Road
61 Forsyth Street
Albemarle, NC 28001
Atlanta, GA 30303
[phone]
[phone]
jeff(a lswcpa.com
j ohnson.peter(& epa. gov
Mr. Joseph Ponzi
Ms. Terri Crosby -Vega
Erwin Plant LLC Environmental Attorney
USEPA Region 4 PCB Coordinator
Brooks Pierce, LLP
PCB & Sustainability Section
2000 Renaissance Plaza
61 Forsyth Street
230 North Elm Street
Atlanta, GA 30303
Greensboro, NC 27401
[phone]
[phone]
crosby-ve ag terrikepa.gov
jponzikbrookspierce.com
Mr. Robert Caplan
Mr. Charles Ivey
USEPA Region 4 Senior Attorney
Erwin Plant LLC Bankruptcy Attorney
61 Forsyth Street
Ivey, McClellan, Gallon & Siegmund, LLP
Atlanta, GA 30303
100 South Elm Street, Suite 500
[phone]
Greensboro, NC 27401
caplan.robertgepa. og_v
[phone]
cmigimgt-law.com
Ms. Kathleen Markey
Project Manager
Mr. Leo Moretz
Division of Waste Management
Project Manager
Brownfields Program
Hart & Hickman, PC
217 West Jones Street
3921 Sunset Ridge Road, Suite 301
Raleigh, NC 27603
Raleigh, NC 27607
[phone]
[phone]
kathleen.markey(,ncdenr.gov
lmoretzA arthickman.com
Ms. Sharon Eckard
Mr. Greg Kanellis
Eastern District Supervisor
QA/QC Officer
Division of Waste Management
Hart & Hickman, PC
Brownfields Program
3921 Sunset Ridge Road, Suite 301
217 West Jones Street
Raleigh, NC 27607
Raleigh, NC 27603
[phone]
[phone]
gkanelliskharthickman.com
sharon. eckardkncdenr. gov
Mr. Norman Avery
Erwin Plant LLC Manager
200 North 13th Street
Erwin, NC 28339
[phone]
navery normanna.aol.com
Mr. Jeffrey Smith
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PCB Waste Assessment
Sampling and Analysis Plan
Erwin Mill
200 North 131h Street
Erwin, North Carolina
H&H Job No. BRP-001
1.0 Introduction
On behalf of Erwin Plant, LLC, Hart & Hickman, PC (H&H) is providing this Sampling and
Analysis Plan (SAP) to conduct assessment activities of the former polychlorinated biphenyl -
(PCB) transformers at the Erwin Mill Brownfields property (Brownfields Project No. 22058-18-
043) located at 200 North 13th Street in Erwin, Harnett County, North Carolina (Site).
1.1 Site Description
The Site (Parcel Identification No. [PIN] 0597-54-8405.000) consists of one parcel of land that
totals approximately 55.25 acres and is developed with the former Erwin Mill facility including
office buildings, warehouse storage buildings, and former textile manufacturing buildings. The
majority of the Site is currently vacant with the exception of several warehouse areas in the
northern and southeastern portion of the Site that have been leased to various tenants for storage
of household goods and appliances, solar panels, hospital files, and other miscellaneous items.
The Site is bordered on the north, northwest, east, and south by residences, on the southwest and
west by vacant land, and on the southeast by downtown Erwin, which includes commercial
businesses, restaurants, a gas station, and municipal buildings. A Site location map is provided as
Figure 1, and the Site and surrounding area are shown on Figure 2.
1.2 Site History
The Site was developed as a textile manufacturing facility in 1904. The facility primarily
focused on the production of denim. Burlington Industries purchased the Site in 1962 and
continued to operate the facility. Burlington Industries merged with Swift Textiles, Inc. in 1987,
and the facility continued to operate through 2000, when the Site was purchased by the current
owner, Schwarz Auman Properties, LLC, renamed Erwin Plant, LLC in 2003. Since 2000, the
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Site has been predominately vacant with the exception of several warehouse buildings that have
been leased to various tenants. Current or recent tenants (since 2000) include general small
businesses, county offices, warehouse users, and some light manufacturing (rifle assembly,
ammunition assembly, and cabinet shop). In 2013, Erwin Plant, LLC filed for bankruptcy.
On November 15, 2018, Erwin Plant, LLC was approved to work with the Brownfields Program
under a "Ready for Reuse" (RFR) Brownfields agreement, in which Erwin Plant, LLC will act as
a proxy for a future prospective developer (PD) to assess the Site as needed. Areas of concern
were developed based on a review of Site history, prior chemical usage and waste management,
and previous assessment activities including a 1997 underground storage tank (UST) closure,
1998 fuel oil removal in the area of the dye storage building, 2001 Phase II Environmental Site
Assessment (ESA), and 2015 Phase I ESA. H&H and the proxy PD discussed data gaps with
DEQ Brownfields personnel and subsequently completed two phases of assessment activities
under the Brownfields Program. Details regarding assessment activities and results, including a
receptor survey and geologic and hydrogeologic information, are documented in the Brownfields
Assessment Report dated September 5, 2019 and Brownfields Assessment Report Addendum
dated January 28, 2020.
According to Erwin Mill records, a total of 35 pad -mounted transformers were historically
present across the Site. Sixteen transformers contained PCB -laden oils while the remaining
19 transformers contained PCB -free oils such as silicone. Thirteen non -PCB transformers were
removed or combined with other Site transformers between 1994 and 2015. Six PCB
transformers were removed in 2009. In November 2019, the United States Environmental
Protection Agency (EPA) conducted a PCB inspection at the Site and subsequently issued a
Notice of Opportunity to Show Cause letter dated December 12, 2019. Subsequent discussions
between Erwin Plant, LLC and EPA representatives indicated that the removal of the remaining
PCB transformers was necessary. In March and April 2020, the remaining ten PCB transformers
and six silicone -containing transformers were removed from the Site. The locations of the
former PCB transformers are depicted on Figure 2 and transformer details are summarized on
Table 1.
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1.3 Previous PCB Assessment Activities
PCB assessment activities were completed during a 2001 Phase II ESA, Brownfields assessment
activities in 2019, and transformer removal activities in 2020. A summary of PCB analytical
data is included in Table 2 and sample locations and detected PCB concentrations above DEQ
Preliminary Soil Remediation Goals (PSRGs) and EPA clean up levels are shown on Figure 3.
ECS 2001 Phase II ESA
In June 2001, Engineering Consulting Services, LTD (ECS) collected soil samples at the
14 exterior PCB transformers and wipe samples at the two interior PCB transformers. Soil
samples were collected by advancing borings to a depth of 4 feet below ground surface at
three locations around the transformer pads and collecting a composite sample from the 4 ft bgs
interval. Samples were submitted for analysis of PCB Aroclors by EPA Method 8082.
Analytical results indicated that Aroclor-1260 and/or Aroclor-1254 were present in soil samples
collected adjacent to 12 PCB transformers. Aroclor-1254 was detected above the EPA cleanup
level of 1 mg/kg in samples collected adjacent to transformers #26 and #27 at concentrations of
2.1 mg/kg and 3.2 mg/kg, respectively. Aroclor-1260 was detected above the EPA cleanup level
of 1 mg/kg in samples collected adjacent to transformers #3 and #913 at concentrations of
23 mg/kg and 1.3 mg/kg, respectively. Soil samples adjacent to transformer #23 demonstrated
concentrations of Aroclor-1254 (0.82 mg/kg) below the EPA cleanup level and soil samples
adjacent to transformers #4, #7, #9A, #IIB, #12, #16, and #17 demonstrated concentrations of
Aroclor-1260 ranging from 0.15 mg/kg to 1.0 mg/kg, below or at the EPA cleanup level. No
other PCBs were detected in soil samples.
Two wipe samples were collected adjacent to each of the two interior PCB transformers (#29 and
#30). Analytical results indicated that Aroclor-1254 were present in two wipe samples at
concentrations of 78 µg/10 cm2 (Wipe-29B) and 76 µg/cm2 (Wipe-30A). No other PCBs were
detected in wipe samples.
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June 2019 Brownfields Assessment
In June 2019, H&H completed Brownfields assessment activities, including the collection of soil
samples adjacent to transformers #3, #26, and #27, which demonstrated the highest PCB
detections during the 2001 assessment. Soil samples were collected via hand auger at an interval
of 3-4 ft bgs and were submitted for analysis of PCB congeners by EPA Method 1668A.
Laboratory analytical results indicated PCB congeners were present in the each of the soil
samples collected. PCB congeners detected at concentrations above PSRGs included congener
77 (up to 0.403 mg/kg), 105 (up to 26.5 mg/kg), 114 (up to 1.64 mg/kg), 118 (up to 52.6 mg/kg),
123 (up to 0.820 mg/kg), 156/157 (up to 9.53 mg/kg), 167 (up to 2.58 mg/kg), and 189 (up to
0.601 mg/kg). In addition, non -dioxin -like congeners were detected above PSRGs in soil
samples at a cumulative concentration ranging from 562 mg/kg to 677 mg/kg in the
three samples. No other PCB congeners were detected above laboratory reporting limits.
November 2019 Brownfields Assessment Addendum
In November 2019, H&H completed additional Brownfields assessment activities, which
included the collection of seven soil samples adjacent to PCB transformers where PCB Aroclor
concentrations exceeded PSRGs and where samples had not been analyzed for PCB congeners.
Soil samples were collected via hand auger from the interval of 3-4 ft bgs adjacent to
transformers #4, #7, #913, # 11 B, # 12, # 17, and #23 and submitted for analysis of PCB congeners
by EPA Method 1668A.
Laboratory analytical results indicated cumulative, non -dioxin -like PCB congeners were detected
above PSRGs in the soil sample adjacent to transformer #17 at concentrations of up to
18.8 mg/kg. Non -dioxin -like congeners were detected at concentrations below PSRGs, in soil
samples collected adjacent to transformers #4, #7, and #12. PCB congeners 77, 108, 118,
156/157, 167, and 189 were detected in the soil sample collected adjacent to transformer #17 at
concentrations below PSRGs. No other PCB congeners were detected above laboratory
reporting limits.
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March 2020 Transformer Removal
In March 2020, H&H oversaw the removal of ten PCB transformers. Four transformers were
located within a courtyard area that was only accessible by a partially sub -terrain concrete
corridor that is commonly referred to as the "tunnel". The tunnel is located north of the Site
reservoir between the dye house and the warping area. Soil was present within the tunnel and
presented a potential hazard to equipment traveling through the tunnel; therefore, the material
was removed from the tunnel and stockpiled on plastic on transformer #27's concrete pad. Two
soil samples (S-1 and S-2) were collected from the stockpile and submitted for analysis of PCB
Aroclors by EPA Method 8082A using EPA extraction method 3546. Analytical results
indicated the presence of Aroclor-1260 at concentrations of 29 mg/kg and 20 mg/kg. Due to the
presence of PCBs in stockpiled soil, the stockpiled soil was covered with plastic and secured to
await disposal directions by the EPA.
In an August 28, 2020 email, the EPA requested additional assessment be conducted to address
data gaps prior to cleanup activities. Based on the EPA request and additional communication
between representatives of Erwin Plant, LLC, EPA, DEQ, and H&H in September 2020, H&H
proposes to conduct soil, concrete, groundwater, surface water, and sediment sampling activities
to further evaluate potential PCB impacts at the Site. Our proposed scope of work is outlined in
the following sections.
1.4 Project Organization
A project organization chart is provided as Appendix A. The individuals participating in the
project and their specific roles and responsibilities are provided below:
Peter Johnson, USEPA Region 4 Project Officer — The USEPA Project Officer has the
responsibility to review and approve the SAP and subsequent report. The US EPA Project
Officer will ensure that assessment activities conducted are consistent with those described in the
SAP.
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Kathleen Markey, DEQ Brownfields Project Manager — The DEQ Brownfields Project
Manager will be involved in the review and approval of the SAP and subsequent report to ensure
plans and activities comply with current DEQ rules and regulations and meet the requirements of
the Brownfields Program.
Greg Kanellis, PE, QA/QC Officer — The QA/QC Officer will remain independent of the group
responsible for data generation and will provide QA/QC technical assistance to the Project
Manager. The QA/QC Officer will be responsible for internal QA audits and QC
implementation of the project. The QA/QC Officer will report all audit results to the Project
Manager and review all implemented corrective actions. The QA/QC Officer will provide a final
internal review of the report prior to distribution.
Leonard Moretz, PG, RSM, Project Manager — The Project Manager will be the primary
decision maker for the project and primary user of the data to determine clean-up actions
necessary for the Site. Specific responsibilities will include:
• Approving the SAP and subsequent revisions in terms of EPA and Brownfields specific
requirements; distribution of the SAP document to the Project Coordinator and all
members of the project team.
• Overall responsibility for the investigation.
• Validating field data.
• Reporting issues/project status and preparing final reports to the USEPA Project Officer,
DEQ Brownfields Project Manager, and Erwin Plant, LLC.
• Making final project decisions with the authority to commit the necessary resources to
conduct the project activities/tasks.
• Responsible for instituting corrective actions for problems encountered in the field
sampling activities.
• Communicating to the Project Coordinator the corrective actions necessary to correct
problems that might be encountered in the field.
Lisa Nickels, PG, Project Coordinator — The Project Coordinator will coordinate project
activities and provide assistance to the Project Manager. Specific responsibilities include:
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• Coordinating field and laboratory activities and conducting project activities in
accordance with the SAP.
• Selecting the field sampling team.
• Upon receipt from the Project Manager, distributing the approved SAP and any
subsequent revisions to the members of the field sampling team.
• Reporting problems encountered in the field to the Project Manager.
• Coordinating with the Laboratory Director/Manager to correct any corresponding
problems encountered in the chemical analyses.
• Compiling documentation detailing any corrective actions and provide them to the
QA/QC Officer.
• Preparing final reports for review by the QA/QC Officer and Project Manager
Chase Goodwin, Field Scientist — The Field Scientist will perform the following duties:
• Conduct the field activities/tasks per the approved SAP.
• Implement corrective actions in the field as directed by the Project Coordinator.
Corrective actions will be documented in the field logs and provided to the Project
Coordinator.
Kerry McGee, Laboratory Project Manager, Con -Test Analytical Laboratory — Con -Test
Analytical Laboratory (Con -Test) was selected to provide laboratory analyses for this project.
The Laboratory Project Manager will coordinate the analysis of the samples and laboratory
validation of the data. The Laboratory Project Manager will coordinate the receipt of the
samples at the laboratory, select the analytical team, and ensure internal laboratory audits are
conducted to meet quality assurance objectives. The Laboratory Project Manager is responsible
for instituting corrective actions for problems encountered in the chemical analyses and will also
report laboratory problems affecting the project data to the Project Coordinator. Corrective
actions for chemical analyses will be detailed in a QA report that will be provided to the Project
Coordinator.
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2.0 Project Objectives and Data Quality Objectives
2.1 Project Task and Problem Definition
The objective of this Site assessment is to collect quality data to further evaluate PCB impacts
identified at the Site and to determine the whether the previous use of PCB transformers at the
Site has resulted in additional releases to the environment that would pose a potential
environmental risk for future Site uses. Future use of the Site is not known; therefore, sampling
will be conducted to meet requirements for high occupancy residential Site use. In addition, the
data will be used to develop a clean-up plan to address any unacceptable enviromnental risk to
future Site uses.
The scope of work was developed based on assessment requested by EPA in an August 28, 2020
email and on additional communication between representatives of Erwin Plant, LLC, EPA,
DEQ, and H&H in September 2020. Specifically, soil, concrete, groundwater, surface water,
sediment, and other materials will be sampled and analyzed for PCB Aroclors to meet
requirements in 40 CFR Part 761 and PCB congeners to meet DEQ Brownfields Program
requirements.
2.2 Quality Assurance/Quality Control Objectives
An evaluation of analytical data with applicable contaminant screening criteria will be used to
determine if the Site is safe for redevelopment based upon the future use or what actions need to
be taken to make the Site safe for redevelopment for this use. It is possible that the results of the
assessment could be used to dictate future land use. The concentrations of PCBs will be
compared to the EPA cleanup level of 1 part per million (ppm) and applicable DEQ regulatory
standards and/or screening levels.
If PCBs are not detected in a sample above regulatory cleanup and/or screening levels, no further
action is necessary in the vicinity of that sample location. If PCBs are detected in one or more
media above regulatory cleanup and/or screening levels, then recommendations for further action
such as additional assessment, remediation, and/or removal will be evaluated.
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If corrective action is deemed necessary, the data collected during the assessment will likely be
sufficient to complete remedial planning, including estimation of quantities of impacted material
and associated costs of corrective action. Data collected during the assessment, which will be
utilized in remedial planning, include analytical data from soil, concrete, groundwater, surface
water, and sediment.
Quality assurance/quality control (QA/QC) procedures are detailed in Section 5.0. A copy of the
laboratory analytical data report and QA package for each group of samples submitted to and
analyzed by the subcontracted laboratory will be provided in an appendix to the final report.
Laboratory QA data consistent with Level II documentation will be requested for this project. A
copy of the completed chain -of -custody record will be appended to the corresponding laboratory
analytical report included with the final report.
2.3 Data Management and Documentation
Data management documents for the project will be produced in two locations: at the Site and at
the laboratory. Project records will include correspondence, field logs/data sheets, raw data,
status/progress reports, laboratory analytical reports, laboratory QA reports data validation
reports, draft reports and the final report. The final report will be submitted to the representatives
of Erwin Plant LLC, the USEPA Region 4 PCB Project Officer, and the NCDEQ Brownfield
Program Project Manager.
2.3.1 Field Data
Field personnel will maintain appropriate documents and records for the sampling event.
Document and record requirements will be maintained per the USEPA Region 4 — Science and
Ecosystem Support Division (SESD), "Field Branches Quality System & Technical Procedures"
(QSTP). Some of the required field documentation include:
• Field book notes written with a waterproof pen with records of field scientist signatures
or initials, weather conditions, equipment use, daily objectives, detailed records of field
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activities and communications, investigative derived waste management, and corrective
actions taken;
• Equipment calibration logs;
• Soil boring logs detailing lithology and field screening results;
• Field maps of sample locations;
• Low flow purging and stabilization parameters; and
• Tailgate safety meeting notes.
In addition, the Field Scientist will prepare Chain -of -Custody forms to accompany all samples
from origin through disposal. All sample containers are labeled with sample location, a unique
identification number, preservative, sampler name, analyses required, and date/time of
collection. The sample location identification (ID) is linked to the labels, chain -of -custody and
field notes. The chain -of -custody form includes the following information:
• Project name and address
• Date and time of sample collection
• Name of sampler
• Sample location ID number
• Number of samples and containers
• Analyses required
• Preservation Methods
• Timeframe for receipt of analytical data results
• Comments/other pertinent notes
The Project Coordinator will review all field notes and field analytical data for accuracy and
completeness. The Project Coordinator will also review all field data forms and compare them to
the field logbooks for completeness, consistency and accuracy. The Project Coordinator will also
review each field data log form for accuracy in calibration, calibration checks, data
completeness, etc. The Project Manager will also review all originally collected field data (data
logbooks, field books, field notes, boring logs, etc.) to ensure that field procedures are in
accordance with the SAP.
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2.3.2 Laboratory Data
Upon receipt of the samples and chain -of -custody information, the laboratory will check sample
container integrity, temperature, preservation, and chain -of custody documentation, log receipt of
the samples, and email a .pdf file copy of the chain -of -custody and login information to the
Project Manager and the QA/QC Officer. Upon receipt of the e-mail sample confirmation, the
Project Manager and the QA/QC Officer will review the .pdf versions of the chain -of -custody
and laboratory login information for consistency with the internal work order that documented
the sampling work and analyses to be conducted during the field event.
The laboratory will ensure all samples are analyzed within the specific holding time
requirements (14 days for solid samples and 7 days for water samples analyzed by EPA Method
8082, 1 year for samples analyzed by EPA Method 1668). The laboratory will provide electronic
of analytical results within 5 — 7 business days of sample receipt. Upon receipt, the Project
Manager and QA/QC Officer will both review the laboratory data. The electronic copy of the
data will be placed in the digital project file maintained on the system server, which is routinely
"backed up" to ensure data integrity. Types of information that will be requested from the
laboratory include:
• Analytical result sheets
• Method blank results
• Surrogate recovery results and acceptance limits
• Matrix spike/matrix spike duplicate results and acceptance limits
• Spike/duplicate results and acceptance limits
• Laboratory control sample results and acceptance limits
• Inductively Coupled Plasma (ICP) serial dilution results
• ICP interference check samples
• Project narrative containing observations and explanation of any data qualifiers
• Signature by laboratory QA Officer
The Laboratory Director is responsible for analytical laboratory records management, archiving
and permanent storage.
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3.0 Sampling Design and Field Methods
The proposed assessment activities will be performed to comply with requirements in 40 CFR
Part 761 and in general accordance with the DEQ Inactive Hazardous Sites Branch (IHSB)
Guidelines for Assessment and Cleanup (Guidelines) dated January 2020 and most recent
versions of the EPA Region IV SESD Field Branches Quality System and Technical Procedures
guidance.
3.1 Equipment Calibration
Equipment used will be dedicated to that project for the duration of field sampling activities. A
list of sample collection equipment and calibration requirements is provided below.
List of Sample Collection Equipment
Equipment
Calibration Method
Minimum Calibration
Dedicated or
Frequency
Non -Dedicated
Stainless Steel
N/A
N/A
Non -Dedicated
Hand Auger
Juniper Systems
N/A
N/A
Non -Dedicated
Geode GPS
PID — MiniRAE
Zero air and
Prior to use each day
Non -Dedicated
isobutylene (100 ppm)
Water Level Meter
N/A
N/A
Non -Dedicated
Peristaltic Pump
N/A
N/A
Dedicated
sampling tubing
Prior to use each day or
YSI 556 Water
Reference Standards
after every 10 samples.
Non -Dedicated
Quality Meter
Measurements repeatability
to within 0.2
Hach Turbidity
Reference Standards
Prior to use each day with
Non -Dedicated
Meter
calibration check at mid -day
The multi -parameter meter (YSI 556 MPS or equivalent) and the Hach turbidity meter will
require testing, routine inspection and maintenance as per the manufacturer's
recommendations/specifications. The multi -parameter or specific individual parameter meters
will be used to measure pH, temperature, turbidity, dissolved oxygen and conductivity for water
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samples while in the field. All equipment manufacturer literature (e.g., operator instruction and
user manual for testing, inspecting and maintaining the meter(s), etc.) will be the maintained and
made available by the Field Scientist.
The Field Scientist will complete an inspection checklist and initial calibration check prior to
mobilizing to the site. A maintenance kit, which will include extra batteries, calibration
standards, and commonly needed spare parts, will be made available at the site for each meter.
Any preventive or corrective maintenance completed will be documented in the field
notes/equipment logs. If any meter fails the initial testing and inspection, a second attempt to
calibrate the meter will be conducted. If the meter fails a second calibration attempt, a spare
meter will be obtained from inventory or rented from an environmental sampling/equipment
supply vendor.
All instrument types, manufacturer, models and calibration records will be recorded on project
field logs for the sampling event and will be given to the Project Manager upon completion of
the sampling event to maintain in the project files. The Project Manager or QA/QC Officer may
request spot checks of equipment calibration logs at any time. Calibration records can be traced
to equipment logs by referencing project specific field notes. Equipment calibrations are
completed in accordance with manufacturer specifications and, as applicable, the SESD-QSTP
Field Measurement Procedures. In the event a piece of field equipment will not hold calibration
within the control limits, that piece of equipment will be replaced from inventory or rented from
an environmental sampling/equipment supply vendor.
Buffer solutions of pH 4.01, 7.0, and 10.0; turbidity standards 1, 2, 10, and 100 Nephelometric
Turbidity Units (NTU); and conductivity standard of 1413 micro ohm/cm will be used in the
field.
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3.2 Sampling Activities
Prior to conducting the field activities, H&H will contact North Carolina 811, the public utility
locator, to mark subsurface utilities located on the Site. H&H will also contract with a private
utility locator to screen proposed sample locations for subgrade utilities that may not be marked
by the public locator. A Site -specific Health and Safety Plan has been prepared in accordance
with Occupational Health and Safety Administration (OSHA) requirements and is included as
Appendix B.
