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HomeMy WebLinkAbout17056_2018MAY- Site Assessment Work Plan-Crompton&KnowlesPrepared for North Carolina Department of Environmental Quality Division of Waste Management Superfund Section 217 West Jones Street Raleigh, North Carolina 27603 SITE ASSESSMENT WORK PLAN CROMPTON AND KNOWLES SITE LOWELL, NORTH CAROLINA Prepared by 1300 Mint Street, Suite 300 Charlotte, North Carolina 28203 Project Number GC6521 May 2018 Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 i 05.14.2018 TABLE OF CONTENTS 1. INTRODUCTION ................................................................................................ 1 1.1 Terms of Reference ..................................................................................... 1 1.2 Investigation Objectives .............................................................................. 1 1.3 Report Organization .................................................................................... 2 2. SITE BACKGROUND ......................................................................................... 3 2.1 Site Description and Setting ........................................................................ 3 2.2 Site History and Previous Remedial Activities ........................................... 4 3. SITE ASSESSMENT ........................................................................................... 7 3.1 Overview ..................................................................................................... 7 3.2 Assessment of Building Materials and Condition of Site Structures .......... 7 3.3 Geophysical Survey ..................................................................................... 8 3.4 Groundwater Investigation .......................................................................... 8 3.4.1 Well Assessment ............................................................................ 8 3.4.2 Groundwater Sampling and Analysis ............................................. 9 3.5 Vapor Intrusion Investigation .................................................................... 10 3.5.1 Overview ...................................................................................... 10 3.5.2 HVS Procedures ........................................................................... 10 3.6 Soil Investigation ....................................................................................... 12 3.6.1 Utility Locating ............................................................................ 12 3.6.2 Soil Sampling ............................................................................... 12 3.7 Sludge Investigation .................................................................................. 15 4. MANAGEMENT PLAN .................................................................................... 16 4.1 Health and Safety Plan .............................................................................. 16 4.2 Quality Assurance and Quality Control Procedures .................................. 16 4.2.1 General Procedures ....................................................................... 16 4.2.2 Cleaning and Decontamination Procedures ................................. 17 4.2.3 QA/QC Sampling Procedures ...................................................... 19 4.3 Field Instrument Calibration Procedures and Measurements .................... 19 Site Assessment Work Plan Crompton and Knowles Site TABLE OF CONTENTS (Continued) GC6521/GA180193_CK Assessment Work Plan Rev 1 ii 05.14.2018 4.4 Personal Protective Equipment .................................................................. 20 4.5 Investigation Derived Waste ..................................................................... 20 4.6 Documentation and Sample Handling ....................................................... 20 4.6.1 Field Documentation .................................................................... 21 4.6.2 Analytical Data QA/QC ............................................................... 26 4.7 Schedule and Reporting ............................................................................. 27 5. REFERENCES ................................................................................................... 28 LIST OF TABLES Table 1 Site Investigation and Remedial Action Chronology Table 2 Well Construction Details Table 3 Summary of Sampling and Laboratory Analyses Table 4 Proposed Sampling Locations LIST OF FIGURES Figure 1 Site Location Map Figure 2 Site Features Figure 3A Monitoring Well Locations Figure 3B Proposed High Volume Sampling Locations Figure 3C Proposed Soil Sampling in Buildings Figure 3D Proposed Outdoor Soil Sampling Locations Figure 4 High Purge Volume Test Assembly LIST OF APPENDICES Appendix A Chemical Removal Documentation and Inventory Appendix B Building Condition Survey Request for Proposal Appendix C USEPA SESD Procedure for Groundwater Sampling (SESDPROC- 301-R3) Site Assessment Work Plan Crompton and Knowles Site TABLE OF CONTENTS (Continued) GC6521/GA180193_CK Assessment Work Plan Rev 1 iii 05.14.2018 Appendix D USEPA SESD Procedure for Soil Gas Sampling (SEDPROC-307- R3) Appendix E USEPA SESD Procedure for Soil Sampling (SESDPROC-300-R3) Appendix F USEPA SESD Procedure for Field Equipment Cleaning and Decontamination (SESDPROC-205-R3) Appendix G USEPA SESD Procedure for Logbooks (SESDPROC-010-R5) Appendix H USEPA SESD Procedure for Sample and Evidence Management (SESDPROC-005-R2) Appendix I USEPA SESD Procedure for Packing, Marking, Labeling, and Shipping of Environmental and Waste Samples (SESDPROC-209- R3) Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 i 05.14.2018 ACRONYMS AND ABBREVIATIONS 15A NCAC 2L Chapter 15A of the North Carolina Administrative Code Subchapter 2L, Groundwater Standards ACM Asbestos-Containing Materials CAP Corrective Action Plan COPC Constituents Of Potential Concern CSM Conceptual Site Model DOT Department of Transportation DPT Direct Push Technology EM Electromagnetic EMR Electromagnetic Resistivity EPH Extractable Petroleum Hydrocarbon ft bgs feet below ground surface GPR Ground-penetrating radar GPS Global Positioning System HBM Hazardous Building Materials HSL Hazardous Substance List HVS High Volume Sampling IATA International Air Transportation Association IDW Investigation Derived Waste MADEP Massachusetts Department of Environmental Protection NCDEQ North Carolina Department of Environmental Quality PCB Polychlorinated Biphenyl PID photoionization detector PPE Personal Protective Equipment PSRGs Preliminary Soil Remediation Goal QA/QC Quality Assurance/Quality Control SAWP Site Assessment Work Plan SPLP Synthetic Precipitation Leaching Procedure SVOCs Semi-Volatile Organic Compounds TCLP Toxicity Characteristic Leaching Procedure TICs Tentatively Identified Compounds USTs Underground Storage Tanks VI Vapor Intrusion VOCs Volatile Organic Compounds VPH Volatile Petroleum Hydrocarbon Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 1 05.14.2018 1. INTRODUCTION 1.1 Terms of Reference Geosyntec Consultants, of NC, PC (Geosyntec) has prepared this Site Assessment Work Plan (SAWP) for the Crompton and Knowles Site (“Site”), located at 1602 North Main Street in Lowell, Gaston County, North Carolina. This Work Plan describes the investigation objectives as well as the procedures for field activities, sampling, analysis, quality assurance/quality control (QA/QC), and documentation associated with the initial Site assessment. Results of the investigation presented in this SAWP will supplement existing data and support the development a robust conceptual site model (CSM) and, ultimately, a path towards Site closure. 1.2 Investigation Objectives The objective of the Site assessment activities proposed herein is to refine the CSM through the investigation of potentially impacted Site soil and groundwater. Based on review of historical maps and documents related to Site operations, the proposed field activities are focused on the following: • assessing on-Site building materials and conditions including surveying each building for asbestos and possible lead-based paints and evaluating structural stability to the extent that field investigations can be conducted safely; • locating potential subsurface features, such as sewer lines, that may have historically contributed to the release of constituents of potential concern (COPC) to the subsurface; • refining the available data set to evaluate the lateral and vertical distribution and magnitude of COPCs in the vadose zone beneath Site structures and areas of the Site where historical operations may have resulted in releases of COPCs; • collecting samples for analysis and updating maps of the distribution and magnitude of COPCs in the groundwater beneath the Site using the existing monitoring well network; and • assessing the potential for vapor intrusion (VI) into Site buildings that may pose an unacceptable risk to Site workers or future occupants. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 2 05.14.2018 The CSM for the Site is anticipated to continue to evolve and support risk management decisions as the understanding of the Site conditions are improved, and remedial actions are implemented and optimized. 1.3 Report Organization The remainder of this SAWP is organized as follows: • Section 2 – Site Background – presents a general Site overview and history, and a summary of previous assessment and remedial activities; • Section 3 – Site Assessment - presents the approach and procedures for proposed Site assessment activities; • Section 4 – Management Plan - presents a management plan, including health and safety requirements, QA/QC procedures, details regarding documentation and sample handling, and a tentative schedule; and • Section 5 – References - provides a list of documents used during the preparation of this SAWP. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 3 05.14.2018 2. SITE BACKGROUND 2.1 Site Description and Setting The Site is situated on approximately 17 acres of currently unoccupied land adjacent to the South Fork Catawba River (Figure 1). The area immediately surrounding the Site is described as follows: • To the north- and southwest – George Poston Park, owned and operated by Gaston County; • To the southeast – undeveloped, forested land; and • To the northeast – the South Fork Catawba River. The Site is a former textile dye manufacturing facility that has been abandoned since 2004. Currently, 25 buildings remain, along with five large wastewater treatment tanks, associated piping, several smaller outbuildings, and other Site infrastructure (e.g., parking lots, electrical infrastructure, lighting, etc.). Site features including existing and demolished building footprints, wastewater treatment tanks, above ground storage tanks, former lagoons and suspect boneyards are depicted in Figure 2. Previously installed monitoring wells are shown in Figure 3A. The Site is located in the Piedmont physiographic province, characterized by rolling hills, and there is steep topographic relief in the northeast portion of the Site close to the river. In general, surface runoff on the property drains from southwest to northeast on the Site, toward the river. Portions of the Site are heavily wooded. On February 8, 2017 a Site visit was performed by North Carolina Department of Environmental Quality (NCDEQ) and Geosyntec personnel. During this visit, several Site buildings were observed to be in poor condition and may pose hazards to occupants during field activities. It was determined that the first phase of the Site assessment will include a building condition survey to determine the relative safety of Site structures for assessment activities. This survey will also include sampling for asbestos-containing materials by a North Carolina-accredited inspector for asbestos and lead-based paint. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 4 05.14.2018 2.2 Site History and Previous Remedial Activities The Site operated as a textile dye manufacturing facility between 1958 and 2004. The most recent facility operators included Crompton & Knowles (which was renamed Chemtura in 2005) and Yorkshire Americas (which declared bankruptcy in 2004). The Site is currently owned by a prospective developer, Lowell Investments I, LLC. Since the early 1990s, the Site has been the subject of numerous investigations and remedial activities, which are summarized in Table 1. Key events and findings are described briefly below. Environmental impacts were first observed in Site groundwater in 1991 as part of a monitoring program associated with a wastewater discharge permit to the South Fork of the Catawba River. The analysis of groundwater samples collected from MW-3 northeast portion of the Site indicated the presence of several COPCs including volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and select metals. Soil impacts in the southern and central portions of the Site were identified through subsequent soil sampling and a sewer line camera survey. In 1993, Crompton & Knowles submitted a Corrective Action Plan (CAP), which included the excavation of soil near the southern wastewater sewer line (near Building 30), closure of the wastewater lagoons, and groundwater extraction from a single recovery well downgradient (towards the river) of the primary lagoon. During soil excavation activities, 1,500 tons of soil were removed from the area upgradient of the primary wastewater lagoon. The excavation included a terra cotta wastewater sewer line and soil up to four feet deep (based on visual assessment of impacts such as staining and discoloration). No post-excavation confirmation samples were collected for analysis. In 2004, the Site ceased operations. The groundwater extraction operation and the water treatment system were also shut down at this time. Between 2006 and 2010, much of the equipment that remained on Site was dismantled and sold (including a spray tower, tanks, pumps, air compressors, etc.). Site reassessment activities conducted between 2006 and 2009 indicate that groundwater impacts are primarily located in the western portion of the Site. Potentially elevated concentrations of inorganic constituents were also measured in sediments and surface water samples from the river adjacent to the Site. A limited soil investigation found evidence of chlorinated benzene impacts near Building 9. Polychlorinated biphenyl (PCB) compounds were also detected in soil at this location at a maximum concentration of 78 mg/kg of Aroclor 1260. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 5 05.14.2018 In 2009, NC Hazardous Waste Section issued a Notice of Violation regarding improper storage of hazardous materials at the Site, which resulted in an extensive chemical removal action completed in 2010. NCDEQ representatives observed at least 800 chemical storage containers of various sizes located in several Site buildings, including Buildings 3, 4, 10, 18, and 33. Building 33 has since been demolished, but the basement slab remains. Chemicals included both liquid and powders, and many of the containers were damaged or deteriorated. Approximately thirty-five 55-gallon containers of lab pack waste were stored in Building 3 (warehouse). Some of the powdered chemicals had spilled onto floor in several buildings, and many containers throughout the facility were reported to be open or damaged so that the chemicals were exposed to the environment. Multiple containers were stored on an asphalt pad in the southwest corner of the Site, many of which were open, damaged, and/or unlabeled. As a result of the removal action, a total of 1,139 drums, 135 one-ton totes, 1,535 25-kilogram bags of dry chemical and powders were removed. Many of these containers were characterized as hazardous waste for toxicity, ignitability, or corrosivity. An inventory of chemicals removed from the Site is included in Appendix A. In 2014, four temporary wells were installed (two located to the northwest of the Site and two on the undeveloped, forested land to the southeast of the Site) by SM&E to evaluate off-Site groundwater impacts. The analysis of samples collected from these temporary wells did not support evidence of migration of contaminated groundwater off Site. Groundwater samples collected from MW-3 included several compounds in concentrations greater than the 15A NCAC 2L groundwater standards: benzene (24 micrograms per liter, µg/L), 1,2,4-trichlorobenzene (470 µg/L), 1,4-dichlorobenzene (13 µg/L), and manganese (1,120 µg/L). Sediment samples were also collected from the South Fork of the Catawba River. Analytical results of these samples indicate that arsenic, chromium, and manganese were detected at concentrations above the Preliminary Soil Remediation Goal (PSRGs); however, these concentrations were consistent with background samples and may be naturally occurring. One SVOC, benzo(a)pyrene, was detected in one sample at a concentration of 0.08 mg/kg, which exceeds the residential PSRG (0.015 mg/kg) but is below the commercial industrial PSRG. As such, surface water and sediment has been assessed at the Site and are not considered to warrant further investigation during this stage of investigation activities. Although this Site has undergone numerous investigations since the 1990s, several data gaps remain. These include the condition and materials used in on Site buildings (i.e., the possible presence of asbestos-containing materials, lead-based paints, and other Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 6 05.14.2018 potentially hazardous building materials), soil beneath Site buildings and in locations of historical spills and leaks (e.g., the asphalt pad in the southwest corner of the Site), sub- slab soil gas and the potential for vapor intrusion into Site buildings, and sludge remaining in the wastewater treatment tanks. This SAWP targets these media, as well as current groundwater conditions, for investigation to address Site data gaps. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 7 05.14.2018 3. SITE ASSESSMENT 3.1 Overview This section summarizes the methods and procedures used to conduct the initial Site assessment. Figures 3A through 3D depicts the proposed soil, groundwater, and soil vapor sampling locations included in this investigation. The proposed field investigation program will include: (i) an assessment of building materials and building condition survey, (ii) a geophysical survey to identify subsurface structures, (iii) groundwater sampling and analysis from existing wells, (iv) sub-slab soil gas sampling, (v) soil sampling and analysis, and (vi) sampling and analysis of sludge in wastewater treatment storage tanks. The overall objectives of the investigation are to identify areas of potential impacts to Site media, assess the extent and magnitude of impacts, to enhance the CSM. 3.2 Assessment of Building Materials and Condition of Site Structures In the first phase of the Site assessment, Geosyntec has identified a subcontractor (Terracon Consultants, Inc.) to perform a building materials assessment and a physical condition assessment of Site structures. This assessment will include: (i) an asbestos- containing materials (ACM) survey; (ii) a survey and inventory of other potentially hazardous building materials (HBM); (iii) a lead-based paint survey, and (iv) a physical conditions assessment of Site buildings. The objectives of these activities are to: identify the presence and locations of ACM/HBM/lead-based paint; evaluate hazards associated with potential demolition of Site structures; characterize building materials for potential landfill acceptance and suitability for use as fill on-Site; and to assess the structural condition and stability of Site structures to evaluate whether they pose hazards to Site workers or future occupants. The detailed scope of work for these activities is described in greater detail in the Request for Proposals used to solicit subcontractor proposals, included as Appendix B. A report detailing the procedures and results of these activities for each Site building will be included with the results and analyses of this assessment. This report will include annotated maps showing the conditions of Site buildings and the extent of ACM-, HBM-, and lead-based paint impacted areas, an inventory of surveyed materials/samples collected, photographic documentation of sampling, and relevant laboratory reports. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 8 05.14.2018 3.3 Geophysical Survey A multifrequency electromagnetic (EM) survey will be performed in and around Site buildings to assess the presence of subsurface features and/or buried material that may serve as sources of potential subsurface contamination (e.g., drains, pipes, and/or tanks). With this approach, it is possible to discriminate between metallic and non-metallic buried materials. The EM survey will be conducted with a multifrequency EM profiler equipped with a sub-meter global positioning system (GPS) survey unit at a grid spacing of approximately three feet. Ground-penetrating radar (GPR) will be used to evaluate anomalous areas found with the EM survey. The geophysical survey will be performed by a geophysical subcontractor during a two- day period at the beginning of field activities. The focus areas of the investigation will be prioritized in the field in consultation with Geosyntec personnel, with a goal of maximizing the area investigated where higher likelihood of releases exists. Particular attention will be paid to potential underground storage tanks (USTs), especially those associated with Building 5 and Building 21 (Hart & Hickman, 2009). It should be noted that the presence of significant rebar within concrete structures has the potential to limit the effectiveness of the survey. The preliminary results of the geophysical investigation will be reviewed in the field and will support the siting of borings discussed in Section 3.6. The geophysical subcontractor will produce a report describing the methods and results of the investigation, including maps of the results. 3.4 Groundwater Investigation 3.4.1 Well Assessment Existing Site groundwater wells will be located in the field, and the condition of each will be assessed. Wells that will be identified include monitoring wells MW-1 through MW- 13, recovery well RW-1, and two water supply wells near the eastern and western corners of the Site (Figure 3A). Known well construction information for these wells is presented in Table 2. Clearing may be performed as necessary to improve access to wells. Wells will be located using a metal detector, if necessary. The locations of wells will be documented with a GPS unit with sub-meter accuracy, and wells will be marked with flagging in cases where they are difficult to locate. The depth of each well will be measured with a decontaminated water level meter to assess the condition and possible Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 9 05.14.2018 damage of each well. The condition of well surface completions will be documented, and maintenance requirements will be noted (e.g., missing locks, caps, or covers). 3.4.2 Groundwater Sampling and Analysis Prior to groundwater sampling, Geosyntec will measure the depth to water in each monitoring well. Water levels will be measured in wells within a 24-hour period prior to pumping to provide a snapshot of natural groundwater elevations and flow conditions. Groundwater samples will be collected using low-flow sampling techniques from existing Site wells. Sampling techniques will be in general accordance with the USEPA Region 4 Science and Ecosystem Support Division (SESD) Field Branches Quality System and Technical Procedures for groundwater sampling (Appendix C). To the extent practical, the purge rate will be set to minimize drawdown, and purging will continue until pH, specific conductance, oxidation-reduction potential (ORP), dissolved oxygen concentration, and turbidity stabilize, which is defined as follows, or until five well volumes have been purged: • ± 0.1 unit for pH • ± 5% for specific conductance • < 10 Nephelometric Turbidity Units (NTU) for turbidity Groundwater samples will be submitted for the following analyses by a North Carolina- certified laboratory: • NCDEQ hazardous substance list (HSL) metals (totals analysis) including antimony, arsenic, beryllium, cadmium, chromium, copper, lead, manganese, mercury, nickel, selenium, silver, thallium and zinc by USEPA Methods 6020B and 7470A; • VOCs by USEPA Method 8260B; analytical methods for VOCs may include a library search (using the National Institute of Standards and Technology mass spectral library) to produce a list of tentatively identified compounds (TICs); • SVOCs by USEPA Method 8270; analytical methods for SVOCs may include a library search (using the National Institute of Standards and Technology mass Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 10 05.14.2018 spectral library) to produce a list of TICs. Aniline will be included in SVOC analysis; and • 1,4-dioxane by USEPA Method 8260 SIM. A summary of groundwater samples to be collected and analytical methods is provided in Table 3. One duplicate sample will be collected for every 10 samples (described further in Section 4.2.3). Groundwater analytical results will be compared with groundwater standards published in 15A NCAC 2L. Groundwater investigation derived waste (IDW) will be managed as described in Section 4.5. The objective of groundwater sampling is to assess current groundwater conditions and identify contaminants of concern using existing Site groundwater wells. The list of contaminants that will be analyzed was developed based on previously identified Site impacts, the operational history of the Site including known chemical use, storage, and releases. Information obtained from the groundwater investigation will be used to guide future groundwater assessment needs, including consideration for the installation of supplemental wells. 