20070618 Ver 1_More Info Received_20070413

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Office Use Only: Form Version March OS
USAGE Action ID No. nWQ No. 0 7 0 6 1 8
(If any particular item is not applicable to this project, please enter "Not Applicable" or "N/A".)
I. Processing
Check all of the approval(s) requested for this project:
X Section 404 Permit ^ Riparian or Watershed Buffer Rules
^ Section 10 Permit ^ Isolated Wetland Permit from DWQ
X 401 Water Quality Certification ^ Express 401 Water Quality Certification
2. Nationwide, Regional or General Permit Numbers} Requested: NWP #27 & GC3626; NWP
#38 & GC3637.
3. If this notification is solely a courtesy copy because written approval for the 401 Certification
is not required, check here: ^
4. If payment into the North Carolina Ecosystem Enhancement Program (NCEEP} is proposed
for mitigation of impacts, attach the acceptance letter from NCEEP, complete section VIII,
and check here: ^
5. If your project is located in any of North Carolina's twenty coastal counties (listed on page
4), and the project is within a North Carolina Division of Coastal Management Area of
Environmental Concern (see the top of page 2 for further details), check here: ^
- ~,
IL Applicant Information `'' ~'
1. Owner/Applicant Information ~xi~ ~ '}~
Name: Blue Ridge Plating Superfund Site - US EPA ~~ ~ ~~ ~ ~'-`~`' /
Mailing Address: 61 Forsyth St., SW, 11~' Floor
Atlanta, GA 30303 ~~ ~, ,r ~.~~,~~k.4
Attn: Jon Bornholm
Telephone Number: 404-562-8820 Fax Number:
E-mail Address: bornholm.jan~amail.epa.~ov
2. Agent/Consultant Information (A signed and dated copy of the Agent Authorization letter
must be attached if the Agent has signatory authority for the owner/applicant.)
Name: Steve Mangum
Company Affiliation: CMC, Inc.
Mailing Address: 1151 Jessamine Station Road
Nicholasville, KY 40356
Telephone Number: 859-885-4955 Fax Number: 859-885-4688
E-mail Address: cmcsmangum(cr~,aol.com
Page 5 of 13

III. Project Information
Attach a vicinity map clearly showing the location of the property with respect to local
landmarks such as towns, rivers, and roads. Also provide a detailed site plan showing property
boundaries and development plans in relation to surrounding properties. Both the vicinity map
and site plan must include a scale and north arrow. The specific footprints of all buildings,
impervious surfaces, or other facilities must be included. If possible, the maps and plans should
include the appropriate USGS Topographic Quad Map and NRCS Soil Survey with the property
boundaries outlined. Plan drawings, or other maps may be included at the applicant's discretion,
so long as the property is clearly defined. For administrative and distribution purposes, the
USAGE requires information to be submitted on sheets no larger than 11 by 17-inch format;
however, DWQ may accept paperwork of any size. DWQ prefers full-size construction
drawings rather than a sequential sheet version of the full-size plans. If full-size plans are
reduced to a small scale such that the final version is illegible, the applicant will be informed that
the project has been placed on hold until decipherable maps are provided.
1. Name of project: Blue Ridge Plating Superfund Site
2. T.LP. Project Number or State Project Number (NCDOT Only)
NA
3. Property Identification Number (Tax PIN): 964420914534
4. Location
County: Buncombe Nearest Town: Arden, NC
Subdivision name (include phase/lot number): NA
Directions to site (include road numbers/names, landmarks, etc.): Take exit 40 (Airport
Rd./SR 280) off I-26 South of Asheville, NC. Travel east on Airport Rd./SR 280 to Bradley Branch
Rd., Turn left on Bradley Branch and travel to Glenn Bridge Rd., Turn right on Glenn Bridge ad site
is located at 171 Glenn Bridge Road.
5. Site coordinates (For linear projects, such as a road or utility line, attach a sheet that
separately lists the coordinates for each crossing of a distinct waterbody.)
Decimal Degrees (6 digits minimum): 35.46267 °N 082.52809 °W
6. Property size (acres): 3.06 Ac. (Buncombe Counter 2003)
7. Name of nearest receiving body of water: Lake Julian
8. River Basin: French Broad River Basin
(Note -this must be one of North Carolina's seventeen designated major river basins. The
River Basin map is available at http:!!h?o.enr.state.nc.us,~adriin%maps%.)
9. Describe the existing conditions on the site and general land use in the vicinity of the project
at the time of this application:_ .The area behind the facility is forested with an unnamed
tributary passing through. The unnamed tribu discharges into Lake Julian 1,845 feet
downstream. The area surrounding the site is light industrial and residential.
Page 6 of 13

10. Describe the overall project in detail, including the type of equipment to be used:
See attached Work Plan
11. Explain the purpose of the proposed work: Contaminated soil remediation (cleanup of
hazardous and toxic waste) as authorized and funded by CERCLA
IV. Prior Project History
If jurisdictional determinations and/or permits have been requested and/or obtained for this
project (including all prior phases of the same subdivision) in the past, please explain. Include
the USACE Action ID Number, DWQ Project Number, application date, and date permits and
certifications were issued or withdrawn. Provide photocopies of previously issued permits,
certifications or other useful information. Describe previously approved wetland, stream and
buffer impacts, along with associated mitigation (where applicable). If this is a NCDOT project,
list and describe permits issued for prior segments of the same T.I.P. project, along with
construction schedules. NA
V. Future Project Plans
Are any future permit requests anticipated for this project? If so, describe the anticipated work,
and provide justification for the exclusion of this work from the current application.
None Anticipated
VI. Proposed Impacts to Waters of the United States/Waters of the State
It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to
wetlands, open water, and stream channels associated with the project. Each impact must be
listed separately in the tables below (e.g., culvert installation should be listed separately from
riprap dissipater pads). Be sure to indicate if an impact is temporary. All proposed impacts,
permanent and temporary, must be listed, and must be labeled and clearly identifiable on an
accompanying site plan. All wetlands and waters, and all streams (intermittent and perennial)
should be shown on a delineation map, whether or not impacts are proposed to these systems.
Wetland and stream evaluation and delineation forms should be included as appropriate.
Photographs may be included at the applicant's discretion. If this proposed impact is strictly for
wetland or stream mitigation, list and describe the impact in Section VIII below. If additional
space is needed for listing or description, please attach a separate sheet.
1. Provide a written description of the proposed impacts: The unnamed tributary must be
Page 7 of 13

temporarily diverted to facilitate removal of metals contaminated soils. The forested wetland
area must be cleared to allow for removal of these soils. The Eco Risk Assessment 2006
concluded that sampled sediments in the tributary and soils in the wetlands area showed toxicit~to
Invertebrate Aquatic life. Additionally, data collected and available onsite documents
contamination in the tributary sediments and wetlands area.
2. Individually list wetland impacts. Types of impacts include, but are not limited to
mechanized clearing, grading, fill, excavation, flooding, ditching/drainage, etc. For dams,
se aratel list im acts due to both structure and floodin .
Wetland Impact Type of Wetland Located within Distance to Area of
Site Number Type of Impact (e.g., forested, marsh, 100-year Nearest Impact
(indicate on map) herbaceous, bog, etc.) Floodplain Stream (acres)
( es/no) (linear feet)
1 Temp. Stream Forested No 0 < 1/10
Diversion (+/- 150 feet) Acre
2 Temp. Stream Forested No 0 < 1/10
Diversion (+/- 150 feet) Acre
Temp. Diversion of < 1/10
3 combined Stream (+/- Forested No 0 Acre
250 feet)
4 Timber Clearing Forested No 0 Approx.
I Acre

Total Wetland Impact (acres) +/- 1
Acre
3. List the total acreage (estimated) of all existing wetlands on the property:l %2 - 2 Acres
USACE Designated Wetlands
4. Individually list all intermittent and perennial stream impacts. Be sure to identify temporary
impacts. Stream impacts include, but are not limited to placement of fill or culverts, dam
construction, flooding, relocation, stabilization activities (e.g., cement walls, rip-rap, crib
walls, gabions, etc.), excavation, ditching/straightening, eta If stream relocation is proposed,
plans and profiles showing the linear footprint for both the original and relocated streams
must be included. To calculate acreage, multiply length X width, then divide by 43,560.
Stream Impact Perennial or Average Impact Area of
Number Stream Name Type of Impact Intermittent? Stream Width Length Impact
(indicate on ma) Before Im act (linear feet) (acres)
1 Unnamed Temp. Stream perennial 2 - 3" +/- 150' •0009
Diversion Acres
2 Unnamed Temp. Stream perennial 5 - 7" +/- 150' •002
Diversion Acres
3 Unnamed Temp. Diversion of perennial 5 - 7" +/- 250' •0033
combined Stream Acres

