19034_IRC_Corrective Action Plan_20121121

Gorreet[ve Action P[an - $o!!
lnternational Resistive Gompany, lnc.
Boone, Watauga County, lt{orth Carolina
lncident No.95191
November 21,2012
Terracon Project No. 861 271 03
Prepared for:
lnternational Resistive Company, lnc.
736 Greenway Road
Boone, Watauga County, NC
Prepared by:
Tenacon Consultants, lnc.
Taylorc, South Carolina
Corrective Action Plan - Soil
lnternational Resistive Company, lnc. r Boone, Watauga Co., NC
November 21,2012 x Terracon Project No.86127103
CORRECTIVE ACTION PLAN . SOIL
INTERNATIONAL RESISTIVE GOMPANY, INC.
736 GREENWAY ROAD
BOONE, WATAUGA COUNTY, NORTH CAROLINA
INCIDENT NO.95191
TERRACON PROJECT NO. 86127103
NOVEMBER11,2012
A. SITE INFORMATION
1. Site lnformation
e Dateof Report: November2l .2012
e Facility lD No.:lncident No.: E!91 Site RisUNon-UST Rank ![g[
a Site Name: lnternational Resistive Companv, lnc.
e Site Street Address: 736 Greenwav Drive
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= City/Town:
= Description of
Geographical Data Point:
Address:
e Property Owner:
Address:
e Property Occupant:
Address:
736 Greenwav Drive. Boone. NC
lnternational Resistive Comoanv. lnc.
Boone Zip Code: 28607 County: Watauoa
Center of Main Plant Buildino
e Location Method: Gooole Earth
e Latitude: 36.19710 Longitude: 81.66760'
2. lnformation About Gontacts Associated with the Release
e AST Orvner: lnternational Resistive Comoanv. lnc.
Tel.:828-40S7823
rel.:E2&z!QHBj!
736 Greenwav Drive. Boone. NC Tel.828-40&7823
e Consultant: Terra@n Consultants lnc.
Address: 3534 Rutherford Road, Taylors, SC 29687 Tel.:9@#9L
e Analytical Laboratory: Shealv Environmental Services. lnc. State Certification No.: 329
Address:106 Vantaoe Point Drive. Cavce. SC 29172 Tel.:80&791-9700
3. lnformation About Release
e Date Disovered: November 23, 201 1
e Estimated Quantity of Release: Unknown
e CauseofRelease: Unknown
PO Box 1860. Boone. NC
lnlemafional Recistiva Comnanv lnc
e Source of Release: AST - located on west side of olant
Correctlve Action Plan - Soi!
lnternational Resistlve Company, lnc. r Boone, Watauga Co., NC
November 21,2012 r Terracon ProJect No. 86'127'103
Jlerracon
AST svstem - surface soill area located on east side of plant
E-
E
E
F--
Sizes and Contents of Tank or Other Containmenl ftom Which the Release Occuned: 2T$qallon No. 2
fuel oil
Date Discovered:November 23,2O11
Estimated Quantity of Release: Unknown
Cause of Release:
Source of Release:
[-Jnknown
Sizes and Contents of Tank or Other Containment from Which the Release Occurred: six (6) '1OO<allon
hydraulic oil ASTs associated with operatinq machinerv in the olant
Certification
I, Georoe K. Flores,rofessional Geologist for Terracon Consultants, lnc., do certity
i-eport is conect and accurate to the best of my knowledge.
,,lol,_
number of the company or corporation is F-0869 (Engineerinq'|.
EXECUTIVE SUMMARY
Describe lhe source, date of dlscovery, and quantity and type(s) of contaminant released:
Former AST Area - 275 gallon fuel oil AST, impacted soil/groundwaler samples reported on 11123111, unknown
quantity
Suiace Spill Area - six (6) 100-gallon hydraulic oil ASTs associated with operating equipment inside plant,
impacted soil/groundwater samples reported on'l 1 l23l 11. unknown guantity
Summarize initial abatement actions, including closure, soil removal, free product recovery, and
provision of alternate water:
Former AST Area - 275 gallon AST has been removed from the site, the AST operated for a period of
approximately't0 years from '1980 to 1990
Suiace Spill Area - hydraulic oil released onto the floor surface inside the plant has been removed from the
floor surface
Describe the results of the hydrogeological investigation:
Groundwaler was encountered at a depth of approximately 10 feet below ground surface in the Former AST
Area and at an approximate depth of 12 feet in the Surface Spill Area
The
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3.
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4.
Gorrective Action Plan - Soil
lnternational Resistive Company, lnc. r Boone, Watauga Co., NC
November 21,2012 r Teracon Project No.86127103
l[erratron
Summarize the results of soil, groundwater, surface water assessment and free product measurement,
indicating the nature and extent of contamination, the estimated rate of migration, and potential for
impacting receptors:
Laboratory analysis of soil samples reported total petroleum hydrocarbons-diesel range organics (TPHono) at a
maximum concentration of 73 milligrams per kilogram (mg/kg) in shallow soils in the Former AST Area.
Laboratory analysis of soil samples reported TPHono at a maximum concentration of 1,400 mg/kg in shallow
soils in the Surface Spill Area. Laboratory analysis of a groundwater sample (Phase ll ESA) collected in the
Former AST Area reported a naphthalene concentration of 9.4 micrograms per liter (pg/L); laboratory analysis of
a groundwater sample (Phase ll ESA) collected in the Surface Spill Area reported a 1,1-dichloroethane
concentration of 8.4 pg/L. Miscellaneous other semi-volatile organics for which there are no applicable
regulatory standard were reported in groundwater samples collected in both areas.
Only limited groundwater assessment has been performed in the two areas due to the impending dernolition of
the onsite buildings in preparation for site sale and redevelopment; additional groundwater assessment will be
performed once dernolition efforts are complete. A separale conective action plan will then be prepared to
address groundwater impact, if necessary.
lndicate the risk classification (or non-UST petroleum/non-petroleum UST rank) and the criteria for that
determinationr
The site has been assigned a "High" risk ranking by NC DENR, because shallow soils in both areas contain
elevated TPDono concentrations (i.e., greater than 40 mg/kg) and there are active potable wells within a 1,000-
foot radius of the site. The concentration (9.4 trg/L) of naphthalene in groundwater in the fuel oil Former AST
Area exceeds the NC 2L Standard of 6.0 pg/L, The 1,1-dichloroelhane concentration of 8.4 pg/L reported
during the Phase ll ESA in the Surface Spill Area is assumed to be associated with the volatile organic
compound (VOC) plume located along the rear of the main plant building; this VOC release is unrelated to the
areas under discussion herein and is being managed by the lnactive Hazardous Sites Branch.
lndicate the soil, groundwater, and sudace water concentration levels to which contamination must be
remediated:
Soil in the two areas must be remediated to less than the Soil-toGroundwater Maximum Soil Contaminant
Concentrations (MSCCs). Groundwater impaded by releases from the two areas will require remediation to the
2L Standards; this will be addressed in a separate document, if required, based on further groundwater
assessment. Surface water has not been sampled but is not suspected to be impacted based upon the
apparent limited extent of groundwater impact as a result of the two releases.
Present the selecied remedy for soil and groundwater contamination and/or actions to reduce the risk
classification (or rank) and briefly state the basis for selection, schedule for implementation,
remediation milestones, and cost:
Excavation and removal with offsite disposal has been selected as the most appropriate soil remedy based
upon the relative cost, ease of implernentability, and both short- and long-term effectiveness. The total cost to
excavate and remove impacted soil in the Former AST and Surface Spill Areas is estimated to be approximately
$15,000. Soil rernoval is planned subsequent to dernolition of the onsite structures which is expected to be
completed in April 2013; it is anticipated that soil rernoval can be completed in approximately one to two weeks.
7.
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Corrective Action Plan - Soil
lnternational Resistive Company, lnc. r Boone, Watauga Co., NC
November 21,2012 r Tenacon Project No. 86127103
C. TABLE OF CONTENTS
Section
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Paoe
A. Site lnformation...1. Site lnformation.............2. lnformation about Contacts Associated with the Release3. lnformation about Release4. Certification .................... il
B. Executive Summary.... ,..................... u
D. Site History and Characterization .........................1
E. Summary of Site Assessment lnformation ............3
F. Objectives of Corrective Action at the Site... .........5
G. Comprehensive Evaluation of Remedial Actions........
EXHIBITS
Exhibit 1: Topographic Vicinity Map
Exhibit 2: Site Map
Exhibit 3: Site Map with Geological Cross-Sections (Former AST Area)
Exhibit 4: Site Map with Geological Cross-Sections (Surface Spill Area)
Exhibit 5: Water Supply Wdl / Surface Water Map
Exhibit 6: Potential Receptor and Land Use Map
TABLES
Table B-1: Site History - AST System and Other Release lnformation
Table B-2: Site History - AST Owner Operator and Other Responsible Party lnformation
Table B-3a: Summary of Soil Sampling Results (Former AST Area)
Table B-3b: Summary of Soil Sampling Results (Surface Spill Area)
Table B-5: Public and Private Water Supply Well and Other Receptor lnformation
Table8-6: PropertyOwner/Occupants
Table B-10: Land Use
Table 1: Generalized Remediation Schedules and Cleanup Progress Milestones
Table 2: Estimated Costs for Remedid Options
APPENDICES
Appendix A Site Specific Health and Safety Plan (HASP)
Appendix B Copy of NORR
Corrective Ac{ion Plan - Soil
lnternational Resistive Company, lnc. r Boone, Watauga Co., NC
November 21,2012 r Teracon Project No.86127103
D. SITE HISTORY AND CHARACTERIZATION
llerracon
1. Provide information for AST owners/operators and other responsible parties:
The names, addresses, telephone numbers, and dates of ownership/operation of the fuel oil AST and the
hydraulic oil ASTs are presented in Table B-2: Site History-UST/AST Owner/Operator and Other Responsible
Pafty lnformation (see Section J of this document). The location of the site is illustrated on Figure '1 .