3.5 Vapor Intrusion Investigation 3.5.1 Overview High volume sampling (HVS) will be used for the initial phase of the Site assessment to evaluate the potential for volatile contaminant impacts below buildings which are expected to remain in place and the potential for vapor intrusion into these buildings. HVS is a technique for sampling sub-slab soil gas and assessing the pneumatic properties of the foundation slab and sub-surface materials. HVS typically draws soil gas from the uppermost foot of soils, providing radial characterization of sub-surface properties over large areas in a short period compared with traditional sub-slab soil gas sampling. HVS will be used to assess the occurrence and distribution of VOCs and/or petroleum hydrocarbons in vadose zone soils and at the water table beneath Buildings 2 and 3A (Figure 3B), which are planned to remain as part of tentative Site redevelopment. 3.5.2 HVS Procedures HVS will be utilized to characterize source geometry and can demonstrate an absence of significant sources over wide areas, rapidly and with high confidence by purging and screening thousands or tens of thousands of liters of soil gas in 60-90 minutes for each test. Two sampling locations in Building 2, and four sampling locations in Building 3A Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 11 05.14.2018 are proposed (Figure 3B). At each HVS sampling location, a hole approximately two inches in diameter will be cored through the concrete slab. The core holes will penetrate the floor slab and enter the underlying granular fill materials but will not continue into the underlying native soil. A 1.5-inch diameter PVC pipe will be set in the cored hole and sealed into place using anchoring cement. Cement seals will be allowed to set before sampling (typically less than 15 minutes). Communication test points, approximately ½ inch in diameter, will be drilled through the slab at 3, 10 and 30 feet radially away and sealed with modeling clay. Additional communication points may be installed based on judgment of field personnel to evaluate the propagation of vacuum across footers or other areas of the slab. The HVS sampling assembly is assembled as shown in Figure 4. Purged air will be routed to the exterior of a building. HVS sampling consists of purging at a consistent flow rate from the sub-slab extraction location and monitoring the concentration of extracted VOC vapors as a function of volume purged. A digital micro-manometer will be used to monitor drawdown (vacuum) at the communication test points and assess the total area influenced or radius achieved. Nylaflow tubing will be used during HVS activities. Samples of the purged soil gas will be periodically screened with a photoionization detector (PID). A sample will be collected at the beginning and completion of each HVS test and submitted for laboratory analysis to supplement field screening data. Following sampling, boring abandonment will be completed using clean fill and concrete patch. Soil gas sampling will include collection of two slip stream samples from each HVS location, one sample at the start of HVS testing and one sample at the mid-point of the HVS tests. Soil gas samples will be collected into 1 L Summa® canisters. Special considerations for soil gas sampling as outlined in U.S. Environmental Protection Agency Science and Ecosystem Support Division (USEPA SESD) Soil Gas Sampling guidance will be followed to the extent applicable (Appendix D). Collection of one duplicate sample for data quality purposes will be performed by using a tee-fitting to collect both samples at the same time. The duplicate will be submitted to the laboratory as a blind sample to assess laboratory reproducibility. Analysis of soil gas samples will be performed by a laboratory to be analyzed for VOCs by USEPA Method TO-15. Soil gas sampling from communication test points may be performed based on the results of the PID screening during the HVS test. Sub-slab samples collected from Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 12 05.14.2018 communication test points will be purged three times using a lungbox and 1 L Tedlar™ bags and screened with a PID and landfill gas meter. 3.6 Soil Investigation Soil impacts at the Site will be characterized through a combination of shallow hand auger borings and deeper soil borings installed using direct push technology (DPT) drilling methods. Soil sampling is proposed in areas shown on Figure 3C for locations inside (or directly adjacent to) Site buildings and Figure 3D for outdoor locations associated with other site infrastructure. A list of soil boring locations describing associated buildings or Site areas with a rationale for each sample location is provided in Table 4. Soil sample locations are planned in and around buildings or areas considered to have a higher likelihood of a historical release. Soil sampling is proposed to be performed in two mobilizations, where surficial sampling is performed (where possible without the use of a drill rig) during the first mobilization, and deeper borings are performed during the second mobilization. Near-surface data from the first mobilization will be used to inform the number, locations, and laboratory analyses performed on soil samples in deep borings. Access with a DPT drill rig may be challenging in some buildings (e.g., Building 2), and boring locations will be adjusted in the field based on access considerations. 3.6.1 Utility Locating A private utility locating subcontractor will use GPR, electromagnetic resistivity (EMR) surveying and/or other geophysical methods to evaluate and mark locations of utilities in the direct vicinity of proposed drilling at the Site. Identified utilities will be clearly marked using paint and/or flagging pins. North Carolina One-Call Utility Locating (811) will be contacted a minimum of three (3) business days prior to start of intrusive drilling activities to have subsurface utilities located and marked. The project team will reassess planned drilling locations if selected boring locations are inaccessible, within three feet of buried utilities, or have health and safety concerns with advancing borings (e.g., overhead powerlines, where a minimum horizontal separation of 25 feet must be maintained with boring location). 3.6.2 Soil Sampling The focus of the first phase of soil sampling will be surficial soils, generally up to 2 feet below ground surface (ft bgs). The number of proposed shallow soil sample locations in/around selected buildings is generally planned to be one per 1,000 square feet of Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 13 05.14.2018 building area, with some adjustments based on judgement of likelihood of a release. Within and around each building, locations of shallow soil borings will be selected in the field in consideration of findings of the geophysical investigation or sub-slab soil gas sampling, observations of staining, chemical storage, knowledge of historical operations, access, or other considerations. The number of borings in each building may be adjusted based on considerations such as evidence of contamination, access, slab thickness, or schedule. At each shallow sampling location, surficial material will be penetrated using concrete coring, hammer drilling, or other methods as appropriate to allow for hand auger access. A stainless-steel, decontaminated hand auger will be advanced into the ground to extract soil to a total depth of approximately 2 ft bgs. Soil will be screened at one-foot intervals using a PID, and the lithology will be logged. One grab sample will be collected from each shallow boring. The sample depth will be selected based on visual inspection, such as soil discoloration, and/or elevated PID readings. If evidence of contamination is not observed, a sample will be collected from the 0 to 6-inch depth interval. Following shallow soil sampling performed during the initial mobilization, data will be tabulated and reviewed to guide deep soil sampling during a subsequent mobilization. The number of deep soil borings shown on Figures 3C and 3D and listed in Table 4 will be updated based on the findings of shallow soil sampling. In general, deep sampling will be performed where surficial impacts were identified, or where deeper impacts are suspected in areas where backfilling has occurred (e.g., former lagoon areas). DPT drilling will be used to advance deeper borings at locations where likely impacts were identified and may extend deeper than 2 ft bgs. DPT soil borings are anticipated to be advanced to depths of approximately 20 feet, although borings may be extended deeper if impacts are observed near 20 ft bgs. In the former lagoon areas, deeper DPT borings will be installed to the approximate depth of the water table, and sampling will be conducted deeper than the previously excavated depth of the lagoon, as assessed by the presence of fill material. DPT soil cores will be screened at one-foot intervals using a PID, and the lithology of each core will be logged. For borings up to 20 ft bgs, up to two grab samples will be collected from each core, unless notable variation in observed impacts across varying lithologies are observed and more samples may be collected and analyzed under consultation with NCDEQ. Visual inspection, such as soil discoloration, and/or elevated PID readings, will guide the number of samples per boring as well as the sampled interval. If no impacts are suspected, one sample will be collected from an interval approximately three feet below the depth of impacts identified in the accompanying shallow boring. If Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 14 05.14.2018 impacts are suspected, samples will be collected from suspect intervals. Samples will not be collected deeper than two feet above the water table. One additional sample will be collected from each deep boring at the interval suspected to have greatest impacts, sent to the laboratory, and placed on hold. Following receipt of analytical data from the grab samples, this sample may be extracted using the Synthetic Precipitation Leaching Procedure (SPLP) by SW-846 Method 1312 and analyzed for constituents identified during the initial analysis. One duplicate sample will be collected for every 10 soil samples. The exact number and locations of DPT borings may vary based on considerations such as accessibility, field observations, or schedule constraints. Shallow soil samples will be analyzed for the following compounds: • HSL metals (totals analysis) including antimony, arsenic, beryllium, cadmium, chromium, copper, lead, manganese, mercury, nickel, selenium, silver, thallium and zinc by USEPA Method 6020B and 7471B; • SVOCs using SW-846 Method 8270; analytical methods for SVOCs may include a library search (using the National Institute of Standards and Technology mass spectral library) to produce a list of TICs. Aniline will be included in SVOC analysis; • VOCs using SW-846 Method 8260; analytical methods for SVOCs may include a library search (using the National Institute of Standards and Technology mass spectral library) to produce a list of TICs; • Select samples will be analyzed for petroleum hydrocarbons using Massachusetts Department of Environmental Protection (MADEP) Volatile Petroleum Hydrocarbon (VPH) and MADEP Extractable Petroleum Hydrocarbon (EPH) only if a nearby petroleum release or petroleum contamination is suspected; and • Samples collected in and around Building 30, and the substation area will be analyzed for PCB Aroclors using SW-846 Method 8082A; and Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 15 05.14.2018 •Samples collected from the vicinity of former acid tanks or releases (e.g., sulfuric acid release area in the western corner of the Site, or portions of Building 5) will be analyzed for pH using SW-846 Method 9045D. Soil samples from deep borings will be analyzed only for constituents detected in accompanying shallow soil borings along with VOCs. In locations where co-located shallow borings are not present (e.g., former primary lagoon), soil samples from deep borings will be analyzed for the constituents as described in the list above. Samples will be properly preserved, labeled, logged onto a chain-of-custody form, placed into an iced cooler and sent to the laboratory for analysis. Following shallow hand-auger borehole termination, remaining cuttings will be returned to the boring. DPT soil boring locations will be tremie grouted to land surface. IDW, which may include drill cuttings and mud, soil, and residuals will be placed in labeled 55-gallon steel drums for off-Site disposal pending laboratory analysis. Boring holes in concrete or asphalt are not proposed to be replaced, with the exception of those in Building 2 and Building 3A, which are expected not to be demolished. 3.7 Sludge Investigation Five above ground storage tanks associated with the Site wastewater treatment system remain on Site. The tank volumes are estimated to be between 206,000 and 994,000 gallons. The sludge in each tank will be sampled and tested to evaluate leaching potential in advance of possible removal. One grab sample from each tank will be collected with a petite ponar grab sampler. The sampler will be lowered into the water column from the top of the tank. When the ponar reaches the sludge-water interface, the jaws will close, and the sludge will be collected. The sludge will then be distributed into laboratory- supplied sample containers with a decontaminated, stainless-steel spoon. One duplicate sample will be collected. Samples will be properly preserved, labeled, logged onto a chain-of-custody form, placed into an iced cooler and sent to the laboratory for analysis. Samples will be analyzed for VOCs, SVOCs, and metals via Toxicity characteristic leaching procedure (TCLP) SW-846 Method 1311 as well as HSL metals (totals analysis) by USEPA Method 6020B and 7471B. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 16 05.14.2018 4. MANAGEMENT PLAN 4.1 Health and Safety Plan A health and safety plan (HASP) will be prepared in accordance with 29 Code of Federal Regulations (CFR) 1910.120 prior to field activities. The HASP will be completed and available on Site during the performance of field activities. The HASP will cover activities to be completed during implementation of this SAWP. The HASP will be made available to subcontractors prior to mobilization. 4.2 Quality Assurance and Quality Control Procedures This subsection of the SAWP provides information on various support procedures to be used by the field team in conducting this field investigation. The field procedures, including those related to sample collection, sample containers, sample preservation, equipment decontamination, and field measurement procedures are in general accordance with the USEPA Region 4 SESD Field Branches Quality System and Technical Procedures 1. 4.2.1 General Procedures The following factors will be considered to meet the objectives of this field effort: • Selection and Proper Preparation of Sampling Equipment - The type of sampling equipment used is dictated by the investigation and is in accordance with USEPA Region 4 SESD guidance included as Appendix C (groundwater), Appendix D (sub-slab soil gas), and Appendix E (soil). • Sampling Equipment Construction Material – The construction material of sampling equipment can affect sample analytical results. Materials must not contaminate the sample being collected and must be readily cleaned so that samples are not cross-contaminated. 1 https://www.epa.gov/quality/quality-system-and-technical-procedures-sesd-field-branches Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 17 05.14.2018 • Sample Containers and Volumes - The sample volume obtained will be sufficient to perform required analyses with an additional amount collected to provide for quality control needs, split samples, or repeat examinations. • Sample Preservation – The analytical laboratory will provide sample containers that contain the appropriate type and amount of preservative for each proposed analysis as listed in Table 3. Samples will be preserved to maintain their integrity as specified in the applicable laboratory methodology. • Sample Holding Times - The elapsed time between sample collection and initiation of laboratory analyses will be consistent with the laboratory specification as listed in Table 3. • Sample Chain of Custody - Chain-of-Custody procedures will be maintained from point of sampling to final analysis. In conjunction with the completion of data entry in the field logbook, field data forms will also be completed and maintained for field activities. 4.2.2 Cleaning and Decontamination Procedures 4.2.2.1 Overview Cleaning and decontamination procedures for sampling activities are discussed below. Sufficient clean equipment will be transported to the field to minimize the need for field cleaning. Reusable sampling equipment will be decontaminated prior to field reuse. At the end of each day, reusable equipment will be decontaminated. 4.2.2.2 Sampling Equipment Decontamination of soil, groundwater, and sub-slab soil gas sampling equipment will take place prior to sample collection at each sampling location in accordance USEPA Region 4 operating procedure for field equipment cleaning and decontamination (USEPA 2015a) included as Appendix F. Decontamination of equipment and tools will be conducted in a centralized area. Prior to arrival on-Site, down-hole drilling equipment will be pressure-washed. Drilling sampling equipment shall be decontaminated using a steam cleaner prior to each use. Equipment used for hand augering, groundwater and Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 18 05.14.2018 sub-slab soil gas sampling will be decontaminated prior to each use and in accordance with the following cleaning procedures: • Physically remove grit or visible contamination using a brush or scrub pad. • Tap water rinse. • Wash equipment thoroughly with Luminox non-phosphate detergent wash. • Rinse thoroughly with tap water. • Rinse with analyte/organic free water. • Air dry (totally). • Aluminum foil wrap (hand augering and stainless-steel soil sampling spoons, mix bowls, etc.). Clean, disposable (vinyl or nitrile) gloves will be worn while handling sampling equipment and tools during decontamination. Some general decontamination requirements will be followed to provide the greatest protection from cross-contamination, recontamination, and quality control. Clean plastic sheeting will be placed on the ground or on a table where decontamination is performed. Decontamination will be conducted in a manner that will guard against cross-contamination of equipment. Sampling equipment will be placed on clean plastic sheeting or on surfaces covered with aluminum foil. Decontamination procedures performed during the field investigation will be documented in the field logbook. Deviations from the standard decontamination protocols will be noted. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 19 05.14.2018 4.2.3 QA/QC Sampling Procedures 4.2.3.1 Overview During each sampling effort, several QA/QC samples will be collected for laboratory analysis. The types of QA/QC samples that will be collected, along with a brief description of each sample type, are outlined below. 4.2.3.2 Equipment Rinsate Blanks Equipment rinsate blanks will be collected from the primary sampling equipment (e.g., hand auger, spoons, bowls) used if/when devices other than the sample bottle itself are required. The purpose for collecting and analyzing these blanks is to verify the cleanliness and proper decontamination of the sampling equipment. Rinsate blanks are comprised of laboratory-grade (deionized or distilled) water which is poured into the sampling device following equipment decontamination, transferred to the appropriate sample containers, and shipped to the laboratory for analysis. Rinsate blanks will be collected at a frequency of one per day while sampling occurs and analyzed for the same constituents targeted in that day’s sampling. 4.2.3.3 Field Duplicates Field duplicates will be collected during the field effort. As a rule, one duplicate will be collected for every 10 samples. Duplicate samples are samples collected simultaneously from the same media source under identical conditions but placed into separate containers. Field duplicates will be labeled so that persons performing laboratory analyses cannot distinguish duplicates from other samples. 4.2.3.4 Trip Blanks Trip blanks will be included in each cooler where VOC samples are shipped to the laboratory. 4.3 Field Instrument Calibration Procedures and Measurements Field equipment needed for sampling will be properly maintained and calibrated prior to and during continued use to assure that measurements are as accurate as possible. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 20 05.14.2018 Personnel will follow manufacturers’ instructions to evaluate whether instruments are functioning within their established operational ranges. Selected spare parts for sampling equipment and field instruments will be made available in the Geosyntec office or at the company from which the equipment is rented. Calibration data will be recorded in the field logbook or on field data sheets. 4.4 Personal Protective Equipment To protect the health and welfare of each employee and to strive towards compliance with state, federal and local regulations, appropriate personal protective equipment (PPE) is required for implementation of this SAWP. More specific PPE requirements are included in the HASP. At a minimum the level of PPE required is Level D, which includes nitrile outer gloves, hard-toed boots, safety glasses, safety vest and hard hat as appropriate. 4.5 Investigation Derived Waste IDW generated during this investigation is anticipated to consist of purged groundwater, soil cuttings, and decontamination fluids. Both solid and liquid IDW is planned to be spread on the ground surface near each borehole or well. However, if highly contaminated material is observed or suspected, soil cuttings shall be properly containerized in labeled 55-gallon drums and staged on Site near the area where it was generated until characterized. Once filled, IDW drums (if any) will be sampled, and samples will be analyzed for VOCs, SVOCs, and inorganics via TCLP SW-846/USEPA Method 1311. For solid IDW, several sub-samples from the drum will be collected into a decontaminated stainless steel bowl, mixed manually using a decontaminated stainless steel spoon, and divided into laboratory-supplied sample containers. For liquid IDW, one grab sample will be collected and divided into laboratory-supplied containers. One sample per drum will be collected as well as one duplicate sample per 10 drums. The need for off-property management will be determined based on laboratory analytical results. 4.6 Documentation and Sample Handling Activities completed as part of the SAWP will be documented in accordance with SESDPROC-010-R5 Logbooks (Appendix G; USEPA 2013b). Sample handling will be conducted in accordance with SESDPROC-005-R2 Sample and Evidence Management Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 21 05.14.2018 (Appendix H; EPA 2013c), and SESDPROC-209-R3 Packing, Marking, Labeling, and Shipping of Environmental and Waste Samples (Appendix I; EPA 2015b). Procedures for documentation and sample handling are described below. 4.6.1 Field Documentation Field work and sample collection programs will be documented using a combination of field logbooks and/or specific field log forms. Sample information to be included in field logs, on sample labels, custody seals, and Chain-of-Custody forms is described below. 4.6.1.1 Field Activity Log Bound field log books, loose-leaf drilling logs, or automated field data entry records generated with laptops/tablets will be used to document field activities. This project will have dedicated field log books, forms, and databases that will not be used for other projects. To the extent possible, field data will be recorded on field forms and not repeated in the field notebook. If a field logbook is used, the logbook will be bound and will have sequentially numbered pages. Entries will be written in indelible ink and will be initialed and dated by the field personnel recording the information. Corrections to log entries will be made by crossing out incorrect entries and initialing and dating the strike-out. The correct entry will then be made. Each page of the logbook will be signed by the individual who prepares it. Information to be provided in the logbooks includes, as appropriate: • Project name/number; • On-Site personnel; • Documentation of daily safety meeting; • Date and weather conditions; • Personnel leaving or arriving on Site; • Time and description of task activities; Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 22 05.14.2018 • Level of personal protective equipment used; • Calibration of field instruments; • Description of samples collected; • Record of sampling activities (techniques, location, sample ID, sample number time matrix, depth, number of containers, and sample description); • Unusual events; • Other progress or problems; and • Communication with others. 4.6.1.2 Sample Containers, Preservation, and Storage Sample containers will be furnished by the laboratory. For those samples that require preservation, preservatives will be added to the appropriate container by the laboratory prior to shipment of the containers. 