Total Stream Impact (by length and acreage) .0062
Acres
Page 8 of 13

5. Individually list all open water impacts (including lakes, ponds, estuaries, sounds, Atlantic
Ocean and any other water of the U.S.). Open water impacts include, but are not limited to
fill, excavation, dredging, flooding, drainage, bulkheads, etc.
Open Water Impact

Site Number
(indicate on ma)
Name of Waterbody
(if applicable)

Type of Impact Type of Waterbody

(lake, pond, estuary, sound, bay,
ocean, etc.) Area of

Impact
(acres)
NA

Total Open Water Impact (acres)
6. List the cumulative impact to all Waters of the U.S. resulting from the proiect:
Stream Impact (acres): .0062
Wetland Impact (acres): +/- 1.0
Open Water Impact (acres): 0
Total Impact to Waters of the U.S. (acres) 0
Total Stream Impact (linear feet): +/- 1
7. Isolated Waters
Do any isolated waters exist on the property? ^ Yes X No
Describe all impacts to isolated waters, and include the type of water (wetland or stream) and
the size of the proposed impact (acres or linear feet). Please note that this section only
applies to waters that have specifically been determined to be isolated by the USACE.
8. Pond Creation
If construction of a pond is proposed, associated wetland and stream impacts should be
included above in the wetland and stream impact sections. Also, the proposed pond should
be described here and illustrated on any maps included with this application.
Pond to be created in (check all that apply): ^ uplands ^ stream
Describe the method of construction (e.g., dam/embankment, excavation,
draw-down valve or spillway, etc.):
Proposed use or purpose of pond (e.g., livestock watering, irrigation, aesthetic, trout pond,
local stormwater requirement, etc.):
Current land use in the vicinity of the pond:
Size of watershed draining to pond: Expected pond surface area:
VII. Impact Justification (Avoidance and Minimization)
Specifically describe measures taken to avoid the proposed impacts. It may be useful to provide
information related to site constraints such as topography, building ordinances, accessibility, and
financial viability of the project. The applicant may attach drawings of alternative, lower-impact
site layouts, and explain why these design options were not feasible. Also discuss how impacts
^ wetlands
installation of
Page 9 of 13

were minimized once the desired site plan was developed. If applicable, discuss construction
techniques to be followed during construction to reduce impacts.
Eco Risk Assessment of 2006 concluded that sampled sediments in the tributary and soils in
the wetlands area showed toxicity to Invertibrate Aquatic life. To minimize disturbance, current
on-going sampling is performed to delineate horizontal and vertical boundaries of contamination
prior to excavating contaminated soils.
VIII. Mitigation
DWQ - In accordance with 15A NCAC 2H .0500, mitigation may be required by the NC
Division of Water Quality for projects involving greater than or equal to one acre of impacts to
freshwater wetlands or greater than or equal to 150 linear feet of total impacts to perennial
streams.
USACE - In accordance with the Final Notice of Issuance and Modification of Nationwide
Permits, published in the Federal Register on January 15, 2002, mitigation will be required when
necessary to ensure that adverse effects to the aquatic environment are minimal. Factors
including size and type of proposed impact and function and relative value of the impacted
aquatic resource will be considered in determining acceptability of appropriate and practicable
mitigation as proposed. Examples of mitigation that may be appropriate and practicable include,
but are not limited to: reducing the size of the project; establishing and maintaining wetland
and/or upland vegetated buffers to protect open waters such as streams; and replacing losses of
aquatic resource functions and values by creating, restoring, enhancing, or preserving similar
functions and values, preferable in the same watershed.
If mitigation is required for this project, a copy of the mitigation plan must be attached in order
for USACE or DWQ to consider the application complete for processing. Any application
lacking a required mitigation plan or NCEEP concurrence shall be placed on hold as incomplete.
An applicant may also choose to review the current guidelines for stream restoration in DWQ's
Draft Technical Guide for Stream Work in North Carolina, available at
http:%1'h2o.enr.state.nc.ushlcwetlands%strmg~ide.html.
Provide a brief description of the proposed mitigation plan. The description should provide
as much information as possible, including, but not limited to: site location (attach directions
and/or map, if offsite), affected stream and river basin, type and amount (acreage/linear feet)
of mitigation proposed (restoration, enhancement, creation, or preservation), a plan view,
preservation mechanism (e.g., deed restrictions, conservation easement, etc.), and a
description of the current site conditions and proposed method of construction. Please attach
a separate sheet if more space is needed.
Following removal of contaminated soils, all disturbed areas will be backfilled and
restored to near pre-existing conditions. Groundcover will be re-established to minimize or
eliminate erosion, per site Work Plan and Erosion Control Plan, and natural re-forestation
will be allowed to occur.
Page 10 of 13

2. Mitigation may also be made by payment into the North Carolina Ecosystem Enhancement
Program (NCEEP). Please note it is the applicant's responsibility to contact the NCEEP at
[phone] to determine availability, and written approval from the NCEEP indicating
that they are will to accept payment for the mitigation must be attached to this form. For
additional information regarding the application process for the NCEEP, check the NCEEP
website at http:!%h2o.enr.state.nc.us%wrp%index.htm. If use of the NCEEP is proposed, please
check the appropriate box on page five and provide the following information:
Amount of stream mitigation requested (linear feet):
Amount of buffer mitigation requested (square feet):
Amount of Riparian wetland mitigation requested (acres):
Amount ofNon-riparian wetland mitigation requested (acres):
Amount of Coastal wetland mitigation requested (acres):
IX.
X.
Environmental Documentation (required by DWQ)
1. Does the project involve an expenditure of public (federaUstate/local) funds or the use of
public (federal/state) land? Yes X No ^
2. If yes, does the project require preparation of an environmental document pursuant to the
requirements of the National or North Carolina Environmental Policy Act (NEPA/SEPA)?
Note: If you are not sure whether a NEPA/SEPA document is required, call the SEPA
coordinator at [phone] to review current thresholds for environmental documentation.
Yes ^ No X
3. If yes, has the document review been finalized by the State Clearinghouse? If so, please
attach a copy of the NEPA or SEPA final approval letter. Yes ^ No ^
Proposed Impacts on Riparian and Watershed Buffers (required by DWQ)
Regional Office may be included as appropriate. Photographs may also be included at the
applicant's discretion.
It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to
required state and local buffers associated with the project. The applicant must also provide
justification for these impacts in Section VII above. All proposed impacts must be listed herein,
and must be clearly identifiable on the accompanying site plan. All buffers must be shown on a
map, whether or not impacts are proposed to the buffers. Correspondence from the DWQ
Will the project impact protected riparian buffers identified within 15A NCAC 2B .0233
(Meuse), 15A NCAC 2B .0259 (Tar-Pamlico), 15A NCAC 02B .0243 (Catawba) 15A NCAC
2B .0250 (Randleman Rules and Water Supply Buffer Requirements), or other (please
identify )? Yes ^ No X
Page 11 of 13

2. If "yes", identify the square feet and acreage of impact to each zone of the riparian buffers.
If buffer mitigation is required calculate the required amount of mitigation by applying the
buffer multipliers.
Zone* Impact
(square feet) Multiplier Required
Miti ation
1 3 (2 for Catawba)
2 1.5
Total
* Zone 1 extends out 30 feet perpendicular from the top of the near bank of channel; Zone 2 extends an
additiona120 feet from the edge of Zone 1.
3. If buffer mitigation is required, please discuss what type of mitigation is proposed (i.e.,
Donation of Property, Riparian Buffer Restoration /Enhancement, or Payment into the
Riparian Buffer Restoration Fund). Please attach all appropriate information as identified
within 15A NCAC 2B .0242 or .0244, or .0260.
Buffer zones will be restored as part of site restoration.
XI. Stormwater (required by DWQ)
Describe impervious acreage (existing and proposed) versus total acreage on the site. Discuss Stormwater
controls proposed in order to protect surface waters and wetlands downstream from the property. If
percent impervious surface exceeds 20%, please provide calculations demonstrating total proposed
impervious level. On-going activities have not and will not alter existing impervious structures/surfaces,
which make up less than 20% of the project site. Silt fences are used on site to retain sediments on site.
Depressions are created up-gradient of the silt fences to act as a sediment retention area. RipRap
structures are installed in the tributary to retard the flow of water and retain sediments on site. Hay bales
are also used in the stream to slow the flow of water and retain sediments, and a former pond located on
the down-gradient side of the site is being used as a sedimentation retention basin
XII. Sewage Disposal (required by DWQ)
Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of
wastewater generated from the proposed project, or available capacity of the subject facility.
All sewage disposal will be performed off-site by a licensed company.
XIII. Violations (required by DWQ)
Is this site in violation of DWQ Wetland Rules (15A NCAC 2H .0500) or any Buffer Rules?
Yes ^ No X
Is this anafter-the-fact permit application? Yes X No ^
XIV. Cumulative Impacts (required by DWQ)
Page 12 of 13