2. Provide AST informdion:
The following information for the fuel oil AST (Former AST Area) and the hydraulic oil ASTs (Surface Spill Area)
is presented in Table B-1: Ste History-ASf System and Other Release lnformation:
E Tank identification number;
E Last contents oftank:
E Capacity of tank in gallons;
E Constructiondetails;
E Tank dimensions;
E Description of associated piping and pumps;
E lnstallation date;
E Slatus of AST (in use or not in use, closed in place, closed by removal, date of last use, date of closure);
and,
lndication of a release.
The locations of the two Areas are depicted on Figure 2. There were no previous contents of the fuel oil AST or
the hydraulic oil ASTs. A run of 3/&inch diamder piping for the fuel oil AST ran from the AST directly to the
humidity steam unit machine. Each hydraulic oil AST was integrated into a separate mold press machine.
These tanks have all been removed from the site as part of site decommissioning adivities. The incident
number for the site is 95191 .
Provide information about petroleum AST systems, petroteum spills, and other non-UST petroleum
releases:
The locations of the former fuel oil AST and the hydraulic oil ASTs are depicted on Figure 2. Specific details
related to the ASTs are presented in Table B-2: Site Histry- ASf System and Other Release lnformation.
Provide a comprehensive description of the release:
A Phase ll Environmental Site Assessment (ESA) was performed at the site in October 2011 by synTara. Two
separate areas, a former fuel oil AST (Former AST Area) and an apparent surface spill location (hydraulic oil
ASTs associated with machinery, also referred to herein as "Surface Spill Area") were identified by synTerra in
the Phase ll ESA report as having a "potential for contamination to be present" based on either historical
operations or the presence of surface staining. Soil and groundwater sampling in these two areas during the
Phase ll ESA indicated a release. The estimated quantity and cause of release in each of these two areas is
unknown.
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Corrective Action Plan - Soil
lnternational Resistive Company, lnc. : Boone, Watauga Co., NC
November 21,2012 a Terracon Project No.86127103
llerratron
5. Provide a brief description of site characteristics:
The site use was formaly utilized by lnternational Resistive Company for industrial purposes but that prooess
has been permanently discontinued and the facility is currently being decommissioned in preparation for
demolition and site redevelopment. Property to the north is used as commercial retail and residential. Proprty
to the east is used as residential. Property to the south is mostly vacant and wooded with some sparse
residential development. Property to the west is used for commercial purposes.
The site is mostly level, similar to property to the north, east, and west. Property to the southeast and
southwest is situated at a higher elevation than the site. Property directly south of the site is significantly higher
over a sho( distance (steep slope).
The southern and southwestern portions of the site are covered with hardwood trees. The eastern and western
portions of the site are covered with grass.
A spring originates on the steep slope south of the site and flows onto the site where it enters a culvert. This
spring flows through the culve( beneath the southern portion of the plant towards the east where it enters a
storm drain box and turns north where it rqnains in a culvert until it flows beneath Greenway Drive and a
residential lot where it flows into a stream bed. A second spring originates from property southeast of the site
and flows into a culvert on the site and enters the storm drain box discussed above.
Two water supply wells are located on the site: DW-1 east of the plant and DW-2 south of the plant. The two
wells are located greater than 250 feet from the Former AST Area and the Surface Spill Area. The wells
formerly supplied water for use in plant operations and were not used as sources of drinking water. Drinking
water for the site was provided by the Town of Boone municipal water system. Municipal water is available in
the area and is used by surrounding commercial properties and residential properties. There are nine
monitoring wells currenfly located on the site that are used to monitor a VOC plume located on the south side of
the plant; this release is being managed by the lnactive Hazardous Sites Branch and is unrelated to the two
areas under discussion herein.
Surface cover north and east of the plant is asphalt; south and west of the plant is grass. The soil type is mainly
sandy clayey silt and sifiy sand. Depth to and nature of bedrock is unknown. Depth to groundwater ranges
from three to eleven feet below ground surface based on existing monitoring wells and soil/groundwater
assessment activities. Based on the groundwater depths measured in the monitoring wells discussed above,
groundwater flow is to the east-northeast across the site.
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Corrective Action Plan - Soil
lnternational Resistive Company, lnc. r Boone, Watauga Co., NC
November 21,2012 r Terracon Project No. 86127103
lferratron
6. Provide information on owners and occupants of the property within or adjacent to the area containing
contamination or where contamination is expected to migrate and describe land use:
Available data indicated that soil and groundwater impacl from the Former AST and Surface Spill Areas is
limited to relatively small areas of the site and that contamination from these Areas is not expected to migrate
offsite. A list of adjacent property owners is included in Table 8-6: Property OwnerilOccupanls and land use is
described in Table B-10: Land Use.
7. Presentlnformation on receptors/potential receptors:
lnformation regarding potential receptors located within 1,500 feet of the site is presented in Table B-5: Public
and Private Water Supply Well and Other Receptor lnformation. The water supply well and spring locations are
depicted on Figure 5.
8. List all reporG previously submitted:
The following reports have been submitted for the two areas:
E Reoort of Findinos-Phase ll Environmental Site Assessment (synTerra, November 23,2011):
=
lnitial Assessment Reoort (S&ME, lnc. February 7,2012); and,
(S&ME, lnc., June 22,2012).
9. Summarize initial abatement and corrective actions performed to date:
Hydraulic fluid released from the mdd press machines (Surface Spill Area) was cleaned from the plant floor
using absorbent malerials. The mold press machinery, including the integrated ASTs, and the fuel oil AST have
all been rernoved from the site. Additional corrective action and/or abaternent measures have not been
undertaken in these areas.
'10. Refer to NORR/NOV requiring CAP preparation and submittal
A copy of the Notice of Regulatory Requirenrents (NORR) letter issued by NC DENR on September 'l1.2012,
requiring preparation and submittal of a Corrective Aclion Plan, is included in Appendix D.
E. SUMMARY OF SITE ASSESSMENT INFORMATION
1. Summarize site assessment information and any pre-CAP monitoring:
Groundwater was en@untered at a depth of approximately 10 feet below ground surface in the Former AST
Area and at an approximate depth oI 12 l*l in the Surface Spill Area. Laboratory analysis of soil samples
reported TPHono at a maximum concentration of 73 mg/kg in shallow soils in the Former AST Area. Laboratory
analysis of soil samples reported TPHono at a maximum concentration of 1,400 mg/kg in shallow soils in the
Surface Spill Area. As part of the Phase ll ESA, laboratory analysis of a groundwater sample collected in the
Former AST Area reported a naphthalene concentration of 9.4 pg/L; laboratory analysis of a groundwater
sample collected in the Surface Spill Area reported a 1,1-dichloroethane ooncentration of 8.4 pg/L.
Miscellaneous other semi-volatile organics for which there are no applicable regulatory standard were reported
in groundwater samples collected in both areas. Soil assessment data are presented in Table B-3: Summaty of
Soil Sampling Resu/fs.
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Gorrective Action Plan - Soil
International Resistive Gompany, Inc. r Boone, Watauga Co., NC
November 21,2012 r Terracon Project No.86127103
l[erracon
2. Describe the geology/hydrogeology of the region and the site:
The site owner has closed plant operations and plans to denrolish the onsite buildings within the next six
months. Therefore, permanent monitoring wells were not installed during the CSA. Should monitoring wells be
needed in these areas, they will be installed onoe denrolition activities are complete. The locations of borings
installed in these two areas during the CSA were surveyed by a NC licensed surveyor to ensure the boring
locations can be located once dernolition is complete.
The site lies within the Blue Ridge Geologic Province of North Carolina. Geology in the area of Boone is
generally comprised of massive to well foliated biotite granitic gneiss (Geologic Map of Noilh Carclina;
Department of Natural Resources and Community Dwelopment, 1985). Generally rocks are strongily foliated
and fradured. The percolation of water downward through the fradures has resulted in the formation of a layer
of residual weathered material (saprolite) and soil at the land surface. The saprolite and residual soils typically
have high porosities but low hydraulic condudivities; thus, they do not readily transmit groundwater. The
saprolite and residuum are considered leaky (semi-pemeable) beds which may store and rechargewater to the
undollng bedrock aquifer. Groundwater occurs within the saprolite and residuum between the clay, silt, and
sand grains. Groundwater also occurs and flows within the bedrock along secondary features, joints, and
planes of weakness. The movernent of groundwater through the saprolite is strongly influenced by topography.
Groundwater within the Blue Ridge generally moves from topographically high areas (recharge zones) to
topographically low areas with and along stream valleys (discharge areas). The site is situated adjacent to a
steep mountain slope to the south. To the north, east, and west, the topography is generally flat. Soils in these
areas may be alluvial deposits.
Generally, soils encountered in the Former AST Area consist of a dark brown organic topsoil to a depth of 0.5
feet. A light brown fine sandy silt was encountered from 0.5 feet to six feet. A light brown sligtttly clayey silt
was encountered from a depth of six feet to eight feet. A light brown line sandy silt was encountered forn a
depth of eight feet to 10 feet down to the termination of soil sampling.
Generally, soils encountered in the Surface Spill Area consisted of a dark brown organic topsoil to a depth of 0.5
foot. A tan, finetocoarse sand was enountered from 0.5 feet to six feet in boring SSA-1 . A dark gray silty day
and sandy day silt was en@untered below the topsoil in borings SSA-2 through SSA-4. An orange-brorn fine
sandy silt was en@untered below the dark gray silty clay. Refusal to direct push technoloSy (DPT) equipment
was en@untered at 15 feet in SSA-1 and 14.5 feet in SSA-3.
Depth to groundwder at the site ranges from three to 11 feet below ground surface based on measurements
obtained from site monitoring wells (associated with a difierent release, managed by the IHSB) and limited
groundwater assessment performed during the CSA. Based on water lervel measurernents in the above
monitoring wells, groundwater flow has historically been documented as occurring to the east-northeast across
the site.