4.6.1.3 Sample Labels After sample collection, sample containers will be labeled with an identification number that uniquely identifies the sample. Each sample container will have a sample label. The sample identification number will be logged in the field log book, along with the following information about the sampling event: • Sampling personnel; • Date and time of collection; • Field sample location and depth (if appropriate); • Type of sampling (composite or grab); • Method of sampling; • Sampling matrix or source; Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 23 05.14.2018 • Results of field screening; and • Intended analyses. Indelible ink will be used to record information on the sample label. The sample identification and numbering procedure is described later in this section. 4.6.1.4 Chain-of-Custody Forms The field Chain-of-Custody Record is used to record the custody of samples or other physical evidence collected and maintained. The Chain-of-Custody Record also serves as a sample logging mechanism for the analytical laboratories’ sample custodian. The following information must be supplied in the indicated spaces in detail to complete the field Chain-of-Custody Record: • the project number • the project name • the signatures of samplers and/or the sampling team leader in the designated signature block • the sampling station ID number, date, and time of sample collection, grab or composite sample designation, and sample preservation (as applicable) must be included on each line (each line shall contain only one sample) • the sampling team leader's name should be recorded in the right or left margin of the Chain-of-Custody Record when samples collected by more than one sampling team are included on the same form • The total number of sample containers must be listed in the indicated space for each sample. The total number of individual containers must also be listed for each type of analysis under the indicated media or miscellaneous columns. Note that it is impossible to have more than one media type per sample. The required analyses should be circled as indicated on the Chain-of-Custody Record. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 24 05.14.2018 • The field investigator and subsequent transferee(s) must document the transfer of the samples listed on the Chain-of-Custody Record in the spaces provided at the bottom of the Chain-of-Custody Record. Both the person relinquishing the samples and the person receiving them must sign the form; the date and time that this occurred must be documented in the proper space on the Chain-of-Custody Record. The last person receiving the samples or evidence should be a laboratory sample custodian. • The remarks column at the bottom of the Chain-of-Custody Record is used to record air bill numbers or registered or certified mail serial numbers. The Chain-of-Custody Record is a serialized document. Once the Chain-of-Custody Record is completed, it becomes a tracking document and must be maintained in the project file. The suitability of any other form for Chain-of-Custody should be evaluated upon its inclusion of the above information in a legible format. 4.6.1.5 Photographic Documentation Photographs will be taken that are representative of field sampling activities and locations. Digital images will be retained electronically with the project files. 4.6.1.6 Sample Identification and Numbering Samples that are collected in the field will be identified with a unique alpha-numeric identification called a sample ID. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 25 05.14.2018 The identification for soil samples associated with Site buildings will follow the following format: BLDG-Y-Z-D1-D2 where: • Y is the building number where the sample was collected. • Z is the boring number within the building. • D1 and D2 are the sample top and bottom depths, respectively, in ft bgs surface. These may be excluded from surficial soil samples. Sample IDs for soil samples not associated with buildings, such as those collected in the former lagoon areas, will use short, descriptive words to denote their location as well as D1 and D2. The identification for groundwater samples will follow the format “MW-X” or “RW-X” where X is the location number. The identification for sub-slab soil gas samples will follow the format “BLDG-Y-Z” where Y is the building number and Z is the sample number within the building. Field duplicates and rinsate blanks will be labeled such that the laboratory cannot determine which QA samples match which parent samples. The log book and/or field form will accurately trace the location (including vertical position below the ground surface or sediment/water interface) of sample collection to the sample number. 4.6.1.7 Sample Packing and Shipping Samples will be packed for shipping in waterproof ice chests and coolers. Depending upon container type, the sample containers may be individually sealed in Ziploc® or other similar plastic bags prior to packing them in the cooler with bubble wrap or Styrofoam packing. Wet ice will be placed in double-bagged plastic bags (to inhibit cross contamination of sample by melt water) and placed with the samples in the cooler to maintain the samples at a temperature of 4 degrees Celsius (+ 2 degrees) during shipping. The Chain-of-Custody Record that identifies the samples is signed as "relinquished" by the principal sampler or responsible party. This Chain-of-Custody Record is sealed in a waterproof plastic bag and is placed inside the cooler, typically by taping the bag to the Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 26 05.14.2018 inside lid of the cooler. A duplicate copy of the Chain-of-Custody Record will be maintained by the Field Manager. Following packing, the cooler lid will be sealed with packing tape. A custody seal will be signed, dated, and affixed from the cooler lid to the cooler body and is additionally covered with clear tape. This ensures that tampering with the cooler contents will be immediately evident. The sample coolers will then be relinquished to laboratory staff or to a laboratory courier for transport to the laboratory. Shipping procedures will comply with Department of Transportation (DOT) regulations (49 CFR 173 to 177) and the International Air Transportation Association (IATA) if air shipping is required. 4.6.1.8 Electronic Data Field data and photographs, as necessary, will be collated following each stage of field activities. Additionally, logbooks and forms used will be scanned and their images saved in the project folder. Laboratory data will be provided as both hard copy reports and as an electronic data deliverable. Laboratory data will be entered into an electronic database format upon receipt. 4.6.2 Analytical Data QA/QC Analytical data generated during the field investigation will be reviewed for completeness after receipt from the laboratory. Level II analytical data packages will be requested from the laboratory. The analytical data will be reviewed to ensure the following: • Data packages are complete. • Holding times were met. • Blanks are reviewed. • Results are qualified if duplicate results are not comparable. • Analytical data are generally complete, reliable, and of high quality. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 27 05.14.2018 4.7 Schedule and Reporting Field activities are anticipated to occur during spring and summer 2018 with the submittal of a Site Assessment Report within two months of receipt of laboratory data. A Site Assessment Report will be prepared to document the findings from this investigation. The report will describe procedures carried out in the investigation and will include figures and tables summarizing investigation results as well as selected field notes, boring logs, calibration forms, and laboratory analytical reports. Site Assessment Work Plan Crompton and Knowles Site GC6521/GA180193_CK Assessment Work Plan Rev 1 28 05.14.2018 5. REFERENCES Hart & Hickman, 2009. Brownfields Assessment Report Former Yorkshire Americas Facility (Western Plant Area). Submitted February 9. USEPA, 2013a. Groundwater Sampling (SESDPROC-301-R3). Region 4 U. S. Environmental Protection Agency, Science and Ecosystem Support Division, Athens, Georgia. USEPA. 2013b. Logbooks (SESDPROC-010-R5). Region 4 U. S. Environmental Protection Agency, Science and Ecosystem Support Division, Athens, Georgia. USEPA. 2013c. Sample and Evidence Management (SESDPROC-005-R2). Region 4 U. S. Environmental Protection Agency, Science and Ecosystem Support Division, Athens, Georgia. USEPA. 2014a. Soil Sampling (SESDPROC-300-R3). Region 4 U. S. Environmental Protection Agency, Science and Ecosystem Support Division, Athens, Georgia. USEPA, 2014b. Soil Gas Sampling (SESDPROC-307-R3). Region 4 U. S. Environmental Protection Agency, Science and Ecosystem Support Division, Athens, Georgia. USEPA. 2015a. Field Equipment Cleaning and Decontamination (SESDPROC-205-R3). Region 4 U. S. Environmental Protection Agency, Science and Ecosystem Support Division, Athens, Georgia. USEPA. 2015b. Packing, Marking, Labeling, and Shipping of Environmental and Waste Samples (SESDPROC-209-R3). Region 4 U. S. Environmental Protection Agency, Science and Ecosystem Support Division, Athens, Georgia. TABLES DRAFT Table 1 - Site Investigation and Remedial Action Chronology Crompton and Knowles Site Lowell, North Carolina Notes: 1. Abbreviations: NC DHR/DHS = North Carolina Department of Human Resources, Division of Health Services SRG = Soil Remediation Goal NCDNR = North Carolina Department of Natural Resouces (currently Department of Environmental Quality NCDEQ)RSL = Regional Screening Level NPDES = National Pollutant Discharge Elimination System mg/kg = milligram per kilogram VOCs = Volatile organic compounds TDS = total dissolved solids SVOCs = Semi-volatile organic compounds PCB = Polychlorinated biphenyl PSRGs = Preliminary Soil Remediation Goals Results/Outcome Three monitoring wells installed (MW-1 through MW-3); determined that groundwater exceeded 15A NCAC 2L standards for benzene, chlorobenzene, chromium, copper, lead, sulfate, chloride, and TDS. Five monitoring wells installed (MW-4 through MW-8); 2L exceedences of benzene, chloroform, tetrachloroethene (PCE), trichloroethene (TCE), chromium, copper, sulfate, chloride, and TDS. Includes installation of recovery well (RW-1) located near the river in the vicinity of MW-3 and MW-11; removal of contaminated soil and replacement of the sewer line to Building 5; and the closure of the 3 wastewater surface impoundments. December 2006 Surface water and sediment sampling by NCDNR Superfund 1995 Wastewater treatment system begins operation Spring 1996 Sludge lagoon and aeration basin closed Fall 2004 Facility became inactive RW-1 begins pumping. Extracted groundwater sent to primary lagoon for treatment and subsequently to the tank treatment system. Included removal of 8,400 tons of sludge mixed with 4,800 tons of reagent (kiln dust). Depth of soil discoloration generally less than 6- 12 inches, except on the south end of the lagoon where discoloration exceeded 18 inches. Areation lagoon was excavated 6-10 inches and up to 24 inches on south berm, and backfilled with off-Site borrow. Recovery well and NPDES wastewater treatment system ceased operation. Detections of several metals and SVOCs greater than three times background concentrations. Date Description of Work Fall 1992 Groundwater Quality Assessment Fall 1991 Groundwater Compliance Monitoring 1,139 drums, 135 one-ton totes, 1,535 25-kilogram bags of dry chemical powders and dyes removed. 2L exceedences of 1,2,4-trichlorobenzene, 1,4-dichlorobenzene, and benzene in groundwater samples collected from MW-3; manganese from off-Site temporary wells to the northwest and southwest and in MW-3 and MW-10; chromium from an off-Site temporary well to the southeast. Sediment samples exceeded PSRGs for unrestricted use for arsenic, chromium, manganese, and benzo(a)pyrene. Fall 1993 Source Removal Action 1994 Source removal action -- Primary lagoon closed Area upgradient of primary lagoon excavated & surficial soils removed from path of sewer line trench during sewer line replacement (~202 cy removed and sent to landfill). 8,775 tons of sludge and contaminated soil removed (underlying 18 inches plus spot removal to deeper depths based on observations of staining). Primary lagoon backfilled; compacted to 97% proctor, included drainage layer of 57 stone covered by geotextile. 2014 Sediments and surface water sampling; installation of temporary wells to assess off-Site impacts 2009-2010 Chemical Waste Removal Action Phenolic compounds, aromatic hydrocarbons, ketones, chlorinated hydrocarbons, and mercury detected in liquid waste and sludge stored in unlined lagoons, but not outside of wastewater treatment system. Summer 2007 Expanded Site Inspection 2009 Brownfields Assessment; 8 additional soil borings Elevated concentrations of VOCs, SVOCs, metals, and several tentatively identified compounds, including aniline detected in groundwater. Groundwater discharges to surface water; however, no near-by groundwater receptors were identified. Multiple chlorinated benzene compounds detected in soil beneath Building 9, with 1,2,4-trichlorobenzene (56 mg/kg) exceeding the Preliminary Soil Remediation Goal (PSRG), but did not exceed the EPA Regional Screening Level. One PCB compound (PCB 1260) was detected at a concentration of 78 mg/kg and exceeded its SRG and RSL. Spring 1993 Corrective Action Plan submitted to NCDNR May 1989 Site Sampling Visit by NC DHR/DHS Superfund Branch Geosyntec Consultants of NC, PC Page 1 April 2018 DRAFT Table 2 - Well Construction Details Crompton and Knowles Site Lowell, North Carolina Well ID Ground Elevation (ft amsl) Top of Casing Elevation (ft amsl) Top of Screen (ft bgs) Bottom of Screen (ft bgs) Monitoring Unit Date Installed Depth to PWR (ft bgs) Depth to Bedrock (ft bgs) MW-1 718.44 720.09 88.5 103.5 Bedrock December-91 44.5 69 MW-2 628.97 630.21 17.5 27.5 Alluvium December-91 16 324 MW-3 628.96 630.06 15 25 Alluvium December-91 14 NA MW-4 699.68 699.34 60 70 Alluvium August-92 NA NA MW-5 691.20 690.87 57 72 Alluvium August-92 53 NA MW-6 711.88 711.70 67 83 Alluvium August-92 82.5 83 MW-7 702.98 702.61 73 88 Alluvium September-92 NA 88 MW-8 695.36 695.34 55 92 Bedrock August-92 NA 55 MW-9 688.49 690.43 67 77 Bedrock January-92 NA 34 MW-10 629.41 630.13 88 98 Bedrock January-92 20 26.5 MW-11 629.35 631.13 10 30 PWR October-93 10 NA MW-12 627.42 629.35 10 25 PWR October-93 10 NA MW-13 NA NA 68 83 NA August-07 NA NA RW-1 628.94 630.77 10 150 Bedrock/PWR October-93 10 30 WSW WSW Notes: 1. All elevations are referenced to mean sea level. 2. MW-13 has not been surveyed. Well screen of 15 feet assumed to extend from bottom of well. 3. Construction details for the Site water supply wells are unknown. 4. Auger refusal was encountered at 32 ft bgs on MW-2. 5. Abbreviations: ft amsl = feet above mean sea level ft bgs = feet below ground surface PWR = partially weathered rock NA = not available NA (Water supply well near eastern corner of site; construction information unknown). NA (Water supply well near western corner of site; construction information unknown). Geosyntec Consultants of NC, PC Page 1 April 2018 DRAFT Table 3 - Summary of Sampling and Laboratory Analyses Crompton and Knowles SiteLowell, North Carolina Sample Type Analysis Analytical Method (s)# Samples Sample Volume Required (g) Sample Hold Times (days) Sample Container Description 6020B (Metals: ICP/MS)Up to 80 10 180 4 oz soil jar7471B (Mercury: CVAA)Up to 80 5 28 4 oz soil jarSVOCs8270D (GC/MS)Up to 80 60 14 4 oz soil jar Volatile Organic Compounds (VOCs)8260B Up to 80 1 terra-core plug 14 Custom VOA kit MADEP VPH MAVPH Up to 80 25 28 40 mL VOC vial w/ Teflon lined screw cap - with 1 mL methanol for every g of soil MADEP EPH MAEPH Up to 80 10 14 4 oz amber glass jarPCB Aroclors 8082A (GC)4 60 1 year 8 oz soil jar pH SW-846 Method 9045D 15 60 1 4 8 oz soil jar 6020B (Metals: ICP/MS)Up to 46 10 180 4 oz soil jar7471B (Mercury)Up to 46 5 28 4 oz soil jarSVOCs8270D (GC/MS)Up to 46 60 14 4 oz soil jar VOCs 8260B Up to 46 1 terra-core plug 14 Custom VOA kit MADEP VPH MAVPH Up to 46 25 28 40 mL VOC vial w/ Teflon lined screw cap - with 1 mL methanol for every g of soil MADEP EPH MAEPH Up to 20 10 14 4 oz amber glass jar pH SW-846 Method 9045D 15 60 1 4 8 oz soil jar 6020B (Metals: ICP/MS)Up to 46 10 180 4 oz soil jar 7470A (Mercury: CVAA)Up to 46 200 28 16 oz soil jar SPLP - SVOCs 8270D (GC/MS)Up to 46 200 14 16 oz soil jar SPLP - PCB Aroclors 8082A (GC)Up to 46 200 14 16 oz soil jar SPLP - VOCs 8260B Up to 46 200 14 16 oz soil jar Sub-Slab Soil Gas VOCs TO-15 13 1 L 15 1 L Summa Canister Two sampling locations in Building 2, and four sampling locations in Building 3; Sample will be collected at the beginning and completion of each high volume sampling (HVS) test; one duplicate sample. 6020B (Metals: ICP/MS)16 100 mL 180 Plastic 250ml - with Nitric Acid 7470A (Mercury)16 100 mL 28 Plastic 250ml - with Nitric Acid SVOCs 8270D (GC/MS)16 2000 mL 7 1 L unpreserved, Amber bottle 8260B-SIM (1,4-dioxane)16 120 mL 14 Vial 40ml - HydrochloricAcid 8260B 16 120 mL 14 Vial 40ml - HydrochloricAcid 6020B (Metals: ICP/MS)6 10 180 4 oz soil jar 7470A (Mercury: CVAA)6 200 28 16 oz soil jarTCLP - SVOCs 8270D (GC/MS)6 200 14 16 oz soil jar TCLP - VOCs 8260B 6 200 14 16 oz soil jar 6020B (Metals: ICP/MS)10 100 mL 180 Plastic 250ml - with Nitric Acid 7470A (Mercury)10 100 mL 28 Plastic 250ml - with Nitric Acid SVOCs 8270D (GC/MS)10 2000 mL 7 1 L unpreserved, Amber bottle PCB aroclors 8082A (GC)10 500 mL 1 Year 250 mL unpreserved, Amber bottle VOCs 8260B 10 120 mL 14 Vial 40ml - HydrochloricAcid Trip Blanks VOCs 8260B 10 120 mL 14 Vial 40ml - Hydrochloric Acid One trip blank per cooler containing samples for VOC analysis Notes: 1. Analytical methods, sample volume required, sample container, preservative and sample hold time information received from TestAmerica. 2. Hold Times listed above represent the minimum allotted time between sampling and lab extraction, preparation or analysis. 3. All samples should be preserved under ice following sample collection. 4. Method 9045D says 'Samples should be analyzed as soon as possible.' TestAmerica will analyze these samples within requested turnaround time. 5. Abbreviations: SVOCs = Semivolatile Organic Compounds IHSB = Inactive Hazardous Sites Branch SPLP = Synthetic Precipitation Leaching Procedure VOCs = Volatile Organic Compounds ICP/MS = Inductively coupled plasma mass spectrometry TCLP = Toxicity Characteristic Leaching Procedure (TCLP) PCBs = Polychlorinated Biphenyls GC = Gas Chromatography oz = ounce MADEP = Massachusetts Department of Environmental Protection VPH = Volatile Petroleum Hydrocarbon mL = milli liter EPH = Extractable Petroleum Hydrocarbon North Carolina Hazardous Substance List Metals (IHSB) Groundwater One sample each from 15 wells (13 monitoring wells, 1 recovery well and 1 water supply well) plus one duplicate. Rinsate Blanks North Carolina Hazardous Substance List Metals (IHSB) One rinsate blank per media (soil and groundwater) per day. Sludge One sample from each above ground wastewater treatment tank (5) plus one duplicate sample TCLP - North Carolina Hazardous Substance List Metals (IHSB) VOCs North Carolina Hazardous Substance List Metals (IHSB) Deep Soil Boring North Carolina Hazardous Substance List Metals (IHSB) Up to 21 deep borings to 20 feet or water table (see Table 4 for locations); Up to 2 samples per boring; one duplicate every 10 samples. Analyses will only be performed for constituents identified in accompanying shallow boring (where applicable). pH analyses will be performed in the vicinity of Building 5, around former sulfuric acid tanks, and locations near western parking lot. PCBs are not anticipated in deep soil borings. SPLP - North Carolina Hazardous Substance List Metals (IHSB)One SPLP per boring, up to 21 borings; Analytical constituents to be determined based on initial analytical results. SPLP samples will be sent to the laboratory on hold, and analysis will be evaluated following receipt of initial data. Up to 71 total boring locations; one grab soil sample from each of boring location. One duplicate every 10 samples. - VPH/EPH analysis number of samples is dependent on field observations. 20 samples are assumed. - PCB analysis around former substation (3 locations) and transformer/building 30 (1 location).- pH analysis is assumed to be performed on samples in Building 5 (11) and around former sulfuric acid tanks (1), and locations near western parking lot (3). Surface Soil Geosyntec Consultants of NC, PC Page 1 March 2018 Draft Table 4 - Proposed Sampling LocationsCrompton and Knowles Site Lowell, North Carolina Location Proposed Sampling Number of Proposed Shallow Soil Sampling Locations Maximum Number of Proposed Deep Soil Sampling Locations Ceiling Height Sampling Rationale Building 1 - Administrative Offices (3,600 sqft)None --8'Low likelihood of chemical management/release. Building 2 - Quality Assurance Laboratories (5,000 sqft)Soil vapor, then soil 4 0 8' Building likely to remain. Laboratory likely included variety of chemical uses. Plan to evaluate sub-slab soil vapor during initial investigation using high-volume sampling to identify potential soil impacts and evaluate vapor intrusion risks. Soil sampling locations selected based on results of soil gas sampling. Low ceiling. Building 3 - Shipping/Receiving/Warehouse (15,000 sqft)Soil vapor, then soil 4 0 12' 6" Building likely to remain. Warehouse likely stored a variety of hazardous materials. Staining observed. Plan to evaluate sub-slab soil vapor during initial investigation using high- volume sampling to identify potential soil impacts and evaluate vapor intrusion risks. Soil sampling locations selected based on results of soil gas. Low ceiling. Building 4 - Grinding/Blending/Milling (4,000 sqft)Soil 4 1 26'/12' mezzanine Formerly housed blenders, pulverizers, dust collector, two air compressors. Used for grinding, blending, and milling and contains floor trenches. Floor staining observed. Building 5 - Synthesis/Filterpress/Ovens (11,000 sqft)Soil 11 3 22'/12' mezzanine Building contained ten filterpresses, 46 pumps, ovens, 22 tanks (caustic, HCL, etc.), scrubber, four dryers, three air compressors. Floor trench drains, staining observed. Building 6 - Boiler Room (2,250 sqft)Soil 2 0 or 1 15'10" Two air compressors, three boilers (all natural gas). Floor drains present. Samples to be collected for possibility of boiler blowdown water being discharged through floor drains. Building 7 - Locker Room/Lunch Room (2,250 sqft)None --9'5"Low likelihood of chemical management/release. Building 8 - Warehouse (2,500 sqft)Soil 3 1 22'/12' mezzanine Contained one 500-gal stainless tank. Used for chemical storage and has floor drains. Building 9 - Synthesis/Liquid Packout (4,800 sqft)Soil 5 1 22'/12' mezzanine Contained 21 tanks (stainless, FRP, Brick), one pump. Used for synthesis and liquid packaging of products. Brick floors, heavy staining, and extensive floor trenches. Building 10 - Warehouse/Whiteners (2,500 sqft)Soil 3 1 21'/12' mezzanine Contained air compressor, two tanks (8,500 gal stainless steel). Used for chemical storage and production of whiteners and has floor drains. Building 11 - Training Room (2,600 sqft)None --11'Low likelihood of chemical management/release. Building 12 - Filterpress (3,000 sqft)Soil 3 1 22'Contained seven filterpresses, air compressor. Used for wastewater filter presses, has brick floors, heavy staining, and extensive floor trenches. Building 13 - Maintenance (7,000 sqft)Soil 4 1 9'5" Contained an air compressor. Probable chemical management/storage based on former use as maintenance building. Low ceiling. Building 14 - Secondary Spray Dryer/Sandmills (2,475 sqft)Soil 2 1 various Building demolished and basement slab remains. Building contained natural gas powered spray dryer, air compressor, 14 pumps, 7 tanks (6 stainless, 1 FRP). Building 15 - Laboratory Flammable Storage (144 sqft)None --10'Very small area, may be sampled as part of soil sampling at Building 2, if appropriate.Building 16 - Bulk Receiving (144 sqft)None --Building demolished, location is uncertain. Building 17 - Waste Treatment Laboratory (625 sqft)Soil 1 0 or 1 12'Building 17A formerly referred to as the "pollution building". Laboratory likely included variety of chemical uses. Building 18 - Warehouse (6,750 sqft)Soil 4 1 14' Probable storage of hazardous materials based on warehouse use. Currently used for storage of plastic material. Low ceiling. Building 21 - Forklift Shop (900 sqft)Soil 1 1 Contained an air compressor. Used for storage of oil drums. Building 22 - Clarifier Pump House (375 sqft)Soil 1 0 Contained pumps. May be sampled if evidence of chemical storage/release is observed. Building 24 - Sludge Filterpress (875 sqft)Soil 1 0 Air compressor, one sludge filterpress. Building 26 - Flammable Storage (900 sqft)Soil 1 1 Used for drum storage of hazardous wastes and flammables and has internal floor drains. Deep boring on immediate edge of awning. Building 27 - Security Office (100 sqft)None --Low likelihood of chemical management/release. Building 28 - Waste Treatment Control Room (672 sqft)None --Low likelihood of chemical management/release. Building 29 - Neutralization Tank Pump House (360 sqft)Soil 1 0 Likely contained pumps. May be sampled if evidence of chemical storage/release is observed. Building 30 - Lift Station Switch Gear (280 sqft)Soil 1 0 Transformer located adjacent to building 30. Potential for PCB-containing equipment. Building 31 - Sludge Thickener Pump House (400 sqft)Soil 1 0 Likely contained pumps. May be sampled if evidence of chemical storage/release is observed. Geosyntec Consultants of NC, PC Page 1 of 2 April 2018 Draft Table 4 - Proposed Sampling LocationsCrompton and Knowles Site Lowell, North Carolina Building 32 - Upflow Filter pump House (180 sqft)Soil 0 0 Location Unknown. Likely contained pumps. May be sampled if evidence of chemical storage/release is observed. Very small building. Building 33 - Primary Spray Dryer (Multi Level)Soil 4 1 Building demolished and basement slab remains. Contained natural gas powered spray dryer. Building 34 - Waste Treatment Equip Room (1,260 sqft)Soil 0 0 Location Unknown. May be sampled if evidence of chemical storage/release is observed. Building 35 - Engineering Trailer (1,440 sqft)Soil --Low likelihood of chemical management/release. Sulfuric Acid Release Area Soil 3 1 2006 Phase I ESA reported suspected release of sulfuric acid on pavement in exterior storage area in SW corner of facility (former drum storage area). Approximately 100 55-gallon drums were previously observed to be stored outside, on a paved parking area in the west side of the subject property. The drums contained sulfuric acid. Staining and evidence of release was identified associated with this exterior storage area. Storm water in this area discharges to the unpaved ground and was not connected to the on-site WWTP. Sample at downgradient runoff locations adjacent to parking lot, or near stormwater inlets (if present). Substation Area Soil 3 0 2006 Phase I ESA reported that the substation at the property is original (1961). No specific staining was observed, but equipment is potentially PCB containing. Former Aeration Lagoon Soil 0 2 Former Primary Lagoon Soil 0 2 Former Sludge Lagoon Soil 0 2 Boneyards Soil 6 2 2006 Phase I ESA reported two extensive boneyards. While no specific areas of staining were observed, tall grass and vegetation made an exact evaluation impossible. Oldest boneyard located west of former Aeration Lagoon. [Location of second boneyard is not indicated]. Former wastewater treatment tanks Sludge --Five above ground wastewater treatment tanks remain in place. Sludge will be sampled before dewatering and disposal. Wastewater lagoons reportedly closed in 1994, with sludge and stained soil removed. Deep soil borings proposed to evaluate soil beneath excavated material. Geosyntec Consultants of NC, PC Page 2 of 2 April 2018 FIGURES Former Aeration Lagoon Nor t h Mai n St r eet / Lowel l Spencer Mount ai n RoadFormer Substation Former sulfuric acid storage tank Possible Boneyard Area Possible Boneyard Area Transformer Former Primary Lagoon Former Sludge Lagoon SOUTH FORK CATAWBA RIVER 5 3A 9 2 18 4 1 6 33 13 7 8 11 12 10 14 34 21 24 28 26 31 17A 29 22 30 15 Notes 1. Site Features are approximated from Annual Groundwater and Surface Water Monitoring Report Figure 4 (AWARE Environemental, Inc., January 2008). 