3.2.1 Soil Sampling Activities
Sampling Design
H&H proposes to conduct soil assessment activities to evaluate current conditions at each former
PCB transformer location. Surficial soil samples will be collected at each location to determine
whether a release has occurred or if direct exposure to impacted soils is a potential risk at the
Site. A deeper soil sample will be collected from the soil borings advanced adjacent to
transformers #3, at which PCBs have historically been detected at concentrations above
10 mg/kg. The proposed sampling plan is summarized in Table 3 and proposed soil sample
locations are depicted on Figure 4.
Field Methods
H&H will advance a soil boring adjacent to each former PCB transformer to depths ranging from
approximately 1 ft bgs to 6 ft bgs using a decontaminated stainless steel hand auger. Exact soil
sampling locations will be determined in the field based on accessibility, visible signs of
potential contamination (e.g., staining on soils or the concrete transformer pad), location of
previously collected samples, and topographical features which may indicate a preferred release
pathway (e.g. downgradient side of the transformer pad). Exterior soil sample locations will be
estimated using a hand-held global positioning system (GPS) unit and interior sample locations
will be estimated by measuring from known benchmarks (e.g. doorways, walls, etc.).
Soil samples will be logged for lithological description and field screened for indication of
potential impacts by observation for staining and the presence of organic vapors using a
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calibrated photoionization detector (PID). A soil sample will be collected as a grab sample at the
surficial soil (0-0.5 ft bgs) interval at each former PCB transformer location. In addition,
one soil sample will be collected as a grab sample from the 5-6 ft bgs depth interval at former
PCB transformer #3. In addition, one soil sample will be collected from the tunnel where
PCB -impacted soil has been identified. The sample will be collected from beneath the concrete
tunnel floor from a depth of 0 to 0.5 ft bgs in either a low lying area or beneath a crack in the
tunnel floor, if present.
Soil samples will be homogenized prior to placement in dedicated laboratory -supplied sample
containers. Sample containers will be filled to the top, taking care to prevent soil from remaining
in the lid threads prior to being closed to prevent potential contaminant migration to or from the
sample. Samples will be labeled with the sample identification, date, and requested analysis, and
placed in a laboratory supplied cooler with ice. Soil samples will be submitted to a North
Carolina certified laboratory under standard chain of custody protocols for analysis of PCB
Aroclors by EPA Method 8082A. In addition, sufficient soil will be collected and submitted to
the laboratory for hold pending analytical results for PCB Aroclors. The sample exhibiting the
maximum concentration of PCB Aroclors for all samples located within a generalized PCB
transformer area (i.e., all samples collected within the courtyard, between the cotton blending
building slab and finishing building, etc.) will be submitted for analysis of PCB congeners by
EPA Method 1668A. In addition, if PCB Aroclors are not detected in a sample and if the
laboratory reporting is greater than 0.23 mg/kg in that sample, then the held sample will be
submitted for analysis of PCB congeners by EPA Method 1668A. Details regarding laboratory
methods and quality assurance and quality control are present in Sections 4.0.
Following sampling activities, borings will be properly abandoned and the surfaces will be
repaired similar to pre -drilling conditions.
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3.2.2 Concrete Sampling Activities
Sampling Design
H&H proposes to collect concrete samples from the center of the concrete pads of former
transformers #3, #9A/B, #IIA/B, #17, #26, and #27, at which historical soil data indicated a
release. In addition, a concrete sample will be collected from the former cotton blending
building slab to be held by the lab pending results of the "tar -like material" (see Section 3.2.5
below). Should PCBs be detected in the "tar -like material", the additional concrete sample will
be analyzed as described below. The purpose of these samples is to evaluate potential
PCB -impacted porous surfaces. The proposed sampling plan is summarized in Table 3 and
proposed concrete sample locations are depicted on Figure 4.
Field Methods
Prior to concrete sampling, H&H will document the condition of the concrete transformer pad
and then remove any debris with a clean brush or cloth from the center of the pad where the
sample will be collected. H&H will then use a rotary hammer drill with a 1.5-inch diameter drill
bit to advance a hole to an approximately 0.5-inch depth. Aluminum foil will be used to contain
the powdered sample. Note that multiple holes located closely adjacent to each other may be
necessary to generate sufficient sample volumes. Concrete sample locations will be estimated
using a hand-held global positioning system (GPS) unit.
Concrete powder generated from the hole(s) will be collected directly into dedicated laboratory -
supplied sample containers, labeled with the sample identification, date, and requested analysis,
and placed in a laboratory supplied cooler with ice. Concrete samples will be submitted to a
North Carolina certified laboratory under standard chain of custody protocols for analysis of
PCB Aroclors by EPA Method 8082A. In addition, sufficient concrete will be collected and
submitted to the laboratory for hold pending analytical results for PCB Aroclors. If PCB Aroclor
data indicate high PCB concentrations or if Aroclor results are non -detect and the reporting
limits for that sample are above the lowest applicable screening level, then held samples will be
submitted for analysis of PCB congeners by EPA Method 1668A.
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3.2.3 Groundwater Sampling Activities
Sampling Design
H&H proposes to collect groundwater samples from monitoring wells MW-12, MW-15, MW-18,
and MW-20, which are located in the vicinity and/or downgradient of former PCB transformers,
to determine whether PCBs have leached from impacted soils to groundwater. The proposed
sampling plan is summarized in Table 3 and monitoring wells are depicted on Figure 4.
Field Methods
Prior to the collection of groundwater samples, the water level will be measured in all Site wells
to determine the direction of groundwater flow across the Site. Wells will be opened and
allowed time to equilibrate. Following equilibration, a decontaminated electronic water level
meter will be used to measure the depth to water to an accuracy of +0.01 feet.
Following water level measurements, groundwater samples will be collected using low flow/low
stress purging techniques using a peristaltic pump and dedicated polyethylene tubing. The intake
point of the pump tubing will be placed approximately in the mid -portion of the screened interval
of the well and groundwater will be removed at a rate no greater than 200 milliliters per minute.
H&H will use calibrated water quality meters such as a YSI Pro Plus and Hach turbidity meter to
measure pH, temperature, dissolved oxygen, oxidation reduction potential, turbidity, and specific
conductivity at 3 to 5-minute intervals during purging. Purging will be considered complete
when water quality parameters stabilize (i.e. pH ± 0.1 SU, conductivity varies no more than 5%,
and turbidity is less than 10 NTUs).
Once groundwater parameters stabilize, groundwater samples will be collected directly into
laboratory supplied sample containers through the peristaltic pump. The sample containers will
be labeled with the sample identification, date, and requested analysis, and placed in a laboratory
supplied cooler and iced. The samples will be delivered to a North Carolina certified laboratory
under standard chain of custody protocols for analysis of PCB Aroclors by EPA Method 8082A.
In addition, sufficient groundwater will be collected and submitted to the laboratory for hold
pending analytical results for PCB Aroclors. If PCB Aroclor data indicate high PCB
concentrations or if Aroclor results are non -detect and the reporting limits for that sample are
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above the lowest applicable screening level, then held samples will be submitted for analysis of
PCB congeners by EPA Method 1668A.
3.2.4 Surface Water and Sediment Sampling Activities
Sampling Design
H&H proposes to collect five co -located surface water and sediment samples for laboratory
analysis from the reservoir, potential wetland area downgradient of the reservoir, and the on -Site
unnamed tributary to Juniper Creek. The purpose of these samples is to evaluate whether
potential PCB releases have migrated to downgradient receptors. The proposed sampling plan is
summarized in Table 3 and proposed sample locations are depicted on Figure 4. Note that H&H
will use prior GPS location data to collect samples from previously sampled locations.
Field Methods
The sample will be taken from flowing, not stagnant, water. For samples collected from the
unnamed tributary, samples will be collected from downstream to upstream locations to
minimize potential cross -contamination. Surface water will be collected by hand directly into
laboratory -supplied sample containers. The sampler will face upstream in the middle of the
stream. The bottle will be uncapped and the cap protected from contamination. The bottle will be
plunged into the water mouth down and filled 6 to 12" below the surface of the water.
Sediment samples will be collected from the base of the surface water body at each sample
location using a decontaminated stainless steel hand auger. Care will be taken to obtain as
representative a sample as possible. The samples will be taken from areas likely to collect
sediment deposits, such as slow -moving portions of streams or from the bottom of a non-moving
water body such as the reservoir or wetland area. Material will be homogenized before transfer
to dedicated laboratory -supplied containers. Sample containers will be filled to the top taking
care to prevent sediment from remaining in the lid groves prior to being sealed in order to
prevent potential contamination migration to or from the sample containers.
The sample containers will be labeled with the sample identification, date, and requested
analysis, and placed in a laboratory supplied cooler and iced. The surface water and sediment
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samples will be delivered to a North Carolina certified laboratory under standard chain of
custody protocols for analysis of PCBs by EPA Method 8082A. In addition, sufficient surface
water and sediment will be collected and submitted to the laboratory for hold pending analytical
results for PCB Aroclors. If PCB Aroclor data indicate high PCB concentrations or if Aroclor
results are non -detect and the reporting limits for that sample are above the lowest applicable
screening level, then held samples will be submitted for analysis of PCB congeners by EPA
Method 1668A.
3.2.5 "Tar -like Material" Sampling Activities
H&H will collect one sample of the "tar -like" material observed at the seam in the concrete slab
of the former cotton blending building to determine if PCBs are present within the material. The
"tar -like" material will be collected directly into a dedicated laboratory -supplied container,
labeled with the sample identification, date, and requested analysis, and placed in a laboratory
supplied cooler and iced. The "tar -like" material sample will be submitted to a North Carolina
certified laboratory under standard chain of custody protocols for analysis of PCB Aroclors by
EPA Method 8082A and PCB congeners by EPA Method 1668A. H&H will request the analysis
of PCB congeners be held pending Aroclor results to generate a complete sample list for
congener analysis prior to beginning analysis.
3.3 Decontamination Procedures
Non -dedicated equipment and tools will be decontaminated prior to use at each boring or
sampling locations and following exposure to soil, groundwater, surface water, sediment, or
other media. Steps for decontamination are as follows:
• Non -phosphate detergent and tap water wash, using a brush if necessary
• Tap -water rinse
• Deionized/distilled water rinse
• Deionized/distilled water rinse (twice)
Equipment will be decontaminated in a pre -designated area on plastic sheeting or enclosed space,
and clean bulky equipment will be stored on plastic sheeting in uncontaminated areas. Cleaned
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small equipment will be stored in plastic bags. Materials to be stored more than a few hours will
also be covered.
3.4 Investigative Derived Waste
In the process of collecting environmental samples, the sampling team will generate different
types of potentially contaminated investigative derived waste (IDW) that include the following:
• Used personal protective equipment (PPE)
• Disposable sampling equipment
• Decontamination fluids
• Soil cuttings from soil borings
• Purged groundwater and excess groundwater collected for sample container filling
The EPA's National Contingency Plan (NCP) requires that management of IDW generated
during sampling comply with all applicable or relevant and appropriate requirements (ARARs)
to the extent practicable. The sampling plan will follow the Office of Emergency and Remedial
Response (OERR) Directive 9345.3-02 (May 1991), which provides the guidance for the
management of IDW. In addition, other legal and practical considerations that may affect the
handling of IDW will be considered. The following actions will be taken in regards to IDW:
• Used PPE and disposable equipment will be double bagged and placed in a municipal
refuse dumpster. These wastes are not considered hazardous and can be sent to a
municipal landfill. Any PPE and disposable equipment that is to be disposed of which
can still be reused will be rendered inoperable before disposal in the refuse dumpster.
• Decontamination fluids that will be generated in the sampling event will consist of
deionized water, residual contaminants, and water with non -phosphate detergent.
Decontamination fluids will be combined with purged groundwater and will be contained
in a 55-gallon drum(s), sampled for waste characterization, and disposed of in an
appropriate manner.
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• Soil cuttings generated during the subsurface sampling will be contained in a 55-gallon
drum(s), sampled for waste characterization, and disposed of in an appropriate manner.
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4.0 Laboratory Analytical Methods
The quality characteristics and non -critical determinations for water and soil will be performed
in the field. The laboratory will determine the concentration of COCs in water and solid media.
H&H has chosen Con -Test Analytical Laboratory to complete the analyses outlined in this SAP.
Refer to Table 3 for a summary of the proposed analyses. All samples will be analyzed for PCB
Aroclors by EPA Method 8082A. Based on the results of the PCB Aroclor analyses, additional
samples will be selected for analysis of PCB congeners by EPA Method 1668A. Extraction
methods will consist of the following:
• Soil, sediment, concrete, and "tar -like" material samples will utilized EPA Method
3540C for extraction for analysis of PCBs by EPA Method 8082A and EPA Method
1668A. These samples will be collected into an 8-oz or 16-oz unpreserved amber jar.
The holding time is 14 days for EPA Method 8082A and 1 year for EPA Method 1668A.
• Groundwater and surface water sampled will utilize microwave extraction for analysis of
PCB by EPA Method 8082A and EPA Method 1668A. These samples will be collected
into two 1-L unpreserved amber glass bottles. The holding time is 7 days for EPA
Method 8082A and 1 year for EPA Method 1668A.
Analytical methods were chosen to comply with 40 CFR Part 761 and requirements of the DEQ
Brownfields Program. The use of non-standard, unpublished, and/or methods not recognized by
the EPA are not anticipated. In general, the laboratory turnaround time for electronic copies for
project data deliverables will be 5 — 7 business days. The Laboratory Director will be
responsible for overseeing all aspects of sample analysis and taking corrective actions whenever
necessary.
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5.0 Quality Assurance/Quality Control
H&H's QA/QC Officer, who is independent from the project sampling team and is not affiliated
with the analytical laboratory, will review the final draft report for completeness and compliance
with overall project goals. The QA/QC Officer will review and evaluate field and laboratory QC
data to determine what data are judged to be valid for use as intended, and what data must be
used with qualifications or eliminated altogether. The QA/QC Officer will communicate the
deficiencies to H&H's Project Manager. These determinations will be documented fully in the
assessment report and associated remediation planning documents.
5.1 Field Quality Assurance / Quality Control
The following activities will be conducted by H&H for QA/QC purposes:
• Non -dedicated equipment and tools will be decontaminated prior to use at each boring or
sampling location, or following exposure to soil or groundwater. Equipment rinsate
blanks will be collected to evaluate field sampling and decontamination procedures by
pouring deionized water over the decontaminated sampling equipment used.
One equipment rinsate blank will be collected per sampling media that is sampled using
non -dedicated equipment (soil, concrete, groundwater, and sediment).
• One duplicate sample will be collected per every 20 samples (5%) per sampling media
per analytical method during assessment activities. Soil, concrete, sediment, and
"tar -like" material samples to be analyzed for PCBs will be homogenized and then be
transferred to the appropriate wide -mouth glass jars for both the regular and duplicate
samples. When collecting duplicate water samples, bottles with the two different sample
identification numbers will alternate in the filling sequence.
The QC/QC samples will be preserved, packaged, and sealed in the manner described for the
environmental samples. A separate sample identification will be assigned to each sample, and it
will be submitted blind to the laboratory. Laboratory analyses for proposed QA/QC sampling is
referenced in Table 3.
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An acceptance criteria analysis of field QA/QC samples (i.e., field duplicates and equipment
blanks) will be performed by H&H's QA/QC Officer using professional judgment and the
procedures described below. If the analysis suggests some or all samples should be recollected,
H&H will notify the EPA Project Officer and Brownfields Project Manager.
1. Field duplicate samples — a comparison of the sample duplicate(s) and the corresponding
sample result(s) will be made to evaluate the reproducibility of the sample results based
on the laboratory analysis and sample collection and transportation procedures. For this
comparison, if the duplicate (D) or sample (S) result is less than five times the reporting
limit when the comparison is made by the absolute difference between the results (S-D).
For water samples, if this difference is less than the magnitude of the (higher) reporting
limit, precision is considered "acceptable". For soil and other solid samples, if the
difference is less than twice the magnitude of the (higher) reporting limit, precision is
considered "acceptable". If these differences are within 2X the "acceptable" limits, they
will be considered "slightly high"; anything beyond that would be considered "high". If
both sample and duplicate results are greater than 5X the reporting limit (RL) (the higher
of the two RLs, if they are not the same), then precision through the relative percent
difference (RPD) between the sample and field duplicate will be calculated according to
the following:
VIU
Absolute value of the difference of the sample and field duplicate results
Average of the sample and field duplicate results
x 100%
An RPD of <35% is acceptable, between 35% and 50% is slightly high, and >50% is
considered high.
2. Equipment rinseate blanks — representativeness is a parameter that evaluates how
accurately the data represent actual environmental conditions. The primary evaluation
criterion for equipment blanks is that no constituents should be detected at concentrations
above the laboratory reporting limit. If constituents are detected, then the associated
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sample results will be reviewed to determine whether or not there is an inherent
variability in the data or if the constituent detection is an isolated occurrence not affecting
other data. Associated sample data will be qualified when there are constituent detections
in blank samples. If constituents are detected in the blank sample but not the associated
sample, no additional actions will be required.
Professional judgment will be exercised by the H&H QA/QC Officer to determine the
usability of the associated sample data. Actions regarding detections in blank samples
depend on the circumstances and origin of the blanks. At a minimum, positive blank
sample results will be documented.
At the end of the field event, H&H's Project Manager or Project Coordinator will review the
field logbooks used by project personnel to 1) evaluate important information that may
significantly impact the project or assist in the interpretation of the lab data and the conceptual
Site model, and 2) check that tasks were performed as specified in the SAP. Any significant
findings (i.e., observations, trends, conclusions, limitations, etc.) of this field data review process
will be documented in the final report. H&H will also document in the final report any missing
data, unresolved questions, non -compliant issues, and variations from the SAP.
Specific items to be reviewed include:
• Samples collected in proper locations
• Field equipment calibration procedures documented in field book and in accordance with
acceptance criteria
• Proper sampling techniques used
• Field QA/QC requirements followed
• Samples analyzed for correct parameters
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5.2 Laboratory Quality Assurance / Quality Control
Laboratory QC samples will be analyzed as part of standard laboratory practice. The laboratory
monitors the precision and accuracy of the results of its analytical procedures through analysis
of QC samples. In part, laboratory QC samples consist of matrix spike/matrix spike duplicate
(MS/MSD) samples to be collected in the field. H&H will collect one MS/MSD sample per
every 20 samples (5%) per sampling media per analytical method during assessment activities.
These samples are an aliquot of the field sample. They are not a separate sample, but a special
designation of an existing sample. The laboratory will be alerted as to which sample is to be
used for QC analysis by a notation on the sample container label and the chain -of -custody
record.
Laboratory QA/QC procedures will be employed to ensure appropriate sample handling and
analysis and to aid in the review and validation of the analytical data. QA/QC procedures will be
conducted in accordance with DEQ and EPA method protocols and will include regular
equipment maintenance, equipment calibrations, and adherence to specific sample custody and
data management procedures. In accordance with approved methodologies, samples will be
analyzed in conjunction with appropriate blanks, laboratory duplicates, continuing calibration
standards, and surrogate standards to monitor both instrument and analyst performance. H&H
will request that the laboratory reporting limits for each analyte will be at or below appropriate
screening criteria. Additionally, H&H will request that the laboratory include J Flags, which are
estimated concentrations for compounds that are detected at levels above the laboratory method
detection limits, but below the laboratory reporting limits.
Laboratory data packages will include project summary, chain -of -custody documentation,
laboratory sample receipt information, and a "Level II" QA/QC package. The Level II package
will include method blank analyses, surrogate recoveries, results of MS/MSD sample analyses
with recovery ranges and relative percent differences, and laboratory control sample analyses
with recovery ranges. Data validation will be accomplished through a series of checks, audits
and reviews intended to assure the reported results are of a verifiable, reproducible, and
acceptable quality. The validation process will include:
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• Quality control blanks meet criteria
• Quality control data (spikes, duplicates, etc.) are acceptable
• Surrogate spike recoveries are acceptable
The Laboratory Director will review and verify the laboratory data generated under their
corrective action system for accuracy according to the laboratory's policies and procedures. The
Laboratory Director will ensure the data package, including all QA/QC data is complete and in
compliance with the stated objectives in the SAP. Any missing or incomplete information will
be addressed by the laboratory and corrected under the supervision of the Laboratory Director.
The Project Manager will monitor the project to ensure quality assurance goals are met. If quality
issues, such as exceeding control limits are identified, the Project Manager will contact the
Laboratory Director to resolve these issues. Mechanisms are in place, such as resampling and
reanalysis, to handle situations that could arise. If the Project Manager and the Laboratory
Director cannot resolve issues between themselves, then these issues will be resolved by strictly
following the EPA SESD Region 4 guidance procedures.
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6.0 Reporting
Following completion of the assessment activities and receipt of the analytical data, H&H will
document our findings in a PCB assessment report. The report will include the following:
• a narrative description of how assessment activities were conducted, including a
discussion of any variances from the SAP;
• a description of field and laboratory quality control and quality assurance procedures
followed;
• a description of procedures used to manage investigative derived waste;
• a discussion of the analytical data in comparison to EPA clean up levels and DEQ
regulatory screening levels and conclusions and recommendations concerning our
activities;
• tabulation of analytical results and copies of laboratory reports including quality
assurance/quality control documentation;
• a figure depicting sample locations, a groundwater potentiometric map, and figures
depicting analytical results; and
• completed lithology logs.
The Project Manager will conduct the final data evaluation and prepare the final report, which
will be reviewed for technical accuracy and data quality by the QA/QC Officer. The final report
will include a summary description of project activities, a summary of all data, the field activity
report, a discussion on any problems encountered during the project and the corrective actions
taken, a discussion of the conclusion(s) drawn from the results and the rationale for these
conclusions and the results of the data quality assessment. The final report will be submitted
within 60 days following the receipt of all final assessment analytical data.
\\hhfs0 I\MasterFiles\AAA-Master Projects\Brooks Pierce (BRP)\Erwin Mill (BRP.001)\PCB Assessment\PCB Assessment Sampling
& Analysis Plan\Sampling & Analysis Plan - Erwin Mill (BPN 22058-18-043).doc
hart hickman
SMARTER ENVIRONMENTAL 504UTIONS