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Corrective Action Plan - Soi!
lnternational Resistive Company, lnc. x Boone, Watauga Co., NC
November 21,2012 N Tenacon Proiect No.86127103
llbrracon
1.
Limited groundwater assessment performed in the two areas has indicated that groundwater is either not
impacied by the release (Surface Spill Area) or is only slightly impacted (Former AST Area). Based upon the
apparent limited extent of soil and groundwater impad, it is considered unlikely that a groundwater contaminant
plume originating from these areas would migrate offsite.
Examine and evaluate assessment information:
Laboratory analysis of soil samples reported TPHono at a maximum concentration of 73 mg/kg in shalloar soils
in the Former AST Area. Laboatory analysis of soil samples reported TPHono at a maximum concentration of
1,400 mg/kg in shallow soils in the Surface Spill Area. The area of soil impact in the Former AST Area is
estimated to be approximately ten feet by six feet, extending to an approximate estimated depth of three to four
feet below ground surface. The area of soil impact in the Surface Spill Area is estimated to be approximately
ten feet by five feet, extending to an approximate estimated depth of four feet bdow ground surface.
Laboratory analysis of a groundwater sample (Phase ll ESA) collected in the Former AST Area reported a
naphthalene concentration of 9.4 pg/L; laboratory analysis of a groundwater sample (Phase ll ESA) colleded in
the Surface Spill Area reported a 1,1-dichloroethane concentration of 8.4 pg/L. Miscellaneous other serni-
volatile organics for which there are no applicable regulatory standard were reported in groundwate samples
collected in both areas. Only limited grcundwater assessment has been performed in the two areas due to the
impending demolition of the onsite buildings in preparation for site sale and redevelopment; additional
groundwater assessment will be performed after dernolition efforts are complete.
The site is dassified as High Risk. Therefore, the applicable soil cleanup levels are the Soil-toGround'water
Maximum Soil Contaminant Concentrations (MSCCs). Groundwater deanup levels for the site (if applicable, to
be determined following additional assessment) are the NC Groundwater Quality Standards (i.e., NCAC 2L
Standards).
As mentioned above, the apparent extent of contamination in these areas, both to soil and groundwater, is
limited. These areas are also both located near the center of the property. These characteristics indicate a low
potential for contaminant migration ofisite or impact to receptors.
The site risk ranking could be lowered by remediation of impacted soil and groundwater (if applicable).
OBJECTIVES OF CORRECTIVE ACTION AT THE SITE
lndicate the NORR requiring the CAP:
A copy of the NORR letter issued by NC DENR on September 11, 2012, requiring preparation and submiftal of a
CAP, is included in Appendix B.
F.
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Corrective Action Plan - Soil
lnternational Resistive Company, lnc. r Boone, Watauga Co., NC
November 21,2012 r Terracon Project No.86127103
lfenatron
2. State purpose and objectives of the CAP:
The purpose of this CAP is to reduce the concentrations of petroleum hydrocarbons in soil. This document !g
not intended to address groundwater impact, if any, in the two areas under review; any potential groundwater
remediation will be addressed in a separate document, if necessary, following additional groundwater
assessment.
3. State the cleanup goals of the CAP:
The soil cleanup goals are the Soil-toGroundwater MSCCs, as discussed in Section E.3.
G. COMPREHENSIVE EVALUATION OF REMEDIAL ACTIONS
1. Present and comprehensively evaluate remedial ofiions:
Remedial Option Evaluation
a. Evaluate risk reduction mechanisms:
Not Applicable - The site risk ranking cannot be reduced solely by supplying an alternative drinking water
source to water supply well users.
b. Evaluate excavation as sole remedial process for soil contamination:
Soil remediation by excavation is a viable remedial option for the two Areas. This alternative o<hibits both
short and long-term effectiveness; is readily implementable; is ost-effective based on the apparent
shallow nature and relatively small volume of impacted soil to be removed; is protective of human helth
and the environment; and, is expected to garner NC DENR acceptance.
c. Evaluate natural attenuation as the sole remedial process for groundwater contamination:
Not Applicable - Groundwater assessment is not complete and any potential groundwater rernediation
which may be required will be discussed in a separate document.
d. Evaluate a minimum of two viable technology-based remedial options for soil and groundwater:
Soil
Soil Vapor Extraction - Soil vapor extradion (SVE) is an in situ unsaturated (vadose) zone soil
remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and
remove volatile and some senri-volatile contaminants from the soil. The gas leaving the soil may be
treated to recover or destroy the contaminants, depending on local and state air discharge regulations.
Vertical extraction vents are typically used at depths of five feet or greate and have been succesfully
applied as deep as 300 feet. Horizontal extraction vents (installed in trenches or horizontal borings) can
be used as warranted by contaminant zone geometry, drill rig access, or other sitespecificfadors.
For the soil surface, geomembrane @vers are oten placed over soil surface to prevent short circuiting
and to increase the radius of influence of the wells.
6Responsive r Resourceful r Reliable
Corrective Action PIan - Soil
lnternational Resistive Company, lnc. r Boone, Watauga Co., NC
November 21,2012 r Terracon Project No.86127103
llerracon
Low Permeability Capping - Hard-surface capping works by maintaining a high-strength, low-permeability
cover over the contaminated area to stabilize surface soil and reduce infiltration of surface water. The low-
permeability layer can be made from either asphalt or concrete. Asphalt usually is selected in favor of
concrete because the bitumen binder in asphalt provides some flexibility, making the oover more resistant
to cracks that tend to form as a result of temperature cycling and/or differential settlement. A top coat of
bitumen or rubberized-bitumen mastic may be applied to further decrease permeability.
For a cap applied in a high-traffic area, gravel may be mixed with the mastic to provide a wear resistant
surface. The lovv-permeability layer typically is placed on a high-permeability foundation laye. The
foundation helps reduce the negative effects of differential settling and allows drainage. Drainage under
the low-permeability layer is needed to prs/ent ponding of small amounts of water that may leak throqgh
the low-permeability layer or migrate upward from the soil. Ponded water can freeze and o<pand durirq
cold weather, causing frost heave damage to the cover.
lf gas generation in the waste volume must be controlled, a permeable vent layer can be plaoed on the
surface as the first layer of the cap. Vapor extraction by applying a vacuum to the vent layer at points
along the edge of the cap allows collection of gas for treatment.
Materials and mdhods used to place a hard-surface cap are similar to conventional road paving, but
indude modifications to reduce permeability and increase durability of the paving that forms the low-
permeability element. For example, an asphalt layer used for capping consists of bitumen mixed with fine
and coarse aggregate to give a specified well-graded aggregate mix as in paving. However, an asphalt
paving mixture used for capping will require a more tightly controlled particle size distribution and a higher
bitumen oontent in comparison to a standard road paving mi*ure.
Groundwater
Not Applicable - See above
For each option evaluated above:
1) Gonsideration of the nature and extent of the contamination at the site:
Surface Soill Area - Soil in this area is impacted by petroleum hydrocarbons from a hydraulic oil
release. The extent of soil impact is estimated to consist of an area measuring approximately five
feet by ten feet, o<tending from surface (or near surface) to a depth of approximately four feet
below ground surface. The surface of this area is grassed so contaminants are oeosed to the
environment.
Fonner AST Area - Soil in this area is impacted by petroleum hydrocarbons from a fud oil release.
The extent of soil impact is estimated to consist of an area measuring approximatdy six fed by ten
feet, extending from surface (or near surface) to a depth of approximately four feet below ground
surface. The surface of this area is grassed so ontaminants are exposed to the environment.
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Corrective Action Plan - Soil
lnternational Resistive Company, lnc. n Boone, Watauga Co., NG
November 21,2012 * Terracon Project No.86127103
'llbrraEon
Description of each remedia! technology, mechanism, or process:
Excavation - This remedy consists of the removal of impacted material from the site and
transportation to a permitted offsite treatment and/or disposal facility; in this case, the material will
be managed as a non-hazardous waste with disposal likely in a municipal solid waste (Subtitle D)
landfill (waste characterization sampling will likely be required by the landfill prior to its acceptance
of the material). The volume of soil to be removed will initially be predetermined based upon data
generated during the CSA. Performance objectives will be quantified by the collection and analysis
of confirmation samples. lf confirmation sampling indicates that additional soil is present above the
remedial objectives, a second round of soil excavation will be performed and additional vermcafun
samples collected. Once perfonnance objectives have been achieved the excavation will be
backfill with uncontaminated soil that is imported from an offsite source. No permitting is
anticipated in conjundion with this alternative. Because this ranedy involves the rmtoval of
impacted material, there are no operation and maintenance oosts.
Low Permeabilitv Cappino - See previous subsection for description of this technology. For
application at this site, a small volume of impacted soil would likely require removal in order to
properly install the cap; this material would be managed as a non-hazardous waste, as described in
the previous alternative. No permitting is anticipated in conjunction with this alternative. Because
this ranedy does not involve treatment and/or removal of the impacted soil, the cap must be
maintained in perpetuity or until site conditions allow otherwise. Caps must be routinely
maintenanced and inspected to insure the integrity of the system is maintained.
Soil Vaoor Extraction - See previous subsection for description of this technology. For application
at this site, it is anticipated that one to two vertical soil vapor extradion (SVE) wells tttould be
installed in or just outside of the impacted area. ln order to for this alternative to funcdion
effectively, it would likely need to be installed in conjunction with a low permeability geomernbrane
cover to prevent short-circuiting of the air flow. A relatively small volume of impacted soil would
require rernoval and management as a non-hazardous waste, as previously described, in order to
install the cover and the vapor extraction well(s). A permit to construct and openate the SVE
systenr would be required; this would include obtaining a permit (or a permit waiver) fom the NC
DENR Division of Air Quality. Routine opaation and maintenance of the SVE systern uould be
required to insure optimum performance.