Will this project (based on past and reasonably anticipated future impacts) result in additional
development, which could impact nearby downstream waaer gtutlity? Yes ^ No ^
If yes, please submit a qualitative or quantitative cumulative impact analysis in accordance with
the most recent North Carolina Division of Water Quality policy posted on our website at
:/'h2ca.enr_state_nc.us/ncwetlanc3.~. If no, please provide a short narrative description:
The pranerty is owned by Blue Ridge Plating, which is a private entity
XV. Other Circumstances (Opfional):
It is the applicant's responsibility to submit the application sufficiently in advance of desired
construction dates to allow processing time for these permits. However, an applicant may
choose to list constrei-~ associated with construction or sequencing that may impose limits on
work schedules (e.g., draw-down schedules for lakes, dates associated with Endangered and
Threatened Species, accessibility prablerns, or other issues outside of the applicants comrol).
This site is a Superfund (CERCI.A) project performed and funby US EPA Region IV We
felt that all substantiative requ~,ements of the permitting process bad been met. Expedited
review of this application is requested.
r1S ~Clr4 d y/re /20a~
AppticsntlAgent'g Signatture bath
s signa#tue is valid only if an authorization letter from the applicant is provided.)
Paget 3 of 13

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0 7 0 6 1 8
Erosion and Sedimentation Control Plan
Blue Ridge Plating Site
Arden, Buncombe County, North Carolina
Prepared for:
United States Environmental Protection Agency
Region IV
Atlanta, Georgia
Prepared by:
CMC Environmental Services, Inc.
1151 Jessamine Station Road
Nicholasville, Kentucky
January 4, 2007

6
Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
Table of Contents
1. Narrative
1.1. Project Description
1.1.1. Site Description
1.1.2. Adjacent Property
1.1.3. Soils
1.2. Planned Erosion and Sedimentation Control Practices
1.2.1. Sediment Basin
1.2.2. Temporary Gravel Construction Entrance/Exit
1.2.3. Temporary Block and Gravel Drop Inlet Protection
1.2.4. Temporary Diversions
1.2.5. Level Spreader
1.2.6. Tree Preservation and Protection
1.2.7. Land Grading
1.2.8. Temporary Sediment Trap
1.2.9. Sediment Fence
1.2.10. Sod Drop Inlet Protection
1.2.1 l.Grass-lined Channel
1.2.12. Riprap-lined and Paved Channels
1.2.13. Construction Road Stabilization
1.2.14.Outlet Stabilization Structure
1.2.15. Surface Roughening
1.2.16. Surface Stabilization
1.2.17. Dust Control
2. Construction Schedule
3. Maintenance Plan
4. Vicinity Map
5. Site Topographic
6. Site Development Plan
7. Site Erosion and Sediment Control Plan Drawings
7.1. Tributary Re-routing Drawing
7.2. Sediment/Silt Fence Drawing
7.3. Sediment -Erosion Control Drawing
8. Detail Drawings and Specifications for Practices Specified
8.1. Sediment/Silt Fence Detail
8.2. Straw Bale Detail
9. Re-vegetation Plan
10. Supporting Calculations
11. Financial Responsibility/Ownership Form
2

Blue Ridge Plafing Site Erosion and Sediment Control Plan, T.O. 0060
1. Narrative
l.l. Project Description
The purpose of the project is to remediate approximately 3,800 cubic yards of contaminated soil
located on approximately 1- 1.5 acres of the Blue Ridge Plating (BRP) site. Approximately 1.5
- 2 acres will be disturbed during execution of the scope of work. Two parcels of land are
involved with the project, the Benefield property (primary site) and the Sheppard property
(located immediately to the west). Both parcels tota15.5 - 6 acres. The project site is located at
171 Glenn Bridge Road in Arden, Buncombe County, North Carolina (see vicinity map).
1.1.1. Site Description
The BRP site (Benefield property) is 3.06 acres in size (Buncombe County, 2003). 'The
coordinates of the site are 35° 27' 44" North latitude and 82° 27' 44" West longitude.
The total relief on the contaminated soil portion of the site is about 30 feet, ranging from
the lowest elevation in the southeast corner at approximately 2195 feet above mean sea
level (amsl) to the highest elevation in the northeast corner at approximately 2,225 amsl.
A series of unnamed tributaries flow across the BRP site, through the forested wetlands
and ultimately discharge into Lake Julian located approximately 1,845 feet downstream
of the site. The unnamed tributary flowing through the forested wetland ranges from 1 to
3 feet in width and 0 to 4 inches in depth, with little or no flow. Drainage from the BRP
site enters Lake Julian along one of the western fingers of the lake, where a series of
unnamed tributaries combine and flow into the lake. Lake Julian ultimately drains into
French Broad River. Both Lake Julian and French Broad River are classified and
protected by the State of North Carolina as water supplies suitable for aquatic life
propagation and survival, fishing, wildlife, secondary recreation, and agriculture.
1.1.2. Adjacent Property
Land use in the vicinity is primarily light industrial and residential. The unnamed
tributary leaving the site flows through these areas and into Lake Julian. Sediment
control measures will be taken to prevent damage to Lake Julian. Approximately 95.5
acres are drained from east of the site by the unnamed tributaries that cross the site in a
westerly direction.
1.1.3. Soils
The onsite regolith can be subdivided into three unique strata. Soil, alluvium and
saprolite are distinct soil strata based on geologic origin which have been identified in the
boring logs on onsite monitoring wells. These distinct soil strata are expected to
influence the rate and extent of contaminant migration through cation exchange with the
clay, and variable transmissivities of the silt, sand, and clay:
a. Soil-fill material, historical thickness is approximately 3 to 6 feet of silt
and clay on site.
b. Alluvium-alluvial material, historical thickness is approximately 1 to 4
feet of clay and sand on site.
W
E
3

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
c. Saprolite-residual soil, historical thickness is approximately 3 to 6 feet of
silt above the water table (70 - 84 feet of silt, sand, and clay below the
water table) on site.
Boring logs of the three onsite production wells show bedrock, or thickness of regolith to
extend 82 - 96 feet bls (NCDENR, 1974)
1.2. Planned Erosion and Sedimentation Control Practices
1.2.1. Sediment Basin
CMC does not anticipate using a formal sediment basin as an erosion control measure at
the site due to the potential for encountering/disturbing contaminated soils in the wetland
area. Riprap and or straw bales will be used downstream to retard the flow of water,
allowing it to spread out and reduce potential for sediment migration off site.
1.2.2. Temporary Gravel Construction Entrance/Ezit
Because of the excessive traffic on Glenn Bridge Road, CMC will prepare an area off Glenn
bridge Road for trucks to unload potential stabilizing agents and load trucks with contaminated
soil for offsite disposal. To accomplish this, CMC plans to excavate, sample, and backfill grids
located on the west side of the facility building first. This should provide a safe area to stage
trucks during the load-out process. Gravel and/or excavator mats will be placed to provide anall-
weather surface for entrance/exit. Mulch will be placed and maintained on the down gradient
side of this area to eliminate/minimize sedimentation runoff.
Poly sheeting and/or woven geotextile fabric will be used to keep this area from becoming re-
contaminated during the load out process. If site conditions warrant, CMC may use the same
procedures to prepaze an area for loading out trucks on the East side of the property.
1.2.3. Temporary Block and Gravel Drop Inlet Protection
NOT USED
1.2.4. Temporary Diversions
The unnamed tributaries flowing across the site ranges from 1 to 3 feet in width and 0 to
4 inches in depth, with little or no flow. These tributaries come onto the site from the
east by flowing through 2 - 36" culverts located under the unnamed driveway that
accesses Hobson Construction Co. The 2 tributaries are approximately 150' apart where
they come onto the site and converge together approximately 100' on the property and
inside the limits of anticipated contaminated soil excavation.
As depicted on the site drawing located in Section 8.1, CMC will excavate a shallow
ditch and divert the water flow from the southern most tributary around the backside of
the proposed limits of excavation. This diversion ditch will tie back into the natural
stream just below the proposed limits of excavation. Also this tributary appears to have
the most water flow, with the northern tributary exhibiting minimal flow or seepage.
4