2. Property boundary and building footprint locations were provided by Gaston County GIS. 3. World Imagery Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community. 4. Abbreviations: AST = above-ground storage tank WWTP = wastewater treatment plant SITE FEATURES Crompton & Knowles Site 1602 N. Main St., Lowell Gaston County, North Carolina Figure 2 Charlotte, North Carolina April 2018 125 0 12562.5 Feet SOUTH FORK CATAWBA RIVER 5 3A 9 2 18 4 1 6 33 13 7 8 11 12 10 14 34 21 24 28 26 31 17A 29 22 30 15 PROPOSED HIGH VOLUME SAMPLING LOCATIONS Crompton & Knowles Site 1602 N. Main St., Lowell Gaston County, North Carolina Figure 3B Charlotte, North Carolina April 2018 125 0 12562.5 Feet 33 14 4 4 348 17A S:1 D:0 or 1 3A S:4 D:0 5 S:11 D:3 18 S:4 D:1 S:4 D:1 9 S:5 D:1 2 S:4 D:0 13 S:4 D:1 S:4 D:1 12 S:3 D:2 10 S:3 D:1 S:2 D:1 S:3 D:1 26 S:1 D:1 21 S:1 D:1 24 S:1 D:0 S:1 D:0 or 1 31 S:0 or 1 D:0 or 1 29 S:0 or 1 D:0 22 S:0 or 1 D:0 30 S:1 D:0 1 6 7 11 28 15 SOUTH FORK CATAWBA RIVER PROPOSED SOIL SAMPLING IN BUILDINGS Crompton & Knowles Site 1602 N. Main St., Lowell Gaston County, North Carolina Figure 3C Charlotte, North Carolina April 2018 125 0 12562.5 Feet &=&= &= &=&= &= &=&= &= &= &= &=&= &= SOUTH FORK CATAWBA RIVER PROPOSED OUTDOOR SOIL SAMPLING LOCATIONS Crompton & Knowles Site 1602 N. Main St., Lowell Gaston County, North Carolina Figure 3D Charlotte, North Carolina April 2018 125 0 12562.5 Feet High Purge Volume Test Assembly Crompton and Knowles Site Lowell, North Carolina Figure 4 Charlotte, North Carolina April 2018 APPENDICES Appendix A Chemical Removal Documentation and Inventory Health and Safety Plan for Former Yorkshire Americas Co Site Lowell, NC Prepared for Haz-Mat Environmental Services/Kings Mountain Ventures Prepared by Greensboro, North Carolina Revision 0 September 2, 2009 Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 Plan Review & Approval: _______ Approved by Jim Hollingsworth Date Director of Health and Safety Shamrock Environmental Corp _______ Approved by Pete Hall Date Project Manager Shamrock Environmental Corp _______ Chris Freeman Date Site Supervisor Shamrock Environmental Corp _______ Michael Mayo Date Haz-Mat Specialist Shamrock Environmental Corp _______ Approved by Doug Wilson Date Senior Manager Haz-Mat Environmental Services _______ Approved by Neil Danziger Date Operations Manager Haz-Mat Environmental Services Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp i TABLE OF CONTENTS 1.0 INTRODUCTION AND SITE ENTRY REQUIREMENTS 1.1 Introduction 1.2 Daily Safety Meetings 1.3 Site Safety Plan Acceptance Acknowledgment 1.4 Training Requirements 1.5 Medical Monitoring Requirements 1.6 Fit Testing Requirements 1.7 Site Orientation Training 2.0 RESPONSIBLE SITE AUTHORITY 2.1 Shamrock Project Team 2.2 Haz-Mat/Kings Mtn Team 2.3 USEPA Team 2.4 Personnel Descriptions 3.0 SITE CHARACTERISTICS 3.1 Objectives 3.2 Site Background 3.3 Scope of Work 4.0 PERSONAL PROTECTION EQUIPMENT 4.1 Description of Protection Levels 4.1.1 Level B 4.1.2 Level C 4.1.3 Modified Level D 4.1.4 Level D 4.2 Task Specific Levels of Protection 4.3 Site Respiratory Protection Program 5.0 SITE HAZARDS 5.1 Chemical Hazards 5.2 Physical Hazards 5.3 Environmental Hazards 5.4 Task Hazard Analysis and Certification Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp ii 6.0 AIR MONITORING 6.1 Purpose 6.2 Air Monitoring Plan 7.0 SITE CONTROL 7.1 Support Zone 7.2 Contamination Reduction Zone 7.3 Exclusion Zone 7.4 Buddy System 7.5 Visitors 7.6 Site Security 7.7 Site Maps 7.8 Site Communication 7.9 Site Inspections 7.10 Traffic Control 8.0 DECONTAMINATION 8.1 Personnel Decontamination 8.2 Equipment Decontamination 8.3 Decontamination Equipment 9.0 SANITARY FACILITIES AND LIGHTING REQUIREMENTS 10.0 CONTINGENCY PLAN 10.1 Contingency Plan Activation 10.2 Emergency Procedures 10.3 Emergency Equipment 10.4 Emergency Telephone Numbers 10.5 Directions to Hospital 11.0 SITE SAFETY PLAN REVIEW AND DOCUMENTATION Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp iii APPENDICIES APPENDIX A: HOSPITAL LOCATION APPENDIX B: SITE SAFETY FORMS APPENDIX C: MATERIAL SAFETY DATA SHEETS ♣ Gasoline ♣ Motor Oil ♣ Hydraulic Oil ♣ Diesel Fuel APPENDIX D: DRUM MANAGEMENT PROCEDURES APPENDIX E: POTENTIAL CONTAMINANTS OF CONCERN Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 1 1.0 INTRODUCTION AND SITE ENTRY REQUIREMENTS 1.1 INTRODUCTION The document describes the health and safety guidelines developed for the Haz-Mat/Kings Mtn Site to address site maintenance and oversight activities. The plan is designed to provide measures necessary to protect on-site personnel, visitors, and the public from physical harm and exposure to the work to be conducted. The procedures and guidelines contained herein were based upon the best available information at the time of the plan’s preparation. Specific requirements will be revised when new information is received, or conditions change. A written amendment will document all changes made to the plan. Any amendments to this plan will be included as attachments. Where appropriate, specific OSHA, EPA standards and/ or other guidance will be cited and applied. 1.2 DAILY SAFETY MEETINGS Daily meetings will be held at the start of each shift to ensure that all personnel understand site conditions and operating procedures, to ensure that personal protective equipment is being used correctly and to address worker health and safety concerns. All new amendments to the Health and Safety Plan will also be reviewed at these meetings. 1.3 SITE SAFETY PLAN ACCEPTANCE ACKNOWLEDGMENT The Project Manager, the Site Supervisor, and the designated Site Safety Officer (SSO) shall be responsible for informing all Shamrock’s personnel and subcontractors at the site of the contents of this plan and ensuring that each person signs the Safety Plan Acknowledgment Form. By signing the Safety Plan Acknowledgment Form, individuals are recognizing the hazards present on-site and the policies and procedures required to minimize exposure or adverse effects of these hazards. 1.4 TRAINING REQUIREMENTS All personnel (including visitors) entering the exclusion zone or contamination reduction zone must have completed training requirements for hazardous site work in accordance with OSHA 29 CFR 1910.120 or be qualified by previous training or experience. Documentation of training requirements is the responsibility of each employer (provided that subcontractors are utilized). Each individual must provide evidence of training before site entry. 1.5 MEDICAL MONITORING REQUIREMENTS All personnel (including visitors) entering the exclusion zone or contamination reduction zone must have completed appropriate medical monitoring requirements under OSHA 29 CFR 1910.120 (f) [HAZWOPER] and 1910.134 [Respiratory Protection]. Documentation of medical Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 2 monitoring is the responsibility of each employer. If there are additional medical monitoring requirements for this site, evidence of compliance must also be included. 1.6 FIT TESTING REQUIREMENTS All personnel (including visitors) entering the exclusion or contamination reduction zone using a full-face tight fitting respirator must have successfully passed a qualitative or quantitative respirator fit test for a tight fitting respirator. When a fit factor of greater than 100 is required for an air-purifying respirator, quantitative fit testing shall be performed. Fit testing shall be performed in accordance with OSHA 29 CFR 1910.134 within the last 12 months. Documentation of fit testing is the responsibility of each employer. All personnel shall be determined fit to wear a respirator by a licensed health care professional prior to respirator use and fit testing. 1.7 SITE ORIENTATION TRAINING All personnel working at the site shall attend a site orientation that includes a review of the Health and Safety Plan including site-specific safety rules and requirements. Personnel accessing the site strictly for deliveries or administrative purposes shall not be required to attend the training. 2.0 RESPONSIBLE SITE AUTHORITY 2.1 The following personnel are identified as the Shamrock’s project team: Title Name Office Phone Number Project Manager Pete Hall Greensboro, NC 336-375-1989/ 336-382-5238 cell Site Supervisor Chris Freeman Greensboro, NC 336-708-0296 Site Safety Officer Pete Hall/Chris Freeman Greensboro, NC See above HazMat Specialist Michael Mayo Richmond, VA 804-980-1584 Corporate H&S Director Jim Hollingsworth Greensboro, NC 336-375-1989 336-402-2230 cell 2.2 The following personnel are identified as the Haz-Mat/Kings Mtn project team: Title Name Office Phone Number Senior Manager Doug Wilson Charlotte, NC 704-426-0848 Operations Manager Neil Danziger Charlotte, NC 704-361-0133 Project Foreman Dan Westerman Charlotte, NC Site Safety Officer Dan Westerman Charlotte, NC Kings Mtn Representative 2.3 The following personnel are identified as the USEPA project team: Title Name Office Phone Number USEPA On-Scene Coordinator (OSC) Ken Rhames Raleigh, NC 919 475 7397 Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 3 2.4 PERSONNEL DESCRIPTIONS Project Manager The Project Manager is responsible for the progress of the work at the project level. He supervises all project personnel to ensure that all on-site work is performed in compliance with the Work Plan specifications. In addition, the Project Manager directs the on-site personnel in correction of non-conformance found in the work. - Prepares and organizes the background review of the work plan. The Project Manager also organizes the field team. - Obtains permission for the site access and coordinates activities with appropriate facility representatives. - Ensures that work plan is completed and on schedule. - Ensures compliance with the HASP. - Briefs and manages the field crews on their specific assignments. - Supports the Site Safety Officer to ensure that safety and health requirements are met. - Prepares the final reports and support files on the field activities. Site Supervisor The Site Supervisor provides daily oversight of all work activities. The Site Supervisor works with the Project Manager to ensure that activities are performed using procedures and equipment designated in the contract. The Site Supervisor alerts the Project Manager of any potential scheduling issues and provides information regarding delivery of materials. - Manages field operations. - Executes the work plan and schedule. - Enforces safety procedures. - Coordinates with the Site Safety Officer in determining protection level. - Enforces site control. - Documents field activities. Corporate Director of Health and Safety The Corporate Director administers and directs the Company’s Health and Safety Program. The Corporate Director will provide the following support to the project: - Oversees development of the Health and Safety Plan - Approves the Health and Safety Plan - Directs the responsibilities of the project health and safety staff Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 4 - Provides technical assistance to site personnel to address unforeseen situations that may arise during the project - Periodically reviews implementation of the Health and Safety Plan. Site Safety Officer (SSO) The SSO reports all site-specific safety issues and concerns to the Project Manager/ Site Supervisor. He is responsible for daily implementation of the HASP, including such issues as PPE, training, policy enforcement, health monitoring and report preparation, among others. He is also responsible for decontamination procedures, equipment, and supplies. - Ensures protective clothing used is consistent with the requirements of the HASP. - Periodically inspects protective clothing and equipment. - Ensures that PPE are properly stored and maintained. - Controls entry and exit at the Access Control Points. - Coordinates safety and health program activities with on-site essential personnel. - Confirms each crewmember’s suitability for work based on a physician’s recommendations. - Monitors the work parties for signs of stress, such as cold exposure, heat stress, and fatigue. - Monitors on-site hazards and conditions. - Participates in the preparation of and the implementation of the HASP. - Conducts periodic inspections to determine if the HASP is being followed. - Enforces the “buddy” system. - Set up decontamination lines and the decontamination solutions appropriate for the type of chemical contamination on site. - Controls the decontamination of all equipment, personnel, and samples from the contaminated areas. - Assists in the disposal of contaminated clothing and materials. - Ensures that all required equipment is available. - Advise medical personnel of potential exposures and consequences. - Is aware of plant emergency procedures, evacuation routes, and the telephone numbers of the ambulance service, local hospital, poison control center, fire department, and police department. - Notifies, when necessary, local emergency officials. - Coordinates emergency medical care. Field Crew Members Depending on the size of the field team, any or all of the field team may be in the Work Party, but the Work Party should consist of at least two people. The field team members may consist of equipment operators, sampling technicians, environmental technicians, etc. The field team has the following specific responsibilities: Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 5 - Safely completes the on-site tasks required to fulfill work plan. - Complies with the HASP. - Notifies Site Safety Officer or Project Manager of any unsafe conditions. 3.0 SITE CHARACTERISTICS 3.1 OBJECTIVES Shamrock has been contracted to provide management of abandoned chemical materials and wastes located at the Former Yorkshire Americas Co Site as a subcontractor to Haz-Mat Environmental Services. Haz-Mat is responsible for managing containerized and bulk commodity chemicals on behalf of Kings Mountain ventures to include all preparing of the materials for transport by highway (USDOT) and vessel (IMDG). Shamrock Environmental will manage containers of deteriorated, poorly labeled and unidentified chemicals. Shamrock may also perform minimal supplementary services to assist the owner and representatives with securing site clean-up/remediation. It is Shamrock’s objective to perform these operations in a safe and efficient manner and in accordance with all Shamrock’s Standard Operating Procedures and all applicable regulations found in 29 CFR 1910.120 and 29 CFR 1926 regulating Hazardous Waste Operations and General Construction. 3.2 SITE BACKGROUND The site consists of an abandoned chemical manufacturing facility. The Former Yorkshire Americas Co Site is located at 1602 N. Main St in Lowell, NC 28098, approximately 4-miles from I-85 South. The facility operated as Yorkshire Americas Co in Gaston County, until about 5-years ago. The facility was reportedly involved in the manufacture of textile chemicals both domestic and internationally. The site is currently and for the last 2-years owned by Kings Mountain Ventures of Kings Mountain, NC. The company purchased the land and facilities for the purposes of pursuing development as multi use real estate. The facilities include warehouse, manufacturing and laboratory space as well as a fully operational waste water treatment facility which is being utilized to treat accumulated storm water. Chemicals that were left at the site by the previous owners included dyes in drum and totes, additives, and reaction based materials which included acids, bases, etc. Partial chemical list is attached as APPENDIX E. Site operations have been placed under the oversight of an On-Scene Coordinator for the US Environmental Protection Agency (EPA) under the authority of CERCLA. 3.3 SCOPE OF WORK The work scope includes tasks conducted by Haz-Mat Environmental Services [Haz-Mat] and Shamrock Environmental [Shamrock] to be conducted consists of the following tasks: Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 6 • Mobilization and Site Preparation • Site Work • Transfer Bulk Muriatic Acid (37% hydrochloric acid) [Haz-Mat] • Transfer Bulk Caustic (Approx 2600 gallons of 50% sodium hydroxide) [Haz-Mat] • Transfer Bulk #4 Fuel Oil Tank(s) (6K and 20K gallon tanks. Approx. 15,000 gallons of fuel) [Haz-Mat] • Manage Abandoned/Mismanaged Drums/Containers (Unlabeled, Improperly Stored Chemicals) [Shamrock] • Prepare Materials for Transport to meet USDOT/IMDG Codes [Haz-Mat] • Demobilization and Project Close-Out 4.0 PERSONAL PROTECTION EQUIPMENT 4.1 DESCRIPTION OF PROTECTION LEVELS In choosing protective clothing, one must be able to distinguish between the different types of fabrics and styles. Job task must be taken into account before selection is made as to prevent permeation, degradation, and penetration of the protective clothing. 4.1.1 LEVEL B Level B provides protection for respiratory hazards and skin contact hazards. This level of protection should be used when: 1. The atmosphere contains an unknown hazard in concentration and/or type of contamination. 2. Potential for dermal exposure has been evaluated and controlled through appropriate chemical protective clothing. 2. Work functions involved potential for moderate splashes, immersion, or the potential for unexpected inhalation of or contact with hazardous levels of any chemical. 3. Level B may be used when atmospheric hazards exist and potential for dermal exposure is controlled through PPE. 4. Level B should be used for remediation/removal actions and exploratory operations. Limiting Criteria: This level should be worn in the exclusion zone when accessing unlabeled/unidentified materials unless deemed otherwise acceptable by Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 7 HSM. Level B is the minimum level allowed in the exclusion zone when handling “unknown materials”. This level provides significant respiratory protection. 4.1.2 LEVEL C Level C provides protection for respiratory hazards and skin contact hazards. This level of protection should be used when: 1. The atmosphere contains a known hazard in both concentration and type of contamination. 2. Work functions involve limited splashes, immersion, or the potential for unexpected airborne emissions of or heavy contact with hazardous levels of any chemical. 3. Level C may be used when known atmospheric hazards exist but controllable potential for dermal exposure is expected. 4. Level C should not be used for exploratory operations. Limiting Criteria: This level should be worn in the exclusion zone. Level C is the minimum level allowed in the exclusion zone. This level provides limited respiratory protection. 4.1.3 MODIFIED LEVEL D Modified Level D includes the components of the Level C ensemble noted above without a respirator and includes a chemical-resistant suit (single or double), chemical resistant inner and outer gloves, and chemical-resistant steel toe boots. Modified Level D shall be used in areas where contaminated surfaces may be contacted but no respiratory hazard exists. Modified Level D provides no protection for respiratory and only limited skin protection 4.1.4 LEVEL D Level D provides no protection for respiratory and minimal skin protection. This level of protection should be used when: 1. The atmosphere contains no hazard. 2. Work functions preclude splashes, immersion, or the potential for unexpected inhalation of or contact with hazardous levels of any chemical. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 8 3. Modified Level D should be used when no atmospheric hazards exist but potential for dermal exposure is expected. Limiting Criteria: This level should not be worn in the exclusion zone, unless deemed acceptable by SSO. Modified Level D is the minimum level allowed in the CRZ and exclusion zone. This level provides no respiratory protection. Reference Section 5.4 Hazardous Analysis Certification Section for specific PPE requirements for each task. Levels of PPE shall be selected to provide protection from chemical hazards. Where use of PPE presents a hazard of greater severity or likelihood of injury than that posed by the chemical hazard, the level of PPE may be downgraded as appropriate. The CIH shall be consulted prior to any downgrade in the required PPE. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 9 4.2 TASK-SPECIFIC LEVELS OF PRTECTION FIELD ACTIVITIES COVERED UNDER THIS PLAN TASK DESCRIPTION TYPE PRIMARY CONTINGENCY ADDITIONAL INFORMATION (*) 1. Mobilization and Site Preparation Non-Intrusive Non-Contact D Modified D „ Observe safe operating procedures during site operations „ Be aware of biological hazards „ Be aware of environmental hazards „ Avoid slip, trip, fall hazards 2. Site Work (See Sub-Tasks) 2a. Transfer Muriatic Acid [Haz-Mat] Intrusive Contact C B „ USE COMPATIBLE/LINED TANKER/TOTE/DRUM „ CONTAIN/COLLECT OFF_GAS FUMES DURING TRANSFER „ NO TANK ENTRY ALLOWED „ STAGE SAFETY SHOWER/EYE WASH AJACENT TO WORK AREA (< 100 ft) „ Ensure all hoses/containers are clean prior to introducing acid „ DO NOT MIX WITH CAUSTICS „ Avoid spray/mist generation „ Be aware of potentially unstable site conditions and unknown hazards. „ Observe safe operating procedures during site operations „ Keep clear of adjacent operations Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 10 FIELD ACTIVITIES COVERED UNDER THIS PLAN TASK DESCRIPTION TYPE PRIMARY CONTINGENCY ADDITIONAL INFORMATION (*) 2b. Transfer Caustic [Haz-Mat] Intrusive Contact C B „ USE 316 SS OR OTHER COMPATIBLE TANKER/TOTE/DRUM „ NO TANK ENTRY ALLOWED „ STAGE SAFETY SHOWER/EYE WASH AJACENT TO WORK AREA (< 100 ft) „ Ensure all hoses/containers are clean prior to introducing caustic „ DO NOT MIX WITH ACIDS „ Avoid spray/mist generation „ Be aware of potentially unstable site conditions and unknown hazards. „ Observe safe operating procedures during site operations „ Keep clear of adjacent operations 2c. Transfer Fuel Oil [Haz-Mat] Intrusive Contact C (Downgrade to Modified D if supported by air monitoring) B „ USE COMPATIBLE TANKER/TOTE/DRUM „ NO TANK ENTRY ALLOWED „ Ensure all hoses/containers are clean prior to introducing fuel oil „ DO NOT MIX WITH ACIDS „ Avoid spray/mist generation „ Be aware of potentially unstable site conditions and unknown hazards. „ Observe safe operating procedures during site operations „ Keep clear of adjacent operations Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 11 FIELD ACTIVITIES COVERED UNDER THIS PLAN TASK DESCRIPTION TYPE PRIMARY CONTINGENCY ADDITIONAL INFORMATION (*) 2d. Manage Abandoned/Mismanaged Drums/Containers [Shamrock] Intrusive Contact B A1 „ Establish controlled access to work area „ Keep nonessential personnel out of work area. „ Use Level B to survey, open and conduct initial survey of containers „ Observe safe drum handling operating procedures during site operations „ Beware of adjacent chemical drums and comingled incompatible materials „ Be aware of and avoid unsafe drum stacks and structures „ Be aware of environmental hazards „ Avoid slip, trip, fall hazards 2e. Prep Materials for USDOT/IMDG Transport [Haz-Mat] Intrusive Contact D NA „ Use Level B to open and conduct initial survey of containers. „ Observe safety procedures during site operations „ Beware of adjacent chemical drums „ Be aware of and avoid unsafe structures „ Be aware of environmental hazards „ Avoid slip, trip, fall hazards 3. Demobilization Non-Intrusive Contact D Modified D „ Observe safe operating procedures during site operations „ Be aware of biological hazards „ Be aware of environmental hazards „ Avoid slip, trip, fall hazards 1 Level A conditions will require shutdown of operations and development of Level A work plan. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 12 • Refer to Section 5.6 Task Hazard Identification and Safe Work Practices for detailed information. • Levels of protection may be downgraded based on acceptable air monitoring data (See action levels in Section 6.2). Downgrades require the concurrence of the Corporate Director of HSE. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 13 4.3 SITE RESPIRATORY PROTECTION PROGRAM With the tasks required for this project, Shamrock Environmental anticipates precautionary need for respiratory protection during the reconnaissance, sampling, repackaging and management of drums and containers. Full-face supplied air respirators may be used to open and survey drums to be sampled. Full-face air purifying respirators may be used for support and peripheral activities and for bulk tank transfer operations. If conditions change, respiratory protection will be adjusted based on air monitoring results. Where air-purifying respirators are used, cartridges shall be changed daily even when action levels are not exceeded during any part of the work shift. Cartridges shall also be changed if and when particulate filter resistance is experienced. All respirator users shall be medically qualified and properly fit tested for the respirator being used. All respirators shall be full-face tight fitting respirators approved by NIOSH. Chemical cartridges shall be North® Defender ™ or equivalent. 5.0 SITE HAZARDS 5.1 CHEMICAL HAZARDS Based on the available health and safety information, potentially significant employee exposure is expected under this scope of work. Potential site contaminants are referenced in APPENDIX E. 5.1.1 CHEMICALS OF CONCERN QUICK REFERENCE - Products Chemicals/materials Shamrock Environmental expected to be on site include gasoline, diesel fuel and other similar materials that may be needed. MSDS sheets for these items are included in Appendix C. As additional materials are used and/ or encountered, the MSDSs will be provided and stored in a central location. 5.1.2 CHEMICALS OF CONCERN QUICK REFERENCE – Site Contaminants APPENDIX E includes a list of potential contaminants of concern. The chemicals present include dyes, amines, aldehydes, glycol ethers, acids, bases, fuel and numerous other hazardous chemicals. Containerized materials will be sampled and characterized to ensure safe handling as well as proper methods of disposal. The scope of work provides for identification and management of these materials. 5.2 PHYSICAL HAZARDS Slip, Trip, Fall – Good housekeeping will be maintained at all work sites. Trip hazards will be removed, marked, or guarded. Extreme caution shall be used when working on or around slippery surfaces. Use of disposable boot covers is discouraged when working on Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 14 slick surfaces. All necessary precautions will be taken to prevent personnel from injuries caused by slick surfaces. Unstable Drum Stacks/Structures – Due to the condition of drums and containers, irregular container stacks and proximity of incompatible materials, tanks, vessels and buildings may be in varying degrees of instability. Consequently extreme caution shall be used when approaching these appurtenances. Where practicable, material handling equipment shall be used. Back Strain – Lifting techniques shall be used when handling heavy or bulky loads. Personnel shall lift with legs, keeping backs straight, and loads close to their bodies. Avoid twisting at the waist during lifting. Personnel shall receive help from others when loads appear to be too heavy. Mechanical means of lifting is the most preferred method and should be used whenever possible. Overhead Hazards – Investigation of a work area must be conducted before any work is to begin. Proper clearances must be maintained at all times. Equipment shall not deviate from established travel ways or work areas where clearances are unknown/ insufficient. Buried Utilities – All buried utilities shall be identified before any intrusive work in the work area. At no time will mechanically powered excavating equipment be used to locate buried utilities. Buried utilities shall be located by hand excavation. Heavy Equipment – Daily inspections of heavy equipment will be conducted to insure all safety and operating mechanisms are in place and working properly (i.e., backup alarm, fire extinguisher, brakes, controls, etc.). This inspection will be documented and kept on file for review. Ground personnel shall communicate with the operator before he enters and after he leaves that operator’s work area. The swing radius of any piece of equipment must be established and at no time are ground personnel to enter that area when the equipment is in operation. Only qualified personnel are allowed to operate equipment. Confined Space – In the event that there are confined spaces present at the job site specific procedures covering, air monitoring, training, permitting, rescue, and PPE as recognized by Shamrock must be reviewed and followed. At no time shall any personnel be allowed to enter a confined space until all criteria as stated by Shamrock’s Confined Space Entry procedures are met. The Shamrock Confined Space Entry Permit will also be completed for any CSE operations. Noise – Personnel exposed to noise levels over 85 dBA will be required to wear approved hearing protection provided by Shamrock. Electrical – Only qualified personnel are authorized to work on electrical circuits. Shamrock’s Lock Out-Tag Out procedures shall be used before any maintenance on electrical circuits is to take place. Extension cords will be inspected daily. Damaged extension cord will be taken out of service. Ground fault circuit interrupters (GFCI) will Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 15 be used on all temporary electrical circuits (i.e., generators, site trailers, etc.). Electrical cords not specifically made for water submersion will be kept out of wet areas. Bulk Fuel Storage Areas – Bulk Storage containers used for flammable liquids must be properly grounded and have bonding cables attached. Flammable-No Smoking signs will be placed at the area so that they are clearly visible. Areas that are designated as a bulk fuel storage area must be capable of retaining 110% of the largest tank inside that area. A dedicated 20-B rated fire extinguisher (20-lb. ABC or equivalent) must be located between 25 and 75 feet of the storage area as per 29 CFR 1926.152. Small Quantity Flammable/ Combustible Materials – Small quantities of flammable/ combustible materials shall be stored in “safety” cans with appropriate flame arrestors, self-closing lids, and labeled according to their contents. Gasoline is allowed only in 5- gallon safety cans. Drum Handling – When handling drums, care must be exercised to avoid overexertion, pinch points, crushing of feet and appendages. Mechanical equipment shall be used where practicable to move drums. The body should be positioned for proper lifting and in a position that the person will not be caught between heavy objects. Leather gloves should be worn over any chemical glove to protect hands from sharp edges and pinch points. When attempting to position drums on mechanized equipment visual contact and verbal communication must be maintained with the operator. 5.3 ENVIRONMENTAL HAZARDS Severe Weather - During severe weather, outdoors operations will be stopped under these conditions: 1) Lightning is within 3 miles of the site. Shamrock’s’ procedures have been based on Red Cross and FEMA guidelines. The Site Safety Officer will measure the time from when the lightning is viewed until the thunder is heard. Since sound travels approximately one mile in five seconds, thunder heard in 15 seconds or less will result in operations shutdown in open areas. Depending on the severity of the storm the speed at which it can move into the immediate area can be swift and the SSO may opt for a more conservative work stoppage. Crews shall discontinue operations, meet at a predetermined staging area and wait for further instructions. 2) Heavy Precipitation (Rain, Snow, Sleet, etc.) that affects visibility, mobility, or the overall conditions in which equipment and personnel can operate safely. In evaluating the time when it is safe for crews to resume work, the supervisor and the SSO will determine if operations can continue in a safe manner. The wait may be as long as 30 minutes to ensure that the foul weather has passed. The “all clear” signal will be given and personnel will return to work. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 16 Animal/ Insect/ Vegetation - Rodents, snakes, stray animals, stinging insects are all environmental hazards that may be encountered during daily site operations. Site investigation to identify the hazards before work related activities are essential. The information obtained can then be passed on to site personnel. Site-specific procedures shall be instituted should there be a reasonable potential for these hazards to exist. Personnel visiting or working at the site who are known to be allergic to insect stings must notify the SHSO and make available their prescribed treatment to first aid trained personnel. All stings and bites should be taken seriously. Personnel should report all insect stings or bites and should be observed for severe swelling of the affected area, shortness of breath, nausea, or anaphylactic shock. If these signs and symptoms are noted, these personnel will be sent for immediate medical attention. In addition, site personnel trained and designated to administer first aid will be trained in and employ universal precautions to prevent possible exposure to blood borne pathogens. Any waste materials contaminated with body fluids generated as a result of administration of first aid will be handled, containerized and disposed of as a biologically hazardous waste. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 17 5.4 TASK HAZARD ANALYSIS AND CERTIFICATION TASK DESCRIPTION: Task 1. Mobilization and Site Preparation HAZARD ANALYSIS CONDUCTED BY: Jim Hollingsworth DATE: September 2, 2009 PHYSICAL HAZARD IDENTIFICATION: [X] PHYSICAL EXERTION [X] HEAT STRESS [o] COLD STRESS [X] HEAVY EQUIPMENT [X] FIRE HAZARDS [X] LIFTING HAZARDS [X] SLIP, TRIP, OR FALL [X] HIGH NOISE ( > 85 dBA ) [X] OVERHEAD UTILITIES [o] EXCAVATION/TRENCHING [o] CONFINED SPACE [o] POISONOUS PLANTS [X] POISONOUS/HAZARDOUS ANIMALS [X] ELECTRICAL [X] HAND/POWER TOOLS [X] PUNCTURE/LACERATION [o] OXYGEN DEFICIENT [o] PRESSURIZED CONTAINERS [o] EXPLOSIVE [o] VISIBILITY [X] VEHICLE TRAFFIC [o] WELDING, CUTTING, BRAZING [o] GLARE/LIGHT HAZARDS [o] SPLASH [o] GRINDING [o] FLYING DEBRIS [X] PINCH/GRAB/ROLL [o] TEMPERATURE HAZARDS [o] OTHER ( SPECIFY ) : CHEMICAL HAZARD IDENTIFICATION: [o] CORROSIVE [o] VOLATILE [o] OXIDIZER [o] TOXIC [o] RADIOACTIVE [o] BIOLOGICAL [o] INERT [o] REACTIVE [o] FLAMMABLE [o] COMBUSTIBLE [o] NON-HAZARDOUS [o] POISON A (GAS) [o] OTHER ( SPECIFY ) : PERSONAL PROTECTIVE EQUIPMENT: LEVEL OF PROTECTION RESPIRATORY PROTECTION PROTECTIVE CLOTHING GLOVES HEAD/FACE/EYE PROTECTION FOOT PROTECTION PRIMARY: D NA Appropriate work attire Leather or cotton work Hard hat, safety glasses w/ side shields Steel toe work boot CONTINGENCY: Modified D NA Tyvek® Coverall Leather or cotton work Hard hat, safety glasses w/ side shields Steel toe work boot ADDITIONAL INFORMATION: ALL PERSONNEL MUST BE PROVIDED SITE ORIENTATION TO WORK ON SITE. ADDITIONAL MODIFICATIONS/ ENGINEERING CONTROLS/ INFORMATION: Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 18 TASK DESCRIPTION: Task 2a. Transfer Bulk Muriatic Acid HAZARD ANALYSIS CONDUCTED BY: Jim Hollingsworth DATE: September 2, 2009 PHYSICAL HAZARD IDENTIFICATION: [X] PHYSICAL EXERTION [X] HEAT STRESS [o] COLD STRESS [X] HEAVY EQUIPMENT [o] FIRE HAZARDS [X] LIFTING HAZARDS [X] SLIP, TRIP, OR FALL [o] HIGH NOISE ( > 85 dBA ) [o] OVERHEAD UTILITIES [o] EXCAVATION/TRENCHING [o] CONFINED SPACE [o] POISONOUS PLANTS [X] POISONOUS/HAZARDOUS ANIMALS [o] ELECTRICAL [X] HAND/POWER TOOLS [X] PUNCTURE/LACERATION [o] OXYGEN DEFICIENT [o] PRESSURIZED CONTAINERS [o] EXPLOSIVE [o] VISIBILITY [X] VEHICLE TRAFFIC [o] WELDING, CUTTING, BRAZING [o] GLARE/LIGHT HAZARDS [o] SPLASH [o] GRINDING [o] FLYING DEBRIS [X] PINCH/GRAB/ROLL [o] TEMPERATURE HAZARDS [o] OTHER ( SPECIFY ) : Unstable Structures CHEMICAL HAZARD IDENTIFICATION: [X] CORROSIVE [o] VOC’s [o] OXIDIZER [X] TOXIC [o] RADIOACTIVE [o] BIOLOGICAL [o] INERT [X] REACTIVE [o] FLAMMABLE [o] COMBUSTIBLE [o] NON-HAZARDOUS [o] POISON A (GAS) [o] OTHER ( SPECIFY ) : ______________ PERSONAL PROTECTIVE EQUIPMENT: LEVEL OF PROTECTION RESPIRATORY PROTECTION PROTECTIVE CLOTHING GLOVES HEAD/FACE/EYE PROTECTION FOOT PROTECTION PRIMARY: C Full-face, tight fitting Air purifying Respirator with Defender (OV-AG-P100) Cartridges Tyvek QC® for closed transfer/incidental splash Saranex® Coverall or Apron for heavy splash Inner Latex or Nitrile Glove Outer Neoprene Nitrile, PVC Glove Hard hat Face Shield for hose breaking/heavy splash Steel toe PVC work boot or latex overboot CONTINGENCY: B Full-face, tight fitting Pressure demand Supplied air Respirator Tyvek QC® for closed transfer/incidental splash Saranex® Coverall or Apron for heavy splash Inner Latex or Nitrile Glove Outer Neoprene Nitrile, or PVC Glove Hard hat Face Shield for hose breaking/heavy splash Steel toe PVC work boot or latex overboot ADDITIONAL INFORMATION: Avoid restricted areas. Upgrade respirator as indicated by air monitoring, odor or irritation. Use Saranex® Coated Coveralls if splash hazard is present. ADDITIONAL MODIFICATIONS/ ENGINEERING CONTROLS/ INFORMATION: Avoid allowing material to contact Aluminum Stainless Steel & Carbon Steel. Severe corrosion may occur. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 19 TASK DESCRIPTION: Task 2b. Transfer Bulk Caustic HAZARD ANALYSIS CONDUCTED BY: Jim Hollingsworth DATE: September 2, 2009 PHYSICAL HAZARD IDENTIFICATION: [X] PHYSICAL EXERTION [X] HEAT STRESS [o] COLD STRESS [X] HEAVY EQUIPMENT [o] FIRE HAZARDS [X] LIFTING HAZARDS [X] SLIP, TRIP, OR FALL [o] HIGH NOISE ( > 85 dBA ) [o] OVERHEAD UTILITIES [o] EXCAVATION/TRENCHING [o] CONFINED SPACE [o] POISONOUS PLANTS [X] POISONOUS/HAZARDOUS ANIMALS [o] ELECTRICAL [X] HAND/POWER TOOLS [X] PUNCTURE/LACERATION [o] OXYGEN DEFICIENT [o] PRESSURIZED CONTAINERS [o] EXPLOSIVE [o] VISIBILITY [X] VEHICLE TRAFFIC [o] WELDING, CUTTING, BRAZING [o] GLARE/LIGHT HAZARDS [o] SPLASH [o] GRINDING [o] FLYING DEBRIS [X] PINCH/GRAB/ROLL [o] TEMPERATURE HAZARDS [o] OTHER ( SPECIFY ) : Unstable Structures CHEMICAL HAZARD IDENTIFICATION: [X] CORROSIVE [o] VOC’s [o] OXIDIZER [X] TOXIC [o] RADIOACTIVE [o] BIOLOGICAL [o] INERT [X] REACTIVE [o] FLAMMABLE [o] COMBUSTIBLE [o] NON-HAZARDOUS [o] POISON A (GAS) [o] OTHER ( SPECIFY ) : ______________ PERSONAL PROTECTIVE EQUIPMENT: LEVEL OF PROTECTION RESPIRATORY PROTECTION PROTECTIVE CLOTHING GLOVES HEAD/FACE/EYE PROTECTION FOOT PROTECTION PRIMARY: C Full-face, tight fitting Air purifying Respirator with Defender (OV-AG-P100) Cartridges Tyvek QC® for closed transfer/incidental splash Saranex® Coverall or Apron for heavy splash Inner Latex or Nitrile Glove Outer Neoprene Nitrile, or PVC Glove Hard hat Face Shield for hose breaking/heavy splash Steel toe PVC work boot or latex overboot CONTINGENCY: B Full-face, tight fitting Pressure demand Supplied air Respirator Tyvek QC® for closed transfer/incidental splash Saranex® Coverall or Apron for heavy splash Inner Latex or Nitrile Glove Outer Neoprene Nitrile, PVC Glove Hard hat Face Shield for hose breaking/heavy splash Steel toe PVC work boot or latex overboot ADDITIONAL INFORMATION: Avoid restricted areas. Upgrade respirator as indicated by air monitoring, odor or irritation. Use Saranex® Coated Coveralls if splash hazard is present. ADDITIONAL MODIFICATIONS/ ENGINEERING CONTROLS/ INFORMATION: Avoid allowing material to contact Aluminum & Carbon Steel. Severe corrosion may occur. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 20 TASK DESCRIPTION: Task 2c. Transfer Bulk Fuel Oil HAZARD ANALYSIS CONDUCTED BY: Jim Hollingsworth DATE: September 2, 2009 PHYSICAL HAZARD IDENTIFICATION: [X] PHYSICAL EXERTION [X] HEAT STRESS [o] COLD STRESS [X] HEAVY EQUIPMENT [o] FIRE HAZARDS [X] LIFTING HAZARDS [X] SLIP, TRIP, OR FALL [o] HIGH NOISE ( > 85 dBA ) [o] OVERHEAD UTILITIES [o] EXCAVATION/TRENCHING [o] CONFINED SPACE [o] POISONOUS PLANTS [X] POISONOUS/HAZARDOUS ANIMALS [o] ELECTRICAL [X] HAND/POWER TOOLS [X] PUNCTURE/LACERATION [o] OXYGEN DEFICIENT [o] PRESSURIZED CONTAINERS [o] EXPLOSIVE [o] VISIBILITY [X] VEHICLE TRAFFIC [o] WELDING, CUTTING, BRAZING [o] GLARE/LIGHT HAZARDS [o] SPLASH [o] GRINDING [o] FLYING DEBRIS [X] PINCH/GRAB/ROLL [o] TEMPERATURE HAZARDS [o] OTHER ( SPECIFY ) : Unstable Structures CHEMICAL HAZARD IDENTIFICATION: [o] CORROSIVE [o] VOC’s [o] OXIDIZER [X] TOXIC [o] RADIOACTIVE [o] BIOLOGICAL [o] INERT [o] REACTIVE [o] FLAMMABLE [X] COMBUSTIBLE [o] NON-HAZARDOUS [o] POISON A (GAS) [o] OTHER ( SPECIFY ) : ______________ PERSONAL PROTECTIVE EQUIPMENT: LEVEL OF PROTECTION RESPIRATORY PROTECTION PROTECTIVE CLOTHING GLOVES HEAD/FACE/EYE PROTECTION FOOT PROTECTION PRIMARY: C Full-face, tight fitting Air purifying Respirator with Defender (OV-AG-P100) Cartridges Tyvek QC® for closed transfer/incidental splash Saranex® Coverall or Apron for heavy splash Inner Latex or Nitrile Glove Outer Neoprene Nitrile, or PVC Glove Hard hat Face Shield for hose breaking/heavy splash Steel toe PVC work boot or latex overboot CONTINGENCY: B Full-face, tight fitting Pressure demand Supplied air Respirator Tyvek QC® for closed transfer/incidental splash Saranex® Coverall or Apron for heavy splash Inner Latex or Nitrile Glove Outer Neoprene Nitrile, PVC Glove Hard hat Face Shield for hose breaking/heavy splash Steel toe PVC work boot or latex overboot ADDITIONAL INFORMATION: Avoid restricted areas. Upgrade respirator as indicated by air monitoring, odor or irritation. Use Saranex® Coated Coveralls if splash hazard is present. ADDITIONAL MODIFICATIONS/ ENGINEERING CONTROLS/ INFORMATION: Monitor tanks for H2S, CO, LEL & O2. If H2S or O2 exceed action limits, upgrade to Level B or provide forced air ventilation to maintain safe levels Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 21 TASK DESCRIPTION: Task 2d. Manage Abandoned/Mismanaged Drums/Containers HAZARD ANALYSIS CONDUCTED BY: Jim Hollingsworth DATE: September 2, 2009 PHYSICAL HAZARD IDENTIFICATION: [X] PHYSICAL EXERTION [X] HEAT STRESS [o] COLD STRESS [X] HEAVY EQUIPMENT [X] FIRE HAZARDS [X] LIFTING HAZARDS [X] SLIP, TRIP, OR FALL [o] HIGH NOISE ( > 85 dBA ) [o] OVERHEAD UTILITIES [o] EXCAVATION/TRENCHING [o] CONFINED SPACE [o] POISONOUS PLANTS [X] POISONOUS/HAZARDOUS ANIMALS [o] ELECTRICAL [X] HAND/POWER TOOLS [X] PUNCTURE/LACERATION [o] OXYGEN DEFICIENT [o] PRESSURIZED CONTAINERS [X] EXPLOSIVE [o] VISIBILITY [X] VEHICLE TRAFFIC [o] WELDING, CUTTING, BRAZING [o] GLARE/LIGHT HAZARDS [X] SPLASH [o] GRINDING [o] FLYING DEBRIS [X] PINCH/GRAB/ROLL [o] TEMPERATURE HAZARDS [o] OTHER ( SPECIFY ) : Unstable Structures, Reactive Drums/Materials, CHEMICAL HAZARD IDENTIFICATION: [X] CORROSIVE [X] VOC’s [X] OXIDIZER [X] TOXIC [o] RADIOACTIVE [o] BIOLOGICAL [X] INERT [X] REACTIVE [X] FLAMMABLE [X] COMBUSTIBLE [X] NON-HAZARDOUS [o] POISON A (GAS) [o] OTHER ( SPECIFY ) : ______________ PERSONAL PROTECTIVE EQUIPMENT: LEVEL OF PROTECTION RESPIRATORY PROTECTION PROTECTIVE CLOTHING GLOVES HEAD/FACE/EYE PROTECTION FOOT PROTECTION PRIMARY: B Full-face, tight fitting Pressure demand Supplied air Respirator Tyvek QC® for closed transfer/incidental splash Saranex® Coverall or Apron for heavy splash Inner Latex or Nitrile Glove Outer Neoprene Nitrile, or PVC Glove Hard hat Face Shield for hose breaking/heavy splash Steel toe PVC work boot or latex overboot CONTINGENCY: B Full-face, tight fitting Pressure demand Supplied air Respirator Barricade® Coverall Inner Latex or Nitrile Glove Outer Neoprene Nitrile, PVC Glove Hard hat Face Shield for hose breaking/heavy splash Steel toe PVC work boot or latex overboot ADDITIONAL INFORMATION: Avoid restricted areas. Upgrade respirator as indicated by air monitoring, odor or irritation. SUSPEND WORK AND EVACUATE AREA IF LEVEL A CONDITIONS ARE IDENTIFIED. Use Barricade® Coated Coveralls if splash hazard is present. ADDITIONAL MODIFICATIONS/ ENGINEERING CONTROLS/ INFORMATION: Monitor work areas for Radiation, OV, H2S, CO, LEL & O2. If H2S or O2 exceed action limits, upgrade to Level B or provide forced air ventilation to maintain safe levels FOLLOW SAFE DRUM HANDLING PRACTICES. AVOID BULGING DRUMS, REACTIVE DRUMS, & POTENTIALLY UNSTABLE MATERIALS UNTIL ASSESSED BY CHEMIST OR HAZMAT SPECIALIST. SEE APPENDIX D. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 22 TASK DESCRIPTION: Task 3. Demobilization and Project Close-Out HAZARD ANALYSIS CONDUCTED BY: Jim Hollingsworth DATE: September 2, 2009 PHYSICAL HAZARD IDENTIFICATION: [X] PHYSICAL EXERTION [o] HEAT STRESS [o] COLD STRESS [o] HEAVY EQUIPMENT [X] FIRE HAZARDS [X] LIFTING HAZARDS [X] SLIP, TRIP, OR FALL [o] HIGH NOISE ( > 85 dBA ) [X] OVERHEAD UTILITIES [o] EXCAVATION/TRENCHING [o] CONFINED SPACE [o] POISONOUS PLANTS [X] POISONOUS/HAZARDOUS ANIMALS [X] ELECTRICAL [X] HAND/POWER TOOLS [X] PUNCTURE/LACERATION [o] OXYGEN DEFICIENT [o] PRESSURIZED CONTAINERS [o] EXPLOSIVE [o] VISIBILITY [X] VEHICLE TRAFFIC [o] WELDING, CUTTING, BRAZING [o] GLARE/LIGHT HAZARDS [o] SPLASH [o] GRINDING [o] FLYING DEBRIS [X] PINCH/GRAB/ROLL [o] TEMPERATURE HAZARDS [o] OTHER ( SPECIFY ) : CHEMICAL HAZARD IDENTIFICATION: [o] CORROSIVE [o] VOLATILE [o] OXIDIZER [o] TOXIC [o] RADIOACTIVE [o] BIOLOGICAL [o] INERT [o] REACTIVE [o] FLAMMABLE [o] COMBUSTIBLE [o] NON-HAZARDOUS [o] POISON A (GAS) [o] OTHER ( SPECIFY ) : PERSONAL PROTECTIVE EQUIPMENT: LEVEL OF PROTECTION RESPIRATORY PROTECTION PROTECTIVE CLOTHING GLOVES HEAD/FACE/EYE PROTECTION FOOT PROTECTION PRIMARY: D NA Appropriate work attire Leather or cotton work Hard hat, safety glasses w/ side shields Steel toe work boot CONTINGENCY: Modified D NA Tyvek® Coverall Leather or cotton work Hard hat, safety glasses w/ side shields Steel toe work boot ADDITIONAL INFORMATION: ADDITIONAL MODIFICATIONS/ ENGINEERING CONTROLS/ INFORMATION: Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 23 6.0 AIR MONITORING 6.1 PURPOSE Air monitoring will consist of an initial and periodic surveys of site conditions in the breathing zone of workers in intrusive areas of the site using real-time survey instrumentation. The primary purpose of this monitoring is to assess the safety of site, document the site conditions and provide for identification of potential for deteriorating (leaking containers) or otherwise hazardous (fire/explosion) conditions. The monitoring results may also be used to adjust the Level of personal protective equipment for a given area. Monitoring will consist of the use of a combustible gas/oxygen meter (e.g. Oxygen O2, LEL, CO, H2S), and an organic vapor monitor (e.g. Photo ionization Detector or Flame Ionization Detector). A general survey for radiation shall also be conducted. 6.2 PERIMETER AIR MONITORING Air monitoring along the perimeter will only be conducted in the event a hazmat release is experienced or if work area measurements indicate the potential for off site migration of significant emissions. 6.3 AIR MONITORING ACTION LIMITS Air monitoring action limits are as follows: PARAMETER MONITORING FREQUENCY/AREA ACTION LIMITS ACTIONS Oxygen (O2) Monitor all confined spaces and work areas O2 <20.9% ±0.3% O2 ≤19.5% Ventilate work area Suspend work. Evacuate area. Ventilate work area Combustible Gases Monitor all confined spaces and work areas >0% LEL ≥10% LEL Increase monitoring frequency Suspend work. Ventilate work area Carbon Monoxide Monitor all confined spaces and work areas >0 ppm ≥25 ppm Increase monitoring frequency Suspend work. Ventilate work area Hydrogen sulfide Monitor all confined spaces and work areas >0 ppm >10 ppm >20 ppm Increase monitoring frequency Suspend work. Ventilate work area Upgrade to Level B Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 24 PARAMETER MONITORING FREQUENCY/AREA ACTION LIMITS ACTIONS VOCs (10.6 eV Photoionization Detector) Monitor general work areas >0 ppm >5 ppm >25 ppm Increase monitoring frequency Upgrade to Level C Upgrade to Level B Radioactivity Conduct general site survey >2 mrem/hr Suspend work. Notify Safety Manager 7.0 SITE CONTROL 7.1 SUPPORT ZONE The support zone will be located in an area that has been determined contamination free or “clean” by supporting analytical data or other objective criteria. In this zone site break areas, toilet facilities, administrative, and other support functions will take place. Contaminated PPE and/ or equipment are prohibited in this area. 7.2 CONTAMINATION REDUCTION ZONE The contamination reduction zone (CRZ) is the area between the exclusion zone and support zone designated for equipment and personnel decontamination. The CRZ may also be a staging area for site tools, emergency equipment, containment equipment, additional PPE, sampling equipment, and air bottle changes. All personnel and/ or equipment exiting the exclusion zone must enter the CRZ for decontamination before entering the support zone. PPE dress outs must be accomplished in the support zone before entry into the CRZ. Contaminated PPE will remain in the CRZ or the exclusion zone until properly disposed. Mainly the distance needed to prevent a potential release, explosion, or other hazard in the exclusion zone from affecting personnel in the CRZ and support zone will determine the location and dimensions of the CRZ. A “clean break station” may be established to provide a rest area where personnel can partially decontaminate and take work breaks. 