Discussion of feasibility and effectlveness of each remedial technology, mechanigrn, or
process:
Excavation - Excavation with offsite disposal is a commonly employed remedy at similar sites. lt is
readily implementable with common construdion equipment, does not require specialized
technology and/or knowledge, and is effective at permanently reducing the risk to human health
and the environment. lt is anticipated that contaminated soil from this site can be managed as a
2)
3)
8Responsive r Resourcefu! r Reliable
Corrective Action Plan - Soil
lnternational Resistive Company, lnc. r Boone, Watauga Co., NC
November 21,2012 r Terracon Proiect No.86127103
llbrracon
non-hazardous waste; therefore, there are a number of proximate treatment and/or disposal
facilities that are permitted to accept impacted soil from this site. There are no operation and
maintenance (O&M) costs associated with this ranedy.
Low Permeabilitv Caooinq - A low permeability cap can be installed using common construction
practices and equipment. Although capping is effective at reducing the potential for leaching to
groundwater and for preventing direct human contact through dermal exposure, it is not effeclive at
reducing the concentration of site contaminants when used as a standalone remedy. Caps and
cap integrity must be maintained long term; therefore, land use restrictions must be employed in
conjunction with a cap. Land use restrictions associated with a cap may impact site rede\relopment
options.
Soil Vaoor Extraction - An SVE systern can be installed with commonly available drilling rigs and
construction equipment. ln most cases, the vacuum extraction pump and other syatent
@mponents are readily available from a number of suppliers. SVE is effective at reducing
conlaminant concentrations in situ through either volatilization or biodegradation. Because surface
and shallow soils at this site are impacted, SVE would require mupling with another technique such
as excavation with the installation of a low permeability geomembrane @ver. ln order to properly
design an SVE systern for a given site, a pilot test is often required. As mentioned praniously, SVE
systerns require regular O&M in order to insure proper operation.
4) Remedial system operation and maintenance plan for each remedial option:
Excavation -There is no O&M schedule associated Wth this remedy.
Low Permeabilitv Caooinq - O&M for a low permeability cap typically includes, at a minimum, an
annual inspection by a qualified person to assqss the condition of the cap and the need for repair
and/or maintenance. Maintenance activities may include re-sealing of the material, repair of
cracks, and/or removal of nearby deep-rooted vegetation (sudt as trees).
Soil Vaoor Extraction - Regular O&M is essential for the proper performance of an SVE systern.
lnitially, it is usually recommended that O&M visits be made by a trained professional on a weekly
basis. This schedule can be reduced to monthly or even quartaly, especially if telerndry is
integrated into the systern. Periodic site visits will continue to be made throughout the operational
life of the systern, however, for routine tasks such as changing filters and belts, adjusting flowrates,
and replacing offgas treatment units and/or disposing of accumulated water. Once ontaminant
rernoval rates have reached an asymptotic level, system operation may be reduced from full-time to
intermittent (or pulsed) to reduce operational costs.
9Responsive r Resourceful r Reliable
Corrective Action Plan - Soil
lnternational Resistive Company, lnc. r Boone, Watauga Go., NG
November 21,2012 r Terracon Project No.86127103
'lferracon
Waste treatmenUdisposal plan for each remedial option:
Excavation - As previously discussed, it is anticipated that contaminated soil from this site may be
managed as a non-hazardous waste with disposal at a Subtitle D landfill. The total volume of soil
to be disposed from both areas is estimated to be approximately 25 tons.
Low Permeabilitv Caooinq - See above for management of impacted soil generated during cap
installation; the total volume of soil to be disposed from both areas is estimated to be less than one
ton. No other wastes are anticipated with this alternative.
Soil Vaoor Extraction - See above for management of impac'ted soil generated during system
installation. The total volume of contaminated soil from this site that would require clisposal is
estimated to be less than one ton. lf off-gas treatment is required, it would likely consist of
treatment via granular activated carbon (GAC); as the GAC units are expended (i.e., 'spent") they
would be replaced with nerrtr units and returned to the manufadurer for regeneration, likely on a
semiannual to annual basis. lt may also be necessary to periodically manage accumulated water;
this material would require charaderization prior to treatment and disposal, however, at this site it
would be anticipated to be managed as a non-hazardous waste. The volume of water to be
managed as a result of SVE operation is estimated to be approimately 100-200 gallons per year.
Monitoring ptan for each remedial option:
Excavation - Monitoring is not required for this alternative.
Low Permeabilitv Caooino - Monitoring in the form of visual assessment would be performed on an
annual basis.
Soil Vapor Extraction - Monitoring of the SVE influent and effluent (post treatment, if applicable)
would be performed on a periodic basis (assumed quarterly once systern has undergone
startup/shakedown phase) using an Organic Vapor Analyzer (OVA), Toxic Vapor Analper (TVA),
or similar field screening dwice. Once per year, an influent sample would be collected for
laboratory analysis using Method TO-15 (i.e., volatile organics). Monitoring results would be
summarized in an annual monitoring report to be submitted to the NCDENR. Once influent
concentrations reach asymptotic levels, soil borings may be advanced into the impaded zone to
collect soil quality data; soil samples will be analyzed for VOCs and/or SVOCs using EPA Mdhods
82608 and 827OC, respectively (or approved equivalent methods).
5)
6)
Responsive r Resourceful r Reliable 10
Corrective Action Plan - Soil
International Resistive Company, lnc. r Boone, Watauga Co., NG
November 21,2012 r Terracon Project No.86127103
llbrracon
7) Comprehensive, well-substantiated schedule for each remedial option:
As previously discussed, IRC plans to denrolish the onsite structures in order to prepare the site for
redevelopment. Therefore, due to the proximity of the two areas under discussion herein to the
main plant building, implenrentation of this CAP will not begin until demolition activities are
complete. With that fundamental understanding, the following approximate schedules are
discussed below and are presented in Table 1.
Excavation - Soil excavation is anticipated to take one to two days to oomplete. Confirmation
sampling will be expedited so that supplernental excavation efforts may be undertaken if
necessary. Once the confirmation sampling results indicate that the remedial objec{ives have been
satisfied, the excavations will be bacKilled with offsite material. lmpacted soil will be te-mporarily
stored onsite until laboratory data indicate that rernedial objectives are achieved. The entire
process is expected to take approximately two to three weeks.
Low Permeabilitv Caooino - Preparation of the cap areas is expected to take one day. lnstallation
of the cap can begin the following day and is expected to take one to two dap to cornplde. As
previously discussed, monitoring in the form of visual assessment will be performed on an annual
basis.
Soil Vaoor Extraction - lt is anticipated that permitting for an SVE systern muld be complded by
the time facility dernolition is complete. The SVE system(s) would be constructed and housed in a
prefabricated building which would be delivered and setup onsite; once an order is placed for a
system, it is expected to take approximately six weeks for delivery; during that time, the SVE wells,
low permeability geomembrane cover, and extradion piping would be installed. Once the system
anives onsite, it can be hooked up to the SVE wells in one to two days. Scheduling and completion
of systan inspection by the municipality and other parties (e.9., electrical provider) is o<pected to
take approximately one week. System startup/shakedown and performance optimization is
anticipated to take approximately two to four weeks. O&M adivities will occur on a quarterly basis,
or more frequently, if wananted. Monitoring of the system influent (and effluent, as necessary) will
be peformed at least one per quarter. Annual reports summary system run time, influenUeffluent
concentrations, maintenance issues, and other related adivities will be submitted to the NC DENR
for review. Once influent concentrations have reached asymptotic levels, soil samples will be
collected for laboratory analysis to verify that remedial objectives have been achisred. lt is
anticipated that active SVE treatment will be required for a period of one to two years. Once
remedial objectivs have been achieved, the SVE systern will be dismantled and rernoved from the
site. All SVE wells will be permanently abandoned in accordance with NC well regulations.
Responsive r Resourceful r Reliable 1'.1
Corrective Action Plan - Soi!
lnternational Resistive Company, lnc. x Boone, Watauga Co., NC
November 21,2012 x Tenacon Project No.86127103
llerracon
8) Detailed cost estimate for each remedial option:
Excavation - The total estimated costs associated with excavation from the two areas is as follows:
. Excavation, backfilling, transportation, & offsite disposal - $7,000
. Confirmation sampling - $1,500
. Professional oversight, project management, & reporting - $6,500
. Estimated total - $15,000
Low Permeabilitv Caooirro - The total estimated osts associated with installation of a lonr
permeability cap in both areas is as follows:
o Area preparation (including excavation, backfilling, transportation, & offsite disposal d
impac;ted soil) and installation of cap - $6,000
. Professional time for design, installation oversight, & projec't management - $4,500
o Annual cap inspection and reporting (assumed 30 years) - $10,000
. Cap maintenance (assumed once per every 5 years, 30 year life span) - $15,000
o Estimated total- $35,500
Soil Vaoor Extraction - The total estimated costs associated with installation of a single SVE
system to service both areas is as follows:
r Preparation of technical specifications - $4,000
o Permitting, induding professional time & fees - $5,000
. SVE system construction, installation, startup, & shakedown - $45,000
r Professional time for installation oversight & project management - $9,000
o Annual reporting (assume 2 year opeational life) - $2,000
. O&M osts (assume 2ye,ar opuational life) - $23,000
o Performance verification sampling, final reporting, & systenr decommissioning - $6,000
o Estimated total - $94,000
2. Select best remedial option and discuss the basis for the selection:
Excavation with offsite disposal is selec'ted as the preferred soil ranedy for the site. This alternative is
selected based upon: the ease of implernentability; the short and long-term effectiveness in reducing site
contaminants of concern; overall protection of human health and the environment; and, the rdative cost. I.lo
permits are required for this rernedial alternative.
H. PUBLIC NOTICE
Because soil cleanup to alternative standards is not proposed, public notice is not required under 15A NCAC 2L
.01 14(b) or .0409(a) for this project.