1
4'
Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
Since the northern tributary cannot feasibly or economically be re-routed around the
limits of excavation, it will be straightened out to allow excavation of contaminated soil.
Upon completion of excavation activities, CMC will restore these tributaries to near pre-
disturbance conditions, as further explained in Section 1.2.7.
1.2.5. Level Spreader
NOT USED
1.2.6. Tree Preservation and Protection
All trees located outside the proposed limits of excavation will remain intact and not be
damaged during the soil remediation process.
1.2.7. Land Grading
Following excavation of contaminated soils on approximately 1.6 acres of the site, CMC
will backfill the excavations to near pre-excavation conditions. All disturbed areas will
be graded to match existing contours.
The up-gradient area of the site, towards the building will be graded to eliminate ponding
water and promote sheet flow. The lower wetland area will be graded as close to pre-
project conditions as is practical. Diversion ditches will be backfilled with clean fill and
tributary drainage across the site will be restored to near original condition and location.
Riprap or gravel bars will be placed in the tributaries to retard the flow of water so the
area will remain a wetland.
1.2.8. Temporary Sediment Trap
NOT USED
1.2.9. Sediment Fence
Sediment or Silt fence will be strategically placed immediately at the base of the slope
where the AOC flattens out into the wetland area to capture and hold sediment that may
be washed from the sloped area. Also, a run of sediment/silt fence will be installed
alongside the northern edge of the northernmost tributary to capture sediment prior to
entering the tributary. A drawing depicting placement of the sediment/silt fence is
provided in Section 8.2.
The sediment/silt fence will have to be removed to facilitate contaminated soil excavation
in these areas. Sedirnent/silt fence that is removed to allow for excavation activities will
be replaced prior to any precipitation event.
Since exact vertical and horizontal limits of excavation are unknown at this time, the site
will be constantly monitored for changing conditions that may indicate the need for
adding additional sediment/silt fence, or other protective measures. Poly sheeting will be
used as necessary to cover stockpiled soils to eliminate run-off or erosion.

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
1.2.10. Sod Drop Inlet Protection
NOT USED
1.2.11. Grass-lined Channel
NOT USED
1.2.12. Riprap-lined and Paved Channels
CMC does not anticipate using riprap or paving materials to line any of the small
tributaries located on site. However, if deemed necessary, riprap may be used as a dike
to retard the flow of water in the tributary.
1.2.13. Construction Road Stabilization
Construction road stabilization will consist of an entrance loading area as defined in
Section 1.2.2, Temporary Gravel Construction Entrance/Exit. The haul road used on site
to transport contaminated soils from the wetland area to the staging/stockpile area will be
constructed using excavator mats. The only equipment allowed on this haul road will be
a rubber tracked dump truck, excavator and/or dozer.
1.2.14.Outlet Stabilization Structure
NOT USED
1.2.15. Surface Roughening
NOT USED
1.2.16. Surface Stabilization
Surface stabilization will be accomplished with vegetation and mulch as specified in the
vegetation plan following final grading of the site.
1.2.17. Dust Control
Given the time of the year that the project will take place, it is not anticipated that dust
suppression will be necessary. However, a Model pDR-1000AN/1200 personal DataRam
will be used to monitor far airborne fugitive dust particles during all soil disturbance
activities. Should fugitive dust levels exceed action levels indicated in the Health and
Safety Plan (HASP) for the site, dust suppression may become necessary and will be
performed using the city water supply to the site via garden hoses and sprinklers and/or
hand applied as necessary with garden hoses and fog nozzles.
6

Blue Ridge Plat/ng Site Erosion and Sediment Control Plan, T.O. 0060
2. Construction Schedule
1. Develop project Work Plan
2. Mobilize to and set-up project site
3. Mark all utilities
4. Define Area of Concern (AOC)
5. Define and mark exclusion zone (EZ)
6. Set-up decon
7. Identify and mark existing monitoring wells
8. Sort debris
9. Recycle/salvage scrap metal
10. T&D debris
11. Clear and grub (C&G) approximate 1.6 acre AOC
12. Chip/grind trees into mulch
13. Reroute tributaries
14. Install sedimentlsilt fence
15. Survey property and excavation boundaries
16. Topo AOC
17. Sample AOC's
18. Excavate AOC's
19. Confirmatory sampling of AOC's
20. Treat soils as necessary for disposal
21. T&D liquid drums
22. T&D excavated soils
23. Backfill excavations
24. Grade site
25. Seed, fertilize, and mulch site
26. Decon equipment
27. Demobilize site
28. Return quarterly for 1 year to inspect for erosion problems
7

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
3. Maintenance Plan
3.1. During on-site operations, all erosion and sediment control practices will be
checked for stability and operation following every runoff-producing rainfall
but in no case less than once very week. Any needed repairs will be made
immediately to maintain all practices as designated.
3.2. Sediment will be removed from in front of the sediment/silt fence when it
becomes about 0.5 feet deep at the fence. The sediment/silt fence will be
repaired as necessary to maintain a barrier.
3.3. Mulch and/or straw will be placed in all wash-out areas as they appear.
3.4. Return quarterly for a period of 1 year following completion of on-site
operations to inspect for and correct deficiencies in erosion control
8

~i
Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060 `~~
4. Vicinity Map
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9

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060 `-~~
5. Site Topographic
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10

Blue Ridge Plating Site Erosion and Sediment Control Plan, T. b. 0060 ~.
b. Site Development Plan
There is no known future development anticipated at this time for the project site.
11

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060 ~~~
7. Site Erosion and Sediment Control Plan Drawings
7.1. Tributary Re-routing Drawing
12

~~
Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060 ~' ~~
7.2. Sediment Silt Fence Drawing
13

~~
Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
7.3. Sediment -Erosion Control Drawing
14