Tables
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS

Table 1 (Page 1 of 2)
Summary of Transformer Details
Erwin Mill
Erwin, North Carolina
H&H Job No. BRP-001
Transformer ID
Transformer
Out -of -Service
Capacity
Number
Serial Number
Date
Removal Date
(gallons
Material
Transformer Type
Transformer Condition at Time of Removal
1
unknown
unknown
unknown, post-
184
Silicone
GE KVA 1120 Voltage
unknown
2000
13,200-600Y/346
3
B-977403
3/20/2020
3/25/2020
375
Pyranol
GE KVA 750 Voltage
some corrosion; staining on northern side; no pitting or holes;
13,200-600Y/346
chippedpaint; rust/discoloration
4
C-856388
3/20/2020
3/25/2020
340
Pyranol
GE KVA 750 Voltage
some corrosion; no pitting or holes; chipped paint;
13,200-600Y/346
rust/discoloration
5
R273248A
3/20/2020
4/3/2020
176
Silicone
GE KVA 750 Voltage
some paint chipping; no pitting, holes, or corrosion; no
13,200-600Y/346
rust/discoloration
6
unknown
unknown
1995
unknown
Silicone
unknown
unknown, combined with Transformer #5
7
C-856390
3/20/2020
3/25/2020
340
Pyranol
y
GE KVA 750 Voltage
no holes, pitting, or corrosion; chi
p g, peed paint; rust/discoloration
13,200-600Y/346
8A
PAB3864-001T
3/20/2020
4/3/2020
315
Silicone
GE KVA 750 Voltage
no holes, pitting, or corrosion; no rust/discoloration
13,200-600Y/346
8B
PAB3865-001T
3/20/2020
4/3/2020
315
Silicone
GE KVA 750 Voltage
no holes, pitting, or corrosion; no rust/discoloration
13,200-600Y/346
9A
unknown
unknown
2/29/2009
340
Pyranol
GE KVA 750 Voltage
unknown
13,200-600Y/346
9B
unknown
unknown
2/29/2009
340
Pyranol
GE KVA 750 Voltage
unknown
13,200-600Y/346
10A
unknown
unknown
unknown, post-
243
Silicone
GE KVA 750 Voltage
unknown
2000
13,200-600Y/346
10B
unknown
unknown
unknown, post-
243
Silicone
GE KVA 750 Voltage
unknown
2000
13,200-600Y/346
11A
unknown
unknown
9/14/2009
340
Pyranol
GE KVA 750 Voltage
unknown
13,200-600Y/346
11 B
unknown
unknown
9/14/2009
340
Pyranol
GE KVA 750 Voltage
unknown
13,200-600Y/346
12
unknown
unknown
9/14/2009
340
Pyranol
GE KVA 750 Voltage
unknown
13,200-600Y/346
13
R273471A
3/20/2020
4/3/2020
176
Silicone
GE KVA 1120 Voltage
no holes, pitting, or corrosion; some paint chipping; some
13,200-600Y/346
rust/discoloration
14
unknown
unknown
unknown, post-
172
Silicone
GE KVA 1120 Voltage
unknown
2000
13,200-600Y/346
15
unknown
unknown
7/4/1996
unknown
Silicone
unknown
unknown
16
C-864352C
3/20/2020
3/25/2020
340
Pyranol
GE KVA 750 Voltage
some corrosion; no pitting or holes; chipped paint;
13,200-600Y/346
rust/discoloration
17
E-692660
3/20/2020
3/25/2020
320
Pyranol
GE KVA 750 Voltage
some corrosion; no pitting or holes; chipped paint;
13,200-600Y/346
rust/discoloration
18
unknown
unknown
unknown, post-
166
1
Silicone
1
GE KVA 1120 Voltage
1
unknown
2000
13,200-600Y/346
Table 1 (Page 1 of 2)
\\hhfs01\MasterFiles\AAA-Master Projects\Brooks Pierce (BRP)\Ervin Mill (BRP.001)\PCB Assessment\PCB Assessment Sampling & Analysis Plan\Tables\EnvinMill PCB Tables
9/28/2020 - - Hart & Hickman, PC

Table 1 (Page 2 of 2)
Summary of Transformer Details
Erwin Mill
Erwin, North Carolina
H&H Job No. BRP-001
Transformer ID
Transformer
Out -of -Service
Capacity
Number
Serial Number
Date
Removal Date
(gallons
Material
Transformer Type
Transformer Condition at Time of Removal
19
E-692923
3/20/2020
3/25/2020
400
Pyranol
GE KVA 2000 Voltage
some corrosion; no pitting or holes; chipped paint;
12,540-4160/2400
rust/discoloration
20
PFB5561-001T
3/20/2020
4/3/2020
252
Silicone
GE KVA 1500 Voltage
some corrosion; no pitting or holes; some rust/discoloration
13,200-600Y/346
21
PFB5561-002T
3/20/2020
4/3/2020
252
Silicone
GE KVA 1500 Voltage
some corrosion; no pitting or holes; some rust/discoloration
13,200-600Y/346
22
unknown
unknown
unknown, post-
215
Silicone
GE KVA 1500 Voltage
unknown
2000
13,200-600Y/346
23
unknown
unknown
9/29/2009
290
No. 1470
WH KVA 1500 Voltage
unknown
Pyranol
13,200-600Y/346
24
unknown
unknown
unknown, post-
249
Silicone
GE KVA 1500 Voltage
unknown
2000
13,200-600Y/346
25
unknown
unknown
1995
unknown
Silicone
unknown
unknown, combined with Transformer #5
26
H-885025
3/20/2020
3/27/2020
279
Pyranol
GE KVA 2500 Voltage
no holes, pitting, or corrosion; slight paint chipping;
12,470-4160Y/2400
rust/discoloration
27
H-883990
3/20/2020
3/25/2020
191
Pyranol
GE KVA 1500 Voltage
some corrosion; staining on northern side; no pitting or holes;
13,200-600Y/346
chippedpaint; rust/discoloration
28
unknown
unknown
1994
unknown
Silicone
unknown
unknown
29
H-885026
3/20/2020
3/27/2020
187
Pyranol
GE KVA 1500 Voltage
no holes, pitting, or corrosion; chipped paint; slight
12,470-4160Y/2400
rust/discoloration
30
H-885583
3/20/2020
3/27/2020
187
Pyranol
GE KVA 1500 Voltage
some paint chipping; no pitting, holes, or corrosion; no
13,200-600Y/346
rust/discoloration
32
unknown
unknown
unknown, post-
435
oil - unspecified
WH KVA 3750 Voltage
unknown
2000
1
12,470-2400Y/1385
33
unknown
unknown
unknown, post-
239
1
Wecosol Fluid
WH KVA 1500 Voltage
unknown
2000
12,470-575Y/332
Notes:
GE = General Electric; WH = Westinghouse
Table 1 (Page 2 of 2)
\\hhfs01\MasterFiles\AAA-Master Projects\Brooks Pierce (BRP)\Ervin Mill (BRP.001)\PCB Assessment\PCB Assessment Sampling & Analysis Plan\Tables\Erwin Mill PCB Tables
9/28/2020 - - Hart & Hickman, PC

Table 2 (Page 1 of 1)
Summary of PCB Analytical Data
Erwin Mill
Erwin, North Carolina
H&H Job No. BRP-001
PCB Aroclors (8082) (mg/kg)
PCB Congeners (1668A) (mg/kg)
Sample ID
Soil Sample
Depth
(ft bgs)
Sample
Date
Transformer
Designation
Number
N
L
o
P
N
o
P
U
U
CO
m
0-
6
o
m
m
a
4
-
m
a)
0-
00
-
m
a)m
a
A
N
m
0-
(6
N
m
S
O
CO
`O
CD
x
_
111�-
(.0
m
x
_
&
`°
CD
x
=
rn
00
c
o c
o
z° � U
EPA Cleanup Level
1
1
--
--
--
--
--
--
--
--
--
--
--
Protection of Groundwater PSRGs
0.091
0.24
0.0084
0.0028
0.047
0.047
0.046
0.047
0.000014
0.077
0.075
0.000075
0.13
0.055
Residential PSRGs
0.23
0.24
0.038
0.012
0.12
0.12
0.12
0.12
0.000036
0.12
0.12
0.00012
0.13
0.23
Industrial/ Commercial PSRGs
0.97
0.99
0.16
0.048
0.49
0.51
0.49
0.50
0.00015
0.51
0.51
0.00051
0.52
0.95
HA-3
4
06/28/01
#3
23
HA-3A
3-4
07/10/19
0.403
26.5 E
1.64
52.6 E
0.750
9.53
2.58
0.601
677
HA-4
4
06/28/01
#4
0.36
HA-4A
3-4
11/21/19
0.025
HA-7
4
06/28/01
#7
0.33
HA-7A
3-4
11/21/19
0.0231
HA-9A
4
06/28/01
#9A
0.32
HA-913
4
06/28/01
#96
1.3
HA-9C
3-4
11/18/19
HA-11A
4
06/28/01
411A
HA-11 B
4
06/28/01
#11 B
1.0
HA-11C
3-4
11/21/19
HA-12
4
06/28/01
#12
0.29
HA-12A
3-4
11/20/19
0.0119
HA-16
4
06/28/01
#16
0.15
HA-17
4
06/28/01
#17
0.55
Ni
NA
HA-17A
3-4
11/21/19
<0.001 b-
0.00585
0.0281
0.016
0.00652
<0.001 y�)
0.00469 J
5.34
Duplicate
11/21/19
0.00234
<0.0018F
0.018
0.0921
0.0545
0.0195
<0.00185
0.0148
18.8
HA-19
4
06/28/01
#19
HA-23
4
06/28/01
#23
0.82
HA-23A
3-4
11/20/19
HA-26
4
06/28/01
#26
2.1
HA-26A
3-4
07/09/19
0.393
24.9 E
1.53
50.1 E
0.820
9.13
2.42
0.572
662
HA-27
4
06/28/01
#27
3.2
HA-27A
3-4
07/10/19
0.316
21.3
1.33
41.7 E
0.668
7.70
2.04
0.479
562
Wipe-29A*
--
06/28/01
#29
Wi e-29B*
--
06/28/01
78
Wipe-30A*
--
06/28/01
#30
76
Wi e-30B*
--
06/28/01
S-1
--
03/25/20
Tunnel
Stockpile
29
S-2
--
03/25/20
20
Notes:
1) Environmental Protection Agency (EPA) Cleanup Levels per 40 CFR § 761.61 (a)(4) (EPA Cleanup Levels)
2) North Carolina Department of Environmental Quality (DEQ) Inactive Hazardous Sites Branch (IHSB) Preliminary Soil Remediation Goals (PSRGs) (July 2020).
*Wipe samples were compared to EPA Cleanup Level of 10 pq/100 crr2 or 1 pg/Wipe. PSRGs have not been established for wipe samples.
Soil concentrations are reported in milligrams per kilogram (mg/kg). Wipe concentrations are reported in micrograms per 10 cn2 (pg/Wipe).
Bold values exceed the lowest PSRGs.
Shaded values exceed EPA Cleanup Levels.
Laboratory analytical methods and units are shown in parentheses.
PCBs = Polychlorinated Biphenyls; ft bgs= feet below ground surface; NA = Not Analyzed; - = Not Applicable; < = Less than Laboratory Method Detection Limit.
J = compound was detected above the laboratory method detection limit but below the laboratory reporting limit resulting in an estimated concentration.
E = compound was detected above the instrument calibration range resulting in an estimated concentration.
Table 2 (Page 1 of 1)
\\hhfs0l\MasterFiles\AAA-Master Projects\Brooks Pierce (BRP)\Erwin Mill (BRP.001)\PCB Assessment\PCB Assessment Sampling & Analysis Plan\Tables\ErwinMill_PCB_Tables
9/28/2020 Hart & Hickman, PC