Responsive r Resourceful r Reliable 12
1 - Topographic Vicinity Map
2 - Site Map
3 - Site Map with Geological Cross-Section (Former AST Area)
4 - Site Map with Geological Cross-Section (Surface Spill Area)
5 - Water Supply Well / Surface Water Map
6 - Potential Receptor and Land Use Map
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TOPOGRAPHIC VICINITY MAP
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REFER TO TABLES 8-6 AND B-10 FOR
INFORMATION REGARDING NUMBERED LOTS
BASE MAP OBTAINED FROM WATAUGACOUNTY
GIS DEPARTMENT
POTENTIAL RECEPTORAND LAND USE MAPllerracon
Consulting Ingineers & Scientists
IRC PLANT
WATAUGA COUNry, NORTH
B-1: Site History - AST System and Other Release lnformation
B-2: Site History - AST Owner Operator and Other Responsible Party lnformation
B-3a: Summary of Soil Sampling Results (Former AST Area)
B-3b: Summary of Soi! Sampling Results (Surface Spill Area)
B-5: Public and Private Water Supply Well and Other Receptor lnformation
8-6: Property Owners/Occupants
B-10: Land Use
1: Generalized Remediation Schedules and Cleanup Progress Milestones
2: Estimated Costs for Remedial Options
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Table B-2
Site History - AST Owner/Operator & Other Responsible Party lnformation
Terracon Project No. 86127103
ASTSystem Name: lnternational Resistive Comoanv. lnc. lncident No.: 95191
6 lntemational Resistire Co., lnc.1960s to 812012 Both
'tmdr€s{:Xxr:.:,.':':::tix't'. TCl6Shbne'Nurnberr.
736 Greenway Road, Boone, NC 28607 828-264-8861
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7 lntemational Resistire Co., lnc.1960s to 812012 Bothr
736 Greenway Road, Boone, NC 28607 828-26+8861
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Revision Date: Mvember 14.2012
lncident Number and Name:
Concentrations in bold indicates reported aborc the method detection limit
MSCC = maximum soil contaminant concentration
fr. BGS = bet below ground surface
ND = non-detect: indicates concentrations of each SVOC are reported below rarious method detection limits
NL = not listed since each VOC and SVOC were reported below respectiw method detection limits
mg/kg =6;111nrams per kilogram
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Table 2: Estimated Costs for Renredial Options
lnternational Resistive Company, lnc.
Greenvray Drive, Boone, Watauga County, l\C
Item Estimated Cost
Excavation, backfillin g, transportation, & offsite d isposal $7,00c
Confirmation Sampling $1,50C
Professional oversight, project mana gement, & reporting $6,50C
ffix$rc
Estimated CostItem
Area preparation (including excavation, backfilling, transportation,
& offsite disposal of impacted soil) and installation of cap $6,00c
Professional time for design, installation oversight, & project
management $4,50C
Annualcap inspection and reporting (assume 30 life cycle)$10,00c
Cap maintenance (assume once per 5 years over life cycle)$15,00c
Item Estimated Cost
Preparation of technical specifications $4,00c
Permitting, including professional time & fees $s,00(
SVE system construction, installation, startup, & shakedown $45,00c
Professional time for installation oversiqht & proiect manaqement $e,00c
Annual reportino (assume 2 vear operationa I life )$2,00c
O&M costs (assume 2 year operational life)$23,00c
Performance verification sampling, final reporting, & system
decommissioning $6,00c
itrffil]U $il6h"::.,'''.;',t'rtl':r::::,,.ffiI;$${'-*}'Ys,il,l,r$l
APPENDICES
A: Site Specific Health and Safety Plan (HASP)
B: Copy of NORR
Site Specific Health and Safety Plan (HASP)
l]'erracon
SAFEW AND HEALTH Plan
for
PETROLEUM HYDROCARBON GONTAM INATION
TERRACON
Date
Rerr: 12105
l[erratron
SAFETY AND HEALTH PLAN
PETRO LE U M HYDROCARBO N CO NTAM I NAT ION ANTIC IPATE D
PROJECT NAME:
LOGATION:
lnternational Resistive Comoanv- !nc.
736 Greenwav Road. Boone. Watauoa Countv. NC
TERRACON PROJECT NUMBER:
START DATE:
86127103
1.0 APPLICABILITY
This Safety and Health Plan (Plan) will be used exclusively for Tenacon projects involving:
. UST Removals (UST Addendum required)o lntrusivelnvestigationso RemedialAssessmentso Site Remediation. SpillGontrol/EmergencyResponse
where petroleum hydrocarbons (gasoline, diesel fuel, waste oils, fuel oils, petroleum based
hydraulic fluids, etc.) are the only known contaminants of concem. lf contaminants other than
petroleum hydrocarbons are known or suspected, the Project Manager will contact the
Corporate Safety and Health Manager to arrange for development of a site and contaminant-
specific Safety and Health Plan.
Subcontractors engaged in prcject activity at this site will comply with applicable prcvisions of the
Occupational Safety and Health Act of 1970, the safety and health requirements set forth in
OccupationalSafety and Health Administration regulation 29 CFR 1910.120, where applicable, and
any applicable state, city or local safety codes. Each subcontractor will be responsible for
supplying a Competent Person to overcee drilling work at this project site. The drilling
subcontnactor has primary responsibility for utilizing equipment and work practices necessary to
protect the safety of the subcontracto/s employees engaged in this project.
The subcontractorwillmaintain an orderly and safe work area arcund drilling/excavation equipment
to minimize the potential for accidents. ln addition, the subcontractor shall provide whatever safety
banicades or waming devices are deemed necessary by Ternacon to prevent accidents or injury to
field personnel and the general public.
Subcontractors engaged on this project site may utilize this site Safety and Health Plan for their
employees, or each subcontractor may develop and utilize their own site Safety and Heafth Plan
prcvided the provisions of the subcontracto/s site Safety and Health Plan are at least as stringent
as the requirements contained in this Plan. Decisions rcgarding equMalence of safety and health
requirements shall be made by Tenacon Project Manager and Corporate Safety and Health
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
Page 2
Manager. Adoption of this Site Safety and Health Plan by subcontract employers shall not relieve
any site subcontractor for the responsibility for the health and safety of its employees.
2.0 SAFETY AND HEALTH ADMINISTRATION
The Project Manager is ultimately responsible for seeing that work on this project is performed
in accordance wiflr the safety and health provisions contained in this Plan. The designated Site
Safety and Health Officer (SSO) will monitor compliance with this Plan during field activities. All
field team memberc engaged in project activities will be required to sign the "Acknowledgment
of lnstruction'form included with this Plan. The SSO will maintain a copy of this Plan on site for
the duration of project activities.
Tenacon and subcontractor task leaders will be responsible for:
. Providing subordinate personnel a copy of this Plan, and briefing them on its content.. Enforcing the applicable provisions of this Plan.. lnspecting and maintaining equipment in compliance with applicable federal, state or local
safety regulations.. Enforcement of conective actions.o lnvestigation of accidents or injuries.
The following
TITLE
individuals will be responsible for implementation and enforcement of the Plan:
Tenracon Safety and Health Manager: Gary K. Bnadley, CSP, CHMM 913-599-6886
Prcject Manager:
Site Safety and Health Officer:
Tenacon Task Leade(s):
NAME
George K. Flores, PE
B. Eric Greenwood
B. Eric Greenwood
George K. Flores
PHONE
864-292-2901
864-304-3288 (M)
864-304-3288 (M)
7A4-il44A54 (M)
lf hazardous conditions develop during the course of project activity, the SSO, in conjunction
with the Terracon Corporate Safety and Health Manager, will coordinate actions required to
safeguard site personnel and members of the general public. Additional safety measures will be
verbally communicated to all project personnel, recorded in writing and appended to this Plan.
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Proiect # 86127 103
Page 3
3.0 MEDICALSURVEILLANCEREQUIREMENTS
All Terracon personnel participating in this project shall be enrolled in a health monitoring
program in accordance with the provisions of OSHA 29 CFR 1910.120 and 1910.134. Each
project participant shall be certified by a Doctor of Medicine as fit for respirator and semi-
permeable/impermeable protective equipment use. All personnel shall have received an
environmental physical examination wittrin one year prior to the start of project activities.
4.0 EMPLOYEETRAININGREQUIREMENTS
All Tenacon personnel, must have completed 40 hour Hazardous Waste Operations Training
and at least three days of supervised fietd activity per the requirements of OSHA 29 CFR
1910.120. ln addition, a current 8-hour annual refresher training certificate will be required for
all personnel. Training certificates for all project personnel will be maintained by the Corporate
Safgty and Health Manager and/or the SSO at the project command center.
Prior to the start of site activities, the SSO will conduct a pre-project safety and health briefing
for all project participants. The personnel responsible for project safety and health will be
addressed, as will site history, scope of work, site control measures, emergency procedures and
site communications. The briefing will address site contaminants, air monitoring protocols,
action levels for upgrade/downgrade of personal protective equipment and level of personal
protective equipment to be employed for each project task.
Safety and health briefings will be presented by the SSO at the start of each work day. ln
addition to a general review of the proposed daily activity and safety requirements, the results of
previous air monitoring and any procedural changes will be addressed.
5.0 RESPIRATORYPROTECTIONPROGRAM
The purpose of the Tenacon respiratory protection program is to prevent personnel exposure to
aibome contaminants in excess of established permissible exposure limits/threshold limit
values. All respirators employed by Terracon personnel will be NIOSH approved. Cartridges
and filters for air purifying respirators will be appropriate for the contaminant(s) of concem.
Cartridge/filter selection will be made by the Terracon Corporate Safety and Health Manager.
Project perconnel required to wear respiratory protection will be medically cleared for respirator
use, trained and successfully fit tested in accordance with OSHA 29 CFR 1 910.134. Personnel
required to wear supplied air respirators will demonstrate competence in donning/doffing and
inspecting the equipment prior to job assignment. All project tasks requiring the use of supplied
air respirators will require properly equipped backup personnel ("buddy system").