7.3 EXCLUSION ZONE The exclusion zone is the restricted area where it has been determined by supporting analytical and site characterizations that chemical and physical hazards exists and poses a risk to personnel. Only authorized personnel that meet all the requirements as stated in Section 1.0 “Introduction and Site Entry Requirements” of this HASP and other applicable requirements of 29 CFR 1910.120 are allowed entrance. The exclusion zone will be well delineated by means of orange fencing. Signs will be placed at the perimeter of the exclusion zone that are highly visible that states the hazard (i.e., WARNING CONTAMINATED AREA - KEEP OUT or HAZARDOUS WORK AREA - AUTHORIZED PERSONNEL ONLY). Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 25 7.4 BUDDY SYSTEM The Buddy System shall be used for all entries into the exclusion zone. This is a system of organizing employees into work teams in such a manner that each team member can observe the activities of each other. Thus, in case of an emergency, the entire team can account for the location and activity of each team member. 7.5 VISITORS All visitors will report to the Shamrock’s Supervisor and Haz-Mat/Kings Mtn immediately upon arrival. All visitors entering the CRZ or exclusion zones must provide all required training and medical monitoring documentation before arrival on-site, if possible. The Haz-Mat/Kings Mtn and Shamrock Environmental representative and the Project Manager/ Site Supervisor must approve the site visit and shall coordinate with the Site Safety Officer. The SSO shall establish a safe route through the site and away from on-going operations. All visitors will be escorted while on site. All visitors shall wear: 1. Steel-Toed Shoes with metatarsal guards 2. Hard-hat 3. Safety Glasses 4. White Tyvek (If Required) 7.6 SITE SECURITY Site security will be provided by customer. Work area security will be maintained by Haz-Mat Environmental and will include: 1. Protecting unauthorized personnel from site physical hazards or chemical exposure 2. Preventing unauthorized personnel from entering exclusion zone 3. Prevent theft or vandalism of company equipment 4. Notify emergency agencies in case of a fire, explosion, or release after work hours. 5. Maintain site surveillance 6. To ensure all visitors are approved and have valid purpose for entering the site. 7. To ensure that all visitors are escorted 7.7 SITE MAPS Site maps will be available and posted showing designated work areas, escape routes, emergency assembly areas, hazardous and utility layouts. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 26 7.8 SITE COMMUNICATION A two-way communication system will be established on site. One net will include an internal communication standard for on-site personnel and the other will be an external communication net for use between on-site and off-site personnel. The internal communication will be used to alert all on-site personnel to potential emergencies. Safety information (such as the current time, the amount of time already spent in the exclusion zone, next air tank change-out, heat stress check, etc.) is also sent out on this net. Common internal communication devices can range from radios to hand/ visual signals. To be effective, all communication commands must be prearranged and all signals recognized by all on-site personnel in advance. The external communication will be used to coordinate outside emergency response, report to management, and maintain contact with essential off-site personnel. This net is essential to provide personnel access to medical and emergency services. Telephones, either landline or cellular, are used to establish this external net. 7.9 SITE INSPECTIONS The Site Safety Officer or Site Supervisor will conduct site inspections formally on a weekly basis, informally on a daily basis. The Site Supervisor can also conduct site inspections. All formal inspections will be documented and kept on job file for review by Corporate Health and Safety. 7.10 TRAFFIC CONTROL The Site Supervisor/ SSO shall ensure that traffic patterns and roadways are designed and operated in a manner that minimizes the potential for vehicle related accidents. Key elements that will be considered and reviewed include: • Minimize the potential for operating vehicles in reverse (i.e., backing) • Avoid traffic patterns with head-on traffic patterns. Where practical, establish traffic patterns that are circular. • Minimize intersections when creating traffic plans. • Avoid areas with overhead obstructions. Where overhead obstructions cannot be avoided, post warning signs and/ or construct warning devices. Warning devices are recommended where traffic includes the use of dump trucks. • Maintain safe vehicle speeds. Slower traffic speeds should be required at intersections, in curves and in areas where pedestrian traffic is common. • Instruct all drivers on proper procedures and speed limits. • Spotters will be used during unloading operations. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 27 To ensure adequate control of traffic, all vehicles entering the Shamrock’s work site shall be required to check in with Shamrock’s personnel. Only authorized vehicles will be allowed beyond the support zone area. All vehicles that enter a potentially contaminated area shall be decontaminated before leaving the site. 8.0 DECONTAMINATION The decontamination process is designed to remove any contamination acquired in the exclusion zone and to keep the spread of contaminated materials from entering the support (clean) area. Care must be exercised to ensure that contaminants are removed from personnel and equipment before the personnel or equipment leaving the site. The decontamination line should extend from the exclusion zone boundary line to the entrance of the support zone. 8.1 PERSONNEL DECONTAMINATION Dry decontamination is the preferred method for Shamrock’s personnel. This method of decontamination involves the removal of contaminated layers of personal protective clothing. If dry decontamination is deemed ineffective or needs to be supplemented, boots will be decontaminated by using a wet method “boot wash” station located at the CRZ. The boot wash will be comprised of two large washtubs. The first tub will be filled with water and soap solution and a brush to remove gross contamination. The second washtub will be a rinse. Preferably the boots will then be taken off and left inside the CRZ area. Once completed, personnel will exit the zone free of contamination. An emergency eyewash will be located at the CRZ in the event that an emergency decontamination is needed. Once all the gross contamination has been removed the affected personnel shall fully decontaminate and exit through the CRZ. All site employees will wash hands and face before leaving the decontamination area. Site personnel shall assist with the emergency decontamination only if they are themselves protected from exposure. The Site Supervisor/ SSO will be notified immediately of any emergency. 8.2 EQUIPMENT DECONTAMINATION Equipment and vehicle decontamination is achieved with wet decontamination methods. This form of decontamination usually involves the use of high-pressure washers. Due to the water generated by this procedure, a wastewater containment area must be constructed. All wastewater generated will be collected for proper disposal. Specific solutions will be on-hand to help decontaminate equipment. It is not anticipated that wet decontamination will be needed during this phase of the work. 8.3 DECONTAMINATION EQUIPMENT [X] Plastic Sheeting [X] Disposable Plastic Bags [X] Pools [X] Buckets [X] Trash Containers [X] Wash Basins Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 28 [X] Brushes [ ] Shower/ Decon Trailer [X] Sprayers [X] Remote Air Bottle for SCBA Change-out 9.0 SANITARY FACILITIES AND LIGHTING REQUIREMENTS Temporary or off-site sanitary facilities will be provided on all Shamrock’s job sites. The requirements for sanitary facilities on site will meet all applicable standards found in CFR 29 1910.120 (n) (3) and the Shamrock’s operating procedure. TOILET FACILITIES Number of employees Minimum number of facilities 20 or fewer One More than 20, fewer than 200 employees One toilet seat and one urinal per 40 More than 200 employees One toilet seat and one urinal per 50 For this project, one sanitary facility shall be provided for every 15 employees and, if necessary, a separate facility for females. Lighting on job sites will meet all applicable standards found in 29 CFR 1910.120 (m). Minimum illumination on job sites will be at 5-foot candles for work areas and 3-foot candles for excavations. 10.0 CONTINGENCY PLAN 10.1 CONTINGENCY PLAN ACTIVATION The Shamrock’s contingency plan may be activated by the following conditions: 1. An injury occurs in any of the zones. 2. A chemical hazard action level is reached or an air monitor alarm sounds. 3. Someone observes the development of an IDLH situation. 4. An unknown odor is detected. 5. There is a security breach and/ or presence of unauthorized personnel. 6. There is a weather-related emergency. 7. There is a major release, explosion, or fire. In case of an emergency, the following equipment will be used to alert on-site personnel. 1. Portable radio communications or, 2. Portable air horns. If this is used, the following alarm signals will be used: 1 Blast - Attention, Contact command post 2 Blasts - Emergency, Assemble at decontamination line. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 29 3 Blasts - General Emergency, Evacuate site immediately and meet at designated assembly area. The designated assembly areas and emergency evacuation routes will be established and posted. All personnel on site will be briefed on all emergency procedures as part of the initial safety briefing. 10.2 EMERGENCY PROCEDURES CRZ or Exclusion Zone Injury: Operations will cease and area will be cleared for emergency personnel. Rescue team designated by SSO will retrieve injured personnel and will decontaminate to the extent possible before movement to support zone. If condition is serious, at least a partial decontamination will be completed. First aid will be administered until professional medical assistance arrives. If movement will aggravate the injury, then the injured personnel will be left in place. If the injured personnel are at a greater risk inside the exclusion zone or emergency personnel are not able to enter the zone, then movement of the injured personnel becomes unavoidable. Care will be exercised to prevent spread of contamination. A copy of the suspected contaminants is to be provided to the responding medical team for transport back to the hospital. NOTE: Rescue of downed personnel where the reason of that occurrence is not known will be performed in the next higher level of PPE. Support Zone Injury: SSO and PM will assess the nature of the injury. If injury does not affect performance of personnel, operations may continue. If injury increases risk to others, operations will cease, until risk is removed or minimized. PPE Failure: The event of PPE failure or alteration, that person and his/ her buddy will immediately leave the exclusion zone and assemble at the decontamination line. Re- Entry will not be permitted until the equipment has been repaired or replaced. Other Equipment Failure: In the event of equipment failure other than PPE, the SSO and PM shall determine if the problem affects the safety of personnel or prevents the safe completion of the tasks. If which case the operation shall cease until repairs/ replacements are made and the risk to safety is removed. Fire or Explosion: Operations will cease and personnel will assemble at the decontamination line or the designated assembly area depending on the alarm given. The SSO and the PM will determine if the fire can be suppressed. If the fire is small and safety is not endangered, a team of properly equipped personnel will make entry to secure the situation. If the event is uncontrollable, all personnel will be evacuated and the proper authorities will be notified. Shamrock’s personnel may assist firefighters if required as well as all emergency responders, with information related to the incident. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 30 Spill, Leak or Release: Operations will cease and the designated suppression personnel will assemble at the upwind vapor suppression area. All other non-essential personnel in the area will meet at the decontamination line or the designated assembly area depending on the alarm given. The SSO and PM will attempt to determine the nature and extent of the release by air monitoring readings taken by Shamrock’s personnel. The SSO or PM will direct the assembled team to contain the release or spill by the appropriate method. The SSO or PM will direct the suppression crew in making the necessary attempts to stop the release and initiate clean up operations. Operations will remain suspended until the incident is stabilized and no longer poses a threat to personnel. The SSO or PM will notify the Fire and Police Department in the unlikely event that a chemical release has migrated off site and that it is an immediate threat to the surrounding community. All incidents and accidents will be reported to the Haz-Mat/Kings Mtn representative as well as Shamrock’s management. 10.3 EMERGENCY EQUIPMENT The following equipment will be located on the job site: • First Aid Kit (Crew truck) • ABC Dry Chemical Fire Extinguishers, located at Crew Truck as well as throughout the site. [o] Carbon Dioxide Fire Extinguisher [X] Purple K Fire Extinguisher [X] Chemical Sorbents Pads and Booms [X] Additional PPE and SCBA [o] Portable Communication Radios [X] Portable Air Horns [o] USCG Approved PFD [o] Rescue Skiff [o] Life Ring w/ Rope Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 31 10.4 EMERGENCY TELEPHONE NUMBERS CHEMTREC 800-424-9300 National Response Center 800-424-8802 National Poison Control Center 800-962-1253 Federal Emergency Management Agency 202-646-2400 Centers for Disease Control 404-488-4100 (24HR) United States Coast Guard 804-441-3516 AT&F (Explosives Information) 800-424-9555 Shamrock’s Environmental, Inc. - Greensboro 800-881-1098 (24HR) Fire Department - 911 Police Department - 911 Ambulance Service 911 (*) Hospital: Gaston Memorial Hospital (704) 834-2000 2525 Court Dr Gastonia, NC 28054 (*) The above emergency agencies shall be contacted and notified on the specific hazards on this project. Coordination for special emergency response requirements with these agencies shall be completed upon arrival. 10.5 DIRECTIONS TO HOSPITAL The location of the hospital is indicated in Appendix A. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 © 2009 Shamrock Environmental Corp 32 11.0 SITE SAFETY PLAN REVIEW AND DOCUMENTATION I have been briefed on and understand this site safety plan. I have been informed of the personnel to contact if I have any questions and know where to report any additional health and safety hazards. I agree to work to the safety plan guidelines and understand that failure to do so could result in removal from the site and/ or termination. DATE PRINTED NAME SIGNATURE ORGANIZATION Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 APPENDIX A HOSPITAL LOCATION Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 HOSPITAL LOCATION/ROUTE N Main St Lowell, NC 28098 1. Head south on N Main St toward Lineberger St 2. Turn right at W 1st St 3. Continue on Lowell Rd/NC-7 4. Turn left at Cox Rd 5. Turn right at Ct Dr Gaston Memorial Hospital 2525 Court Dr Gastonia, NC 28054 (704) 834-2000 Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 APPENDIX B SITE SAFETY FORMS Instructions: Conduct a safety meeting daily prior to beginning each day’s site activities. Attendance by all site personnel is mandatory. Complete form by checking off specific topics covered during that meeting. Obtain signatures from all Shamrock employees, subcontractor employees, Client Rep’s, etc. Submit originals to the Job File at the end of the Project. SHAMROCK ENVIRONMENTAL CORP. Daily Safety Meeting Log Project Name: Date / Time: Location: Project No: Meeting conducted by: Check the topics covered in this meeting: ! Daily work scope ! SHSP review and location ! Location / directions to closest hospital Emer Rm ! Unanticipated emergency – notification / procedures ! Fire extinguisher locations ! First aid kit location ! Eyewash station location ! Buddy system assignments ! Designated work zones ! Special Permits: CSE, Hot Work, Lockout, etc ! Air monitoring results / requirements ! Decon procedures ! Eating, drinking and smoking in designated break area ! Hazard Communication - MSDS location ! Vehicle safety, inspections, driving conditions ! Hard hat, safety glasses, steel toe work boots ! Back injury prevention ! Noise and hearing loss ! Slip, trip and fall hazards ! Housekeeping ! Electrical hazards, extension cords and GFI’s ! Lock and tag-out, isolation from hazardous energy ! Heavy equipment inspection and operation ! Utility location and marking ! Excavations and trenches – entry requirements ! Rigging and hoisting Discussion/Comments/Follow-up Action: Employee No. or Name Signature Company Name Instructions: Conduct a safety meeting daily prior to beginning each day’s site activities. Attendance by all site personnel is mandatory. Complete form by checking off specific topics covered during that meeting. Obtain signatures from all Shamrock employees, subcontractor employees, Client Rep’s, etc. Submit originals to the Job File at the end of the Project. SHAMROCK ENVIRONMENTAL CORP. Daily Safety Meeting Log Attendance Record Continued Date: Employee No. or Name Signature Company Name AIR MONITORING INSTRUMENT CALIBRATION LOG Instrument Information Instrument Type: □ CGI/O2 □ 4-Gas Meter □ PID (_____ eV) □ Other:___________ Model: Serial #: SEC Unit #: Calibration Data Sensor Date Zero Span Span Span Span Adjustments/Comments Calibrated By AIR MONITORING LOG – REAL-TIME MONITORING INSTRUMENTS Project Information Project Name: Project No: Instruments Used: Calibration OK? □ Yes □ No, If no, describe corrective action: Site Conditions/Comments: Monitoring Data Date: Parameter Time Log Point Wind Direction Reading Reading Reading Reading Reading Initials Supervisor’s Incident/Accident Report Page 1 of 2 Supervisor’s Incident/Accident Investigation Report Part I: General Information Employee Name: Division: Location: Employee No: Date of Incident: Hour: am/pm Exact Location: Name of Witness: Division: Part II: Description of Incident/Accident Summarize the incident, providing details: Part III: Cause of Incident/Accident Determine the cause(s) by analyzing all factors involved. A. Describe any Unsafe Acts: Supervisor’s Incident/Accident Report Page 2 of 2 B. Describe any Unsafe Conditions: Part IV: Corrective Action Taken Summarize actions taken and recommendations made to prevent a similar incident or recurrence of the same incident/accident. Before completing this section, review the steps identified in the instructions. If no actions have been taken, Provide reason: Signatures: Supervisor HSO Date Report Prepared: ‰ Check if additional sheets/information attached. Shamrock Environmental Corporation Employee Report of Accident/Illness Department: Location: Name: Employee Number: Home Address: City/State/Zip: Tel No.: Age: ‰ M ‰ F Occupation: Total Experience This Occupation: Years Months Date of Accident: Time: ‰ a.m. ‰ p.m. Location of Accident: Describe The Accident (use or additional sheet as needed): Describe The Injury Including Part of the Body Affected: Did You Report Accident? ‰ Y ‰ N To Whom? When? Did anyone witness the accident? ‰ Y ‰ N Whom? Was First Aid Or Medical Treatment Provided? ‰ Y ‰ N By Whom? Did an Unsafe Condition Cause or Contribute To This Accident? ‰ Y ‰ N If So, Please Describe This Condition: Was This Condition Previously Reported? ‰ Y ‰ N If So By Whom/When? Employee's Signature: Date: Review By: Date: WITNESS FORM NAME AGE ADDRESS PHONE MARITAL STATUS OCCUPATION DATE ACCIDENT WITNESSED TIME LOCATION OF ACCIDENT MY POSITION AT TIME OF ACCIDENT MY LOCATION AT TIME OF ACCIDENT NARRATIVE REPORT Describe in your own words what happened. (What did you see, hear, smell, do, etc.): I have read the above report and it is true and correct to the best of my knowledge. I do not recall any other facts of this accident. (Signature of witness) (date) 1 of 5 Supervisor Site Safety Inspection Checklist Project Name: Project Number: Project Location: Site Supervisor: Auditor’s Name: MEDICAL AND FIRST AID YES NO N/A 1. Are First Aid Kits accessible and identified? _____ _____ _____ 2. Are emergency eye wash and safety showers available? _____ _____ _____ 3. Are First Aid Kits inspected weekly? _____ _____ _____ PERSONAL PROTECTIVE EQUIPMENT 1. Have levels of personnel protection been established? _____ _____ _____ 2. Do all employees know their level of protection? _____ _____ _____ 3. Are respirators decontaminated, inspected, and _____ _____ _____ stored according to standard procedures? 4. Have employees been fit-tested? _____ _____ _____ 5. Is defective personal protective equipment tagged? _____ _____ _____ 6. Does compressed breathing air meet CGA Grade "D" _____ _____ _____ minimum? 7. Are there sufficient quantities of safety equipment _____ _____ _____ and repair parts? 8. Does Level D protection consist of safety glasses, _____ _____ _____ hard hats, and steel toe boots? FIRE PREVENTION 1. Is smoking prohibited in flammable storage areas? _____ _____ _____ 2. Are fire lanes established and maintained? _____ _____ _____ 3. Are flammable dispensing systems grounded and bonded? _____ _____ _____ 4. Are approved safety cans available for storage of _____ _____ _____ flammable liquids? 5. Has the local fire department been contacted? _____ _____ _____ 6. Are fire extinguishers available near refueling areas? _____ _____ _____ AIR MONITORING 1. Is air monitoring being conducted as required by the _____ _____ _____ site safety plan? 2. Are air monitoring instruments calibrated daily? _____ _____ _____ 3. Is the air monitoring logbooks up to date? _____ _____ _____ 4. Are user manuals available? _____ _____ _____ 5. Are instruments clean and charged? _____ _____ _____ 2 of 5 WELDING AND CUTTING (29 CFR 1926 Subpart J) YES NO N/A 1. Are fire extinguishers present at welding and cutting operations? _____ _____ _____ 2. Are confined spaces; such as, tanks, pipelines, and trenches; tested prior to cutting and welding operations? _____ _____ _____ 3. Are Hot Work Permits available? _____ _____ _____ 4. Are proper helmets, goggles, aprons, and gloves available for welding and cutting operations? _____ _____ _____ 5. Are welding machines properly grounded? _____ _____ _____ 6. Are oxygen and fuel gas cylinders stored a minimum of 20 feet apart? _____ _____ _____ 7. Are only trained personnel permitted to operate welding and cutting _____ _____ _____ equipment? HAND AND POWER TOOLS (29 CFR 1926 Subpart I) 1. Are defective hand and power tools tagged and taken out of service? _____ _____ _____ 2. Is eye protection available and used when operating power tools? _____ _____ _____ 3. Are guards and safety devices in place on power tools? _____ _____ _____ 4. Are power tools inspected before each use? _____ _____ _____ 5. Are non-sparking tools available? _____ _____ _____ MOTOR VEHICLES 1. Are vehicles inspected daily? _____ _____ _____ 2. Are personnel licensed for the equipment they operate? _____ _____ _____ 3. Are unsafe vehicles tagged and reported to supervision? _____ _____ _____ 4. Are vehicles shut down before fueling? _____ _____ _____ 5. When backing vehicles, are spotters provided? _____ _____ _____ 6. Is safety equipment on vehicles? _____ _____ _____ 7. Are loads secure on vehicles? _____ _____ _____ 8. Are vehicle occupants using safety belts if provided? _____ _____ _____ EMERGENCY PLANS 1. Are emergency telephone numbers posted? _____ _____ _____ 2. Have emergency escape routes been designated? _____ _____ _____ 3. Are employees familiar with the emergency signal? _____ _____ _____ 4. Has the emergency route to the hospital been established and posted? _____ _____ _____ MATERIALS HANDLING 1. Are materials stacked and stored as to prevent sliding or collapsing? _____ _____ _____ 2. Are flammables and combustibles stored in non-smoking areas? _____ _____ _____ 3. Is machinery braced when personnel are performing maintenance? _____ _____ _____ 4. Are tripping hazards labeled? _____ _____ _____ 5. Are semi-trailers chocked? _____ _____ _____ 6. Are fixed jacks used under semi-trailers? _____ _____ _____ 7. Are riders prohibited on materials handling equipment? _____ _____ _____ 8. Are cranes inspected as prescribed and logged? _____ _____ _____ 9. Are OSHA approved manlifts provided for the lifting of personnel? 