Table 3 (Page 1 of 2)
Proposed Sampling Locations and Analyses
Erwin Mill
Erwin, North Carolina
H&H Job No. BRP-001
Sample ID
Sample Depth
(ft bgs)
Sample Location
PCB Analyses
EPA 8082A
EPA 1668A
Soil Samples
PCB-3
0-0.5
Transformer #3
X
on hold
5-6
X
on hold
PCB-4
0-0.5
Transformer #4
X
on hold
PCB-7
0-0.5
Transformer #7
X
on hold
PCB-9A
0-0.5
Transformer #9A
X
on hold
PCB-9B
0-0.5
Transformer #9B
X
on hold
PCB-11A
0-0.5
Transformer #11 A
X
on hold
PCB-11 B
0-0.5
Transformer #11 B
X
on hold
PCB-12
0-0.5
Transformer #12
X
on hold
PCB-16
0-0.5
Transformer #16
X
on hold
PCB-17
0-0.5
Transformer #17
X
on hold
PCB-19
0-0.5
Transformer #19
X
on hold
PCB-23
0-0.5
Transformer #23
X
on hold
PCB-26
0-0.5
Transformer #26
X
on hold
PCB-27
0-0.5
Transformer #27
X
on hold
PCB-T1
0-0.5
Tunnel
X
on hold
Subtotal
16
TBD
Concrete Samples
CS-1
--
Transformer #3
X
on hold
CS-2
--
Transformer #9A
X
on hold
CS-3
--
Transformer #9B
X
on hold
CS-4
--
Transformer #11 A
X
on hold
CS-5
--
Transformer #11 B
X
on hold
CS-6
--
Transformer #17
X
on hold
CS-7
--
Transformer #26
X
on hold
CS-8
--
Transformer #27
X
on hold
CS-9
--
Transformer #29
X
on hold
CS-10
--
Transformer #30
X
on hold
CS-11
--
Tunnel
X
on hold
CS-12
__
Former Cotton Blending Building
Slab
on hold
Subtotal
11
TBD
Groundwater Samples
MW-12
--
North of Transformer #26
X
on hold
MW-15
--
South of Transformer #7
X
on hold
MW-18
--
Southwest of Transformer #30
X
on hold
MW-20
--
Downgradient of Wetlands Area
X
on hold
Subtotal
4
TBD
Surface Water Samples
SW-1
--
Reservoir
X
on hold
SW-2
--
Potential Wetland
X
on hold
SW-3
--
Upstream
X
on hold
SW-5
--
Mid -Stream
X
on hold
SW-6
--
Downstream
X
on hold
Subtotal
5
TBD
Table 3 (Page 1 of 2)
\\hhfs0l\MasterFiles\AAA-Master Projects\Brooks Pierce (BRP)\Erwin Mill (BRP.001)\PCB Assessment\PCB Assessment Sampling & Analysis Plan\Tables\ErwinMill_PCB_Tabl
10/13/2020 lhart Hickman, PC

Table 3 (Page 2 of 2)
Proposed Sampling Locations and Analyses
Erwin Mill
Erwin, North Carolina
H&H Job No. BRP-001
Sediment Samples
SED-1
--
Reservoir
X
on hold
SED-2
--
Potential Wetland
X
on hold
SED-3
--
Upstream
X
on hold
SED-5
Mid -Stream
X
on hold
SED-6
--
Downstream
X
on hold
Subtotal
5
TBD
Other Samples
OS-3 -- Tar -Like Material
X
X
Subtotal
1
1
QA/QC Samples
Field Duplicate (5%)
--
Per media
6
1-6
Equipment Rinseate
Blank 5%
Per media sampled using non-
dedicated equipment
4
1-4
MS/MSD (5%)
--
Per media
6
1-6
Subtotal
16
3-16
TOTAL SAMPLES
58
3-59
Notes:
PCBs = polychlorinated biphenyls; QA/QC = Quality Assurance/Quality Control; MS/MSD = matrix spike/matrix spike duplicate; TBD
= To Be Determined; ft bgs = feet below ground surface.
Table 3 (Page 2 of 2)
\\hhfs0l\MasterFiles\AAA-Master Projects\Brooks Pierce (BRP)\Erwin Mill (BRP.001)\PCB Assessment\PCB Assessment Sampling & Analysis Plan\Tables\ErwinMill_PCB_Tabl
10/13/2020 lhart Hickman, PC

Figures
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS

03
utaEi
Gem

v
2
C0
,l~7
m
i
W. H STREET
ELECTRICAL
SUBSTATION
COMPRESSOR AREA
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SHIPPING &
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#20
F
A
m
rn
—1 SPINNING
AREA
#22
#1
WINDING
AREA
I
I
n
55-GALLON DRUM
I
STORAGE AREA
I
AMMONIA
FINISHING
MW-
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#26 T
—
#21
SPINNING
AREA
—ALLEY
BEAMING
AREA
COURTYARD
SHOP
AREA
P,
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WAREHOUSE/OFFICES
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E. J STREET
PARKING LOT
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v DYE PIT BRUSHING
#6A/B®T AREA FUEL OIL
W 4� W-3 DYE #10A/s0 BOILER
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i
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m
y
-�i
OS
FORMER COAL
POWER PLANT
GARAGE/SHOP
BATTERY
CHARGING AR A
TUNNEL N#27 MW-9
MW-10 MW-15
NI
W-8
WAREA GMW-16 0,
VSOIL MW 7
#30 STOCKPILE oUS
RESERVOIR FORMER CHEMICAL WAREHOUSE BUILDINGS—
GS-
STORAGE AREA
MW-18+
00
DYE STO
AGE AREA
MW-190
GRASS
^ \
I
I
BMW-20"
\
l FORM
R 150,000-
GALL
FUEL OIL ASTs
I
FORMER 1,000,
PARKING LOT
00-
n
GALLON FUEL
IL AST
L
/1
POTENTIAL
WETLAND AREA
I
W. F STREET
1
CHIEF JOSEPH LANE
i
2 w
cn
,Z~] C/)
m A
m
m
m
y
LEGEND
SITE PROPERTY BOUNDARY
FORMER BUILDING
WATER FEATURE
FENCE LINE
TRENCH DRAIN
-->-->- DITCH
#16 E2 FORMER PCB TRANSFORMER
#21 ®T FORMER NON -PCB TRANSFORMER
=U- FORMER UST
® FLOOR DRAIN
PERMANENT MONITORING WELL
ABANDONED/DESTROYED WELL LOCATION
NOTES:
1. PCB = POLYCHLORINATED BIPHENYLS
2. PCB TRANSFORMERS #9A, #9B, #11A, #11 B, #12, AND #23 WERE
REMOVED IN 2009. THE REMAINING PCB TRANSFORMERS
WERE REMOVED IN MARCH 2O20.
3. NON -PCB TRANSFORMERS #6 AND #25 WERE COMBINED WITH
TRANSFORMER #5 IN 1995. NON -PCB TRANSFORMERS WERE
REMOVED BETWEEN 1994 AND 2020.
4. LOCATIONS OF NON -PCB TRANSFORMERS #18 AND #28
ARE UNKNOWN.
5. SOIL FROM TUNNEL STOCKPILED ON FORMER TRANSFORMER
#27 PAD.
8
APPROXIMATE
0 200 400
SCALE IN FEET
SITE MAP
---- ERWIN MILL FACILITY
200 NORTH 13TH STREET
ERWIN, HARNETT COUNTY, NORTH CAROLINA
'"`• h i e k m a n Raleigh,
alg,Sunset
N. Ridge Road, Suite 301
hart
Raei hNorth Carolina 27607
P. 919-847-4241(p) 919-847-4261(1}
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
DATE: 9-28-20 REVISION NO. 0
JOB NO. BRP-001 FIGURE NO. 2

HA-19
AROCLORS (6/28/2001)
<PSRGs & EPA CLEANUP LEVEL
CONGENERS - NOT ANALYZED
HA-3/3A
AROCLORS (6/28/2001)
AROCLOR-1260 23
CONGENERS (7/10/2019)
77-TeCB
0.403
105-PeCB
26.5 E
114-PeCB
1.64
118-PeCB
52.6 E
123-PeCB
0.75
156/157-HxCB
9.53
167-HxCB
2.58
189-HxCB
0.601
NON -DIOXIN LIKE CONGENERS
677
m
HA-4/4A
AROCLORS (6/28/2001)
AROCLOR-1260 1 0.36
CONGENERS (11/21/2019)
<PSRGs
HA-17/17A
AROCLORS (6/28/2001)
AROCLOR-1260 1 0.55
CONGENERS (11/21/2019)
NON -DIOXIN LIKE CONGENERS 1 18.8*
ELECTRICAL
SUBSTATION
WIPE-30A/30B
AROCLORS (6/28/2001)
AROCLOR-1254 1 76
CONGENERS - NOT ANALYZED
HA-26/26A
AROCLORS (6/28/2001)
AROCLOR-1254 2.1
CONGENERS (7/9/2019)
77-TeCB
0.393
105-PeCB
24.9 E
114-PeCB
1.53
118-PeCB
50.1 E
123-PeCB
0.820
156/157-HxCB
9.13
167-HxCB
2.42
189-HxCB
0.572
NON -DIOXIN LIKE CONGENERS
662
9
2
m
i
SHIPPING &
RECEIVING
SPINNING
AREA
#22
WINDING
AREA
7
TUNNEL
WARPING
AREA
#30
MW-18+
`/
O O DYE TO
TUNNEL SOIL STOCKPILE SAMPLES
S1
AROCLORS (3/25/2020)
AROCLOR-1260 1 29
CONGENERS - NOT ANALYZED
S2
AROCLORS (3/25/2020)
AROCLOR-1260 1 20
CONGENERS - NOT ANALYZED
MW-19
n \
I \ FORM R 150,0
\M V l GALL FUEL
j FORMER 1,000, �00-
\ GALLON IUEL IL AST
R`
I
I POTENTIAL
WETLAND AREA
W F STREET
WIPE-29A/29B
AROCLORS (6/28/2001)
AROCLORS
78
J DRUM CONGENERS - NOT ANALYZED
E AREA
I AMMONIA
#21
SPINNING AREA I I ' T #16
ALLEY
HA-16
AROCLORS (6/28/2001)
<PSRGs & EPA CLEANUP LEVEL
CONGENERS - NOT ANALYZED
USE/OFFICES
t #2 `Y
BEAMING #14H
AREA I J I
I
1 HA-12/12A
FORMER
DURTYARD I LI OTT N I MW-13
BLE
BUILDING
AREA I FINISHING
I �
SHOP � I I I �.#1�A/B
AREA I HA-11A_ -
DYE PIT BRUSHING
� AREA FUEL OIL
-71 MW 4 � W-3 DYE #10A/BE BOILER
HOUSE BUILDING
MW 5 HA-9B/9C T HA-9A
MW-2� #7 HA-7/7A #
F J.�
#W#3M
W
MW-10 �- MW-1H 7/
27AM8
S MW 7
STO PILE
RESERVO FORMER CHEMI L WAREHOUSE BUILDI
STORAGE AREA HA-7/7A
AROCLORS (6/28/2001)
AROCLOR-1260 1 0.33
CONGENERS (11/21/2019)
<PSRGs
AREA
HA-27/27A
AROCLORS (6/28/2001)
AROCLOR-1254 3.2
CONGENERS (7/10/2019)
77-TeCB
0.316
105-PeCB
21.3
114-PeCB
1.33
118-PeCB
41.7 E
123-PeCB
0.668
156/157-HxCB
7.70
167-HxCB
2.04
189-HxCB
0.479
NON -DIOXIN LIKE CONGENERS
562
PAP
HA-23/23A
AROCLORS (6/28/e
AROCLOR-1254
CONGENERS (11/20
<PSRGs
HA-12/1
AROCLORS((
AROCLOR-12E
CONGENERS('
<PSR(
J
I WARE H OUSE/OFFICI
HA-11 B/11 C
AROCLORS (6/28/2001)
AROCLOR-1260 1.0
CONGENERS (11/21/2019)
<PSRGs
z
w
ER DYE I HA-11A
HOUSE AROCLORS (6/28/2001)
<PSRGs & EPA CLEANUP LEVEL
CONGENERS - NOT ANALYZED
COAL SILOS
FORMER COAL
POWER PLANT
GARAGE/SHOP
BATTERY
433 CHARGING AREA
HA-9A
AROCLORS (6/28/2001)
AROCLOR-1260 0.32
CONGENERS - NOT ANALYZED
HA-9B/9C
AROCLORS (6/28/2001)
AROCLOR-1260 1.3
CONGENERS (11/18/2019)
<PSRGs
JO
LEGEND
SITE PROPERTY BOUNDARY
- - - -
FORMER BUILDING
- - -
WATER FEATURE
FENCE LINE
TRENCH DRAIN
-->-->-
DITCH
#16 ®
FORMER PCB TRANSFORMER
#21
FORMER NON -PCB TRANSFORMER
OUST
FORMER UST
®
FLOOR DRAIN
PERMANENT MONITORING WELL
ABANDONED/DESTROYED WELL LOCATION
PCB CONGENERS SOIL SAMPLE LOCATION
SAMPLE ID-� PCB TYPE & DATE
CONSTITUENT -
HX-7/iK
AROCLORS (6/28/2001)
AROCLOR-1260 1 0.33
CONGENERS (11/21/20 9)
<PSRGs
CONCENTRATION)
NOTES: (mg/kg)
1. SOIL SAMPLES COLLECTED BETWEEN 3 TO 4 FT BGS INTERVAL.
2. ONLY PCB COMPOUNDS DETECTED ABOVE NC PRELIMINARY
SOIL REMEDIATION GOALS (PSRGs) ARE SHOWN.
3. BOLD INDICATES AN EXCEEDANCE OF EPA CLEAN UP LEVEL
OF 1 mg/kg OR 1 µg/WIPE FOR AROCLORS.
4. PCB = POLYCHLORINATED BIPHENYLS
TeCB = TETRACHLOROBIPHENYL
PeCB = PENTACHLOROBIPHENYL
HxCB = HEXACHLOROBIPHENYL
<MDL = LESS THAN METHOD DETECTION LIMIT
E = COMPOUND DETECTED ABOVE INSTRUMENT CALIBRATION
RANGE RESULTING IN ESTIMATED CONCENTRATION
* = CONCENTRATION FROM DUPLICATE SAMPLE
BGS = BELOW GROUND SURFACE
5. 2001 SAMPLES COLLECTED BY ENGINEERING CONSULTING
SERVICES, LTD.
0
APPROXIMATE
0 200 400
SCALE IN FEET
PCB CONCENTRATION MAP
(n I I ERWIN MILL FACILITY
w
200 NORTH 13TH STREET
ERWIN, HARNETT COUNTY, NORTH CAROLINA
gto
(3f0}1hart �hlckma� Raleigh, North Ridge
27607m . 919-847-4241(p) 919-847-4261m
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
y
DATE: 9-28-20
REVISION NO. 0
JOB NO. BRP-001
FIGURE NO. 3

2
C0
,l~7
m
i
W. H STREET
ELECTRICAL
SUBSTATION
55-GALLON DRUM
STORAGE AREA
COMPRESSOR AREA
WATER TANK
SHIPPING &
RECEIVING #21
#zo
F
z SPINNING AREA
p� #13—#19
r r ALLEY
C/)
~ BEAMING
m AREA
—1 SPINNING
AREA 1--,
MW-18+ /
RTYARD
#22
#17 -61 1 r
F #5 SHOP
WINDING AREA
4 AREA
DYE PIT
#8A/BM
40 MW-4
DYE
yMW 3
HOUSE
7 1 1 MW-2;
I
I
n
I
I
I
I AMMONIA
FINISHING
W-11
(0 ®
——
(0
®
®
® ®
F
_= I
WAREHOUSE/OFFICES
T #16
E. J STREET
PARKING LOT
#14H T• �a�u�1
#12
FORMER
COTTON MW-13
BLENDING J
BUILDING ® WAREHOUSE/OFFICES
AREA i FINISHING
I ® FORMER DYE
1 1#11 A/B ® HOUSE
BRUSHING
AREA FUEL OIL
#10A/13Q BOILER (
BUILDING
#�
#32 MW-14
MW-9
TUNNEL
MW-1040- MW-15
,i, MN/-8
WAREA GMW-160, VS
OIL MW 7
#30 STOCKPILE
RESERVOIR FORMER CHEMICAL
STORAGE AREA
LJFT �
lJ �'
O O DYE STO AGE AREA
Mw-19 O
w
2
GRASS co
m
y
-�i
OS
FORMER COAL
POWER PLANT
GARAGE/SHOP
BATTERY
CHARGING AR A
oUS
WAREHOUSE BUILDING
oUS
\ ` \ \ �-FIRMI 150,000-
\MW-20 - l
GALL FUEL OIL ASTs
PARKING LOT
FORMER 1,000, 00-
GALLON FUEL IL AST
POTENTIAL
WETLAND AREA
W. F STREET
1
Cn
2
m
i
CHIEF JOSEPH LANE
LEGEND
SITE PROPERTY BOUNDARY
—
FORMER BUILDING
—
WATER FEATURE
FENCE LINE
TRENCH DRAIN
-->-->-
DITCH
#16 E2
FORMER PCB TRANSFORMER
#21 ®r
FORMER NON -PCB TRANSFORMER
=US
FORMER UST
®
FLOOR DRAIN
PERMANENT MONITORING WELL
ABANDONED/DESTROYED WELL LOCATION
PROPOSED SURFICIAL SOIL SAMPLE LOCATION
PROPOSED SUBSURFACE SOIL SAMPLE
LOCATION
PROPOSED CONCRETE SAMPLE LOCATION
PROPOSED GROUNDWATER SAMPLE LOCATION
PROPOSED SURFACE WATER / SEDIMENT
SAMPLE LOCATION
PROPOSED "TAR -LIKE" MATERIAL SAMPLE
LOCATION
NOTES:
1. PCB = POLYCHLORINATED BIPHENYLS
8
APPROXIMATE
0 200 400
SCALE IN FEET
PROPOSED SAMPLE LOCATION MAP
---- ERWIN MILL FACILITY
200 NORTH 13TH STREET
ERWIN, HARNETT COUNTY, NORTH CAROLINA
e 301
hart 1 hickman Raleigh,
aleg nset ,N.,1 CaRoad, ina27607
Ralei h, North Carolina 27607
. 919-847-4241(p) 919-847-4261(1}
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
DATE: 9-28-20 REVISION NO. 0
JOB NO. BRP-001 FIGURE NO. 4