At a minimum, air purifying respirator cartridges will be changed daily prior to use. More
frequent change of respirator cartridges will be based on the results of site air monitoring.
Under no circumstances will air purifying respirators be used in areas deficient in oxygen
(<19.5%), in areas classified as immediately dangerous to life and health (IDLH) or in areas
where contaminants have not been characterized.
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
Page 4
Respirators will be inspected and required fit checks will be performed prior to use, and any
necessary repairc will be made before proceeding to the project site. Respirators will be
sanitized daily after use.
6.0 SITE HISTORY/SCOPE OF SERVICES
Preliminary information obtained from the client indicates that this project site may be
contaminated with petroleum hydrocarbons. The personal protective equipment and direct
reading air monitoring protocols specified below are designed to prevent perconnel exposure to
contramination in excess of permissible exposure limits.
6.1 Scope of Services
{ Soit/GrcundwaterSampling
_ Soil Boring (Drill Rig)
_ Remedial System lnstallation
{ Otner (soil removal)
_ Soil Boring (Hand Auger)
_ UST Removal (requires
tank removal addendum)
_ Monitoring Well lnstallation
7.0 HAZARD ASSESSMENT
7.1 Chemical Hazards
Soils/groundwater at this project site may be contaminated with petroleum hydrocarbons.
Benzene is the most significant health hazard contained in petrcleum blends and typically
comprises less than 1% of regular grade gasolines. Specific health hazard information on
petroleum compounds and their most healtr-significant volatile fractions are provided below.
Additional health-hazard information may be found in the chemica! product information sheets
attached to this Plan. Personnel engaged in monitoring well sampling are advised that organic
vapors from contaminated groundwater can collect in wells and be displaced by bailers.
Perconnel are advised to approach monitoring wells from the upwind side, remove the cap and
allow the well to vent momentarily prior to sampling. Keep breathing zone to the upwind side of
wells during bailing activities.
BEl.lzENE
Permissible Exposure Limit
1 ppmOSHAPEL
5 ppm OSHA 10 min Ceiling
0.5 ppm OSHA Action Level
Benzene is a central nervous system depressant and an eye and skin initant. Poisoning may
cause hemonhages and immunosuppression. A relationship has been discovered between
benzene exposure and leukemia. Benzene is regulated as an occupational carcinogen. Acute
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127103
Page 5
exposure may cause dizziness, excitation, weakness, headache, giddiness, breathlessness and
chest constriction.
TOLUENE
Permissible Exposure Limit
50 ppm ACGIH TLV
(Skin Absorbable)
Toluene is an eye, skin and mu@us membrane initant and a central nervous system
depressant. Poisoning may affect the liver and kidneys. Prolonged exposure may affect the
heart and blood. The ingestion of alcoholic beverages may enhance the toxic effects of toluene.
Symptoms of exposure include respiratory tract irritation, headache, dizziness and eye imtation.
Toluene may be absorbed to the bloodstream via skin contact.
ETHYL BEMENE
Permissible Exposure Limit
100 ppm OSHA PEL
Ethyl benzene is a skin, eye and mucous membrane initant. lt is moderately toxic by ingestion
and slightly toxic by skin absorption. Ethyl benzene is a central nervous system depressant.
Poisoning may affect the liver. Symptoms of exposure may include a sense of chest constriction
and nervous disorders. Skin contact may result in first and second degrce bums. The odor can
be detected at 14O ppm ant irritation occurs at 200 ppm.
XYLENE
Permissible Exposure Limit
100 ppm OSHA PEL
Xylene is a mild eye and mu@us membrane initant, primary skin initant and a central nervous
system depressant. lngestion causes severe gastrointestinal upset and creates an aspiration
hazard. Chronic inhalation results in symptoms that resemble acute poisoning, but are more
severe systemically.
GASOLINE
Permissible Exposure Limit
300 ppm ACGIH TLV
Gasoline is initating to the skin, eyes and mucous membranes. Dermatitis may result from
prolonged contact with the liquid. Gasoline acts as a central nervous system depressant.
Exposure may cause staggering gait, sluned speech and mental confusion. Gasoline exposute
may affect the liver, kidneys and spleen. Absorption of alkyl lead antiknock compounds
contained in many gasolines poses an additional health concem, especially wherc there is
prolonged skin contact.
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
Page 6
DIESEL FUEL (No.2-D)
Permissible Exposure Limit
400 ppm OSHA PEL (As petroleum distillates/naphtha)
Diesel fuel is a skin and mucous membmne initant and a central nervous system depressant.
Poisoning may affect the liver and kidneys. Skin contact may result in drying and cracking of the
skin.
FUEL OIL (No. 6)
Permissible Exposure Limit
400 ppm OSHA PEL (as petroleum distillates/naphtha)
0.2 mg/m3 OSHA PEL (CoalTar Pitch Volatiles, "PNA'S")
Fuel oil No. 6, or "Bunker Fuel", may be initating to the eyes and skin. Poisoning may affect the
liver, kidneys and digestive system. This substance is likely to contiain polynuclear aromatic
hydrocarbons (PNA's), some of which are considered carcinogenic. PNA's present a skin
contact hazard. Avoid skin contact with potentially contaminated site materials.
7.2 Phvsical Hazards
Activities to be performed on site may involve drilling equipment and materials. Personne!
should be aware that as personal protective equipment increases, dexterity and visibility may be
impacted and performing some tasks may be more difficult. Tape all loose protective clothing to
avoid entanglement in rotating equipment. Before drilling proceeds, underground utilities must
be located and marked. Other drilling safety precautions to be observed during this assessnent
include the following:
o All personnel working around drill rigs will be familiarized with emergency shutdown
procedures and the position of "kill" switches.
o No loose fitting clothing, jewelry or unsecured long hair is permitted near the rig.
. Keep hands and feet away from all moving parts while drilling is in progress. Shovel auger
cuttings with long handled shove!. DO NOf use hands or feet.
o Daily inspection of all ropes, cables and moving parts is mandatory.
. A first aid kit and fire extinguisher will be immediately available at all times.
o All drill crews shall consist of at least two persons.
o No drilling is permitted during impeding electrical storms, tornadoes or when rain creates a
hazardous work environment.
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
PageT
o A minimum horizontal and vertical clearance distance of 10 feet must be maintained
between the drill rig and overhead power lines; use spotters to help rig operator maneuver
the vehicle when near overhead power lines.
Other physical hazards which may be present on this project site include:
Back injuries due to improper lifting - Use proper lifting techniques. Lift with the legs, not
the back. Keep loads close to the body and avoid twisting. Loads heavier than 50
pounds (lbs) require a second person or mechanical device for lifting. Use mechanical
devices such as drum dollies, hand trucks, and tool hoists (for lifting augers) to lift or
move heavy loads whenever possible.
Ergonomic Stress - Lift carefully with load close to body with the legs taking most of the
weight. Get help with lifts greater than 40 lbs. When working with a heavy tool or object,
keep legs under the load and do not overreach or twist to the side. Reposition body to
be more square to the load and work. Push loads, rather than pull, whenever feasible.
Do not persist with lifting when the load is too heavy. Use a mechanical lifting aid or
have a coworker assist with the lift. Rotate repetitMe tasks to avoid soft-tissue fatigue.
Falls From Elevated Surfaces - Protect employees from falling off surfaces that have a
side or an edge that is 6 ft or more above a lower level. Provide a safety harness and
shock-absorbing lifeline or adequate fall protection where applicable. Employees must
wear them when woking 6 ft or higher above the platform or main work deck. lnstall
either a guardrail system or fall arrest system that conforms to 29 CFR 1926.502 (d) and
is approved by the American National Standards lnstitute.
Fire and Explosion - Make ABC fire extinguishers accessible in the work area. Store
flammables in Underwrite/s Laboratory and Occupational Safety and Health
Administration (OSHA) approved metal safety cans equipped with spark arrestors. Store
flammable containers more than 50 ft from possible ignition sources. Keep exhaust
equipment powered by internal combustion engines well away from flammables and
combustibles. Secure hot work permits/approvals before welding or cutting. Store and
use compressed gases in a safe manner. Never refuel equipment (e.9., genenators)
while it is in operation or hot enough to ignite fuel vapors. Conspicuously mark
operations that pose fire hazards "No Smoking' or "Open Flames." Remove trash,
weeds, and unnecessary combustibles from the Exclusion Zone (EZ). Transfer of
potentially flammable liquids will be conducted with intrinsically safe pumping equipment.
Drums will be bonded and grounded prio_r to transfer of potentially flammable liquids.
Vehicles - Obey all site traffic signs and speed limits. Seat belts must be functional and
in use during operation of any site vehicles (including rentals). Operator shall regularly
inspect the vehicle for defective parts, such as brakes, controls, motor, chassis and
drives. Always be aware and stay alert to traffic around the work area.
lnclement Weather - The project may be shutdown by the SSO during the following
inclement weather conditions: poor visibility; precipitation severe enough to impair safe
movement or travel; lightning in the immediate area; steady winds in excess of 40 mph;
Site Safety and Health Plan
Former AST and Surface Spil! Areas
Terracon Project # 86127 103
Page 8
or, other conditions as determined by the SSO or Corporate Safety and Health Manager.
Work will resume when the conditions are deemed safe by the SSO.
. Noise - Wear hearing protection when speech becomes difficult to understand at a
distance of 10 ft and while standing within 20 to 25 ft from heavy equipment, pneumatic
power tools, steam cleaners, and other equipment in operation that can generate more
than 85 decibels (A-weighted scale) (dBA).
. Slips, Trips, and Falls - Clear work area of obstructions and debris before setting up.