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
8. Detail Drawings and Specifications for Practices Specified
8.1. Sediment/Silt Fence Detail
~~
~~~
O. O~~ DiEV.
Sediment Fence Construction Specifications:
1. Construct sediment/silt fence on low side of soil stockpiles, at base of slope, and on
slope side of tributary to prevent sediment from being washed into the tributary.
2. For soil stockpile locations, the fence should extend around approximately 70% of
the perimeter of the stockpile.
3. Locate posts down slope of fabric to help support fencing.
4. Bury toe of fence approximately 6 - 8" deep to prevent undercutting.
5. When joints are necessary, securely fasten the fabric at a support post with overlap to
the next post.
6. Filter fabric to be of nylon, polyester, propylene or ethylene yarn with extra strength
- 50 lb/linear inch (minimum) and a flow rate of at leas 0.3 gal./ft2/minute. Fabric
should contain ultraviolet ray inhibitors and stabilizers.
15

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
8.2. Straw Bale Detail
Stream Bed Plan View
Straw Bales
~I
Straw Bale Side View
Stream Bed T-P st Straw Bale
Straw Bale Construction Specifications:
1. Straw bales are to be used to retard the flow of water in the tributary causing the water to
spread out and slow down allowing sediments to fall out prior to flowing off-site.
2. Straw bales and/or mulch are to be used as a temporary erosion control measure
anywhere washouts are occurring during construction activities.
3. Place straw bales on edge across the tributary, without completely blocking the flow of
water.
4. Two (2) each metal T-post or wooden stakes are to driven in to the straw bales to hold
them in place
16

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
9. Re-vegetation Plan
Prior to re-vegetation, CMC will backfill excavated areas with clean soil suitable for
vegetative growth. During backfill the last 4-6 inches of backfill will remain loose and
un-compacted. Soil samples will be collected and analyzed to determine fertilizer and
lime needs for the backfilled area. Fertilizer and lime will be applied at rates
recommended by these soil tests.
After backfilling, the excavated areas will be seeded with rye grass, or other type of grass
indigenous to the area and suitable to the appropriate growing season, and mulched. For
slopes steeper than 3:1 a hydraulic seeder will be used apply both the seed and fertilizer.
For gentle slopes or flat areas, seed will be applied using a broadcast cyclone spreader
and gently raked into the ground. After seeding, CMC will apply 1001b. / 1,000 ft2 grain
straw cover with secure netting to slopes 3:1 or greater. If seeding is done in spring or
early fall a 451b. / 1,000 ft2 wood fiber mulch will be used. On gentler slopes or flat
areas CMC will apply 90 lb. / 1,000 ft2 wood fiber mulch.
CMC will inspect re-vegetation areas quarterly throughout the following year to confirm
vegetative cover and inspect and repair mulch and netting if applicable. If growth is not
adequate during inspections then a 10-10-10 fertilizer topdressing will be applied.
All restoration and re-vegetation will be conducted in accordance with the North
Carolina Sediment and Erosion Control Planning and Design Manual.
17

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
10. Supporting Calculations
Per the attached topographical drawing, located in Section 5, approximately 95.5 acres of
watershed potentially drains across the project site via the two small tributaries that
converge to form one tributary approximately 150' in on the site.
18

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.O. 0060
11. Financial Responsibility/Ownership Form
The Blue Ridge Plating site is funded and performed under the authority of the
Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986, (SARA), by the United States Environmental Protection Agency (EPA), Region
IV, out of Atlanta, Georgia.
19

Blue Ridge Plating Site Erosion and Sediment Control Plan, T.q. 0060
20

Blue Ridge Plating Site Work Plan, T. 0. 0060
^` ,07 0 61 8
Work Plan
Blue Ridge Plating Site
Arden, Buncombe County, North Carolina
Prepared for:
United States Environmental Protection Agency
Region IV
Atlanta, Georgia 30303
Prepared by:
CMC Environmental Services, Inc.
1151 Jessamine Station Road
Nicholasville, Kentucky 40356
January 4, 2007

Blue Ridge Plating Site Work Plan, T.O. 0060
'~ Table of Contents
1. Introduction
2. Site Background
3. Soil Phase Remedial Activities
4. Resource Requirements
4.1. Equipment
4.2. Labor
4.3. Material
4.4. Subcontractors
5. Description of Remedial Construction Activities
5.1. Mobilization
5.2. Site Prep
5.3. Clearing and Grubbing
5.4. Soil Treatability Study
5.5. Delineation of Area of Excavation
5.6. Contaminated Soil Excavation
5.7. Contaminated Soil Stabilization
5.8. Loading, Transportation, and Disposal
5.9. Backfdling, Grading, and Revegetating
5.10. Site Cleanup and Landscaping
~.,,, 5.11. Demobilization
5.12. O & M
6. Air Monitoring
6.1. Particulate Perimeter Air Monitoring
6.2. Particulate Personnel air monitoring
7. Sampling and Analysis
8. Organizational Structure
9. Project Schedule
10. Reports/Deliverables
11. Conclusion
Attachment A -Project Maps & Drawings
Attachment B -Project Schedule
2

Blue Ridge Plating Site Work Plan, T 0. 0060
1.0 Introduction
CMC Environmental Services, Inc. (CMC) has prepared this work plan to provide an outline of
activities to accomplish the scope of work specified in Task Order 02-04-F4-0060, and in
accordance with the Final Design Report issued by Black and Veatch, dated October 2005 for the
Soil Remediation phase for the Blue Ridge Plating (BRP) site located in Arden, Buncombe County,
North Carolina. The following sections describe the process for accomplishing these tasks.

Blue Ridge Plating Site Work Plan, T 0. 0060
2.0 Site Baclzground
CMC, Inc. received Task Order #0060 to provide remediation services at the Blue Ridge Plating
(BRP) site located at 171 Glenn Bridge Road in Arden, Buncombe County, North Carolina. The
BRP facility consists of one main manufacturing building and land use around the site is primarily
rural to light industrial. The coordinates of the BRP site are 35° 27' 44" North latitude and 82° 27'
44" West longitude. The BRP site is 3.06 acres in size.
The BRP site is bounded to the north by Glenn Bridge Road, to the east by an unnamed dead end
road, and to the south and west by wooded wetland areas. The BRP site is located in the watershed
of an unnamed tributary that feeds Lake Julian, a cooling lake for Progress Energy Company.
Directly south of the BRP facility is the former 70,000 gallon lagoon that was used to collect
wastewater. The onsite monitoring wells surround the former lagoon and are located downgradient
of the building. It was reported by the NC Department of Environment and Natural Resources
(NCDENR) that the lagoon was backfilled in September 2000 which was confirmed during a
November 2002 site visit conducted by Black and Vetch. To the West of the facility is the
abandoned plating vat area which is overgrown and contains old plating vats, several 55-gallon
drums, and other miscellaneous debris per NCDENR in 2001.
BRP site drainage enters an unnamed tributary south of the former concrete lagoon area located
directly south of the site. The unnamed tributary flows from the BRP site through an area of
forested wetlands into another unnamed tributary. This tributary eventually discharges into Lake
Julian, approximately 1,845 feet downstream of the BRP site. Lake Julian ultimately drains into
French Broad River per NCDENR, 1999.
Both Lake Julian and French Broad River are classified by the State of North Carolina and
protected as water supplies suitable for aquatic life propagation and survival, fishing, wildlife,
secondary recreation, and agricuhure per NCDENR, 1999.
The Record of Decision (ROD) for the BRP site describes several sources of contamination
identified based on the history of the site. Those sources include (EPA, 2004b):
Contaminated sail at the backdoor of the workshop, an alleged location. of illicit dumping.
Contaminated soil behind the building near a bmken pipe.
Contaminated soil in the abandoned plating vat area
Contaminated soil near the former concrete lagoon area.
Metals contamination appears to be widespread in the surface soils and to a lesser extent in shallow
subsurface soils, primarily 2 to 4 feet below land surface (bls). The following contaminants were
identified as the BRP site-specific chemicals of concern (COCs) for soil media: tetrachloroethene;
1,1,1-trichloroethane, 2-methylnapthalene, naphthalene, cadmium, chromium, cyanide, iron, and
manganese. The majority of the soil contamination is found within the top 1.5 feet for an estimated
~ volume of contamin~-ted soil of 3,870 cubic yards (CY} using the RI data (EPA, 2004b).

Blue Ridge Plating Site Work Plan, T.O. 0060
Overall, metal concentrations in the groundwater also appear to be widespread under the BRP site
and correlates, to some degree, with the surface soil metal contamination. Volatile and
semivolatile organic contaminants were detected in isolated areas of the aquifer beneath the BRP
Site. BRP site COCs for groundwater include: chloroform; l,l-dichloroethane; 1,1-dichloroethene;
tetrachloroethane; l,l,l-trichloroethane; trichloroethene; 2-methylnapthalene; naphthalene;
pentachlorophenol; arsenic; cadmium; cyanide; iron; manganese; and nickel. Cadmium and
manganese contamination delineate the boundaries of the plume. There is an estimated 3,900,000
gallons of contaminated groundwater underlying the project site.
Surface water and sediment have been collected on three occasions. The first sampling event
occurred in 1999, the second event was in 2000, and the last event was in 2003 as part of the RI.
Neither semivolatile organics nor pesticides/polychlorinated biphenyls (PCBs) were detected in the
surface water, and no pesticides/PCBs were detected in the sediment. The Baseline Human Health