Appendix A
Project Organization Chart
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS

USEPA Region 4
Project Officer
Mr. Peter Johnson
[phone]
NCDEQ Brownfields
Project Manager
Ms. Kathleen Markey
[phone]
Laboratory Project
Manager
Con -Test Analytical
Laboratory
Ms. Kerry McGee
[phone]
Project Organization Chart
Sampling & Analysis Plan
Erwin Mill
Erwin, North Carolina
Erwin Plant LLC
Mr. Norman Avery
Manager
[phone]
Hart & Hickman
Leonard Moretz, PG
Project Manager
[phone]
Hart & Hickman
Lisa Nickels, PG
Project Coordinator
[phone]
The QA Manager has
independent authority and
is separate from those who
generate the data
Hart & Hickman
Greg Kanellis, PE
--- QA/QC Officer
[phone]
Hart & Hickman
Chase Goodwin
Field Scientist
[phone]
14
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS

Appendix B
Site -Specific Health and Safety Plan
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS

Health & Safety Plan
PCB Waste Assessment and
Remediation
Erwin Mill
200 North 13tn Street
Erwin, North Carolina
H&H Job No. BRP-001
October 1, 2020
f + ENVIRONMENTAL SOLUTIONS
� 54 5x:•
}f F ,1
}y111�r�lklS\5
2923 South Tryon Street, Suite 100 3921 Sunset Ridge Rd, Suite 301
Charlotte, NC 28203 Raleigh, NC 27607 www.harthickman.com
704.586.0007 main 919.847.4241 main

Health and Safety Plan
PCB Waste Assessment and Remediation
Erwin Mill
200 North 13th Street
Erwin, North Carolina
H&H Job No. BRP-001
Table of Contents
Section
Page No.
1.0 Summary..................................................................................................................................1
2.0 Applicability............................................................................................................................3
3.0 Purpose and Scope of Work...................................................................................................4
4.0 Responsibilities........................................................................................................................5
4.1 Project Manager (H&H)........................................................................................................5
4.2 Project Coordinator (H&H)...................................................................................................6
4.3 Site Safety Officer (H&H).....................................................................................................6
4.4 Manager, Health and Safety (H&H)......................................................................................7
4.5 Field Sampling Technicians (H&H)......................................................................................8
4.6 Subcontractor's Safety Representative...................................................................................8
4.7 Subcontractor Personnel........................................................................................................8
5.0 Job Hazard Analysis.............................................................................................................11
5.1 Heat Stress and Cold Stress Recognition and Control........................................................12
5.2 Chemical Hazards................................................................................................................13
5.3 Noise Hazards......................................................................................................................18
5.4 Underground Utilities (Pre -Drilling Protocol).....................................................................18
5.5 Work Area Protection..........................................................................................................18
5.6 Hazard Communication.......................................................................................................19
5.7 Heavy Equipment................................................................................................................20
5.8 Site Physical Hazards..........................................................................................................20
6.0 Exposure Monitoring Plan...................................................................................................21
6.1 Chemical Exposure Monitoring...........................................................................................21
6.2 Background Readings..........................................................................................................22
6.3 Data Logging.......................................................................................................................22
6.4 Dust Control........................................................................................................................23
7.0 Personal Protective Equipment...........................................................................................24
8.0 Site Control............................................................................................................................25
8.1 General.................................................................................................................................25
8.2 Work Zones.........................................................................................................................25
8.3 Surrounding Community Exposure Protection....................................................................26
9.0 Decontamination Procedures...............................................................................................27
10.0 Safe Work Practices............................................................................................................28
11.0 Emergency Response Plan..................................................................................................30
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SMARTER ENVIRONMENTAL SOLUTIONS

11.1
Places of Refuge................................................................................................................31
11.2
Fire.....................................................................................................................................31
11.3
Communication.................................................................................................................31
11.4
Incident Report..................................................................................................................32
11.5
Operation Shutdown..........................................................................................................32
11.6
Spill or Hazardous Materials Release................................................................................32
11.7
Emergency Medical Treatment Procedures.......................................................................32
11.8
Community Safety.............................................................................................................33
12.0 Training
and Medical Surveillance...................................................................................34
13.0 Recordkeeping.....................................................................................................................35
14.0 Toxic
Snake and Insect Bites and Plants..........................................................................36
14.1
Poisonous Snakebites........................................................................................................36
14.2
Poisonous Insect Bites.......................................................................................................37
14.3
Tickborne Diseases............................................................................................................39
14.4
Poisonous Plants................................................................................................................41
15.0 Medical Surveillance...........................................................................................................42
List of Appendices
Appendix A Heat Stress and Cold Stress Guidance
Appendix B Health and Safety Equipment List
Appendix C Hospital Route Map
Appendix D H&H Forms and Reports
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SMARTER ENVIRONMENTAL SOLUTION5

Health and Safety Plan
PCB Waste Assessment and Remediation
Erwin Mill
200 North 13t" Street
Erwin, North Carolina
H&H Job No. BRP-001
Contact Numbers
Client Contact: Jeffrey Smith
[phone]
Bankruptcy Administrator
Lynn, Smith & Webb, PLLC
Site Contact: Norman Avery
Erwin Mill Vice President
[phone]
Fire/Ambulance/Police:
911
Hospital: Betsy Johnson Hospital
[phone]
800 Tilghman Drive
Dunn, NC 28334
Poison Control: [phone]
Project Manager: Leo Moretz, PG [phone] (o)
[phone] (c)
Manager, Health & Safety: Shannon Cottrill [phone] (o)
[phone] (c)
Project Coordinator: Lisa Nickels, PG [phone] (o)
[phone] (c)
Site Safety Officer: Chase Goodwin [phone] (c)
Preparation Date: October 1, 2020
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SMARTER ENVIRONMENTAL SOLUTION5

Health and Safety Plan
PCB Waste Assessment and Remediation
Erwin Mill
200 North 13t" Street
Erwin, North Carolina
H&H Job No. BRP-001
Approvals
Project Manager
9/30/20
Leo Moretz, PG, RSM (Date)
Health & Safety Manager
r�
10/1/20
Shannon Cottrill (Date)
This Health and Safety Plan is valid only for this specific project as described in Section 3.0. It
is not to be used for other projects or subsequent phases of this project without the written
approval of the Manager of Health and Safety.
iv
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SMARTER ENVIRONMENTAL SOLUTION5