Alter work areas as necessary to provide a safe, reasonably level area. All walking and
working surfaces shall mntinually be inspected and maintained to be free of slip, trip,
and fall hazards. Keep platforms, stairs, and immediate work areas clear. Do not allow
oil, grease, or excessive mud to accumulate in these arcas. Eliminate slip, trip, and fal!
hazards or identify them clearly with caution tape, barricades, or equivalent means.
Store loose or light material and debris in designated areas or containers. Secure tools,
materials, and equipment subject to displacement or falling.
o Traffic Control - lf site activities interrupt the normal flow of pedestrian or vehicular traffic,
banicades and waming signs which comply with the Manual on Unifonn Traffic Control
Devices and/or State or local ordinances will be erected around affected equipnrent.
Safety omnge work vests will be wom by personnel working within 10 feet of any active
roadway. All borings or partially completed groundwater monitoring wells will be
adequately epvered and/or barricaded if left unattended for any period of time.
8.0 SITE CONTROL
An Exclusion Zone, Contaminant Reduction Zone and a Support Zone will be established
whenever project activities require Level C or Level B personal protective equipment. Defined
access and egress points will be established and personnel will enter only through those points.
As permitted by site topography, the area within a 50 foot radius of a drill rig and 100 foot radius
of UST removal excavation shall be considered the Exclusion Zone. Only those personnel
designated by the Project Manager/SSO are allowed to enter the Exclusion Zone. Where
practical, or where their use will prevent public injury, temporary signs or barricade fencing will
be established to define the Exclusion Zone. ABSOLUTELY NO SMOKING WILL BE
PERMITTED WITHIN THE EXCLUSION OR CONTAMINANT REDUCTION ZONES ON ANY
PETROLEUM CONTAMINATED SITE.
!f unauthorized personnel attempt to enter the exclusion zone, the SSO will verbally inform the
individual(s) to leave the project site. lf unauthorized individuals refuse to leave the Exclusion
Zone or are considered in danger or pose danger to project personnel, the SSO will cease
project activities (i.e., shut down drill rigs, excavation equipment, etc.) and notify the client
representative or the local police of the situation. Site activities will not resume until
unauthorized personnel have left the project site.
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
Page 9
9.0 AIR MONITORING AND SITE ACTION LEVELS
This air monitoring protocol is designed to prevent personnel exposure to airborne contraminants
in exoess of established permissible exposure limits. The results of field air monitoring will be
used to determine the continued adequacy of initial personal protective equipment.
Air monitoring equipment required for petroleum contaminated sites will include the following:
r PhotoionizationDetector
Task Leader(s) will be knowledgeable in the operation of the photoionization detec*or. A
manual on the operation of the PID and the appropriate calibration kit will be mobilized to the
project site with the instrument. Photoionization detectorc will be calibrated under field
conditions each day prior to use. Task Leaders are instructed to consult the manufacture/s
specifications for appropriate calibration gas and calibration techniques.
A photoionization detector (PlD) will be used to determine approximate hydrocarbon vapor
conentrations in the BREATHING ZONE of site personnel. Continuous breathing zone air
monitoring will be conducted during initial phases of intrusive activities (i.e., boring, excavation).
lf PID readings are less than 10 ppm, monitoring may be conducted at intervals of 10 minutes.
lf initial PID readings exceed 10 ppm, or if hydrocarbon odors become evident upon during
auger advancement, continuous breathing zone air monitoring will be conducted..
lf sustained PID readings in the breathing zone exceed 25 ppm, personnel will upgrade to
respiratory protection as outlined below. Personnel will remain in air purifying respirators until
the photoionization detector readings in the breathing zone have fallen and stabilized below 25
ppm.
9.1 Site Action Levels
lnstrument
PID
Level D/D Mod LevelG Site Evacuation
> 300 ppm< 25 ppm > 25 ppm
The Action Levels indicated above are for air in the breathing zone and NOT applicable to vapor
above containerized soil samples. The Action Levels are established to prevent exposure to
airborne petroleum hydrocarbon vapors in excess of established exposurc limits. Although the
Action Levels indicated for Site Evacuation are within the protective capacity of the respinator
cartridges specified below, personnel will evacuate to the UPWIND side of the site if the
continuous breathing zone vapor concentrations exceed these limits. The SSO will contact the
Corporate Safety and Health Manager for discussion and re-evaluation of personal protective
equipment and air monitoring requirements if airbome contamination exceeds Site Evacuation
Action Levels. ln the event that site evacuation is required, a modification of this safety and
health plan will be issued with contingencies for combustible gas monitoring and upgrading to
Level B personal protective equipment.
THIS PLAN IS NOT VALID FOR LEVEL B SITE ACTIVITIES.
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
Page 10
1O.O PERSONAL PROTECTIVE EQUIPMENT REQUIREMENTS
The air monitoring regimen identified above will allow initial project activity to begin in LEVEL D
personal protective equipment to include:
o Hard Hat
. Chemically Protective Safety Boots (Hazmax, other as approved by S&H Mgr.)
o Nitrile, Neoprene Rubber or Silver Shield Outer Gloves
. Nitrile or Latex lnner Liners
. Safety Eye Wear (ANSI Z-87 approved)
. Hearing Protection (if within 10 feet of dri!! rigs, concrete coring or other equipment
which impairs normal conversation at < 5 feet.)
lf petroleum saturated soils and potential splashing conditions devebp during the cource of the
asseSSrnent,personnelwi|lupgradeto@persona!protectiveequipment.
Leve! D Modified personal protective equipment ensemble consists of the above, plus:
. Polylaminated Tyvek Goveralls
. Tape Sleeves/Legs to Gloves and Boots
lf air monitoring exceeds Action Level specified for upgrade to LEVEL C personal protective
equipment, personnel will don:
o Full Face Air Purifying Respirator
. Equipped with Combination Organic Vapor/Acid Gas/HEP.A Cartridges
11.0 DECONTAMINATION
Equipment decontamination is necessary on all petroleum hydrocarbon sites. Perconnel
decontamination for projects below personal protective Level C will consist of washing off safety
footwear, proper cleaning or disposal of outer and inner gloves and thorough washing of face,
arms and hands. A full body shower will be required as soon as possible upon leaving the
p$ect site, For projects involving Level C perconal protective equipment, a decontiamination
station will be established and the following procedures enforced.
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
Page 11
11.1 PersonalDecontamination
Personnel will establish a decontamination station
Contaminant Reduction Zone will be established
decontamination station.
on the interface of the Exclusion Zone. A
and will extend 10 feet beyond from the
o Two Wash Tubs. Scrub Brusho Plastic Bagso Waterand Alconox Detergent
The wash tub on the exclusion zone side of the site will contain a solution of water and Aloonox
detergent; the second wash tub will contain clean rinse water. Personnel decontamination will
consist primarily of detergent washing and rinsing of reusable exterior protective gear.
Coverclls will be rernoved by turning the clothing inside out.
Perconnel may not leave the contaminant reduction zone without proceeding through the
decontamination sequence described below. Decontamination station will consist of:
. Wash work gloves, boots and polylaminated protective coveralls,
o Rinse work gloves, boots and coveralls,
. Remove tape at wrists and ankles,
. Remove protective coveralls,
o Remove respirator
. Dispose of spent cartridges; wash and rinse respinator
. Remove outer gloves
. Remove inner gloves
Expendable personal protective equipment will be placed in plastic trash bags, sealed and
disposed of per client agreement. Decontamination solutions will be containerized or disposed
of as ananged by Project Manager.
11.2 Equioment Decontamination
Decontamination of equipment will be performed to limit the migration of contaminants off-site.
All equipment will be cleaned prior to site entry to remove grease, oil and encrusted soil.
Decontamination of large equipment will consist of physically removing gross contamination with
shovels, brushes etc. followed by detergent and water high pressure wash with a clean water
rinse. The Project Manager is responsible for determining if decontamination solutions must be
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
Page 12
containerized. lf so, a decontamination sump or polyethylene sheeting and fluid containers will
be mobilized and established in the decontamination area. Deepntamination of hand samplers
and similar small equipment will be performed at a designated location within the Contaminant
Reduction Zone. Decontamination of such equipment will consist of detergent solution wash
and clean water rinse.
12.0 STTECOMMUNTCATTONS
Communication between personnelwithin the Exclusion Zone will be via verbal communication
or hand signals. Visual contact between members of task teams should be possible throughout
the course of project activities. Contact with the SSO will be through direct verbal
communication. The following hand signals will be used by personnel wherever rcspiratory
protection and/or equipment noise limit verbal communication.
Sional Meanino
Thumbs Up OK, all is well
Grab throat with both hands Can't breathe
Shake head, thumbs down NO, negative
Point right (when facing equipment operator) Move/steer left
Point left when facing equipment operator) Move/steer right
Grab partner's wrist Leave area immediately
13.0 EMERGENCYRESPONSEPROCEDURES
The Project Manager is responsible for obtaining and recording the following emeqency
information prior to site mobilization:
Location of Nearest Telephone: No telephone service onsite. Emplovees must have
Terracon or personal cell phone with them onsite at all times.
Nearest Hospital/Ctinic: Watauoa MedicatCenter Phone: [phone]
Estimated Drive Time: 5 minutes
Directions From Site: Turn risht onto Greenwav Road and head east (Greenwav
becomes Leola Street). Turn left on Pride Drive and head north. Turn riqht onto Blowinq
Rock Road (US-221IUS321) and head southeast. Turn left onto Deerfield Road. proceed
approximatelv 0.2 miles. hospital is on risht hand side of road.
Ambulance: 911
Fire Department: 911
Police: 911
Poison ControlGenter: FAAO-222-1222
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
Page 13
Project Manager:
Safety and Health Manager:
Glient Contact:
864-2e2-2e01 (O)
704-614-4054 (M)
913-599-6886
336-877-7357 (Jim Milam mobile)
13.1 Personal lniurv
The SSO and at teast one other individual on site will be appropriately trained to administer first
aid. A certificate issued by the American Red Cross, National Safety Council or equivalent will
be considered acceptable.