Risk Assessment (BHHRA) concluded that surface water was not a media of concern for any
scenario; therefore, no COCs were selected. Cadmium, chromium, and iron were determined to be
COCs in dry sediment/surface soil (EPA, 2004b).
5

Blue Ridge Plating Site Work Plan, T.O. 0060
3.0 Soil Phase Remedial Activities
The September 2004 ROD requires the following: excavating contaminated soil to an
approximated depth of 1. 5 feet over an area of approximately 1.6 acres equating to an approximate
volume of 3,870 CY; treating through the stabilization of those soils requiring treatment (using
stabilizing agents such as fly ash or cement) prior to transportation to a disposal facility; and offsite
disposal of all contaminated soils at the appropriate facility. This soil removal will also address the
threat to ecological receptors. As part of the soil cleanup phase, additional soil sampling will be
conducted to ensure that contaminated sediment/soil is removed to protect ecological receptors.
All sampling activities will be governed by the Sampling and Analysis Plan (SAP) and Quality
Assurance Project Plan (QAPP) which details quality assurance and quality control issues.
Specific remedial activities are to include:
• Preparing appropriate plans/obtain necessary permits.
• Conducting heatability study to determine optimal stabilizing agent(s), as necessary.
• Clearing and grubbing necessary area.
• Completing delineation of area to be excavated.
• Iteratively, excavating and characterizing soils to ascertain contaminated volumes to be
removed, treated, and disposed.
• Stabilizing those soils requiring treatment prior to disposal
• Disposing of all soils (treated and untreated) at a RCRA Subtitle D landfill.
• Backfilling and grading, re-vegetating, and conducting general cleanup of approximately
1.6 acres in accordance with the Sedimentation and Erosion Control Plan.
• Cleanup and landscaping affected area.

Blue Ridge Plating Site Work Plan, T.O. 0060
4.0 Resource Requirements
4.1 Equipment
CMC anticipates using the following equipment at the BRP project site (number in parentheses
indicates number of):
• Kobelco SK210 trackhoe (or equivalent) w/smooth digging bucket and gappler attachment
(possibly 2)
• Cat 924 rubber tire loader w/bucket and fork attachment
• John Deere 450 dozer
• Skid Steer loader
• Shredder/Chipper
• Vibratory/roller compactor
• Trackhoe mats
• Project equipment storage trailer
• Office/break trailer
• Generator
• Pickups (4)
Equipment requirements may change as the project progresses. Should elaborate stabilization of
the building be required, additional equipment may become necessary. Additional equipment
needs will be discussed with and approved by the RPM prior to mobilization.
4.2 Labor
T'he following personnel requirements are anticipated at the at the BRP project site:
• Project Manager -Level II
• Field Clerk
• Disposal Coordinator
• Equipment Operators (4)
• Laborer (1 - 3 )
Personnel requirements may also change as the project progresses. Additional personnel needs will
be discussed with and approved by the RPM prior to mobilization.
4.3 Material
The following materials will be required at the BRP project site; exact quantities are to be
determined in the field:
• Poly sheeting -used to cover stockpiles, protect clean areas, and protect trucks during the
load out process
• Poly truck liners -used to line trucks used to transport contaminated soils far disposal
• Silt/sediment fence -used for erosion control
• Crushed rock or stone -used for haul road construction and possibly backfilling wet areas
• Stabilization agent (to be determined}- used to stabilize/treat soils for disposal at subtitle D
landfill
• Contractor fence -used to secure areas and barricade excavations
• Backfill Soil -used to backfill excavations to original contours

Blue Ridge Plating Site Work Plan, T.O. 0060

4.4 Subcontractors
The following subcontracted services will be required at the B1ZP project site:
• Chipping/grinding trees and brush
• Site surveying services
• Transportation and disposal of debris
• Transportation and disposal of contaminated soil
• Backfill materials
• Consulting and sampling services
• Analytical services
• Soil Stabilization Treatability Study (if necessary)
n

Blue Ridge Plating Site Work Plan, T.O. 0060
5.0 Description of Remedial Construction Activities
5.1 Mobilization
Initial mobilization of equipment, materials, and personnel to the BRP site will begin on or about
November 27, 2006. The originating point for mobilization will be Nicholasville, Kentucky. Only
resources required to begin site operations will be mobilized at this time. Additional resources will
be mobilized as they aze needed to accomplish the scope of work.
5.2 Site Prep
Site prep activities will begin as soon as a site safety/project strategy briefing has been held with
the project team. Site prep activities include the following:
• Identify access points, potential equipment and material staging areas, decon location, and
potential location of office/break trailer and/or canopy.
• Locate and mazk all monitoring wells.
• Locate and re-mark all sample point markers.
• Walk site and identify any and al] obstacles and potential hazards.
• Notify North Carolina One-call to have all utilities located and marked.
• Scale drawings and mark outer limits of excavation (Area of Concern).
• Locate property boundaries.
• Coordinate activities with BRP facility manager.
~--~
5.3 Clearing and Grubbing
CMC will begin clearing and grubbing (C&G) operations as soon as access is cleared, utilities are
located, and all monitoring wells and obstacles are marked and identified. The area to be cleared
and grubbed will be delineated based on the Area of Concern (AOC} as identified in Figure 4-1 of
the Final Design Report for Remedial Action Plan (RA Plan), prepared by Black 8e Veatch,
October 2005.
A lot of debris exist on site in the form of; scrap metal for recycle, scrap metal for disposal, old
rusted empty metal drums, empty plastic drums, plastic piping, wood pallets, and general trash.
CMC will competitively source a recycler to transport and receive salvageable scrap metal. A
trackhoe mounted hydraulic rotating grappler will be used to segregate this metal from non-
salvageable metal and load it into roll-off containers for recycle. Proceeds from the sale of
recycled metal will be sent to the special EPA account set up to handle funds of this nature.
Non-salvageable metals (lined vats and containers), plastic items, wood pallets, and general trash
will be profiled for disposal at anon-hazardous subtitle D landfill as approved by EPA. This
disposal will be competitively sourced and pending facility selection and approval by EPA, CMC
will load, manifest, transport and dispose of these materials.
CMC will clear and grub the trees and woody vegetation from the AOC prior to any excavation
~ activities taking place. The trackhoe mounted hydraulic rotating grappler will be utilized to handle
trees as they are cut off above ground level with a chainsaw. As the trees are cut, they will be
9

Blue Ridge Plating Site Work Plan, T.O. 0060
~ stockpiled in the area on the east side of the site to where they can be feed into a chipper for
shredding. All trees identified in the AOC will be cut and stockpiled prior to bringing the chipper
on site, as the trackhoe will need to be utilized to feed the chipper. This keeps the chipper from
having to wait on material to process. Stockpiled wood chips will be staged on site to later be used
as mulch during site restoration activities. All trees will be felled and stockpiled in a manner as to
minimize contact with contaminated soil. Trackhoe mats will be used as necessary to minimize
disturbance of these soils and help prevent contamination of the trees and woody vegetation.
5.4 Soil Treatability Study
Coinciding with initial soil sampling activities, CMC will collect samples from the AOC to submit
for treatability testing. CMC will competitively source this task and the successful bidder will be
selected based on price and availability to meet the schedule. The information gathered will be
used to select the best method and stabilization agent to use for treating site soils, if deemed
necessary.
5.5 Delineation of Area of Excavation
During the C & G phase of the project, CMC plans to scale off the drawings in the RA plan to
identify the trees and vegetation to be removed. Once the C & G operations aze complete, CMC
will grid off the AOC, by use of a third party licensed surveyor. Each grid will be approximately
2,500 sf (50' by 50') per the RA Plan. A topo of the AOC will also be performed to provide a
baseline elevation far site restoration and to be used for calculating in-place cubic yards removed.
The topo information will also be used as a baseline in restoring the lower, wetland area to near
pre-existing conditions. During this survey, property boundaries for the Benefield property and the
Sheppard property (immediately to the west) will be marked to insure work is performed only on
property with existing access agreemerrts.
5.6 Contaminated Soil Excavation
CMC will have to take a methodical approach to the contaminated soil excavation phase. The
following complications exist and will have to be accounted for during this phase:
• Limited room to back or pull trucks in during the soil load-out phase
• Limited space for stockpiling soils
• Limited space for soil stabilization
• 16" City sanitary line crosses through the AOC
• Two (2) possible private facility sanitary drop inlets are potentially in the AOC
• Potential exists for facility process piping to be located in the AOC
• Low overhead utilities located on the East side of the AOC
• Potential deep excavations near the facility structure, which already has structural issues
• Limited space for staging equipment outside the AOC
• Excessive fast moving traffic on Glenn Bridge Road
Prior to the start of excavation activities, CMC will sample grids in the AOC per procedures