Health and Safety Plan
PCB Waste Assessment Remediation
Erwin Mill
200 North 13th Street
Erwin, North Carolina
1.0 Summary
Hart & Hickman, PC (H&H) will perform assessment and remediation work on behalf of Erwin
Plant, LLC at the Erwin Mill property located at 200 North 131h Street in Erwin, Harnett County,
North Carolina. Work is being performed under the direction of the North Carolina Department
of Environmental Quality (NCDEQ) Brownfields Program and the United States (U.S.)
Environmental Protection Agency (EPA). Erwin Mill (Parcel Identification No. [PIN] 0597-54-
8405.000) consists of one parcel of land that totals approximately 55.25 acres and is developed
with multiple office buildings, warehouse storage buildings, and former textile manufacturing
buildings.
Erwin Mill was developed as a textile manufacturing facility in 1904. The facility primarily
focused on the production of denim. Burlington Industries purchased the Site in 1962 and
continued to operate the facility. Burlington Industries merged with Swift Textiles, Inc. in 1987,
and the facility continued to operate through 2000, when Erwin Mill was purchased by the
current owner, Schwarz Auman Properties, LLC, renamed Erwin Plant, LLC in 2003. Since
2000, Erwin Mill has been predominately vacant with the exception of several warehouse
buildings that have been leased to various tenants. Current or recent tenants (since 2000) include
general small businesses, county offices, warehouse users, and some light manufacturing (rifle
assembly, ammunition assembly, and cabinet shop). In 2013, Erwin Plant, LLC filed for
bankruptcy.
H&H and/or subcontractors will be conducting various types of work associated with the
assessment, investigation, sampling and remediation of environmental media at this site. This
work may include, but is not limited to:
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• soil sampling;
• concrete sampling;
• surface water and sediment sampling;
• sampling of groundwater monitoring wells; and
• excavation of impacted soils.
According to previous investigations conducted at the site, impacted soil has been identified in
numerous areas across the Site. Petroleum -related constituents have been detected in soil and
groundwater and polychlorinated biphenyls (PCBs) have been detected in soil adjacent to former
PCB -containing transformer locations. In addition, low levels of volatile organic compounds
(VOCs) have been detected in groundwater in various portions of the Site.
Skin contact with potentially contaminated soil and groundwater will be minimized by wearing
personal protective clothing (as described in Section 6.0). Inhalation of vapors during soil and
groundwater sampling and other related environmental activities will be minimized by air
monitoring, and engineering controls including the use of respiratory protection, if necessary.
Ingestion of contaminated materials will be minimized by good personal hygiene practices (i.e.,
thoroughly washing face and hands with soap and water before eating or drinking).
A photoionization detector (PID) will be used to monitor for organic vapors. The analyzer will
be used on a regular basis to monitor air in the breathing zone in the work area. If readings
exceed an average of 0.5 parts per million (ppm) (benzene TWA = 0.5 ppm) for more than one
minute above background, monitoring in the operator's breathing zone (OBZ) of the person
working nearest the borehole will start immediately, and personnel will don protective clothing
as described in Section 7.0. Additional exposure monitoring and personal protective equipment
criteria are found in Sections 6.0 and 7.0, respectively.
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2.0 Applicability
The purpose of this Health & Safety Plan (HSP) is to assign responsibilities, establish personal
protection standards and mandatory safety procedures, and provide for contingencies that may
arise while operations are being conducted at the site. This plan was developed specifically for
operations at the Erwin Mill facility. This plan complies with, but does not replace, Federal
Health and Safety Regulations as set forth in 29 CFR 1910 and 1926. This plan is to be used by
H&H's personnel as a supplement to such rules, regulations, and guidance. The provisions of the
plan are mandatory for all on -site H&H's employees engaged in hazardous material management
activities associated with this project which may involve health and safety hazards.
H&H will be performing work on behalf of Erwin Plant, LLC and under contract with Brooks
Pierce. Neither H&H, Erwin Plant, LLC, nor Brooks Pierce will be responsible for the health
and safety of subcontractor personnel. H&H will monitor subcontractor safety for general
compliance with this plan and provide suggestions regarding compliance with their individual
safety programs. The site subcontractors will be responsible for establishing and implementing
their HSPs.
Changing and/or unanticipated site conditions may require modification of this plan in order to
maintain a safe and healthful work environment. Any proposed changes to this plan should be
reviewed with the H&H Manager of Health and Safety (MH&S), or his properly qualified
designee, prior to their implementation. If this is not feasible, the Project Manager (PM) may
modify the plan and record changes in the field log book. Under no circumstances will
modifications to this plan conflict with federal, state, or local health and safety regulations.
H&H will provide a copy of this Health and Safety Plan to site subcontractors in order to fulfill
its obligations under 29 CFR 1910.120(b)(iv) to inform subcontractors of site hazards and to
guide the site subcontractors in development of their individual HSPs. However, each of H&H's
subcontractors is to provide their own HSP that addresses the activities of their employees
relative to this project.
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3.0 Purpose and Scope of Work
H&H is under contract to perform assessment activities at the Erwin Mill facility located at
200 North 13th Street in Erwin, Harnett County, North Carolina. As part of these site activities,
H&H and the site subcontractors will conduct various types of work associated with the
assessment and/or remediation of PCB waste in soil, groundwater, concrete, surface water,
and/or sediment at this site.
The primary site activities to be performed by site subcontractors include the following:
• construction of institutional controls;
• operation of heavy equipment during remediation activities; and
• operation of heavy equipment during investigation -derived waste (IDW) handling
activities.
H&H will provide services that will include:
• soil, groundwater, sub -slab gas, surface water, and sediment sample collection;
• observation, coordination, and inspection of the site subcontractor activities; and
• perimeter and ambient air monitoring.
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4.0 Responsibilities
The provisions of the HSP are mandatory for on -site H&H employees who are engaged in
hazardous material management activities including, but not limited to, field investigations, soil
and groundwater sampling, remedial actions, remediation system installation, and remediation
system operations and maintenance (O&M). This plan has been developed under U.S. EPA
guidelines and complies with applicable regulations, including Occupational Safety and Health
Administration (OSHA) standards [29 Code of Federal Regulations (CFR) 1910 and 1926].
H&H will have site safety and health oversight and coordination responsibilities for H&H
personnel. Each subcontractor will be held accountable for the safe and healthful performance of
work by each of their employees, subcontractor, or support personnel who may enter the site.
The provisions of this HSP along with the applicable regulations issued by governmental entities
will be adhered to by H&H.
4.1 Project Manager (H&H)
The Project Manager (PM) shall direct on -site operations. The PM may delegate all or part of
these duties to a properly qualified H&H employee who is designated as the Project
Coordinator (PC) or Site Safety Officer (SSO). At the site, the PM, assisted by the PC and SSO,
has primary responsibility for:
1. Seeing that appropriate personal protective equipment and monitoring equipment are
available and properly utilized by on -site H&H personnel.
2. Establishing that H&H personnel are aware of the provisions of this plan, are instructed
in the work practices necessary to ensure safety, and are familiar with planned procedures
for dealing with emergencies.
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3. Establishing that H&H on -site personnel have completed a minimum of 40 hours of
health and safety training and have appropriate medical clearance as required by 29 CFR
1910.120, and have been fit tested for the appropriate respirators.
4. Seeing that H&H personnel are aware of the potential hazards associated with site
operations.
5. Monitoring the safety performance of all H&H personnel to see that the required work
practices are employed.
6. Correcting H&H work practices or conditions that may result in injury or exposure to
hazardous substances.
7. Preparing accident/incident reports for H&H activities (see Section 13.0).
8. Halting H&H site operations, if necessary, in the event of an emergency or to correct
unsafe work practices.
9. Reviewing and approving this project health and safety plan.
4.2 Project Coordinator (H&H)
The Project Coordinator (PC) is responsible for seeing that site activities are carried out in
accordance with the project planning documents. The PC is responsible for providing quality
assurance of field generated data and assists in the preparation of reports, coordination of field
activities conducted by subcontractors. The PC is also responsible for maintaining clear
communications between the field personnel, subcontractors, and PM.
4.3 Site Safety Officer (H&H)
The Site Safety Officer's (SSO) duties may be carried out by the PM or other H&H site manager.
The SSO, unless specifically directed by this HSP, does not mandate health and safety guidance
to any subcontractor unless there is an imminent endangerment to personnel, in which case
guidance is to be directed to the Subcontractor's Safety Representative (SSR) only. The SSO:
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1. Implements project health and safety plans, and reports any deviations from the
anticipated conditions described in the plan to the PM, and, if necessary, the MH&S.
2. Determines that monitoring equipment is used properly by H&H personnel and is
calibrated in accordance with manufacturer's instructions or other standards, and that
results are properly recorded and filed.
3. Checks with the MH&S to see that assigned H&H personnel have current Fit -For -Duty
medical and training authorizations.
4. Assumes any other duties as directed by the PM or MH&S.
5. Identifies all H&H personnel with special medical problems (i.e., allergies, perforated
eardrum, etc.).
6. Conducts daily safety meetings and completes the Site Safety Briefing Report (see form
in Appendix D).
7. Provides ongoing review of the protection level needs as project work is performed, and
informs the PM of the need to upgrade/downgrade protection levels as appropriate.
8. Sees that decontamination procedures listed in Section 9.0 are followed by H&H
personnel.
9. Establishes monitoring of H&H personnel and records results of exposure evaluations.
10. Halting H&H site operations, if necessary, in the event of an emergency or to correct
unsafe work practices.
4.4 Manager, Health and Safety (H&H)
The Manager, Health & Safety (MH&S) shall:
1. Determine the need for periodic audits of the operation to evaluate compliance with this
plan.
2. Provide health and safety support as requested by the SSO, PC, and PM.
3. Prepare, review, and approve this health and safety plan.
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4.5 Field Sampling Technicians (H&H)
Field sampling technicians involved in on -site investigations and operations are responsible for:
1. Taking reasonable precautions to prevent injury to themselves and to their fellow
employees.
2. Performing only those tasks that they believe they can do safely, and immediately
reporting any accidents, near misses, and/or unsafe conditions to the SSO or PM.
3. Implementing the procedures set forth in the HSP, and reporting deviations from the
procedures described in the Plan to the SSO or PM for action.
4. Notifying the PM and SSO of any special medical problems (i.e., allergies) and seeing
that on -site H&H personnel are aware of any such problems.
5. Reviews the HSP and signs acceptance form.
4.6 Subcontractor's Safety Representative
Each subcontractor is requested to designate a Subcontractor's Safety Representative (SSR), who
is the subcontractor supervisor. The SSR is responsible for the safe and healthful performance of
work by his work force and subcontractors. During the subcontractor's activities on -site, the SSR
will perform continuing work area inspections, and conduct safety meetings and safety
orientations for all new employees. The SSR will attend periodic safety meetings with the
SSHO. The SSR will also investigate accidents and overexposures involving subcontractor
personnel.
4.7 Subcontractor Personnel
H&H will insist on the following health and safety requirements from its subcontractors:
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• Subcontractor employees must have appropriate training [i.e., either a 40-hour or 24-hour
OSHA -required (29 CFR 1910.120) health and safety course for hazardous waste work,
or certified equivalent training].
• Personnel working at hazardous waste sites must have had an annual physical (or
physician's waiver for biennial physical) and be certified "fit for duty" and "fit for
respirator use," if necessary, by a qualified physician.
• Upon request H&H will obtain proof of both training and a physical before site work may
begin.
• Personnel must have appropriate personal protective equipment (PPE) for the specific
job. At a minimum, personnel shall have the following equipment:
— Hard hat
— Safety shoes
— Gloves
— Goggles/safety glasses
— Hearing protection, if appropriate
— Respiratory protection, if appropriate (with fit test)
— Other equipment as specified by the HSP.
• Drilling equipment and field operations must meet applicable safety standards and satisfy
H&H's field inspection. Unsafe equipment or operations will necessitate shut down of
the job at a cost to the subcontractor.
Before field activities begin, the subcontractor must develop a health and safety plan. H&H will
provide a copy of its health and safety plan, but this is not a substitute for an independent plan by
the subcontractor. If the subcontractor has not developed a site -specific health and safety plan,
H&H will assist the subcontractor in preparing its own separate, site -specific HSP for
implementation by the subcontractor. The subcontractor must agree to comply with at least the
minimum requirements of its own site -specific HSP and be responsible for the health and safety
of its own employees. The subcontractor also must agree that it will take any additional
measures it deems necessary to meet at least minimum applicable health and safety standards if
unforeseen circumstances arise.
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The subcontractor will provide at least minimum safety equipment as required by the site -
specific HSP. When respirators are necessary, the subcontractor will provide a respirator fit test
certificate and a physician's "fit for respirator use" declaration upon request.
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5.0 Job Hazard Analysis
The primary hazards anticipated are potential exposures to VOCs, semi-VOCs, PCBs, and
inorganic compounds. Other hazards include physical hazards due to lifting, use of tools and
heavy equipment, use of drilling equipment and drill rigs, excavation hazards, and electrical
hazards.
Possible contaminants of concern at the facility include VOCs, semi-VOCs, PCBs, and inorganic
compounds. The compounds listed below are the result of assessment conducted activities
conducted in 2001, 2018, and 2019, and reflect exceedances of the NCDEQ
Industrial/Commercial Preliminary Soil Remediation Goals (PSRGs), Action Levels, and/or
North Carolina 2L Groundwater Standards.
Potential VOCs include:
— Benzene
— 1,1-dichloroethane (DCA)
— Naphthalene
Potential semi-VOCs include:
— Benzo[a]anthracene
— Benzo[a]pyrene
— Benzo[b]fluoranthene
— Chrysene
— Indeno[1,2,3-cd]pyrene
— Naphthalene
Potential Total Petroleum Hydrocarbons include:
— Diesel range organics (DRO) C 10-C28
Potential PCBs include:
— Aroclor 1260
— Aroclor 1254
— PCB Congeners 77, 81, 105, 114, 118, 123, 126, 156/157, 167, 169, 189
— Non -Dioxin Like Congeners
Potential metals or inorganic compounds include:
— Arsenic
— Chromium
— Lead
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While the exposures anticipated from these materials during assessment activities are expected to
be minimal, and not all of the above contaminants are necessarily expected to be encountered at
the site, the provisions of this plan are directed toward helping to ensure that potential exposures
are minimized during site activities. When necessary, on -site personnel will wear NIOSH-
approved air -purifying respirators with combination high -efficiency particulate air (HEPA) and
organic vapor filters as warranted by site conditions and sampling procedures.
Physical hazards at this work site include those associated with heat stress and cold stress, slip,
trip and fall type accidents, back injuries due to improper lifting, being caught in or struck by
moving equipment and electrocution or explosion hazards associated with drilling or excavation
activities, such as contact with overhead or underground power lines or pipelines.
5.1 Heat Stress and Cold Stress Recognition and Control
The wearing of PPE can place a hazardous waste worker at considerable risk of developing heat
stress. This can result in health effects ranging from transient heat fatigue to serious illness or
death. Heat stress is caused by a number of interacting factors, including environmental
conditions, clothing, work load, and the individual characteristics of the worker. Because heat
stress is probably one of the most common (and potentially serious) illnesses at hazardous waste
sites, regular monitoring and other preventive precautions are vital.
Heat stress monitoring should commence when personnel are wearing PPE, including Tyvek-
type coveralls, and the ambient temperature exceeds 70°F. If standard work garments (cotton
coveralls) are worn, monitoring shall commence at 85°F. Heat stress monitoring and control
guidance can be found in Appendix A.
Protection against cold stress shall be initiated when temperatures drop below 45°F. Cold stress
guidance is provided in Appendix A.
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5.2 Chemical Hazards
From an occupational health standpoint, given that potential exposure to site personnel will be
only for a short period of time (intermittent for several days), the levels of contaminants expected
at the site should not represent a significant concern. Overviews of the hazards associated with
exposure to the major potential compounds of concern are presented below in terms of the
following types of occupational exposure limits:
• PEL - Permissible Exposure Limit
• TLV - Threshold Limit Value
• TLV-STEL - Short Term Exposure Limit
• C — Ceiling
• IDLH — Immediately Dangerous to Life and Health
OSHA Permissible Exposure Limits (PELs), ACGIH Threshold Limit Values (TLVs), and time -
weighted averages (TWAs) are generally defined as concentrations for an 8-hour work day, 40-
hour work week to which almost all workers can be repeatedly exposed without suffering adverse
health effects.
Short Term Exposure Limit (STEL) is defined as the concentration to which workers can be
exposed for short time periods without irritation, tissue damage, or narcosis sufficient to likely
cause impairment of self -rescue or precipitate accidental injury. The STEL is typically a 15-
minute time -weighted average that should not be exceeded at any time during the work day.
A ceiling value (c) is a concentration that should not be exceeded at any time in any work day.
The current NIOSH immediately dangerous to life or health (IDLH) value is defined as the
situation that poses a threat of exposure to airborne contaminants when that exposure is likely to
cause death or immediate or delayed permanent adverse health effects or prevent escape from
such an environment. The purpose of establishing an IDLH is to "ensure that the worker can
escape from a given contaminated environment in the event of failure of the respiratory
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protection equipment." The following table summarizes the potential contaminants at the site
and their respective TWA, STEL/ ceiling, and IDLH values.
Compound
CAS
Air TWA
Air
STEL/Ceiling
IDLH
(pp m )
(ppm)
(pp m)
Arsenic (inorganic compounds, as
7440-38-2
0.01 mg/m3
---
5 mg/m3
As)
Benzene
71-43-2
0.5
2.5
500
Benz [a] anthracene
56-55-3
1.2 mg/m3*
79 mg/m3*
---
Benzo[a]pyrene
50-32-8
0.1 mg/m3
---
80 mg/m3
Benzo[b]fluoranthene
205-99-2
---
---
---
Chromium (hexavalent chromium)
18540-29-9
0.005 mg/m3
---
---
Chrysene
218-01-9
0.1 mg/m3
---
80 mg/m3
1, 1 -dichloroethane (DCA)
75-34-3
100
---
3,000
Indeno[1,2,3-cd]pyrene
193-39-5
---
---
---
Lead
7439-92-1
0.05 mg/m3
---
100 mg/m3
Naphthalene
91-20-3
10
15
250
Polychlorinated biphenyls (PCBs)
varies
0.5 mg/m3
(skin)
5 mg/m3
Ref Latest versions of the NIOSH Pocket Guide and ACGIH TVLs and BEIs
*TWA/STEL/Ceiling not available; Temporary Emergency Exposure Limit ('PEEL-]) used in place of TWA and
TEEL-3 used in place of STEL/Ceiling
Arsenic and Inorganic Compounds (CAS 7440-38-2)
Arsenic is a naturally occurring element and a known human carcinogen. Breathing high
concentrations of inorganic arsenic can cause sore throat or irritated lungs. Ingestion of high
levels of inorganic arsenic can result in death. Lower levels of arsenic can cause nausea and
vomiting, decreased production of red and white blood cells, abnormal heart rhythm, damage to
blood vessels, and a sensation of "pins and needles" in hands and feet. Acute exposure by
inhalation or ingestion may cause a darkening of the skin and appearance of small "corns" or
"warts" on the palms, soles, and torso. Skin contact with inorganic arsenic may cause redness
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and swelling. Several studies have shown that inorganic arsenic can increase the risk of lung,
skin, bladder, liver, kidney, and prostate cancer.
Benzene(CAS No. 71-43-2)
Benzene is a central nervous system depressant. Symptoms include headache, nausea, tremors,
and fatigue, but these do not typically occur until exposure concentrations are in excess of
150 ppm. There is significant evidence that chronic exposures are carcinogenic causing a
progressively malignant disease of blood -forming organs (leukemia). Benzene is known to the
State of California to cause cancer under the criteria of Proposition 65. Benzene is poorly
absorbed through intact skin, but contact with liquid benzene may cause blistering and dermatitis.
Benzene vapors can cause transient eye irritation. The mean air odor threshold for benzene is
34 ppm, which yields unsatisfactory warning properties. Benzene's ionization potential (IP) is
9.25 eV.
Benz ral anthracene (CAS No. 56-55-3)
Benz [a] anthracene is a colorless leaflet or plate or coarse gold powder. It is expected to be a
carcinogen. Exposure may cause skin, eye, and/or respiratory tract irritation, drowsiness,
dizziness, and damage to organs, particularly the kidneys. Benz [a] anthracene has a vapor
pressure of 2.1E-07 mmHg.
Benzoralpyrene (CAS No. 50-32-8)
Benzo[a]pyrene is an odorless compound found in coal tar that is considered a potent mutagen
and carcinogen. Exposure may cause skin, eye, and/or respiratory tract irritation, drowsiness,
dizziness, and damage to organs. Benzo[a]pyrene has a vapor pressure of 5.5E-09 mmHg.
Benzoralfluoranthene (CAS No. 205-99-2)
Benzo[a]fluoranthene is a colorless aromatic hydrocarbon found in coal tar. It is expected to be a
carcinogen. Exposure may cause skin, eye, and/or respiratory tract irritation, drowsiness,
dizziness, and damage to organs. Benzo[a]fluoranthene has a vapor pressure of 5.0E-07 mmHg.
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Chromium, Hexavalent WAS 18540-29-9)
Hexavalent chromium (Cr[VI]) is a toxic form of the element chromium. Hexavalent chromium
is rarely found in nature and is generally man-made. Cr(VI) is widely used in pigments, metal
finishing (electroplating), wood preservatives and fungicides, and in chemical synthesis as an
ingredient and catalyst. Breathing in high levels of hexavalent chromium can cause irritation to
the nose and throat. Symptoms may include runny nose, sneezing, coughing, itching and a
burning sensation.
Chrysene (CAS No. 218-01-9)
Chrysene is a white, crystalline aromatic hydrocarbon found in coal tar that is considered a
carcinogen. It is toxic to humans and the environment and is suspected of causing genetic
defects. Chrysene has a vapor pressure of 6.23E-09 mmHg.
1,1-Dichloroethane (CAS No. 75-34-3)
1,1-Dichloroethane is a colorless liquid with an ether -like odor. If inhaled, it can cause irritation
of the respiratory tract. Symptoms may include salivation, sneezing, coughing, dizziness, nausea,
and vomiting. Contact with the eyes can cause irritation, lacrimation, and reddening. Contact
with the skin can cause irritation, and prolonged contact may produce a slight burn. Swallowing
of substantial amounts could cause nausea, vomiting, faintness, drowsiness, cyanosis, and
circulatory failure.
Indeno[1,2,3-cd]p3rene (CAS No. 193-39-5)
Indeno[1,2,3-cd]pyrene is a yellowish aromatic hydrocarbon found in certain foods, gasoline and
diesel exhaust, coal tar, and other petroleum products. It is a suspected carcinogen and toxic to
human health.
Lead and Inorganic Compounds (CAS 7439-92-1)
Acute lead poisoning usually manifests as gastroenteritis. Lead accumulates in the body; chronic
lead poisoning is manifested by anemia, constipation, and abdominal pain. Accumulation in the
peripheral nerves leads to wrist and ankle drop. Lead enters the body primarily by inhalation. In
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the respiratory tract, most lead compounds are absorbed rapidly and stored in nerve tissue so that
poisoning can develop from long-term exposure to low doses. Poisoning can also develop slowly
from ingestion via lead contaminated food, drink or tobacco products. Prevention of lead
poisoning is almost entirely a matter of good personal hygiene and housekeeping.
Naphthalene (CAS 91-20-3)
Naphthalene is an eye irritant. Symptoms may include headaches, confusion, excitement,
malaise, nausea, vomiting, abdominal pain, profuse sweating, jaundice, hematuria, dermatitis,
optical neuritis, corneal damage and/or renal shutdown. Naphthalene is not considered
carcinogenic. The ionization potential for naphthalene is 8.12 eV and the vapor pressure is
0.08 mm Hg.
Polychlorinated Biphenyls (PCBs)
PCBs are light, straw-colored liquids with typical chlorinated aromatic odors. Symptoms of
short-term exposure include irritation to nose, throat and lungs. Levels above 10 mg/m3 are
reported to be unbearable. Inhalation may contribute significantly to all symptoms of long-term
exposure. Sensitized individuals may develop a rash after two days exposure by dermal contact
or inhalation. High levels of PCB vapor, 1 to 10 mg/m3, may produce burning feeling in eyes,
nose and face; dry throat; lung and throat irritant; nausea; dizziness and aggravation of acne.
Chemical acne, black heads, dark patches of skin, and unusual eye discharge have been reported
by all routes of exposure. Liver damage and digestive disturbance have been reported in some
individuals. PCBs may impair the function of the immune system. PCBs at high levels have
been shown to produce cancer and birth defects in laboratory animals. Whether PCBs produce
these affects in humans is not known.
Based on the anticipated scope of work, the following potential exposures may exist at the site:
• Skin contact with contaminated materials (soil and/or water);
• Inhalation of vapors or particulates (dust); and
• Ingestion of contaminated materials: especially if poor personal hygiene is practiced.
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Skin contact with potentially contaminated soil or water will be minimized by the use of PPE (as
described in Section 7.0). Air monitoring and the use of engineering controls and respiratory
protection will minimize inhalation of vapors or particulates during sampling activities if action
levels (see Section 6.1) are exceeded. Ingestion of contaminated materials will be minimized by
the use of appropriate personal hygiene procedures during decontamination (i.e., thoroughly
washing face and hands with soap and water after leaving the work area and prior to eating or
drinking).
5.3 Noise Hazards
The primary noise hazard at this site is from the potential use of drilling equipment. Previous
surveys indicate that such equipment may produce continuous and impact noise at or above the
action level of 85 decibels (dBA). H&H personnel and H&H contractors within 25 feet of
operating equipment shall wear hearing protective devices (either muffs or plugs). Personnel
will wash their hands with soap and water prior to inserting ear plugs as a good hygiene practice.
5.4 Underground Utilities (Pre -Drilling Protocol)
H&H will contact NC One Call to mark public utilities prior to the commencement of drilling
activities. A private utility locator will also be used to identify subsurface utilities in drilling
locations. All boring locations will be cleared for subsurface utilities using a hand auger to 5 feet
below ground surface. If any obstructions are encountered in the proposed boring locations with
the hand auger, H&H will notify the PM and the boring location may be adjusted in the field.
5.5 Work Area Protection
As the project operations may be undertaken in a driveway or parking lot, motor vehicles may be
a hazard. The work area shall be sufficiently cordoned, flagged, and barricaded from other traffic
(if possible). In general, personnel working in areas of traffic concerns will utilize safety vests
and traffic cones.
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5.6 Hazard Communication
The H&H Hazard Communication Program complies with the OSHA Hazard Communication
Standard (HCS) found in 29 CFR 1910.1200 and 29 CFR 1926.59, which applies to any
chemical present in the workplace in such a manner that employees may be exposed under
normal conditions of use or in a foreseeable emergency. Although waste materials are excluded
from the OSHA requirement, decontamination chemicals for sampling apparatus or protective
clothing (such as acetone) and calibration standards (such as isobutylene gas) require Safety Data
Sheets (SDSs).
The principle of communicating the hazards of materials used in the workplace to employees
applies broadly to firm -wide activities, from informational programs on the conduct of hazardous
waste activities to the firm's insistence upon adequate safety and health training. It is also
important for personnel to have an awareness of client concern for Hazard Communication due
to Federal, state, and local regulations directly affecting certain client activities.
In order to comply with Hazard Communication Standard (29 CFR 1910.1200), H&H has
determined that:
• Containers of hazardous chemicals must be appropriately labeled or tagged to identify the
hazard and provide information on effects and appropriate protective measures.
• Labels, tags, or signs must be properly affixed and visible at all times while a hazard is
present and removed promptly when the hazard no longer exists.
• Written information provided on SDSs on hazardous chemicals in the workplace must be
available to employees working with the substance.
• Appropriate SDSs will be available to any contractor or subcontractor employees working
in H&H offices or laboratories or at construction, excavation, or other sites under H&H's
control.
• Hazard Communication Training shall be provided to H&H employees.
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5.7 Heavy Equipment
Operation of heavy equipment in drilling, excavation, or other activities presents potential
physical hazards to personnel. Precautions shall be observed whenever heavy equipment is in
use. PPE such as steel -toed shoes, safety glasses or goggles, and hard hats shall be worn
whenever such equipment is present. Personnel shall at all times be aware of the location and
operation of heavy equipment, and take precautions to avoid getting in the way of its operation.
Never assume that the equipment operator sees you; make eye contact and use hand signals to
inform the operator of your intent. Never walk directly in back of, or to the side of, heavy
equipment without the operator's knowledge. When an equipment operator must operate in tight
quarters, the equipment subcontractor shall provide a person to assist in guiding the operator's
movements. Keep all non -essential personnel out of the work area. Heavy equipment that is
used in the exclusion zone shall remain in that zone until its task is completed. The equipment
subcontractor should completely decontaminate such equipment in the designated equipment
decontamination area as required.
5.8 Site Physical Hazards
Erwin Mill is a large former textile mill that has been vacant or under-utilized for approximately
20 years. Certain areas of the facility contain hazards inherent to mill operations, such as large
vaults in the floor, that are exacerbated by lack of electric lighting to the facility. In addition,
lack of consistent upkeep in some of the buildings have resulted in material degradation and
areas within the facility that may be subject to falling debris or weak flooring. Caution shall be
exercised while on the premise. Use caution tape, or similar, while working around vaults or
openings in floor. Be sure to bring adequate lighting for job activities and check integrity of
building structures prior to entering the building and throughout planned activities. Don
effective PPE (hard hat) when entering the building and while working around other low hanging
hazards.
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6.0 Exposure Monitoring Plan
Heat stress, noise, and chemical exposures are site hazards with may require monitoring. Heat
stress monitoring and prevention is addressed in Section 5.0. Noise levels generally will not be
monitored; H&H personnel will wear hearing protection as described in Section 5.3. Chemical
exposure monitoring is discussed below.
6.1 Chemical Exposure Monitoring
The field instrumentation described in this subsection has been specifically selected for the
contaminants that may be reasonably anticipated to be encountered during the course of this
project. Selection factors include anticipated airborne concentrations, potential interferences,
ionization potentials, instrument sensitivity, and occupational exposure limits. The action levels
described below are established with the expectation that these specific instruments will be used.
Do not substitute instruments without the consent of the HSP preparer or the MH&S.
A PID will be used to monitor intermittently for organic vapors. If readings exceed an average of
0.5 ppm (benzene, TWA = 0.5) for more than one minute, monitoring in the operator's breathing
zone (OBZ) of the person working nearest the borehole will start and personnel will don
protective clothing as described in Section 7.0. The solution may include the use of engineered
controls, hazard elimination by retreating to a non -contaminated area as discussed below, or
donning additional PPE such as respirators. The site action level should be discussed at a safety
briefing prior to the start of work each day.
An OBZ reading steadily above 0.5 ppm for more than one minute will require the use of full -
face respirators with organic vapor cartridges. If the PID reads more than 20 ppm
instantaneously (>5 seconds) or 10 ppm for more than one minute, work will stop, and workers
will move upwind while the vapors dissipate; if elevated levels remain for more than five
minutes, the boring and cuttings will be covered with clean soil, plastic sheeting, or foam, and
the MH&S, HSP Preparer or PM will be contacted for further guidance.
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A summary of the response criteria is presented below.
PID Analyzer
Reading*
Location
Time Period
Action
< 0.5 ppm
OBZ (work area,
Continue periodic monitoring, no respirators
upwind and
----
required.
downwind)
> 0.5 ppm
OBZ (work area,
> 1 minute
Monitor OBZ; don protective clothing as
upwind and
described in Section 7.0; don full -face
downwind)
respirator with HEPA/organic vapor cartridges;
establish work zones described in 8.1
> 20 ppm
OBZ (work area,
Instantaneous
Stop work; move upwind while vapors
upwind and
(> 5 seconds)
dissipate; if elevated levels persist for more
downwind)
than 5 minutes, cover soil, evacuate upwind
and notify SSO or PM for guidance on
implementing engineering solution.
OR
> 10 ppm
OBZ (work area,
> 1 minute
Stop work; move upwind while vapors
upwind and
dissipate; if elevated levels persist for more
downwind)
than 5 minutes, cover soil, evacuate upwind