10. Are personnel in manlifts wearing approved fall protection devices? _____ _____ _____ FIRE PROTECTION 1. Has a fire alarm been established? _____ _____ _____ 2. Do employees know the location and use of all fire extinguishers? _____ _____ _____ 3. Are fire extinguisher locations marked? _____ _____ _____ 3 of 5 FIRE PROTECTION (Continued) YES NO N/A 4. Are combustible materials segregated from open flames? _____ _____ _____ 5. Have fire extinguishers been professionally inspected during the last year? _____ _____ _____ 6. Are fire extinguishers visually inspected monthly? _____ _____ _____ ELECTRICAL (29 CFR 1926 Subpart K) 1. Is electrical equipment and wiring properly guarded? _____ _____ _____ 2. Are electrical lines, extension cords, and cables guarded and maintained in good conditions? _____ _____ _____ 3. Are extension cords kept out of wet areas? _____ _____ _____ 4. Is damaged electrical equipment tagged and taken out of service? _____ _____ _____ 5. Have underground electrical lines been identified by proper authorities? _____ _____ _____ 6. Has positive lock-out system been established by a certified project electrician? _____ _____ _____ 7. Are GFCI's being used as needed? _____ _____ _____ 8. Are extension cords being inspected daily for ground continuity and structural integrity? (i.e., group pin in place, no unapproved splices) _____ _____ _____ 9. Are warning signs exhibited on high voltage equipment (250V or greater)? _____ _____ _____ 10. Is extension cord inspection documented? CRANES AND RIGGING (29 CFR 1926.550) 1. Are cranes inspected daily? _____ _____ _____ 2. Are crane swing areas barricaded or demarked? _____ _____ _____ 3. Is all rigging equipment tagged with an identification number and rated capacity? _____ _____ _____ 4. Is rigging equipment inspection documented? _____ _____ _____ 5. Are slings, chains, and rigging inspected before each use? _____ _____ _____ 6. Are damaged slings, chains, and rigging tagged and taken out of service? _____ _____ _____ 7. Are slings padded or protected from sharp corners? _____ _____ _____ 8. Do employees keep clear of suspended loads? _____ _____ _____ 9. Are employees in the lift area wearing hard hats? _____ _____ _____ COMPRESSED GAS CYLINDERS 1. Are breathing air cylinders charged only to prescribed pressures? _____ _____ _____ 2. Are like cylinders segregated in well ventilated areas? _____ _____ _____ 3. Is smoking prohibited in cylinder storage areas? _____ _____ _____ 4. Are cylinders stored secure and upright? _____ _____ _____ 5. Are cylinders protected from snow, rain, etc.? _____ _____ _____ 6. Are cylinder caps in place before cylinders are moved? _____ _____ _____ 7. Are fuel gas and oxygen cylinders stored a minimum of 20 feet apart? _____ _____ _____ 8. Are propane cylinders stored and used outside the structure? _____ _____ _____ SCAFFOLDING (29 CFR 1926.451) 1. Is scaffolding placed on a flat, firm surface? _____ _____ _____ 2. Are scaffold planks free of mud, ice, grease, etc.? _____ _____ _____ 3. Is scaffolding inspected before each use? _____ _____ _____ 4. Are defective scaffold parts taken out of service? _____ _____ _____ 5. Does mobile scaffold height exceed 4 times the width or base dimension? _____ _____ _____ 6. Does scaffold planking overlap a minimum of 12 inches? _____ _____ _____ 7. Does scaffold planking extend over end supports between 6 to 18 inches? _____ _____ _____ 8. Are employees restricted from working on scaffolds during storms and high winds? _____ _____ _____ 9. Are all pins in place and wheels locked? _____ _____ _____ 10. Is perimeter guarding (top rail, mid rail, and toe board) present? _____ _____ _____ 4 of 5 WALKING AND WORKING SURFACES YES NO N/A 1. Are ladders a Type I or industrial? _____ _____ _____ 2. Are accessways, stairways, ramps, and ladders clean of ice, mud, snow, or debris? _____ _____ _____ 3. Are ladders being used in a safe manner? _____ _____ _____ 4. Are ladders kept out of passageways, doors, or driveways? _____ _____ _____ 5. Are broken or damaged ladders tagged and taken out of service? _____ _____ _____ 6. Are metal ladders prohibited in electrical service? _____ _____ _____ 7. Are stairways and floor openings guarded? _____ _____ _____ 8. Are safety feet installed on straight and extension ladders? _____ _____ _____ 9. Is general housekeeping up to Company standards? _____ _____ _____ 10. Are ladders tied off? _____ _____ _____ SITE SAFETY PLAN 1. Is a site safety plan available on site or accessible to all employees? _____ _____ _____ 2. Does the safety plan accurately reflect site conditions and tasks? _____ _____ _____ 3. Have potential hazards been described to employees on site? _____ _____ _____ 4. Is there a designated safety official on site? _____ _____ _____ 5. Have all employees signed the acknowledgment form? _____ _____ _____ SITE POSTERS 1. Are the following documents posted in a prominent and accessible area? A. Minimum Wage _____ _____ B. OSHA Health and Safety _____ _____ C. Equal Employment Opportunity _____ _____ SITE CONTROL 1. Are work zones clearly defined? _____ _____ _____ 2. Are support trailers located to minimize exposure from _____ _____ _____ a potential release? 3. Are support trailers accessible for approach by emergency vehicles? _____ _____ _____ 4. Is the site properly secured during and after work hours? _____ _____ _____ HEAVY EQUIPMENT (29 CFR 1926 Subpart O) 1. Is heavy equipment inspected as prescribed by the manufacturer? _____ _____ _____ 2. Is defective heavy equipment tagged and taken out of service? _____ _____ _____ 3. Are project roads and structures inspected for load capacities and proper clearances? _____ _____ _____ 4. Is heavy equipment shut down for fueling and maintenance? _____ _____ _____ 5. Are back-up alarms installed and working on equipment? _____ _____ _____ 6. Are designated operators only operating equipment? _____ _____ _____ 7. Are riders prohibited on heavy equipment? _____ _____ _____ 8. Are guards and safety appliances in place and used? _____ _____ _____ EXCAVATION (29 CFR 1926 Subpart P) 1. Has a "competent person" been designated to supervise this excavation activity? _____ _____ _____ 2. Have utility companies been advised of excavation activities? _____ _____ _____ 3. Prior to opening excavations, are utilities located and marked? _____ _____ _____ 4. Has a professional engineer evaluated all excavations greater than 20 feet deep? _____ _____ _____ 5. Is there rescue equipment on-site and accessible to excavation? _____ _____ _____ 6. Is excavated material placed a minimum of 24 inches from the excavations? _____ _____ _____ 7. Are the sides of excavations sloped or shored to prevent caving in on employees? _____ _____ _____ 5 of 5 EXCAVATION (29 CFR 1926 Subpart P - Continued) YES NO N/A 8. Has excavation greater than 4-feet deep been monitored for hazardous atmospheres (i.e. LEL/02 deficiency)? _____ _____ _____ 9. Are ladders used in excavations over 4-feet deep? _____ _____ _____ 10. Are ladders present every 25 feet? _____ _____ _____ 11. Are barriers, i.e. guardrails or fences placed around excavations near pedestrian or vehicle thoroughfares? _____ _____ _____ 12. Is excavation inspected daily by competent persons and documented? _____ _____ _____ CONFINED SPACES (Proposed Regulation 29 CFR 1910.146) 1. Have employees been trained in the hazards of confined spaces? _____ _____ _____ 2. Are confined space permits available on project site? _____ _____ _____ 3. Is the contractors confined space safety procedure on the project? _____ _____ _____ 4. Has a rescue plan been established? _____ _____ _____ PERSONNEL DECONTAMINATION 1. Are decontamination stations set up on site? _____ _____ _____ 2. Are waste receptacles available for contaminated clothing? _____ _____ _____ 3. Are steps taken to contain liquids used for decontamination? _____ _____ _____ 4. Have decontamination steps and procedures been covered by the _____ _____ _____ site supervisor or safety official? 5. Is all personal protective equipment and respiratory equipment _____ _____ _____ being cleaned on a daily basis? EQUIPMENT DECONTAMINATION 1. Has equipment decontamination been established? _____ _____ _____ 2. Is contamination wash water properly contained and disposed of? _____ _____ _____ 3. Are all pieces of equipment inspected for proper decontamination _____ _____ _____ before leaving the site? 4. Is all equipment being cleaned on a daily basis? _____ _____ _____ HAZARD COMMUNICATION (29 CFR 1926.59) 1. Is there a written program on-site? _____ _____ _____ 2. Is there a MSDS FOR EACH HAZARDOUS CHEMICAL present on-site? _____ _____ _____ 3. Are all containers properly labeled, as to content, hazard? _____ _____ _____ 4. Have employees been trained on chemical hazards? _____ _____ _____ 5. Are employee's trained on chemical hazards while doing non-routine tasks? _____ _____ _____ 6. Do employees (including subcontractors) know and understand the acute and chemical effects of exposure from the chemicals on-site? _____ _____ _____ 7. Have all subcontractors signed the Haz-Comm acknowledgment form? _____ _____ _____ Signature Date Site Supervisor: _________________________________ _________ Project Manager: _________________________________ _________ Auditor: _________________________________ _________ Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 APPENDIX C MATERIAL SAFETY DATA SHEETS ♣ Gasoline ♣ Motor Oil ♣ Hydraulic Oil ♣ Diesel Fuel Material Safety Data Sheet Collection Genium Publishing Corp. 1171 RiverFront Center Amsterdam, NY 12010 (518) 842-4111 Diesel Fuel Oil No. 2-D DIE1400 Temp: was 0470.html Issue Date: 2003-02 Copyright © 2003 by Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Judgments as to the suitability of information herein for the purchaser’s purposes are necessarily the purchaser’s responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser’s intended purpose or for consequences of its use. Section 1 - Chemical Product and Company Identification 51/57 Material Name: Diesel Fuel Oil No. 2-D CAS Number: 68334-30-5 Chemical Formula: Un Structural Chemical Formula: Unspecified; variable EINECS Number: 269-822-7 Synonyms: AUTOMOTIVE DIESEL OIL; DIESEL FUEL; DIESEL FUEL OIL NO. 2-D; DIESEL OIL (PETROLEUM); DIESEL OILS; DIESEL TEST FUEL; FUELS,DIESEL; OLEJ NAPEDOWY III; SANTOS MOOMBA DISTILLATE Derivation: Fuel oil may be a distilled fraction of petroleum, a residuum from refinery operations, a crude petroleum or a blend of two or more of these. General Use: This medium viscosity residual fuel oil has both light and heavy grades, and is used in furnaces and boilers of utility and industrial power plants, ships, locomotives, and metallurgical operations. Section 2 - Composition / Information on Ingredients Name CAS % Diesel fuel oil no. 2-D 68334-30-5 ca 100% vol; diesel fuels consist primarily of aliphatic (64% vol), aromatic (35% vol), and olefinic (1-2% vol) hydrocarbons. Trace Impurities: May contain sulfur (< 0.5 ), benzene (<100 ppm), and additives such as sulfurized esters. OSHA PEL No data found. ACGIH TLV TWA: 100 mg/m3; as total hydrocarbons, skin. NIOSH REL No data found. Section 3 - Hazards Identification 0 2 0 — Fire Diamond 01234 Flammability Toxicity Body Contact Reactivity Chronic ChemWatch Hazard Ratings Min Low Moderate High Extreme 1 0 2 HMIS Health Flammability Reactivity ANSI Signal Word Warning! Flammable Emergency Overview Diesel fuel oil no. 2-D is a brown, slightly viscous liquid with a kerosene-like odor. It is irritating to the skin and respiratory tract. Inhalation of mist or vapor may result in headache, nausea, vomiting, diarrhea, central nervous system (CNS) depression, tachycardia (rapid heart beat), cyanosis (blue coloration of skin due to oxygen deficiency), pulmonary edema (fluid in the lungs), and liver or kidney injury. Diesel fuel oil no. 2-D is an environmental hazard when spilled. When exposed to heat or flame, this flammable liquid is a fire hazard. When heated to decomposition, diesel fuel oil no. 2-D will emit acrid smoke and irritating vapors. Potential Health Effects Target Organs: Skin, CNS, cardiovascular system (CVS), respiratory system, liver, kidneys Primary Entry Routes: Inhalation, ingestion, skin contact/absorption Acute Effects Inhalation: Euphoria, respiratory irritation, cardiac dysrhythmia, increased respiration rates, cyanosis, pulmonary edema, hemoptysis (spitting up blood from the respiratory tract), respiratory arrest, renal (kidney) and liver injury, and CNS toxicity can result from inhalation of diesel fuel oil no. 2-D mist or vapor. Eye: Contact may result in irritation. 2003-02 Diesel Fuel Oil No. 2-D DIE1400 Copyright © 2003 Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Page 2 of 4 Skin: Contact may cause irritation, systemic effects (see Inhalation), and block the sebaceous (oil) glands, resulting in a rash of acne-like pimples and spots, usually on the arms and legs. Ingestion: Gastrointestinal irritation, vomiting, diarrhea, and in severe cases, CNS depression progressing to coma and death and other systemic effects (see Inhalation) can result. Aspiration can result in transient CNS depression or excitement, hypoxia, infection, pneumatocele (abnormal cavities in lungs) formation, and chronic lung dysfunction. Carcinogenicity: NTP - Not listed; IARC - Group 3, Not classifiable as to carcinogenicity to humans; OSHA - Not listed; NIOSH - Not listed; ACGIH - Not listed; EPA - Not listed; MAK - Not listed. Medical Conditions Aggravated by Long-Term Exposure: None reported. Chronic Effects: Prolonged or repeated skin contact causes dermatitis and possible systemic toxicity. Prolonged or repeated inhalation can cause CNS and peripheral nervous system damage. Section 4 - First Aid Measures Inhalation: Remove exposed person to fresh air and support breathing as needed. Eye Contact: Do not allow victim to rub or keep eyes tightly shut. Gently lift eyelids and flush immediately and continuously with flooding amounts of water for at least 15 minutes. Consult a physician or ophthalmologist if pain and/or irritation develops. Skin Contact: Quickly remove contaminated clothing. Rinse with flooding amounts of water followed by washing the exposed area with soap and water. For reddened or blistered skin, consult a physician. Ingestion: Never give anything by mouth to an unconscious or convulsing person. Have the conscious and alert person drink 1 to 2 glasses of water. Contact a poison control center. Because of aspiration risk, do not induce vomiting unless the poison control center advises otherwise. After first aid, get appropriate in-plant, paramedic, or community medical support. Note to Physicians: Gastric lavage is contraindicated due to aspiration risk. Instead, consider administration of charcoal or milk. If ingestion amount is large, gastric emptying in the alert patient can be accomplished through administration of Syrup of Ipecac. Treat overexposure symptomatically and supportively. Section 5 - Fire-Fighting Measures Flash Point: 100.4 °F (38 °C), Closed Cup Autoignition Temperature: 351-624 °F (177-329 °C) LEL: 1.3% v/v UEL: 75% v/v Flammability Classification: OSHA Class II Combustible Liquid Extinguishing Media: Use dry chemical, carbon dioxide, foam, low velocity water fog or spray. Use a smothering technique to extinguish fire. Water may be ineffective in putting out a fire involving diesel fuel oil no. 2-D, and a solid water stream may spread the flames; however, a water spray may be used to cool fire-exposed containers, and flush spills away from ignition sources. General Fire Hazards/Hazardous Combustion Products: Heating diesel fuel oil no. 2-D to decomposition can produce acrid smoke and irritating vapors. Vapor or mist can form explosive mixtures in air. In still air, the heavier- than-air vapors of diesel fuel oil no. 2-D from a large source may travel along low-lying surfaces to distant sources of ignition and flash back to the material source. Containers may explode in heat of fire. Fire-Fighting Instructions: Do not release runoff from fire control methods to sewers or waterways. Because fire may produce toxic thermal decomposition products, wear a self-contained breathing apparatus (SCBA) with a full facepiece operated in pressure-demand or positive-pressure mode. Section 6 - Accidental Release Measures Spill/Leak Procedures: Eliminate all ignition sources (no smoking, flares, sparks or flames in immediate area). Ground all equipment used when handling this product. Do not touch or walk through spilled material. Stop leak if you can do it without risk. Prevent entry into waterways, sewers, basements or confined areas. A fire fighting foam may be used to suppress vapors. Absorb or cover with dry earth, sand or other non-combustible material and transfer to containers. Use clean non-sparking tools to collect absorbed material. Small Spills: Absorb diesel fuel oil no. 2-D with vermiculite, earth, sand or similar material. Large Spills: For large spills, consider downwind evacuation of at least 1000 ft (300 m). Dike far ahead of liquid spill for later disposal. Do not release into sewers or waterways. Ground all equipment. Use non-sparking tools. Spills can be absorbed with materials such as peat, activated carbon, polyurethane foam, or straw. Sinking agents, gelling agents, dispersants, and mechanical systems can also be use to treat oil spills. Regulatory Requirements: Follow applicable OSHA regulations (29 CFR 1910.120). 0 2 0 — Fire Diamond 2003-02 Diesel Fuel Oil No. 2-D DIE1400 Copyright © 2003 Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Page 3 of 4 Section 7 - Handling and Storage Handling Precautions: Avoid vapor or mist inhalation, and skin and eye contact. Use only with ventilation sufficient to reduce airborne concentrations to non-hazardous levels (see Sec. 2). Wear protective gloves (or use barrier cream), and clothing (see Sec. 8). Keep away from heat and ignition sources. Ground and bond all containers during transfers to prevent static sparks. Use non-sparking tools to open and close containers. . Never eat, drink, or smoke in work areas. Practice good personal hygiene after using this material, especially before eating, drinking, smoking, using the toilet, or applying cosmetics. Recommended Storage Methods: Store in tightly closed container in cool, well-ventilated area, away from heat, ignition sources and incompatibles (see Sec. 10). Periodically inspect stored materials. Equip drums with self-closing valves, pressure vacuum bungs, and flame arrestors. Regulatory Requirements: Follow applicable OSHA regulations. Also 29 CFR 1910.106 for Class II Combustible Liquid. Section 8 - Exposure Controls / Personal Protection Engineering Controls: To prevent static sparks, electrically ground and bond all containers and equipment used in shipping, receiving, or transferring operations. Provide general or local exhaust ventilation systems to maintain airborne concentrations as low as possible. Local exhaust ventilation is preferred because it prevents contaminant dispersion into the work area by controlling it at its source. Administrative Controls: Enclose operations and/or provide local exhaust ventilation appropriately designed for flammable mist and vapor at the site of chemical release. Where possible, transfer diesel fuel oil no. 2-D from drums or other storage containers directly to process containers. Minimize sources of ignition in surrounding low-lying areas. Personal Protective Clothing/Equipment: Wear chemically protective gloves, boots, aprons, and gauntlets. Wear protective eyeglasses, per OSHA eye- and face-protection regulations (29 CFR 1910.133). Contact lenses are not eye protective devices. Appropriate eye protection must be worn instead of, or in conjunction with contact lenses. Respiratory Protection: Seek professional advice prior to respirator selection and use. Follow OSHA respirator regulations (29 CFR 1910.134) and, if necessary, wear a MSHA/NIOSH-approved respirator. Select respirator based on its suitability to provide adequate worker protection for given working conditions, level of airborne contamination, and presence of sufficient oxygen. For emergency or nonroutine operations (cleaning spills, reactor vessels, or storage tanks), use an SCBA. Warning! Air-purifying respirators do not protect workers in oxygen-deficient atmospheres. If respirators are used, OSHA requires a written respiratory protection program that includes at least: medical certification, training, fit-testing, periodic environmental monitoring, maintenance, inspection, cleaning, and convenient, sanitary storage areas. Other: Separate contaminated work clothes from street clothes. Launder before reuse. Remove this material from your shoes and clean personal protective equipment. Make emergency eyewash stations, safety/quick-drench showers, and washing facilities available in work area. Section 9 - Physical and Chemical Properties Appearance/General Info: Brown, slightly viscous; kerosene-like odor. Physical State: Liquid Odor Threshold: 0.7 ppm Vapor Pressure (kPa): < 0.1 mm Hg at 68 °F (20 °C) Vapor Density (Air=1): > 6 Formula Weight: N/A Specific Gravity (H2O=1, at 4 °C): < 0.86 Boiling Point: 340-676 °F (171-358 °C) Freezing/Melting Point: -29.2 °F (-34 °C) Viscosity: 1.9-4.1 centistoke at 104 °F (40 °C) Surface Tension: 23-32 dynes/cm at 68 °F (20 °C) Water Solubility: Insoluble Section 10 - Stability and Reactivity Stability/Polymerization/Conditions to Avoid: Diesel fuel oil no. 2-D is stable at room temperature in closed containers under normal storage and handling conditions. Hazardous polymerization cannot occur. Exposure to heat and ignition sources. Storage Incompatibilities: Include strong oxidizing agents. Hazardous Decomposition Products: Thermal oxidative decomposition of diesel fuel oil no. 2-D can produce low molecular weight hydrocarbons, hydrocarbon derivatives, carbon oxides (COx), and sulfur oxides (SOx). 2003-02 Diesel Fuel Oil No. 2-D DIE1400 Copyright © 2003 Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Page 4 of 4 Section 11 - Toxicological Information Acute Oral Effects:\ Rat, oral, LD50: 7500 mg/kg.\ Acute Skin Effects:\ Rabbit, skin, LD: > 5 mL/kg.\ Irritation Effects:\ Rabbit, skin, standard Draize test: 500 µL/24 hr, resulted in severe reaction.\ Other Effects:\ Rat, inhalation: 2 g/m3/6 hr/3 weeks, intermittently, resulted in changes in blood erythrocyte (RBC) count, and focal fibrosis (pneumonoconiosis) and other changes in the lung, thorax or respiration.\ Rat, inhalation: 400 µg/m3/16 hr/2.5 years, intermittently, caused other changes in the blood, and biochemical effects - transaminases.