For minor injuries, such as cuts, burns, exhaustion, heat cramps, insect stings, etc., the affected
employee will be removed to an uncontaminated area. The SSO or other designated employee
trained in first aid procedures will administer appropriate first aid. lf the injury wanants additional
medicalattention, the affected employee will be properly decontraminated and transported to the
nearest hospital or emergency medical facility.
For more serious injuries the Site Safety Officer or designee will summon an ambulance to the
pQect site. No attempt will be made by Terracon personnelto move the victim, without the aid
and/or instructions of qualified medical personnel.
Where air monitoring indicates the absence of toxic gases or vapors, the ambulance will be
directed to the affected employee. lf site conditions wanant and as time permits, the wheels of
the ambulance will be decontiaminated with high pressure wash. The SSO or designee will
accompany the ambulance to the medical facility, and provide guidance coneerning additional
decontamination which may be required for the injured employee, ambulance or attendants.
Whenever an injury occurs on sites with contamination requiring personal protective equipment
greater than Level D modified, a minimum of two employees will don appropriate equipment and
proceed to the victim. An ambulance will be called immediately. lf the extent of injuries permit,
the injured employee will be removed to fresh air. Appropriate first aid will be administered.
lf rescuer(s) assess that the victim cannot be removed without a stretcher or other specialized
equipment, the victim will be removed at the earliest possible moment by appropriately attired
Tenacon personnel with the direction and/or assistance of qualified medical response
personnel. The injured employee will be immediately decontaminated and transported to the
nearest medicalfacility. A crew member designated by the SSO will inform the ambulance crew
of contaminants of con@rn and provide assistance with additional decontamination if required.
13.2 Evacuation and Shutdown Procedures
The SSO will establish and notify site personnel of emergency "rally" points. ln the event of a
site emergency, personnel will immediately exit the site and assemble at the designated rally
point. Evacuation routes will be dependent on site topography and wind conditions. The routes
will be selected and presented by the SSO daily prior to site activity.
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
Page 14
lf emergency evacuation becomes nec€ssary, the SSO will sound the emergency alarm (e.9.
support vehicle horn or compressed air hom). Personnel will safely shutdown all electrical and
mechanical equipment and quickly proceed to closest designated rally point. The SSO willthen
account for each crew member on site.
ln the event that a Terracon employee does not report to the designated rally point within 5
minutes of the evacuation alarm, the SSO will perform an immediate assessment of site
conditions. lf site conditions do not pose an immediate hazard to life or health, the SSO will
initiate search and rescue efforts utilizing two crew members attired in appropriate personal
protective equipment.
14,0 HEAT STRESS
14.1 @
Whenever ambient temperature exceeds 70 degrees F and personal protective equipment
requirements are Level D or Level D modified, the following heat stress monitoring and
preventive measures will be implemented.
At least one gallon of water will be available for each field employee during each day of site
activity. The designated Site Safety Officer and one designee will observe personnelfor signs of
heat stress (excessive percpiration, flushed skin, nausea, etc.).
lf such signs are observed, affected workers will be required to leave the contaminant zone,
loosen protective clothing and rest. During the rest period affected personnel will drink at least
one 8 oz. glass of cool water. Pulse will be checked at the beginning of the rest period.
Personnelwill not return to work until pulse rate is less than 90.
14.2@
ln addition to the above precautions, the following procedures will be implemented whenever
the ambient temperature exceed 70 degrees F and personal protective equipment requirements
are Level C or above. Ambient temperature will be measured with a dry bulb thermometer and
percent cloud cover will be estimated:
1.0 = No Clouds
0.75 = 25% Clouds0.5 = 50o/o Clouds
0.25 = 75% Clouds0.0 = 100o/o Clouds).
Calculate the adjusted temperature using the following formula:
ADJUSTED TEMPERATURE = 13(% CLOUD COVER) + DRy TEMPERATURE
Rest regimens and physiological monitoring (oraltemperature and radial pulse) willbe
implemented at frequencies dependent upon adjusted temperature.
Site Safety and Health Plan
Former AST and Surface Spill Areas
Terracon Project # 86127 103
Page 15
Adiusted Temperature
90+
87.5-90
82.5-87.4
77.5-82.5
70.5-77.4
Rest Period/Monitorino Frequencv
After 15 minutes
After 30 minutes
After 60 minutes
After 90 minutes
After 120 minutes
Employees will return to work only after oral temperature is below 99.7 degrees F and pulse rate
< 90. Fluid replacement will be encouraged during each rest period. The use of stimulants and
alcoholic beverages in off hours will be discouraged.
15.0 COLD STRESS
Percons working outdoors in low temperatures, especially at or below freezing are subiect to
cold stress. Exposure to extreme cold for a short time can cause severe injury to the surface of
the body or result in profound gener:alized cooling which, in extreme cases, can lead to coma
and death. Areas of the body which have high surface area, such as fingers, toes and ears are
most susceptible.
Protective clothing generally does not provide protection against cold stress. ln many instiances
it may increase susceptibility due to excessive perspiration which can rapidly cool the body
when exposed to cold, windy conditions. The greatest incremental increase in wind chill occurs
when a wind of 5 mph increases to 10 mph. And, because water conducts heat approximately
240 times faster than air, the body will cool rapidly when chemical protective equipment is
removed if undergarments are saturated with perspiration.
Whenever ambient temperatures are expected to be below freezing, Tenacon personnel will
consult the cold strcss section of the Tenacon Safety and Health Policy and Procedures Manual
to re-familiarize themselves with signs, symptoms and treatment of cold injuries. Thermal boot,
glove and hard hat liners will be mandatory for all personnel conducting field activities in
ambient temperatures below freezing.
ACKNOWLEDGMENT OF INSTRUCTION
All Terracon personnel are required to sign the following acknowledgment of instruction form
prior to conducting project activities. This acknowledgment is not a waiver. lt is the primary
method used in compiling environmental experience and contaminant exposure records for
Terracon personnel. Upon written request, a copy of your environmental work record will be
provided by the Corporate Safety and Health Manager.
I underctand that this project involves the removal of soil containing petroleum hydrocarbon
contamination from the subject site. I have read this Safety and Health Plan and have received
instructions for safe work practices, personal protective equipment and air monitoring
requirements. I further understand that if I encounter unanticipated contamination ! am to leave
the site and immediately notify the Project Manager and Corporate Safety and Health Manager
of conditions disovered.
PROJECT NAME: lnternational Resistive Comoanv. !nc.
TERRACON JOB #: 86127 103
Name (Please Print)Sisnature Date
PERSONAL PROTECTIVE EQUIPMENT UTILIZED:
LEVEL D LEVEL D MOD.LEVEL C
Safety briefing performed by:
PETROLEUM CONTAMTNANT(S):
Date:
AIR MONITORING RESULTS (Attach separate page if required.)
Appendix B
Notice of Regulatory Requirements (NORR)
q
&
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue, Govemor Division of Waste Management Pee FrejeT?n, Secretary
UST Section - Dexter R. Matlhews, Director
September ll,2012
Mr. Jim Milam
IRC
736 Greenway Road
Boono, North Carolina 28607. I 860
Re: Notice of Regulatory Requiremonts
l5A NCAC 2L .0106(c) and (h)
Corective Action
International Resistive Company
736 GreenwayRoad
Boone, Watauga County, North Carolina
IncidentNumber: 95191
Ranking: High
Dear Mr. Milam:
,
firc Comprehensive Asssssment Report received on June 27,2012 has been revievied by ttre UST
$ection, lVinston-Salem Regional Office. The rpview indicates that conective action is nrircessary to
remediate environmental contamination, You are required to comply with the assessment and oleanup
requirements of Title l5A NCAC 2L .0106(c) and2L.0l06(h). A Conective Action Plan (CAP) with a
schedule for implementation of the CAP prepared in accordance with these requirements and tho most
recont version of the IJST Section Gutdelines for the Invesligation and Renediation o! Contamination
from Non-US? Petrolewn Releases must be received by this office within 60 days of the date of this
notice. Failure to implement the plan and sohedule in the manner and time specified may result in tho
assessment of civil penalties and/or the use of other enforcement mechanisms.
Besouse a release or discharge has been confirmed, a Licensed Ceologist or a Professional
Engineer, certified by tho State of North Carolina, is required to preparc and certify all reporls submitted
to the Department in accordance with l5A NCAC 2L ,0103(e) and 2L.01I l(b).
If you have any questions regarding the actions that must be taken or the rules mentioned in this
letter, please contact me at the address or telephone number listed below,
Sincerely, L/
1nut-l-adLm,L)y^--'
Carin Lee Kromm, L.G.
UST Regional Supervisor
Winston-Salem Regional Oflice
og: Watauga County Health Department
USTRegional Offices
Achevlllc (ARO) - 2090 US Hlglrway 70, Swrnnanos NC 28?78 (828) 296-{500
I
a
Notice of Regulatory Requirements September I I , 201 2
Intemational Resistive Co, Boone, ll/atauga County, NC Page 2
IncidentNo.95l9l
UST Regional Offices
Asheville (ARO) - 2090 US Highway 70, Swannano4 NC 28778 [phone]
Fayetteville (FAY) - 225 Green Street, Suite 714, Systel Building, Fayetteville, NC 28301 [phone]
Mooresville (MOR) - 610 East Center Avenue, Suite 301, Mooresville, NC 281l5 [phone]
Raleigh (RRO) - 1628 Mail Service Center, Raleigh, NC 27699 [phone]
Washington (WAS) - 943 Washington Square Mall, Washington, NC 27889 (252)9464481
Wilmington (WIL) - 127 Card;nal Drive Extension, Wilmington, NC 28405 [phone]
Wineton-Salem (WS) - 585 Waughtor,r,n Street, Winston-Salem, NC 27107 (336) 77f -5000
Guilford County Environmental llealth, 400 West Market Street, Suite 300, Greensboro, NC 27401, 836) 641-3771