and notify SSO or PM for guidance on
implementing engineering solution.
*Above background readings, see Section 6.2.
6.2 Background Readings
All direct -reading instrument readings will be evaluated relative to background readings, not
"meter zero". Prior to the start of work at each shift, and whenever there is a significant shift in
wind direction, instrument readings will be obtained upwind of the site work zone in order to
determine the level of "background" readings from local vehicle traffic, emissions from nearby
operations unrelated to the site, etc. Site readings will be evaluated against these background
readings (i.e., if an action level is listed as 20 ppm, it is evaluated as 20 ppm above background).
6.3 Data Logging
Exposure monitoring data, including background readings, will be logged in the field book. The
results of daily instrument calibrations should also be logged in the field book. Monitoring
instruments will be calibrated, in accordance with the manufacturer's instructions, prior to the
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start of each work day. Calibration should also be performed when inconsistent or erratic
readings are obtained. If an instrument cannot be calibrated to specification, or becomes
otherwise inoperable, invasive site work (i.e., drilling, excavating) will cease until the instrument
is appropriately repaired or replaced. The PM, MH&S or HSP Preparer should be contacted for
further guidance.
6.4 Dust Control
Elevated levels of organic contaminants may be present at the site. Airborne exposure could
potentially occur during drilling operations. If drilling operations generate sustained visible dust,
a water mist shall be applied to reduce dust generation. If the mist is not effective in reducing
dust generation or this is impractical, personnel will don respirators (full -face as appropriate for
analyzer readings) with combination organic vapor-HEPA cartridges (such as North's OV/P 100
cartridges) once visible dust becomes airborne.
The sand which may be used in groundwater monitoring well construction may contain free silica
(quartz). Airborne exposure to silica dust may occur during handling of these sands. Half -face
respirators with HEPA cartridges shall be worn for those handling operations where there is a
possibility for exposure to sustained airborne dust from pouring and mixing of dry sand.
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7.0 Personal Protective Equipment
Minimum protective equipment for site personnel shall include: hardhat, ear protection when
around drilling equipment or other high noise equipment, safety glasses and steel -toed boots. If
the OVA reading is greater than the action level prescribed in Section 5.1 of this plan, the area
will be evaluated until a safe engineering solution is determined. The solution may include the
use of engineered controls and PPE such as respirators. The list of proper PPE which may be
required is provided in Appendix B.
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8.0 Site Control
8.1 General
The purpose of site control is to minimize potential contamination of workers, protect the public
from site hazards, and prevent vandalism. Site control is especially important in emergency
situations. When necessary, several site control procedures will be implemented to reduce
worker and public exposure to chemical, physical, biological, and safety hazards. Barricades and
barricade tape should be used to delineate a work zone for safety purposes around the work area.
The barriers shall be set in a 25-foot radius (as practical) around the work area to provide
sufficient maneuvering space for personnel and equipment.
At the end of the shift, boring/sampling holes and excavations must be covered or otherwise
secured. Cuttings and decontamination fluids are to be handled in accordance with relevant
regulations and instructions from the PM.
8.2 Work Zones
When necessary, the following work zones will be established:
• Exclusion Zone - a 25-foot (as practical) circle around the work area will be defined
before work starts. The encircled area will constitute the "Exclusion Zone". This
zone is where potentially hazardous contaminants and physical hazards to the workers
will be contained. Full personal protection will be required in this area. The size of
the Exclusion Zone may be altered to accommodate site conditions and to ensure
contaminant containment.
• Contamination Reduction Zone (CRZ) - Decontamination activities will occur in the
CRZ. A waste container will be placed at the end of the CRZ so contaminated
disposal equipment can be placed inside and covered. No H&H personnel will be
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permitted into the Contamination Reduction Zone or Exclusion Zone unless they are
in full compliance with the requirements of this Plan.
• Support Zone - a Support Zone in an uncontaminated or clean area, must be defined
for each field activity. Normal work clothes are appropriate within this zone. The
location of this zone depends on factors such as accessibility, wind direction (upwind
of work area), and resources (i.e., roads, shelter, utilities).
8.3 Surrounding Community Exposure Protection
In an effort to protect the surrounding community, the field personnel will be responsible for
containing and staging investigative derived waste (IDW) for subsequent characterization and
disposal coordination by H&H. IDW is expected to include boring cuttings, development water,
decontamination fluids, and personal protective equipment. IDW soil and water shall be staged
in 55-gallon metal drums provided by the contractor. The drums will be secured and covered to
protect personnel on -site and off -site. Field personnel and/or contractors will conduct drilling or
excavation activities to minimize IDW to the extent practical. IDW staging areas shall be
identified and approved by H&H prior to initiating drilling and/or excavation activities.
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9.0 Decontamination Procedures
PPE removal and decontamination procedures shall be conducted in the CRZ. Using
decontamination solutions, decontaminate the shovels, hand augers, auger flights, etc. by
brushing them under a water rinse. A high-pressure steam cleaner may also be used for
decontamination activities. If required, waste and spent decontamination solutions will be
properly contained. The decontamination area will be covered with plastic sheeting which will
be replaced when torn or heavily soiled.
Decontamination chemicals for sampling equipment or protective clothing (such as alcohols,
acid, or detergents) and calibration standards (such as isobutylene gas) require SDSs. If
requested, the SSO will make copies of these SDSs available to subcontractors (i.e. drillers,
remediation contractors, etc.) on this project.
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10.0 Safe Work Practices
The following safe work practices will be followed:
1. Eating, drinking, chewing gum or tobacco, and smoking are prohibited in the work area.
2. Personnel will wash their hands and face thoroughly with soap and water prior to eating,
drinking or smoking.
3. Avoid contact with potentially contaminated substances. Do not walk through puddles,
pools, mud, etc. Avoid, whenever possible, kneeling on the ground, leaning or sitting on
equipment or ground. Do not place monitoring equipment on potentially contaminated
surfaces (i.e., ground, etc.).
4. All field crew members shall make use of their senses to alert them to potentially
dangerous situations in which they will not become involved (i.e., presence of strong,
irritating or nauseating odors).
5. Only those vehicles and equipment required to complete work tasks shall be permitted
within the exclusion/work zone (drill rigs, excavators, and similar items). All non-
essential vehicles will remain within the support zone.
6. Containers, such as drums, will be moved only with the proper equipment and will be
secured to prevent dropping or loss of control during transport.
7. Field survey instruments, such as OVAs, will be covered with plastic or similar covering
as necessary to minimize the potential for contamination.
8. No matches or lighters will be permitted in the work area/exclusion zone or
contamination reduction zone.
9. Contaminated protective equipment, such as respirators, hoses, boots and disposable
protective clothing, will not be removed from the work area/exclusion zone or
decontamination area until it has been cleaned.
10. Prevent splashing and spills of the contaminated materials or decontamination fluids. In
the event that a spillage occurs, contain liquid if possible.
11. Field crew members shall be familiar with the physical characteristics of investigations,
including: wind direction in relation to contaminated area, accessibility to equipment and
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vehicles, communications, hot zones (areas of known or suspected contamination), site
access and nearest water sources.
12. The number of personnel and equipment in the contaminated area will be minimized but
only to the extent consistent with workforce requirements of safe site operations.
13. Wastes generated during H&H and/or subcontractor activities at the site will be disposed
as directed by the PM.
14. Personal protective equipment will be used as specified and required.
15. The buddy system will be used where practical or necessary due to site conditions. The
buddy system is when two or more co-workers work together to safely complete a job.
The co-workers help one another to follow safe work practices.
16. Personnel are to notify immediately the SSHO or Site Manager if any indications
potential explosions or unusual conditions are observed.
17. No one wearing contact lenses or having a beard will be permitted in the work area if
respirators are required.
18. Face masks, gloves, and social distance practices shall be employed at the site to
minimize exposures related to coronavirus (COVID-19) pandemic; additional guidance
can be referenced in H&H's COVID-19 Preparedness and Response Guidance,
Revision I (dated August 12, 2020).
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11.0 Emergency Response Plan
It is H&H's policy to evacuate personnel from areas involved in hazardous material emergencies
and to summon outside assistance from agencies with personnel trained to deal with the specific
emergency. This section outlines the procedures to be followed by H&H personnel in the event
of a site emergency. These procedures are to be reviewed during daily on -site safety briefings
conducted by the SSO. The safety briefings will be noted in the field book. In the event of a fire
or medical emergency, the numbers at listed at the front of this plan can be called for assistance.
The nearest hospital to the site is the Betsy Johnson Hospital located at 800 Tilghman Drive in
Dunn, North Carolina. From the site, head south on North 131h Street toward East H. Street for
approximately 500 ft, then turn left onto Denim Drive. Continue on Denim Drive for 2.1 miles,
then continue on Erwin for 0.5 miles. Turn right on Tilghman Drive and continue for 0.4 miles.
The Hospital will be on your right. The phone number is [phone]. A map to the hospital
is provided in Appendix C.
Paramedics shall be summoned in the event of a serious injury; they will arrange to transport the
victim to the nearest appropriate facility. A first aid kit will be available at the site for use in case
of minor injuries. If anyone receives a splash or particle in the eye, a clean eyewash solution will
be used to irrigate the eye for 15 minutes. If direct contact with contaminants occurs, affected
skin areas will be washed immediately with soap and water.
In the event of serious trauma or unknown chemical exposure, the employee should be stabilized
by others after checking that the scene is safe. An emergency phone call will be made as soon as
possible.
Workers with suspected back or neck injuries are NOT to be moved except by professional
emergency workers.
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11.1 Places of Refuge
In the event of a site emergency requiring evacuation, all personnel will evacuate to a pre -
designated area located in the support zone, a safe distance from the exclusion zone boundary.
The SSO will designate the assembly area prior to the start of work each day and will discuss this
location in each safety briefing.
11.2 Fire
Whenever the possibility of a fire or explosion exists which could affect field investigation
personnel or adjacent work area personnel, or which could occur as the result of the
investigation, a special emergency action plan will be prepared as part of the task specification.
Subcontractors will be made aware of the provisions of the emergency action plan. In general,
Type ABC fire extinguishers will be available on -site to contain and extinguish small fires. The
local fire department shall be summoned (911) in the event of fires. If it is safe to do so, site
personnel may use fire fighting equipment available on -site to control or extinguish the fire
and/or remove or isolate flammable or other hazardous materials that may contribute to the fire.
11.3 Communication
A communication network may be set up to alert site personnel of emergencies and to summon
outside emergency assistance. Where voice communication is not feasible, an alarm system
(i.e., sirens, horns, etc.) shall be set up to alert employees of emergencies. Radio communication
may also be used to communicate with personnel in the exclusion zone. Where phone service is
not readily available, radios or mobile phones will be used to communicate with outside
agencies. Site personnel shall be trained on the use of the site emergency communication
network. The location of emergency phone numbers and phones shall be established for outside
communication. The SSO is responsible for establishing the communication network prior to the
start of work, and for explaining it to all site personnel during the site safety briefing.
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In the event of an injury or illness, work is to be stopped until the SSO and the MH&S have
determined the cause of the incident and have taken the appropriate action. Any injury or illness,
regardless of severity, is to be reported to the Project Manager and MH&S.
11.4 Incident Report
In the event of a near miss, injury, or illness, work is to be stopped until the SSO and the MH&S
have determined the cause of the incident and have taken the appropriate action. Any injury or
illness, regardless of severity, is to be reported on the accident report form (see Appendix D).
11.5 Operation Shutdown
Under certain hazardous situations, the on -site personnel, SSO, or SSR may request that site
operations be temporarily suspended while the underlying hazard is corrected or controlled.
Once a shutdown has been initiated the PM, SSO, and other necessary members will review,
investigate, and determine the best practices going forward to eliminate or mitigate the hazard.
H&H personnel will follow H&H's Stop Work Authority Procedure, Revision 1.
11.6 Spill or Hazardous Materials Release
Small spills are immediately reported to the SSO and are dealt with according to chemical
manufacturers' recommended procedures. Spills or release of hazardous materials which result in
human exposure or off -site environmental contamination are promptly reported by the SSO to the
proper authorities and appropriate measures are taken to contain and/or collect the material for
approved storage and disposal.
11.7 Emergency Medical Treatment Procedures
Any person who becomes ill or injured in the Exclusion Zone must be decontaminated to the
maximum extent possible. If the injury or illness is minor, full decontamination shall be
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completed and first aid administered prior to transport. If the patient's condition is serious, at
least partial decontamination should be completed (i.e., complete disrobing of the victim and
redressing in clean coveralls or wrapping in a blanket). First aid should be administered while
awaiting an ambulance or paramedics. All injuries and illnesses must be reported immediately to
the PM.
Personnel who are transported to a clinic or hospital for treatment should take with them
information on the chemical(s) they have been exposed to at the site. This information is
included in Section 5.2 of this Plan. Any vehicle used to transport contaminated personnel will
be treated and cleaned, as necessary.
11.8 Community Safety
There is a low potential for migration of chemicals from the site as a result of project activities.
In the unlikely event that a significant release of contaminants occurs during the course of the
field work, appropriate actions will be taken to protect the public health and mitigate the
contaminant released.
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13.0 Recordkeeping
The PM and SSO are responsible for site recordkeeping. Prior to the start of work, they will
review this plan; if there are no changes to be made, they will sign the approval form and forward
a copy to the H&H MH&S.
H&H personnel will review the HSP and sign the plan acceptance form in Appendix D; copies of
these forms will be forwarded to the H&H MH&S.
The SSO will conduct a Site Safety Briefing in accordance with Section 12.0 prior to each shift
and have all attendees sign the form in Appendix D; copies will be forwarded to the H&H
MH&S for filing.
Any accident or exposure incident will be investigated and the form in Appendix D will be
completed and forwarded to the H&H MH&S.
All instrument readings and calibrations, PPE used and changes, health and safety -related issues,
and deviations from or problems with this HSP will be recorded in the field log or the
appropriate form (if applicable).
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14.0 Toxic Snake and Insect Bites and Plants
14.1 Poisonous Snakebites
Reactions from snakebite are aggravated by acute fear and anxiety. Other factors that affect the
severity of local and general reaction from poisonous snakebite include: the amount of venom
injected and the speed of absorption of venom into the victim's circulation; the size of the victim;
protection from clothing, including shoes and gloves; quick antivenin therapy; and location of the
bite.
First Aid Procedure
The objective of first aid is to reduce the circulation of blood through the bite area, to delay
absorption of venom, to prevent aggravation of the local wound, and to sustain respiration.
The most important step is to get the snakebite victim to the hospital quickly. Meanwhile, take
the following first aid measures:
1. Keep the victim from moving around.
2. Keep the victim as calm as possible and preferably in a lying position.
3. Immobilize the bitten extremity and keep it at or below heart level. If the victim can reach a
hospital within 4 to 5 hours and if no symptoms develop, no further first aid measures need
be applied.
4. If mild -to -moderate symptoms develop, apply a constricting band 2 to 4 inches above the
bite, but not around a joint (the elbow, knee, wrist, or ankle) and not around the head, neck,
or trunk. The band should be 3/4 to 1 1/2 inches wide, not thin like a rubber band. The band
should be snug but loose enough for a finger to be slipped underneath. Watch out for
swelling. Loosen the band if it becomes too tight, but do not remove it. Periodically check
the pulse in the extremity beyond the bite to ensure that the blood flow has not stopped.
Several other factors must be considered in cases of snakebite:
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• Shock. Keep the victim lying down and comfortable, and maintain his or her body
temperature.
• Breathing and heartbeat. If breathing stops, give mouth-to-mouth resuscitation. If breathing
stops and there is no pulse, perform cardiopulmonary resuscitation (CPR) if you have been
trained to do so.
• Identifying the snake. If you can kill the snake without risk or delay, bring it to the hospital
for identification, but exercise extreme caution in handling the snake.
• Cleaning the bitten area. You may wash the bitten area with soap and water and blot it dry
with sterile gauze. You may apply dressings and bandages, but only for a short period of
time.
• Medicine to relieve pain. Do not give the victim alcohol, sedatives, aspirin, or any medicine
containing aspirin. Some painkillers, however, may be given. Consult a doctor or other
medical personnel for specific medications that may be used.
• Snakebite kits. Keep a kit accessible for all outings in primitive areas or areas known or
suspected to snake infested.
It is not recommended that cold compresses, ice, dry ice, chemical ice packs, spray refrigerants,
or other methods of cold therapy be used in the first aid treatment of snakebite.
14.2 Poisonous Insect Bites
Spiders
Spiders in the United States are generally harmless, with two notable exceptions: The Black
Widow spider (Latrodectus Mactans) and the Brown Recluse or violin spider (Lox Osceles
Reclusa).
The symptoms of a Black Widow spider bite are: slight local reaction, severe pain produced by
nerve toxin, profuse sweating, nausea, painful cramps in abdominal muscles, and difficulty in
breathing and speaking. Victims recover in almost all cases, but an occasional death is reported.
Symptoms are relatively similar for bites from the Brown Recluse.
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Field personnel will exercise caution when lifting covers off manholes, sumps, etc., since Black
Widow and Brown Recluse spiders can typically be found in these areas.
Scorpions
Scorpions inject venom through a stinger in the tail. In bites from the more dangerous species,
there are marked systemic effects within I to 2 hours. Fatalities have been recorded.
The symptoms of a scorpion bite are: excruciating pain at the site of the sting, nausea and
vomiting, abdominal pain, shock, and possible development of convulsions and coma.
General First Aid for Poisonous Insect Bites:
1. Minor Bites and Stings
• Cold applications.
• Soothing lotions, such as calamine.
2. Severe Reactions
• Give artificial respiration if indicated.
• Apply a constricting band above the injection site on the victim's arm or leg (between the
site and the heart). Do not apply tightly. You should be able to slip your index finger
under the band when it is in place.
• Keep the affected part down, below the level of the victim's heart.
• If medical care is readily available, leave the band in place; otherwise, remove it after 30
minutes.
• Apply ice contained in a towel or plastic bag, or cold cloths, to the site of the sting or bite.
• Give home medicine, such as aspirin, for pain.
• If the victim has a history of allergic reactions to insect bites or is subject to attacks of hay
fever or asthma, or if he or she is not promptly relieved of symptoms, call a physician or
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take the victim immediately to the nearest location where medical treatment is available.
In a highly sensitive person, do not wait for symptoms to appear, since delay can be fatal.
• In case of a bee sting, remove and discard the stinging apparatus and venom sac.
14.3 Tickborne Diseases
Lyme Disease
Lyme disease is an illness caused by a bacterium which may be transmitted by the bite of a tick
(Nodes Dammini), commonly referred to as the "Deer Tick". The tick is about the size of a
sesame seed, as distinguished from the Dog Tick, which is significantly larger. The Deer Tick is
principally found along the Atlantic coast, living in grassy and wooded areas, and feeds on
mammals such as mice, shrews, birds, raccoons, opossums, deer, and humans. Not all ticks are
infected with the bacterium, however. When an infected tick bites, the bacterium is passed into
the bloodstream of the host, where it multiplies. The various stages and symptoms of the disease
are well recognized and, if detected early, can be treated with antibiotics.
Removal of ticks is best accomplished using small tweezers. Do not squeeze the tick's body.
Grasp it where the mouth parts enter the skin and tug gently, but not firmly, until it releases its
hold on the skin. Save the tick in a jar labeled with the date, body location of the bite, and the
place where it may have been acquired. Wipe the bite thoroughly with an antiseptic and seek
medical attention as soon as possible.
The illness typically occurs in the summer and is characterized by a slowly expanding red rash,
which develops a few days to a few weeks after the bite of an infected tick. This may be
accompanied by flu -like symptoms along with headache, stiff neck, fever, muscle aches, and/or
general malaise. At this stage treatment by a physician is usually effective; but, if left alone,
these early symptoms may disappear and more serious problems may follow. The most common
late symptom of the untreated disease is arthritis. Other problems which may occur include
meningitis and neurological and cardiac abnormalities. It is important to note that some people
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do not get the characteristic rash but progress directly to the later manifestations. Treatment of
later symptoms is more difficult than early symptoms and is not always successful.
When in an area suspected of harboring ticks (grassy, bushy, or woodland area) the following
precautions can minimize the changes of being bitten by a tick:
1. Wear long pants and long-sleeved shirts that fit tightly at the ankles and wrists.
2. Wear light colored clothing so ticks can be easily spotted.
3. Wearing tick repellents may be useful.
4. Inspect clothing frequently while in tick habitat.
5. Inspect your head and body thoroughly when you return from the field.
6. Remove any attached ticks by tugging with tweezers where the tick's mouth parts enter the
skin. Do not squeeze or crush it.
Rocky Mountain Spotted Fever
In the eastern and southern United States this tckborne disease is transmitted by the infected Dog
Tick (Dermacentor Variabilis). It is important to note that the Dog Tick is significantly larger
than the Deer Tick. Nearly all cases of infection occur in the spring and summer, generally
several days after exposure to infected ticks. The onset of illness is abrupt and often
accompanied by high fever, headache, chills, and severe weakness. After the fourth day of fever,
victims develop a spotted pink rash that usually starts on the hands and feet and gradually
extends to most of the body. As with Lyme disease, early detection and treatment significantly
reduces the severity of illness. The disease responds to antibiotic therapy with tetracycline or
chloramphenicol.
Other Tickborne Diseases
Ticks transmit several other diseases, most of which are rare and occur only in specific areas.
Babesiosis occurs mainly in the Cape Cod area and eastern Long Island. Colorado tick fever is
similarly regional and occurs only among those who live or work at altitudes above 4,000 feet.
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44.4 Poisonous Plants
Characteristic Reactions
The majority of skin reactions following contact with offending plants are allergic in nature and
are characterized by general symptoms of headache and fever, itching, redness, and a rash.
Some of the most common and most severe allergic reactions result from contact with plants of
the Poison Ivy group including Poison Oak and Poison Sumac. The most distinctive features of
poison ivy and Poison Oak are their leaves, which are composed of three leaflets each. Both
plants also have greenish -white flowers and berries that grow in clusters. Such plants produce a
severe rash characterized by redness, blisters, swelling, and intense burning and itching. The
victim can also develop a high fever and become very ill. Ordinarily, the rash begins within a
few hours after exposure, but it may be delayed for 24 to 48 hours.
First Aid Procedure
1. Remove contaminated clothing.
2. Wash all exposed areas thoroughly with soap and water, followed by rubbing alcohol.
3. Apply calamine or other soothing skin lotion if the rash is mild.
4. Seek medical advice if a severe reaction occurs, or if there is a known history of previous
sensitivity.
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15.0 Medical Surveillance
29 CFR 1910.120 requires employers to institute a medical surveillance program for employees
who are or may be exposed to hazardous substances at or above occupational exposure limits for
more than 30 days per year. Since it is not feasible to monitor every employee at every
potentially hazardous work site, H&H requires all employees whose work includes potential
exposure to hazardous substances shall participate in a medical surveillance program.
H&H has in effect a Medical Surveillance Program that allows the Program's Medical Director
to:
* Certify individuals to work at H&H sites as required by OSHA regulations;
* Establish a baseline against which any future changes in health or physical wellbeing
can be evaluated;
* Identify any underlying illnesses or conditions which might be aggravated by certain
exposures or job activities; and
* Recognize any abnormalities, toxic reactions, or other changes at the earliest
opportunity so that corrective measures may be taken.
No individual shall participate in H&H site activities in which a potential exposure or injury
could occur unless the Medical Director has determined that the individual is medically qualified
to perform field activities with potential for exposure to hazardous substances activities and
medically qualified to use respiratory protection.
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Appendix A
Heat Stress and Cold Stress Guidance
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Cold Stress/Heat Stress
COLD STRESS
If site work is to be conducted during the winter, cold stress is a concern to the health and safety
of personnel. With regard to the wearing of Tyvek suits, because such disposable clothing does
not "breathe well," perspiration does not evaporate and the suits can become wet. Wet clothes
combined with cold temperatures can lead to hypothermia. If the air temperature is less than
40 degrees Fahrenheit (°F) and an employee perspires sufficiently to wet clothing, the employee
should change to dry clothes. The following section describes the signs and symptoms of cold
stress.
Signs and Symptoms of Cold Stress
Incipient frostbite is a mild form of cold stress characterized by sudden blanching or whitening
of the skin.
Chilblain is an inflammation of the hands and feet caused by exposure to cold moisture. It is
characterized by a recurrent localized itching, swelling, and painful inflammation of the fingers,
toes, or ears. Such a sequence produces severe spasms, accompanied by pain.
Second-degree frostbite is manifested by skin with a white, waxy appearance and the skin is
firm to the touch. Individuals with this condition are generally not aware of its seriousness,
because the underlying nerves are frozen and unable to transmit signals to warn the body.
Immediate first aid and medical treatment are required.
Third-degree frostbite will appear as blue, blotchy skin. The tissue is cold, pale, and solid.
Immediate medical attention is required.
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Hypothermia develops when body temperature falls below a critical level. In extreme cases,
cardiac failure and death may occur. Immediate medical attention is warranted when the
following symptoms are observed:
• Involuntary shivering
• Irrational behavior
• Slurred speech
• Sluggishness.
HEAT STRESS
Wearing PPE also puts a worker at a considerable risk of developing heat stress. Table 2
describes the signs and symptoms of heat stress. This can result in health effects ranging from
heat fatigue to serious illness or death. Consequently, regular monitoring and other precautions
are vital.
For workers wearing standard work clothes, recommendations for monitoring and work/rest
schedules are those approved by ACGIH and NIOSH. Workers wearing semipermeable PPE or
impermeable PPE shall be monitored when the temperature in the work area is above 70 F. To
monitor the worker, the following shall be measured:
• Heart rate --The radial pulse should be counted during a 30-second period as early as
possible in the rest period.
- If the heart rate exceeds 110 beats per minute at the beginning of the rest period, the
next work cycle should be shortened by one third and the rest period should be kept
the same.
- If the heart rate still exceeds 110 beats per minute at the next rest period, the
following work cycle should be shortened by one third.
- Oral temperature --A clinical thermometer (3 minutes under the tongue) or similar
device should be used to measure the oral temperature at the end of the work period
(before drinking).
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- If the oral temperature exceeds 990F (37.6 degrees Celsius (°C)), the next work
cycle should be shortened by one third, without the rest period being changed.
- If the oral temperature still exceeds 99.6 F (37.6 C) at the beginning of the next rest
period, the following work cycle should be shortened by one third.
- A worker should not be permitted to wear a semipermeable or impermeable garment
when his/her oral temperature exceeds 100.6 F (38.1 Q.
• Body water loss, if possible --Weight should be measured on a scale accurate to +/- 0.25
pound at the beginning and end of each work day to see if enough fluids are being taken
to prevent dehydration. Weights should be taken while the employee wears similar
clothing. The body water loss should not exceed 1.5 percent of total body weight loss in
a workday.
Proper training and preventive measures will help avert serious illness and loss of work
productivity. Preventing heat stress is particularly important. To avoid heat stress, the following
steps shall be taken:
• Work schedules should be adjusted.
• Shelter (air-conditioned, if possible) or shaded areas should be provided to protect
personnel during rest periods.
• Workers' body fluids should be maintained at normal levels to ensure that the
cardiovascular system functions adequately. Daily fluid intake must approximately
equal the amount of water lost in sweat, i.e., 8 fluid ounces (0.23 liter) of water must
be ingested for approximately every 8 ounces (0.23 kilogram) of weight lost. The
normal thirst mechanism is not sensitive enough to ensure that enough water will be
drunk to replace lost sweat. When heavy sweating occurs, the worker should be
encouraged to drink more. The following strategies may be useful:
- Water temperature should be maintained at 50°F to 60°F (10'to 150C).
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- Small disposable cups for water should be provided.
- Encourage workers to drink 16 ounces (0.5 liter) of fluid (preferably water or
diluted drinks) before beginning work. Urge workers to drink a cup or two every
15 to 20 minutes, or at each monitoring break. A total of 1 to 1.6 gallons (4 to 6
liters) of fluid per day are recommended, but more may be necessary to maintain
body weight.
• Encourage the use of cooling devices to aid natural body heat exchange during
prolonged work or severe heat exposure.
Signs and Symptoms of Heat Illness
Heat rash may result from continuous exposure to heat or humid air.
Heat cramps are caused by heavy sweating with inadequate electrolyte replacement. Signs and
symptoms include:
• Muscle spasms
• Pain in the hands, feet, and abdomen.
Heat exhaustion occurs from increased stress on various body organs, including inadequate
blood circulation due to cardiovascular insufficiency or dehydration. Signs and symptoms
include:
• Pale, cool, and moist skin
• Heavy sweating
• Dizziness, fainting, and nausea.
Heat stroke is the most serious form of heat illness. Temperature regulation fails, and the body
temperature rises to critical levels. Immediate action must be taken to cool the body before
serious injury or death occurs. Competent medical help must be obtained. Signs and symptoms
are:
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• Red, hot, and unusually dry skin
• Lack of or reduced perspiration
• Dizziness and confusion
• Strong, rapid pulse, and coma
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Appendix B
Health and Safety Equipment List
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Health and Safety Equipment List
Hardhats
Safety glasses
Ear plugs or muffs
Tyvek and polycoated Tyvek coveralls
Chemical resistant steel -toed boots
Work gloves
Nitrile gloves
Latex gloves
Plastic sheeting (visqueen)
55 gallon 17-H drums (for contaminated solids) and 17-E drums (for liquids)
Drum liners
Barricade tape and barricades
Wash tubs and scrub brushes
Decontamination solution
First Aid kit
Drinking water
Gatorade or similar drink
Type ABC fire extinguishers
Half -face and full -face respirators (NIOSH/MSHA approved)
Organic vapor cartridges
Organic Vapor Analyzer (OVA) and calibration kit
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Appendix C
Hospital Route Map
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54 s (0.2 mi)
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7 min (3.3 mi)
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2.1 mi
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0.5 mi
r 5. Turn right onto Tilghman Dr
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r 6. Turn right
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Betsy Johnson Hospital: Emergency Room
800 Tilghman Dr, Dunn, NC 28334