described in further detail in the Site specific Sampling and Analysis Plan.. (SAP). All sampling and
analysis will be per EPA Region 1V protocol. Pace Analytical Laboratories out of Asheville, North
Carolina was the successful bidder to provide analytical services for the project site. The following
10

Blue Ridge Plating Sife Work Plan, T.O. 0060
table summarizes the analytical needs for the project. Pace Analytical Laboratories will be
required to provide Leve12 data packages on all samples.
Excavation Perimeter Volatile Organic Compounds
Metals
EPA SW-846 Method 5035 48 hours
EPA SW-846 Method 200 Series 48 hours
Excavation Area. ~folattle arganle Compounds EPA 5W-846 Method 5035 48 hours
Serrrlvotatite OrganGc Compounds EPA SV~/-846 Method 625 48 hours
Cyanide EPA SW-846 Method 335.4 48 Ftours
Metals EPA SW-846 Method 200 Series 48 hours
Stoctcpide T a Be E2etermined To Be [Yetermtned 'Po Be
t')eternsined
Backfltl Vrslat'tie ®rganic Compounds EPA SW-846 Method 5035 48 hours
Sable Crgarrtc Corrflpound EPA 5~-846 P~ethod 625 48 hours
PesticldeslPCBs EPA SVRt-&16 Method 8081/8082 48 hours
Cyanide EPA SW-846 Method 335.4 48 hours
Metals ~ -..__ .,~ __ ~ EPA SW-846 Method 200 Series 48 hours
Because of the excessive traffic on Glenn Bridge Road, CMC will have to prepare an area to get
the trucks used to deliver stabilizing agents (if necessary) and the trucks used to transport
contaminated soil to the landfill off the road for unloading/loading. To accomplish this, CMC
plans to excavate, sample, and backfill grids located on the west side of the facility building first.
Soils excavated from this area will be stockpiled at the rear of the building pending analytical and
stabilization (if necessary) prior to disposal. This should provide an area to stage trucks during the
load-out process. Poly sheeting and/or woven geotextile fabric will be used to keep this area from
becoming re-contaminated during the load out process. If site conditions warrant, CMC may use
the same procedures to prepare an area for loading out trucks on the East side of the property.
Initial grids will be excavated to a depth of 1 foot, sampled per SAP procedures and RA
requirements and analyzed for chemicals of concern (COCs) identified in the RA Plan. Pending
analytical data results, each grid will be backfilled or excavated again (should COC levels be above
action levels identified in the Final Design Report). Grids requiring additional soil removal will be
excavated in one (1) foot increments and the above process repeated until analytical data indicates
they are ready for backfill, or groundwater is encountered. Once the initial one (1) foot lift is
excavated across the AOC, the sidewalk of the excavation will be sampled per RA requirements
and analyzed for (COCs) identified in the RA Plan. Tf any of these results come back above the
action levels identified in the RA Plan, CMC will excavate a one (1) foot lift laterally from that
11

Blue Ridge Plating Site Work Plan, T.O. 0060
~ sample point, ten (10) feet outwards from that sample point and twenty-five (25) feet wide on
either side.
Due to limited space for stockpiling and treating soils, CMC anticipates excavating grids and
stockpiling soils unti1500 -1,000 (CY) have accumulated. Croce the stockpile azea fills up, CMC
will cease excavating and start loading contaminated soils for disposal at an approved Class D
landfill. Once the stockpiled soil has been loaded and shipped off site, excavation activities will
resume. This process will be repeated until all contaminated soils have been excavated, treated (if
necessary) and shipped offsite for disposal. Excavated grids, which have been confirmed clean by
laboratory analytical, will be covered with poly sheeting to help prevent re-contamination. All
stockpiles will be covered as necessary to prevent spread of contamination or for protection from
ram or snow.
CMC understands that the sixteen (16) inch city sanitary line, crossing the AOC, is 8.5 feet deep
and should not complicate the remediation process. However, there may be 2 sanitary drop inlets
going into this line, one from the BRP facility and one from the construction firm located behind
the BRP facility that may cause concern. The city representative that marked the line assumes both
lines feed in from the top. CMC will attempt to locate these lines prior to excavating contaminated
soil in the AOC. The same applies for any potential process piping coming from the facility.
CMC will take extreme care when excavating grids next to the facility building, as the structural
~ integrity is unknown at this time. if post excavation confirmation analytical indicates the need to
excavate deeper than the initial 1 foot, this will be evaluated at the time and the appropriate
measures taken. Options include: sloping or benching the excavation away from the building,
installing sheet piling next to the building or not excavating deeper than 1 foot next to the building
and backfilling this area with a compacted clay layer.
Wet excavated soils that will not pass paint filter test will have to be dried or solidified prior to
transporting for disposal. If weather conditions and project schedule allows, CMC will air dry wet
soils by stirring stockpiles with a tracked excavator until soils pass paint filter tests. If not, kiln
dust or fly ash will be added to solidify soils to a point where they pass paint filter and meet the
disposal facility requirements.
5.7 Contaminated Soil Stabilization
Contaminated soils may or may not have to be stabilized prior to loading and transporting to a
landfill. This determination will be made based on analytical data collected from each grid.
Should contaminated soils have to be stabilized, this will be done based on the results of the
treatability study performed on the soils.
CMC will perform stabilization by mixing a stabilizing agent (i.e. fly ash, cement, or other material
as indicated by the treatability study) into the soils with a irackhoe. Treated soil stockpiles will be
sampled and analyzed for constituents identified in the RA Plan prior to loading for transport and
disposal (T&D) to insure the soils are acceptable for disposal at anon-hazardous class D landfill.
Treated soil stockpiles will be covered with poly sheeting until they are ready to be loaded out for
T&D.
12

Blue Ridge Plating Site Work Plan, T. 0. 0060
5.8 Loading, Transportation, and Disposal
CMC will competitively source transportation and disposal Earns in the area that are licensed and
permitted to handle materials of this nature. Selection of approved trucking firms will be based on
price and availability to meet the project schedule. Disposal facilities will be selected based on
price, permits to accept the waste materials, and facility approval by EPA Region 1V.
Soil stockpiles, not requiring stabilization and those that have been treated to acceptable levels, will
be loaded out onto trucks for transport to an approved disposal facility. As stated previously, a
load out area will be prepared on the west side of the facility allowing trucks to back in on a clean
area. Poly sheeting will be used to insure this area doesn't become re-contaminated. This material
will be replaced as necessary to insure the trucks don't have to back out onto contaminated soil,
thereby eliminating the need for a truck wheel wash. Trucks will be lined with poly sheeting
(liners) prior to loading, and poly sheeting will be draped over the sides if necessary to keep the
sides of the trucks from becoming contaminated.
Nearing the end of the contaminated soil load out process, CMC will decontaminate all equipment
so that contaminated materials removed can go out with the last loads. This will insure there is no
re-contamination of clean areas and all contaminated materials are disposed of in bulk.
5.9 Backfilling, Grading, and Revegetating
~ Once all soil excavation, transportation and disposal activities have been completed and laboratory
analytical confums the site clean up goals have been met, CMC will begin the site restoration
phase.
Backfill materials will be competitively sourced and the successful bidder will be selected based on
price, availability, and delivery schedule. As soon as the backfill material vendor has been
selected, CMC will obtain a representative sample from the borrow pit, and have it analyzed for;
volatile organics, semivolatile organics, pesticides/PCBs, metals, and cyanide, to determine if the
material is suitable for use on the site.
For deeper, potentially wet excavations where compaction issues may be problem, CMC may elect
to use gravel or rock as backfill material until the excavation has been filled to a point where it is
stable enough to compact a general fill material. Use of gravel or rock as backfill in the "wetland"
area of the site will be avoided if possible.
CMC will backfill excavations in eight (8) inch loose lifts and compact in place with a roller
compactor and/or heavy equipment. This process will be repeated until the pre-excavation
contours aze re-established. The final eight (8) inch lift will be a topsoil type material and graded
in place with a dozer. The roller compactor will not be used on the final lift or in the areas on site
designated as "wetlands". "Wetland" areas of the site will only be compacted with the dozer.
Upon completion of the bac~ll and grading operations, CMC will re-vegetate the site with seed
r--~ indigenous to the area and capable of germinating during the time of year that the seed are applied,
as in accordance with the Sedimentation and Erosion Control Plan for the project site. Fertilizer
13

Blue Ridge Plating Site Work Plan, T.O. 0060
and lime will be applied at rates recommended based on soil samples collected from the area.
Wood chips produced from chipping and shredding trees removed from the AOC, will be spread
back across the site as mulch. CMC will also blend a mulch mixture into the soils being backfilled