Appendix D
H&H Forms and Reports
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ACCIDENT / EXPOSURE REPORT FORM
EMPLOYEE NAME DATE OF BIRTH
HOME ADDRESS PHONE NO.
SEX: MALE FEMALE JOB TITLE SOC. SEC. NO.
OFFICE NO. _ OFFICE LOCATION DATE OF HIRE
HOURS USUALLY WORKED: HOURS PER DAY HOURS PER WEEK
TOTAL HOURS WEEKLY
WHERE DID ACCIDENT, OR EXPOSURE OCCUR? (INCLUDE ADDRESS)
COUNTY ON EMPLOYER'S PREMISES? YES NO
WHAT WAS EMPLOYEE DOING WHEN THE ACCIDENT OCCURRED? (BE SPECIFIC) _
HOW DID THE ACCIDENT OR EXPOSURE OCCUR? (DESCRIBE FULLY)
WHAT STEPS COULD BE TAKEN TO PREVENT SUCH AN OCCURRENCE?
OBJECT OR SUBSTANCE THAT DIRECTLY INJURED EMPLOYEE
DESCRIBE THE INJURY OR ILLNESS
PART OF BODY AFFECTED
NAME AND ADDRESS OF PHYSICIAN
S:\Office Mgmt Docs\Health & Safety\Health & Safety Plan Templates\Accident_Exposwe Report.docx hart : h i c kma n
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IF HOSPITALIZED, NAME AND ADDRESS OF HOSPITAL
DATE OF INJURY/ILLNESS TIME OF DAY
LOSS OF ONE OR MORE DAY OR WORK? YES/NO
IF YES, DATE LAST WORKED
HAS EMPLOYEE RETURNED TO WORK? IF YES, DATE RETURNED
DID EMPLOYEE DIE? IF YES, DATE
COMPLETED BY (PRINT)
SIGNATURE
TITLE DATE
AN ACCIDENT, EXPOSURE REPORT MUST BE COMPLETED BY THE SUPERVISOR
OR SITE SAFETY OFFICER IMMEDIATELY UPON LEARNING OF THE INCIDENT.
THE COMPLETED REPORT MUST BE IMMEDIATELY TRANSMITTED TO THE
MANAGER, HEALTH & SAFETY.
S:\Office Mgmt Docs\Health & Safety\Health & Safety Plan Templates\Accident_Exposwe Report.docx hart : h i c kma n
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Equipment Damage/Loss/Theft Report Form
Hart & Hickman, PC (H&H) employees are required to report any damage, loss, or theft of H&H owned or rented
equipment immediately upon damage or discovery of loss/theft to the H&H Health & Safety Officer and to the Project
Manager (PM). A completed copy of this form is to be submitted to the Health & Safety Officer within 72 hours of the
incident or time that equipment has been identified as being lost/stolen. Please note, depending on the nature of the
incident H&H may require that the form be submitted sooner than 72 hours. Where an injury occurs as a result of any
damage, loss, or theft of H&H owned or rented equipment, employees are required to report the incident immediately,
and submit a completed Accident/Incident Report Form.
Damage / Loss / Theft - Reported By
Emplovee Name:
Position:
Site:
Incident Information
Incident Date (dd/mm/yy):
*or date equipment identified as missing
Reported on (dd/mm/yy):
/J
Reported to:
Equipment Information
List of Equipment Damaged
/ Lost / Stolen (Please Specify)
Serial/Identifying
Number(s)
Equipment Location at
Time of Damage / Loss
How Was the Equipment
Damaged / Lost / Stolen?
(Complete Description)
Description of Damage to
Equipment
S:\BBB Health and Safety\Safety Reports\Loss Reports\Blank Loss Reports.docx haft : hickman
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Equipment Damage/Loss/Theft Report Form
Damage / Loss / Theft Details
What was the last known
location of the equipment?
Was this equipment being
stored securely when not in use?
When was the equipment last
seen?
When was the equipment last
used?
Please describe the steps taken
to locate the equipment:
Are you requesting that the
❑ YES ❑ NO
equipment be replaced?
Please describe the steps that
will have been taken to prevent
equipment loss from occurring
in the future:
Police Report Information
Police File #: Officer in Charge:
Station #: Phone #:
Name: Signature:
(person reporting loss, damage, or theft)
To be completed by the Health & Safety Manager
Investigation Date:
Replace Equipment?
YES
NO
Name (Health & Safety Officer):
Signature:
POLICE REPORT (IF THEFT) AND REPLACEMENT COST INVOICE MUST BE RECEVIED WITH THIS FORM FOR PAYMENT TO
BE MADE.
PLEASE RETURN TO: [e-mail] Email to Safety Reporting
S:\BBB Health and Safety\Safety Reports\Loss Reports\Blank Loss Reports.docx
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NEAR MISS REPORT
A Near Miss is a potential hazard or incident that has not resulted in personal injury. It is everyone's
responsibility to report and/or correct these potential incidents immediately. Please complete this form to
report Near Miss situations.
Project #/Name:
Location:
Weather:
Please check all appropriate conditions: Unsafe act
Unsafe condition
Was a Stop Work Authority initiated? ❑ Yes
Were pictures taken of the Near Miss? ❑ Yes
Describe the Near Miss or Potential Hazard:
Employee Name: (Optional)
Near Miss Investigation
Date:
Time:
❑ Unsafe equipment
❑ Unsafe use of equipment
❑ No
❑ No
Date:
To be completed by the Health & Safety Manager
Root Causes (Primary & Contributing):
Corrective Actions (Immediate & Long-term):
H&S Manager Name:
Investigation Date:
S:\BBB Health and Safety\Safety Reports\Near Miss Reports\Near Miss - Fillable Draft revs - che.docx
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ROOT CAUSE ANALYSIS
Why Near Loss or
Loss Incident Occurred
Personal Job Factor External O
Factor Factor
Did Not Follow Procedures or'
Acceptable Practices Because
0
Lack Of Skill Or
Knowledge
Doing The Job According
2
To Procedures Or
Lack Of Or Inadequate
­5
Acceptable Practices Take
Procedures
More Time Or Effort
Inadequate
Short -Cutting Procedures
Communication Of
3
Or Acceptable Practices Is
Expectations
6
Positively Reinforced Or
Regarding Procedures
Tolerated
Or Acceptable
Practices
In Past, Did Not Follow
41
Procedures Or Acceptable
Practices And No Incident
Inadequate Tools Or
Equipment
7
Occurred
(available, operable & safely
(injury, product quality incident,
maintained, proper task &
equipment damage, regulatory
workplace design)
assessment, or production delay)
Solution(s) Implementation Of
Verification And
Solution(s)
Validation

SITE SAFETY BRIEFING FORM
JOB NAME NUMBER
DATE START TIME COMPLETED
SITE LOCATION
TYPE OF WORK (GENERAL)
SAFETY ISSUES
TASK (THIS SHIFT)
PROTECTIVE CLOTHING/EQUIPMENT
CHEMICAL HAZARDS
PHYSICAL HAZARDS
CONTROL METHODS
SPECIAL EQUIPMENT/TECHNIQUES
NEAREST PHONE
HOSPITAL NAME/ADDRESS
SPECIAL TOPICS (INCIDENTS, ACTIONS TAKEN, ETC.)
SA\BBB Health and Safety\HASP Templates & Forms\Forms\Safety Briefing Form.docx hart : h i c kma n
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ATTENDEES
PRINT NAME SIGN NAME
MEETING CONDUCTED BY:
■
S:\BBB Health and Safety\HASP Templates & Forms\Fo=s\Safety Briefing FOT]n.docx hart hickman
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