into the wetland areas. This will minimize erosion until the seed can germinate and re-establish a
root system. All work will be performed to standards required by the State of North Carolina and
Buncombe County.
5.10 Site Cleanup and Landscaping
Upon completion of all above mentioned activities, CMC will cleanup all areas of the site,
removing any trash and debris generated from construction activities. The office/break trailer will
be removed and this area and any areas used for parking equipment will be restored and landscaped
to preconstruction conditions.
5.11 Demobilization
Once all tasks have been completed and approved by the RPM, CMC will load all equipment and
demobilize the project site. All equipment and personnel will be demobilized back to the
Nicholasville, Kentucky office.
5.12 O & M
Far one (1) year following completion of site operations, CMC plans to travel to the project site
one (1) time/quarter to inspect the site far signs of soil subsidence, building settling, and erosion
~ and sedimentation. If during this time any of these conditions are observed, necessary corrective
actions will be conducted until the problems are mitigated and site vegetation is re-established.
Any corrective actions necessary will be coordinated with the RPM prior to initiation of these
activities. Within 30 days following the O & M site visits, a quarterly site visit report will be
prepared and submitted to the RPM.
14

Blue Ridge Plating Site Work Plan, T 0. 0060
6.0 Air Monitoring
Particulate air monitoring at the site will be conducted before and during soil excavation activities.
Air monitoring based on procedures outlined in Section 14 of the EPA Region 4 EISOPQAM will
be conducted around the perimeter of the facility and will also be used to monitor individual work
zones.
The drivers for the BRP air monitoring program are the compounds with the lowest or most
stringent permissible exposure limit (PEL} and/or time weighted average (TWA). For the BRP site
the VOC/SVOC driver is Naphthalene that has an GjSHA TWA of 10 parts per million, and the
metals driver is Cadmium that has an OSHA TWA! of 0.05 milligrams per meter cubed. If any
personnel and/or perimeter particulate monitor averages above 0.05 milligrams per meter cubed
over an eight hour work day then the air in the area will be sampled for metal content to determvne
if the particulates in air do indeed contain any specific metal of concern. If any personnel and/or
perimeter PID/FID results in a reading of above 10 parts per million for an eight hour workday then
the air in the area will be sampled to determine the exact content of the organic chemicals of
concern. If air sample results show any chemical of concern in air above its TWA then CMC will
discuss with EPA RPM and determine engineering ~`~controls to reduce levels and proper PPE to
protect site personnel.
6.1 Perimeter .Air Monitoring
Four air-monitoring stations will be constructed around the perimeter of the facility to continuously
monitor particulates and volatile organic compounds in the air throughout the workday. The
perimeter air monitors will be set up before work begins in order to assess and compare
background particulate and volatile organic data to data during soil removal and handling activities.
After each day of monitoring, the data from the monitors will be downloaded to a computer for
review and analysis. If data review shows particulates above 0.05 milligrams per meter cubed
and/or volatile organic compounds above 10 parts per million, air samples will be collected for the
chemicals of concern. CMC will continually monitor air quality throughout the life of the project.
After each workday, CMC will compare readings to background readings and will notify the EPA
RPM of any observed spikes and request the EPA RPM to advise CMC, Inc, on appropriate
engineering measures needed to lower particulate and/or volatile organic readings and/or change in
PPE.
6.2 Personnel Air Monitoring
Personal particulate air monitors and volatile organic compound meters will be placed on
equipment operators and/or laborers working directly in the work zone with the most probability
for exposure. After each day of monitoring, the data from the monitors will be downloaded to a
computer for review and analysis. If data review shows particulates above O.OS milligrams per
meter cubed and/or volatile organic compounds above 10 parts per million in air samples will be
collected for the chemicals of concern. CMC will continually monitor air quality throughout the
life of the project. After each workday, CMC will compare readings to background readings and
will notify the EPA RPM of any observed spikes and request the EPA RPM to advise CMC, Inc,
on appropriate engineering measures needed to lower particulate and/or volatile organic readings
and/or change in PPE.

Blue Ridge Plating Site Work Plan, T 0. 0060
~.
7.0 Sampling and Analysis
Soil sampling at the project site will be conducted based on Section 12 of the USEPA Region 4
EISOPQAM. The excavation area and constituents of concern were defined and determined
through previous site investigation and sampling activities conducted by Black and Veatch at the
facility. Site-specific soil sampling locations and protocol were outlined and described in the Final
Design Report prepared by Black and Veatch and dated October 2005.
During soil removal activities, soil samples will be collected from the bottom and boundary
sidewalk (first 12" lift) of the grids defined in the excavation zone in order to confu~m the vertical
and horizontal extent of contamination. Specific project site procedures for sampling and analysis
are better defined in the Site specific Sampling and Analysis Plan (SAP) for the Blue Ridge Plating
Site.
n

Blue Ridge Plating Site Work Plan, T.O. 0060
8.0 Organizational Structure
Agency/Company Contact
USEPA Remedial Project Manager John Bornholm
(RPM):
U. S. EPA
61 Forsyth Street, S.W.
Atlanta, GA 30303
404-562-8820 (Office)
ERRS Contractor/Point of Contact Clay M. Gorman
(POC):
CMG, Inc.
1151 Jessamine Station Road
Nicholasville, KY 40356
859-885-4955 (Office)
859-885-4688 (Fax)
Site Safety and Health Officer (SSO): Steve Mangum (CMG)
859-948-8120 (Cell Phone)
ERRS Project Manager (PM): Steve Mangum (CMG)
859-948-8120 (Cell Phone)
~:`~;
~~
~'
Responsibilities
Overall project responsibilities
representing U.S. EPA Region IV
POC representing ERRS contractor
Responsible for H&S of ERRS and
subcontract personnel
Project accountability representing
ERRS, Direct report to RPM

Blue Ridge Plating Site Work Plan, T.O. 0060
9.0 Project Schedule
CMC's project schedule is provided in Attachment B. The initial project schedule is based on
information known at the time of completion of the schedule. All task identified in the future have
tentative beginning and ending dates and total time of completion for each task is estimated. It is
impossible to know all the variables that may be encountered during execution of the project; i.e.
weather delays, vertical and horizontal extent of contaminated soil, subsurface obstacles, potential
subcontractor delays, etc. For this reason the project schedule will be considered an evergreen
document that will be updated on a routine basis. The following is a summary of the anticipated
schedule for completion of major task required for the project site:
Schedule Summary
Task ~ Date
_ Initial Mobilizaton _ November 27, 2006

_ ________ Site Prep __ ~
_ _
November 28, 2006 __
Begin Clearing and Grubing AOC _ December 4, 2006
______ Begin Chipping Trees
_ _ _ December 12, 2006
_
Install Erosion Control Measures _
_
~ ___
December 18, 2006
Begin Surveying Site
----- -- --------

Demobilize for H
olida
s
-----

-- December 21, 2006

-----
---- ---
December 22
2006
_ _
_
y
______ ___
~ ______ _ ,
Rem_ob_ilize_-_Post Holidays___ __
~ _ _____ _ __Ja_nuary 2, 2007
Begin Sampling Perimeter/Excav_ation January 3,
2007

Begin Excavation Activities
-- -
- _
_
__ _
January 3, 2007
----
--------
____ Begin Backfilling Operations --------
_ ~ ------ ----
Janu 30,2007 ____
Site Grading & Final Restoration _ _ __ February 5, 2007
Final Demobilization _ _ February 10, 2007
_
~___ Submittal of Draft RA Report__ __ __ February 23, 2007

Blue Ridge Plating Site Worts Plan, T.O. 0060
10.0 Reports/Deliverables
Submittal Schedule
Document/Submittal Due
Work Plan Prior to initiation of ro'ect activities
HASP Prior to initiation of ro'ect activities
SAP, (includes FSP & QAPP) Prior to initiation of ro'ect activities
Monthl Pro'ect Re ort B 15~' da of followin month
CERCLA Dis osal Re ort 10 da s followin com letion of dis osal activities
O&M Quarterl Site Visit Re ort 30 da s followin O&M ins ections
RA Re ort 30 days after final ins ection
All reports and submittals will be provided in draft form for review and comment. Two (2) hard
copies will be provided, and one (1) electronic copy using Microsoft Word or Excel. Following
review and comment by EPA, CMC will make necessary adjustments and return final documents,
two (2) hard copies and one (1) electronic as per the schedule outlined in Attachment 1 of
Appendix A of the Task Order Statement of Work, Summary of Major Submittals for the Remedial
Action,

Blue Ridge Plating Site Work Plan, T.O. 0060
11.0 Conclusion
CMC is a fully licensed, competent ERRS contractor for U.S. EPA Region N with a vast amount
of experience performing projects of this nature. All project tasks will be performed as outlined in
the Task Order Statement of Work, the Black and Veatch Final Design Report for Remedial
Action, dated October 2005, and this Work Plan. Any deviation from this plan will be discussed
with and approved in writing with the RPM, pmor to execution thereof.

Blue Ridge Plating Site Work Plan, T 0. 0060
ATTACHMENT A
PROJECT MAPS & DRAWINGS

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Blue Ridge Plating Site Work Plan, T.O. 0060
ATTACHMENT B
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