\ Rabbit, skin: 80 mL/kg/12 days, continuously, resulted in other changes in the liver, kidney, ureter, and bladder, and death. See NIOSH, RTECS HZ1800000, for additional data. Section 12 - Ecological Information Environmental Fate: Diesel fuel oil no. 2-D will evaporate from water or soil. In surface water, it may partition from the water column to suspended sediments. Biodegradation may occur in soil and water. Ecotoxicity: Juvenile American shad, salt water TLm: 204 mg/L/24 hr; mallard duck, LD50=20 mg/kg. Section 13 - Disposal Considerations Disposal: Contact your supplier or a licensed contractor for detailed recommendations. Follow applicable Federal, state, and local regulations. Section 14 - Transport Information DOT Transportation Data (49 CFR 172.101): Shipping Name: Diesel fuel Hazard Class: 3 ID No.: NA1993 Packing Group: III Label: None Section 15 - Regulatory Information EPA Regulations: RCRA 40 CFR: Not listed CERCLA 40 CFR 302.4: Not listed SARA 40 CFR 372.65: Not listed SARA EHS 40 CFR 355: Not listed TSCA: Listed Section 16 - Other Information Disclaimer: Judgments as to the suitability of information herein for the purchaser’s purposes are necessarily the purchaser’s responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser’s intended purpose or for consequences of its use. MOBIL OIL CORP, AMERICAS MARKE -- MOBIL REGULAR UNLEADED GASOLINE ======================================================= MSDS Safety Information ======================================================= FSC: 9130 NIIN: 00-148-7103 MSDS Date: 05/17/2000 MSDS Num: CLDBG Product ID: MOBIL REGULAR UNLEADED GASOLINE MFN: 03 Responsible Party Cage: 3U728 Name: MOBIL OIL CORP, AMERICAS MARKETING AND REFINING Address: 3225 GALLOWS ROAD City: FAIRFAX VA 22037 Info Phone Number: 800-662-4525/ 856-224-4644 Emergency Phone Number: 609-737-4411 Resp. Party Other MSDS No.: 33126-00 Chemtrec IND/Phone: (800)424-9300 Published: Y ======================================================= Contractor Summary ======================================================= Cage: 3U728 Name: MOBIL OIL CORP, NORTH AMERICAS MARKETING AND REFINING Address: 3225 GALLOWS ROAD City: FAIRFAX VA 22037 Phone: 800-662-4525/ 856-224-4644 ======================================================= Item Description Information ======================================================= Item Name: GASOLINE,AUTOMOTIVE Unit of Issue: GL UI Container Qty: X ======================================================= Ingredients ======================================================= Cas: 8006-61-9 RTECS #: LX3300000 Name: GASOLINE (PRODUCT) (COMPONENTS FOLLOW BELOW) Percent by Wt: 100. OSHA PEL: 900 MG/KG;300 PPM OSHA STEL: 1500 MG/KG;500 PPM ACGIH TLV: 890 MG/M3;300 PPM ACGIH STEL: 1480 MG/M3;500 PPM ------------------------------ Cas: 1634-04-4 RTECS #: KN5250000 Name: METHYL T- BUTYL ETHER Percent by Wt: 15. ACGIH TLV: 144 MG/M3;40 PPM EPA Rpt Qty: 1 LB DOT Rpt Qty: 1 LB ------------------------------ Cas: 64-17-5 RTECS #: KQ6300000 Name: ETHANOL Percent by Wt: 11. OSHA PEL: 1900 MG/M3;1000 PPM ACGIH TLV: 1880 MG/M3;1000 PPM ------------------------------ Cas: 1330-20-7 RTECS #: ZE2100000 1 Name: XYLENE Percent by Wt: 10. OSHA PEL: 435 MG/M3; 100PPM OSHA STEL: 655 MG/M3; 150 PPM ACGIH TLV: 434 MG/M3;100 PPM ACGIH STEL: 651 MG/M3;150 PPM EPA Rpt Qty: 1000 LBS DOT Rpt Qty: 1000 LBS ------------------------------ Cas: 78-78-4 RTECS #: EK4430000 Name: ISOPENTANE Percent by Wt: 9. ACGIH TLV: 1770 MG/M3; 600 PPM ------------------------------ Cas: 108-88-3 RTECS #: XS5250000 Name: TOLUENE Percent by Wt: 5. OSHA PEL: 375 MG/M3; 100 PPM OSHA STEL: 560 MG/M3;150 PPM ACGIH TLV: 188 MG/M3;50 PPM S EPA Rpt Qty: 1000 LBS DOT Rpt Qty: 1000 LBS ------------------------------ Cas: 95-63-6 RTECS #: DC3325000 Name: PSEUDOCUMENE Percent by Wt: 5. OSHA PEL: 125 MG/M3; 25 PPM ACGIH TLV: 123 MG/M3; 25 PPM ------------------------------ Cas: 106-97-8 RTECS #: EJ4200000 Name: BUTANE Percent by Wt: 4. OSHA PEL: 1900 MG/M3; 800 PPM ACGIH TLV: 1900 MG/M3;800 PPM ------------------------------ Cas: 107-83-5 RTECS #: SA2985000 Name: 2-METHYLPENTANE Percent by Wt: 4. ACGIH TLV: 1760 MG/M3;500 PPM ACGIH STEL: 3500 MG/M3;1000 PPM ------------------------------ Cas: 109-66-0 RTECS #: RZ9450000 Name: PENTANE Percent by Wt: 4. OSHA PEL: 1800 MG/M3; 600 PPM OSHA STEL: 2250 MG/M3; 750 PPM ACGIH TLV: 1770 MG/M3;600 PPM ------------------------------ Cas: 25551-13-7 RTECS #: DC3220000 Name: TRIMETHYL BENZENE Percent by Wt: 3. OSHA PEL: 125 MG/M3; 25 PPM ACGIH TLV: 123 MG/M3;25 PPM ------------------------------ Cas: 96-14-0 Name: 3-METHYLPENTANE 2 Percent by Wt: 2. ACGIH TLV: 1760 MG/M3; 500 PPM ACGIH STEL: 3500 MG/M3;1000 PPM ------------------------------ Cas: 71-43-2 RTECS #: CY1400000 Name: BENZENE Percent by Wt: 2. OSHA PEL: 1 PPM OSHA STEL: 5 PPM ACGIH TLV: 0.5 MG/M3;1.60 PPM ACGIH STEL: 2.5 MG/M3; 8 PPM EPA Rpt Qty: 10 LBS DOT Rpt Qty: 10 LBS ------------------------------ Cas: 79-29-8 RTECS #: EJ9350000 Name: 2,3-DIMETHYLBUTANE Percent by Wt: 2. ACGIH TLV: 1760 MG/M3;500 PPM ACGIH STEL: 3500 MG/M3;1000 PPM ------------------------------ Cas: 110-54-3 RTECS #: MN9275000 Name: N-HEXANE Percent by Wt: 2. OSHA PEL: 180 MG/M3; 50 PPM ACGIH TLV: 176 MG/M3;50 PPM EPA Rpt Qty: 1 LB DOT Rpt Qty: 1 LB ------------------------------ Cas: 100-41-4 RTECS #: DA0700000 Name: ETHYL BENZENE Percent by Wt: 2. OSHA PEL: 435 MG/M3;100 PPM OSHA STEL: 545 MG/M3; 125 PPM ACGIH TLV: 434 MG/M3;100 PPM ACGIH STEL: 543 MG/M3;125 PPM EPA Rpt Qty: 1000 LBS DOT Rpt Qty: 1000 LBS ------------------------------ Cas: 589-34-4 Name: 3-METHYLHEXANE Percent by Wt: 2. Other REC Limits: 1640 MG/M3; 400 PPM ----------------------------- Cas: 591-76-4 Name: 2-METHYLHEXANE Percent by Wt: 1. Other REC Limits: 1640 MG/M3; 400 PPM ----------------------------- Cas: 108-87-2 RTECS #: GV6125000 Name: METHYLCYCLOHEXANE Percent by Wt: 1. OSHA PEL: 1600 MG/M3;400 PPM ACGIH TLV: 1610 MG/M3;400 PPM ======================================================= Health Hazards Data ======================================================= LD50 LC50 Mixture: ORAL, RATS, LD50:>2000 MG/KG. Route Of Entry Inds - Inhalation: YES 3 Skin: YES Effects of Exposure: EYE IRRITATION, RESPIRATORY IRRITATION, DIZZINESS, NAUSEA, LOSS OF CONSCIOUSNESS. SKIN IRRITATION. STUDIES CONDUCTED EXAMINING CAUSES OF DEATH OF DISTRBUTION WORKERS WITH LONG-TERM EXPOSURE TO GASOLIN E HAVE NOT FOUND ANY GASOLINE-RELATED HEALTH EFFECTS. REPORTS OF CHRONIC GASOLINE ABUSE (SUCH AS SNIFFING) AND CHRONIC MISUSE OF GASOLINE AS SOLVENT OR CLEANING AGENT HAVE REPORTED A RANGE OF NEUROLOG ICAL EFFECTS (NERVOUS SYSTEM EFFECTS), SUDDEN DEATHS FROM CARDIAC ARREST, HEMATOLOGIC CHANGES (BLOOD EFFECTS) AND LEUKEMIA. THESE EFFECTS ARE NOT EXPECTED TO OCCUR AT EXPOSURE LEVELS ENCOUNTERED IN DI STRIBUTION AND USE AS A MOTOR FUEL. Explanation Of Carcinogenicity: LONG-TERM EXPOSURE TO GASOLINE VAPOR HAS CAUSED KIDNEY AND LIVER CANCER IN LABORATORY ANIMALS. Signs And Symptions Of Overexposure: EYES: IRRITATION. SKIN: IRRITATION. INHALATION: RESPIRATORY IRRITATION, DIZZINESS, NAUSEA, LOSS OF CONSCIOUSNESS. CHRONIC GASOLINE ABUSE (EFFECTS NOT EXPECTED TO OCCUR AT EXPOSURE LEVELS ENCOUNTERED IN THE DISTRIBUTATION AND USE OF GASOLINE AS A MOTOR FUEL.) : NERVOUS SYSTEM EFFECTS; SUDDEN DEATH FROM CARDIAC ARREST; HEMATOLOGIC CHANGES (BLOOD EFFECTS); LUKEMIA. First Aid: EYE CONTACT: FLUSH THOROUGHLY WITH WATER. IF IRRITATION OCCURS, CALL A PHYSICIAN. SKIN CONTACT: WASH CONTACT AREAS WITH SOAP AND WATER. REMOVE CONTAIMINTED CLOTHING. LAUNDER CONTAMINATED CLOTHING BEFO RE REUSE. INHALATION: MOVE TO FRESH AIR. IF RESPIRATORY IRRITATION, DIZZINESS, NAUSEA, OR UNCONSCIOUSNESS OCCCURS, SEEK MEDICAL ASSISTANCE. IF BREATHING STOPPED, ASSIST VENTILATION WITH BAG-VALVE-MASK DEVISE OR USE MOUTH-TO-MOUTH RESUSCITATION. INGESTION: SEEK IMMEDIATE MEDICAL ATTENTION. DO NOT INDUCE VOMITING. ======================================================= Handling and Disposal ======================================================= Spill Release Procedures: ELIMINATE IGNITION SOURCES. RUNOFF MAY CREATE FIRE OR EXPLOSION HAZARD IN SEWER SYSTEM. ABSORB ON FIRE RETARDANT TREATED SAWDUST, DIATOMACEOUS EARTH, ETC. SHOVEL UP AND DISPOSE. PREVENT SPILLS FROM EN TERING STORM SEWERS, DRAINS, SOIL. REPORT SPILLS AS REQUIRED TO AUTHORITIES. U.S. COAST GUARD REQUIRES IMMEDIATE REPORTING OF SPILLS THAT COULD REACH ANY WATERWAY INCLUDING INTERMITTENT (SEE BELOW). Neutralizing Agent: (FROM ABOVE) DRY CREEKS. REPORT SPILL TO COAST GUARD TOLL FREE (800-424-8802); ROAD SPILLS NOTIFY CHEMTREC. Waste Disposal Methods: PRODUCT IS SUITABLE FOR BURNING FOR FUEL VALUE IN COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS.DISPOSAL OF UNUSED PRODUCT MAY BE SUBJECT TO RCRA REGULATIONS (40 CFR 261) DUE TO BENZENE (2.32%, TCLP , FLASH<-40F). DISPOSAL OF USED PRODUCT MAY ALSO BE REGULATED DUE TO IGNITABILITY, CORROSIVITY, REAC TIVITY, OR TOXICITY AS DETERMINED BY TCLP. Handling And Storage Precautions: NEVER SIPHON GASOLINE BY MOUTH AND DO NOT USE AS A SOLVENT OR CLEANING AGENT. USE NON-SPARKING TOOLS AND EXPLOSION-PROOF EQUIPMENT. USE IN WELL VENTILATED AREAS AWAY FROM IGNITION SOURCES. PORTABLE CO NTAINERS MUST BE PLACED ON GROUND AND NOZZLE KEPT IN CONTACT WHEN FILLING TO PREVENT STATIC SPARKS. Other Precautions: DRUMS MUST BE GROUNDED AND BONDED AND EQUIPPED WITH SELF-CLOSING VALVES, PRESSURE VACUUM BUNGS, AND FLAME ARRESTERS. STORE AWAY FROM IGNITION SOURCES IN A COOL AREA EQUIPPED WITH AUTOMATIC SPRINKLING SYSTEM. OUTSIDE OR DETACHED STORAGE PREFERRED. STORAGE CONTAINERS SHOULD BE GROUNDED AND BONDED. ======================================================= Fire and Explosion Hazard Information ======================================================= Flash Point Method: TCC Flash Point: <-40.C, -40.F Lower Limits: 1.4 Upper Limits: 7.6 Extinguishing Media: CARBON DIOXIDE, FOAM, DRY CHEMICAL, WATER FOG. NFPA HAZARD ID: HEALTH: 1; FLAMMABILITY: 3; REACTIVITY: 0. Fire Fighting Procedures: FOR FIRES IN ENCLOSED AREAS, FIRE FIGHTERS MUST USE SELF-CONTAINED BREATHING APPARATUS. FOR LARGE SPILLS, FOAM IS THE PREFERRED 4 AGENT; BLANKETING THE GASOLINE SURFACE. WATER SPRAY MAY BE USED TO FLUSH SPILL AWAY FROM EXPOSURE; PREVENT SPREADING GASOLINE INTO SEWERS, STREAMS, DRINKING WATER SUPPLIES. Unusual Fire/Explosion Hazard: EXTREMELY FLAMMABLE. VAPOR ACCUMULATION COULD FLASH AND/OR EXPLODE IF IN CONTACT WITH OPEN FLAME. IF SPILL HAS NOT IGNITED, ADD FOAM BLANKET TO SUPPRESS RELEASE OF VAPORS. IF FOAM NOT AVAILABLE, A WAT ER SPRAY CURTAIN CAN BE USED TO DISPERSE VAPORS AND PROTECT PERSONNEL ATTEMPTING TO STOP THE LEAK. ======================================================= Control Measures ======================================================= Respiratory Protection: APPROVED RESPIRATORY EQUIPMENT MUST BE USED WHEN AIRBORNE CONCENTRATIONS ARE UNKNOWN OR EXCEED THE TLV. Ventilation: USE IN WELL VENTILATED AREA WITH LOCAL EXHAUST VENTILATION. VENTILATION REQUIRED AND EQUIPMENT MUST BE EXPLOSION PROOF. USE AWAY FROM ALL IGNITION SOURCES. Protective Gloves: IMPERVIOUS GLOVES SHOULD BE WORN. Eye Protection: SAFETY GLASSES WITH SIDE SHIELDS OR CHEMICAL GOGGLES IF SPLASH IS POSSIBLE. Work Hygienic Practices: GOOD PERSONAL HYGIENE PRACTICES SHOULD ALWAYS BE FOLLOWED. ======================================================= Physical/Chemical Properties ======================================================= HCC: F2 Boiling Point: >35.C, 95.F Vapor Pres: >400.0 MMHG @20C Vapor Density: 3.0 Spec Gravity: 0.79 Viscosity: <1.0 CST@ 40 C Evaporation Rate & Reference: NOT ESTABLISHED Solubility in Water: NEGLIGIBLE Appearance and Odor: CLEAR LIQUID (MAY BE DYED), GASOLINE ODOR. ======================================================= Reactivity Data ======================================================= Stability Indicator: YES Stability Condition To Avoid: HEAT, SPARKS, FLAME AND BUILD UP OF STATIC ELECTRICITY. Materials To Avoid: HALOGENS, STRONG ACIDS, ALKALIES, AND OXIDIZERS. Hazardous Decomposition Products: CARBON MONOXIDE. Hazardous Polymerization Indicator: NO Conditions To Avoid Polymerization: WILL NOT OCCUR. ======================================================= Toxicological Information ======================================================= Toxicological Information: ORAL, RATS, LD50: >2000 MG/KG; PRACTICALLY NON-TOXIC. DERMAL, RABBITS, LD50: > 2000 MG/KG, PRACTICALLY NON-TOXIC. INHALATION, RATS, LC50: > 5 MG/L, PRACTICALLY NON-TOXIC. EYE IRRITATION, RABBITS, DRAI ZE SCORE: >6 BUT 15 OR LESS, PRACTICALLY NON-IRRITATING. SKIN IRRITATION, RABBITS, PRIMARY IRRITATION INDEX: 3 OR > BUT < 5. IRRITANT. OTHER ACUTE TOXICITY DATA: INHALATION OF VAPORS/MISTS MAY CAUSE R ESPIRATORY SYSTEM IRRITATION. EXPOSURE TO HIGH CONCENTRATIONS OF CARBON MONOXIDE CAN CAUSE LOSS OF CONSCIOUSNESS, HEART DAMAGE, BRAIN DAMAGE, DEATH. EXPOSURE TO HIGH CONCENTRATIONS OF CARBON DIOXIDE C AN CAUSE (CONTD. SEE "ECOLOGICAL") ======================================================= Ecological Information ======================================================= Ecological: ENVIRONMENTAL FATE AND EFFECTS: NOT ESTABLISHED. NOTE: MOBIL PRODUCTS ARE NOT FORMULATED TO CONTAIN PCBS. USE: UNLEADED MOTOR FUEL. (CONTD. FROM "TOXICOLOGICAL'') ASPHYXIATION. NEUROTOXICOLOGY: NO SI GNIFICIANT ADVERSE EFFECTS IN STUDY WITH RATS. REPRODUCTIVE TOXICOLOGY: ONE 5 GENERATION REPRODUCTION STUDIES, SHOWED NO ADVERSE EFFECTS IN RATS. A TWO GENERATION STUDY SHOWED NO REPRODUCTIVE OR DEVELOP MENTAL EFFECTS IN RATS. A TERATOLOGY INHALATION STUDY IN RABBITS SHOWED NO DEVELOPMENTAL EFFECTS. CHRONIC TOXICOLOGY: AN INCREASE INCIDENCE OF KIDNEY AND LIVER TUMORS (CONTD. SEE "FEDERAL") ======================================================= MSDS Transport Information ======================================================= Transport Information: USA DOT: PSN: GASOLINE; CLASS: 3; UN 1203; ERG NUMBER: 128; PG I I; LABEL: FLAMMABLE LIQUID; PLACARD: FLAMMABLE; RQ: N/A. RID/ ADR: CLASS: 3;SUB-CLASS: 3(B); LABEL: 3; DANGER NUMBER: 33; UN 1203; SHIP PING NAME: HYDROCARBONS, LIQUID HAVING A FLASH POINT BELOW 21C. IMO: CLASS: 3.1; UN 1203; PG I I; SHIPPING NAME: GASOLINE; LABEL: FLAMMABLE LIQUID. ICAO/ IATA: CLASS:3; UN 1203; PG I I; SHIPPING NAME : GASOLINE; LABEL: FLAMMABLE LIQUID. ======================================================= Regulatory Information ======================================================= Sara Title III Information: THIS PRODUCT CONTAINS N0 "EXTREMELY HAZARDOUS SUBSTANCES". SARA (311 / 312) REPORTABLE HAZARD CATEGORIES: FIRE, CHRONIC, ACUTE. THIS PRODUCT CONTAINS SARA (313) TOXIC RELEASE CHEMICALS: SEE MANUFACTUR ER'S MSDS FOR TOXIC RELEASE CHEMICALS AND THE LIST CITATIONS UNDER WHICH THE LISTED INGREDIENTS ARE CITED. PRECAUTIONARY LABEL TEXT: CONTAINS GASOLINE. DANGER! SEE MANUFACTURER'S MSDS FOR PRECAUTIONAR Y LABEL TEXT. Federal Regulatory Information: ALL COMPONENTS COMPLY WITH TSCA, AND EINECS/ ELINCS. (CONTD. FROM "ECOLOGICAL") WAS OBSERVED IN LABORATORY ANIMALS. THESE EFFECTS ARE NOT CONSIDERED SIGNIFICANT TO HUMANS. SKIN SENSITIZATION: NEGATIVE GUINEA PIG TEST. GASOLINE AND REFINERY STREAMS: STUDIES CONDUCTED BY THE AMERICAN PETROLEUM INSTITUTE EXAMINED A REFERENCE UNLEADED GASOLINE FOR MUTAGENIC, TERATOGENIC, AND SENSITIZATION POTENTIAL; N O EVIDENCE OF THESE HAZARDS WAS FOUND. AS FAR AS SCIENTISTS KNOW, LOW LEVEL OR INFREQUENT EXPOSURES TO GASOLINE VAPORS ARE UNLIKELY TO BE ASSOCIATED WITH CANCER OR OTHER SERIOUS DISEASES IN HUMANS. State Regulatory Information: THIS WARNING IS GIVEN TO COMPLY WITH CALIFORNIA HEALTH AND SAFETY CODE 25249.6 AND DOES NOT CONSTITUTE AN ADMISSION OR A WAIVER OF RIGHTS. THIS PRODUCT CONTAINS A CHEMICAL KNOWN TO STATE OF CALIFORNIA TO CAUSE CANCER, BIRTH DEFECTS, OR OTHER REPRODUCTIVE HARM. REFER TO PRODUCT MATERIAL SAFETY DATA BULLETIN FOR FURTHER SAFETY AND HEALTH INFORMATION. ======================================================= Other Information ======================================================= Other Information: EU LABELING: SYMBOL: F+ T EXTREMELY FLAMMABLE, TOXIC; RISK PHRASE: R 12-45-38-22; EXTREMELY FLAMMABLE. MAY CAUSE CANCER. IRRITATING TO SKIN. HARMFUL IF SWALLOWED. SAFETY PHASES: S53-45-2-23-24-29-43-6 2. AVOID EXPOSURE - OBTAIN INSTRUCTIONS BEFORE USE. IN CASE OF ACCIDENT OR IF YOU FEEL UNWELL, SEEK MEDICAL ADVICE (SHOW LABEL WHERE POSSIBLE). KEEP OUT OF REACH OF CHILDREN. DO NOT BREATHE VAPOR. AV OID CONTACT WITH SKIN. DO NOT EMPTY INTO DRAINS. IN CASE OF FIRE USE CARBON DIOXIDE, FOAM, DRY CHEMICAL, WATER FOG. IF SWALLOWED, DO NOT INDUCE VOMITING: SEEK MEDICAL ADVICE AND SHOW LABEL. CONTAINS : LOW BOILING POINT NAPHTHA. ======================================================= Transportation Information ======================================================= Responsible Party Cage: 3U728 Trans ID NO: 157074 Product ID: MOBIL REGULAR UNLEADED GASOLINE MSDS Prepared Date: 05/17/2000 Review Date: 05/23/2001 MFN: 3 Net Unit Weight: BULK Multiple KIT Number: 0 Unit Of Issue: GL 6 Container QTY: X Additional Data: TRANSPORTATION DATA PER MANUFACTURER'S MSDS. ======================================================= Detail DOT Information ======================================================= DOT PSN Code: GTN DOT Proper Shipping Name: GASOLINE Hazard Class: 3 UN ID Num: UN1203 DOT Packaging Group: II Label: FLAMMABLE LIQUID Special Provision: B33,B101,T8 Non Bulk Pack: 202 Bulk Pack: 242 Max Qty Pass: 5 L Max Qty Cargo: 60 L Vessel Stow Req: E ======================================================= Detail IMO Information ======================================================= IMO PSN Code: HRV IMO Proper Shipping Name: GASOLINE IMDG Page Number: 3141 UN Number: 1203 UN Hazard Class: 3.1 IMO Packaging Group: II Subsidiary Risk Label: - EMS Number: 3-07 MED First Aid Guide NUM: 311 ======================================================= Detail IATA Information ======================================================= IATA PSN UC IATA UN ID Num: 1203 IATA Proper Shipping Name: GASOLINE IATA UN Class: 3 IATA Label: FLAMMABLE LIQUID UN Packing Group: II Packing Note Passenger: 305 Max Quant Pass: 5L Max Quant Cargo: 60L Packaging Note Cargo: 307 Exceptions: A100 ======================================================= Detail AFI Information ======================================================= AFI PSN UC AFI Proper Shipping Name: GASOLINE AFI Hazard Class: 3 AFI UN ID NUM: UN1203 AFI Packing Group: II Special Provisions: P5 Back Pack Reference: A7.3 ======================================================= HAZCOM Label ======================================================= Product ID: MOBIL REGULAR UNLEADED GASOLINE Cage: 3U728 Company Name: MOBIL OIL CORP, NORTH AMERICAS MARKETING AND REFINING Street: 3225 GALLOWS ROAD City: FAIRFAX VA Zipcode: 22037 Health Emergency Phone: 609-737-4411 7 Label Required IND: Y Date Of Label Review: 05/23/2001 Status Code: A Label Date: 05/23/2001 Origination Code: F Eye Protection IND: YES Skin Protection IND: YES Signal Word: DANGER Respiratory Protection IND: YES Health Hazard: Moderate Contact Hazard: Moderate Fire Hazard: Severe Reactivity Hazard: None Hazard And Precautions: DANGER ! CONTAINS GASOLINE. EXTREMELY FLAMMABLE LIQUID AND VAPOR. VAPOR MAY CAUSE FLASH FIRE. MAY CAUSE SKIN, NOSE, THROAT, LUNG IRRITATION, DIZZINESS, NAUSEA, AND LOSS OF CONSCIOUSNESS. IF SWALLOWED, MAY BE ASPIRATED AND CAN CAUSE SERIOUS LUNG DAMAGE. ======================================================= Disclaimer (provided with this information by the compiling agencies): This information is formulated for use by elements of the Department of Defense. The United States of America in no manner whatsoever expressly or implied warrants, states, or intends said information to have any application, use or viability by or to any person or persons outside the Department of Defense nor any person or persons contracting with any instrumentality of the United States of America and disclaims all liability for such use. Any person utilizing this instruction who is not a military or civilian employee of the United States of America should seek competent professional advice to verify and assume responsibility for the suitability of this information to their particular situation regardless of similarity to a corresponding Department of Defense or other government situation. 8 MATERIAL SAFETY DATA SHEET EQUILON MSDS: 61011E-01 01/04/99 SHELL HYDRAULIC OIL 150 TELEPHONE NUMBER: 24 HOUR EMERGENCY ASSISTANCE GENERAL MSDS ASSISTANCE EQUIVA SERVICES: 877-276-7283 877-276-7285 CHEMTREC: 800-424-9300 NAME AND ADDRESS EQUILON ENTERPRISES LLC PRODUCT STEWARDSHIP P.O. BOX 674414 HOUSTON, TX 77267-4414 _______________________________________________________________________________ SECTION I NAME _______________________________________________________________________________ PRODUCT: SHELL HYDRAULIC OIL 150 CHEM NAME: MIXTURE (SEE SECTION II-A) CHEM FAMILY: PETROLEUM HYDROCARBON; HYDRAULIC OIL SHELL CODE: 65240 HEALTH HAZARD: 1 FIRE HAZARD: 1 REACTIVITY: 0 _______________________________________________________________________________ SECTION II-A PRODUCT/INGREDIENT _______________________________________________________________________________ NO. COMPOSITION CAS NO. PERCENT --- ----------- ------- ------- P SHELL HYDRAULIC OIL 150 1 HYDROTREATED HEAVY NAPHTHENIC DISTILLATE 64742-52-5 >98 2 ADDITIVE MIXTURE <2 NFPA HAZARD RATING: HEALTH 0 FIRE 1 REACTIVITY 0 _______________________________________________________________________________ SECTION II-B ACUTE TOXICITY DATA _______________________________________________________________________________ NO. ACUTE ORAL LD50 ACUTE DERMAL LD50 ACUTE INHALATION LC50 --- --------------- ----------------- --------------------- P NOT AVAILABLE 1 >5 G/KG, RAT * >5 G/KG, RABBIT * * BASED ON API STUDIES _______________________________________________________________________________ SECTION III HEALTH INFORMATION _______________________________________________________________________________ THE HEALTH EFFECTS NOTED BELOW ARE CONSISTENT WITH REQUIREMENTS UNDER THE OSHA HAZARD COMMUNICATION STANDARD (29 CFR 1910.1200). EYE CONTACT: LUBRICATING OILS ARE GENERALLY CONSIDERED TO BE NO MORE THAN MINIMALLY IRRITATING TO THE EYES. SKIN CONTACT: LUBRICATING OILS ARE GENERALLY CONSIDERED TO BE NO MORE THAN SLIGHTLY IRRITATING TO THE SKIN. PROLONGED AND REPEATED CONTACT MAY RESULT IN SKIN DISORDERS SUCH AS DERMATITIS, OIL ACNE OR FOLLICULITIS. ACCIDENTAL RELEASE UNDER HIGH PRESSURE APPLICATIONS MAY RESULT IN INJECTION OF OIL INTO THE SKIN CAUSING LOCAL NECROSIS. INHALATION: THE INHALATION OF VAPORS (GENERATED AT HIGH TEMPERATURES ONLY) OR OIL MIST MAY CAUSE A MILD IRRITATION THE OF UPPER RESPIRATORY TRACT. INGESTION: LUBRICATING OILS ARE GENERALLY CONSIDERED NO MORE THAN SLIGHTLY TOXIC IF SWALLOWED. SIGNS AND SYMPTOMS: IRRITATION AS NOTED ABOVE. LOCAL NECROSIS MAY BE EVIDENCED BY DELAYED ONSET OF PAIN AND TISSUE DAMAGE A FEW HOURS FOLLOWING HIGH PRESSURE INJECTION. AGGRAVATED MEDICAL CONDITIONS: PREEXISTING SKIN AND RESPIRATORY DISORDERS MAY BE AGGRAVATED BY EXPOSURE TO THIS PRODUCT. OTHER HEALTH EFFECTS: THIS PRODUCT AND ITS COMPONENTS ARE NOT CLASSIFIED AS CARCINOGENS BY 1 INTERNATIONAL AGENCY FOR RESEARCH ON CANCER (IARC), NATIONAL TOXICOLOGY PROGRAM (NTP) OR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA). _______________________________________________________________________________ SECTION IV OCCUPATIONAL EXPOSURE LIMITS _______________________________________________________________________________ COMP OSHA ACGIH NO. PEL/TWA PEL/CEILING TLV/TWA TLV/STEL OTHER --- ------- ----------- ------- -------- ----- P 5 MG/M3* NONE 5 MG/M3* 10 MG/M3* *OIL MIST, MINERAL _______________________________________________________________________________ SECTION V EMERGENCY AND FIRST AID PROCEDURES _______________________________________________________________________________ EYE CONTACT: FLUSH WITH WATER FOR 15 MINUTES WHILE HOLDING EYELIDS OPEN. GET MEDICAL ATTENTION. SKIN CONTACT: REMOVE CONTAMINATED CLOTHING AND WIPE EXCESS OFF. WASH WITH SOAP AND WATER OR A WATERLESS HAND CLEANER FOLLOWED BY SOAP AND WATER. IF IRRITATION OCCURS, GET MEDICAL ATTENTION. IF MATERIAL IS INJECTED UNDER THE SKIN, GET MEDICAL ATTENTION PROMPTLY TO PREVENT SERIOUS DAMAGE; DO NOT WAIT FOR SYMPTOMS TO DEVELOP. INHALATION: REMOVE VICTIM TO FRESH AIR AND PROVIDE OXYGEN IF BREATHING IS DIFFICULT. GET MEDICAL ATTENTION. INGESTION: DO NOT INDUCE VOMITING. IN GENERAL, NO TREATMENT IS NECESSARY UNLESS LARGE QUANTITIES OF PRODUCT ARE INGESTED. HOWEVER, GET MEDICAL ADVICE. NOTE TO PHYSICIAN: IN GENERAL, EMESIS INDUCTION IS UNNECESSARY IN HIGH VISCOSITY, LOW VOLATILITY PRODUCTS, I.E., MOST OILS AND GREASES. _______________________________________________________________________________ SECTION VI SUPPLEMENTAL HEALTH INFORMATION _______________________________________________________________________________ NONE IDENTIFIED. _______________________________________________________________________________ SECTION VII PHYSICAL DATA _______________________________________________________________________________ BOILING POINT (DEG F): SPECFIC GRAVITY (H2O = 1): VAPOR PRESSURE (MM HG): NOT AVAILABLE 0.9129 <0.1 MELTING POINT (DEG F): SOLUBILITY IN WATER: VAPOR DENSITY (AIR = 1): +15 (POUR POINT) NEGLIGIBLE NOT AVAILABLE VISCOSITY: 135-165 (CS @ 104 DEG F) EVAPORATION RATE (NORMAL BUTYL ACETATE = 1):NOT AVAILABLE APPEARANCE AND ODOR:PALE YELLOW OIL. SLIGHT HYDROCARBON ODOR. PHYS/CHEM PROPERTIES: SEE ABOVE FOR DETAILS _______________________________________________________________________________ SECTION VIII FIRE AND EXPLOSION HAZARDS _______________________________________________________________________________ FLASH POINT AND METHOD: 400 DEG F (PMCC) FLAMMABLE LIMITS/PERCENT VOLUME IN AIR: LOWER: N/AV HIGHER: N/AV EXTINGUISHING MEDIA: USE WATER FOG, FOAM, DRY CHEMICAL OR CO2. DO NOT USE A DIRECT STREAM OF WATER. PRODUCT WILL FLOAT AND CAN BE REIGNITED ON SURFACE OF WATER. SPECIAL FIRE FIGHTING PROCEDURES AND PRECAUTIONS: MATERIALS WILL NOT BURN UNLESS PREHEATED. DO NOT ENTER CONFINED FIRE SPACE WITHOUT FULL BUNKER GEAR (HELMET WITH FACE SHIELD, BUNKER COATS, GLOVES AND RUBBER BOOTS), INCLUDING A POSITIVE PRESSURE NIOSH APPROVED SELF-CONTAINED BREATHING APPARATUS. COOL FIRE EXPOSED CONTAINERS WITH WATER. UNUSUAL FIRE AND EXPLOSION HAZARDS: NONE IDENTIFIED _______________________________________________________________________________ SECTION IX REACTIVITY _______________________________________________________________________________ STABLITY: STABLE HAZARDOUS POLYMERIZATION WILL NOT OCCUR 2 CONDITIONS AND MATERIALS TO AVOID: AVOID HEAT, OPEN FLAMES, AND OXIDIZING MATERIALS. HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION PRODUCTS ARE HIGHLY DEPENDENT ON THE COMBUSTION CONDITIONS. A COMPLEX MIXTURE OF AIRBORNE SOLID, LIQUID, PARTICULATES AND GASES WILL EVOLVE WHEN THIS MATERIAL UNDERGOES PYROLYSIS OR COMBUSTION. CARBON MONOXIDE AND OTHER UNIDENTIFIED ORGANIC COMPOUNDS MAY BE FORMED UPON COMBUSTION. _______________________________________________________________________________ SECTION X EMPLOYEE PROTECTION _______________________________________________________________________________ RESPIRATORY PROTECTION: IF EXPOSURE MAY OR DOES EXCEED OCCUPATIONAL EXPOSURE LIMITS (SEC. IV) USE A NIOSH-APPROVED RESPIRATOR TO PREVENT OVEREXPOSURE. IN ACCORD WITH 29 CFR 1910.134 USE EITHER AN ATMOSPHERE-SUPPLYING RESPIRATOR OR AN AIR-PURIFYING RESPIRATOR FOR ORGANIC VAPORS AND PARTICULATES. PROTECTIVE CLOTHING WEAR CHEMICAL-RESISTANT GLOVES AND OTHER PROTECTIVE CLOTHING AS REQUIRED TO MINIMIZE SKIN CONTACT. WEAR SAFETY GOGGLES TO AVOID EYE CONTACT. TEST DATA FROM PUBLISHED LITERATURE AND/OR GLOVE AND CLOTHING MANUFACTURERS INDICATE THE BEST PROTECTION IS PROVIDED BY NITRILE GLOVES. ADDITIONAL PROTECTIVE MEASURES: NONE IDENTIFIED _______________________________________________________________________________ SECTION XI ENVIRONMENTAL PROTECTION _______________________________________________________________________________ SPILL OR LEAK PROCEDURES: MAY BURN ALTHOUGH NOT READILY IGNITABLE. USE CAUTIOUS JUDGMENT WHEN CLEANING UP LARGE SPILLS. *** LARGE SPILLS *** WEAR RESPIRATOR AND PROTECTIVE CLOTHING AS APPROPRIATE. SHUT OFF SOURCE OF LEAK IF SAFE TO DO SO. DIKE AND CONTAIN. REMOVE WITH VACUUM TRUCKS OR PUMP TO STORAGE/SALVAGE VESSELS. SOAK UP RESIDUE WITH AN ABSORBENT SUCH AS CLAY, SAND OR OTHER SUITABLE MATERIAL; DISPOSE OF PROPERLY. FLUSH AREA WITH WATER TO REMOVE TRACE RESIDUE. *** SMALL SPILLS *** TAKE UP WITH AN ABSORBENT MATERIAL AND DISPOSE OF PROPERLY. _______________________________________________________________________________ SECTION XII SPECIAL PRECAUTIONS _______________________________________________________________________________ MINIMIZE SKIN CONTACT. WASH WITH SOAP AND WATER BEFORE EATING, DRINKING, SMOKING OR USING TOILET FACILITIES. LAUNDER CONTAMINATED CLOTHING BEFORE REUSE. PROPERLY DISPOSE OF CONTAMINATED LEATHER ARTICLES, INCLUDING SHOES, THAT CANNOT BE DECONTAMINATED.STORE IN A COOL, DRY PLACE WITH ADEQUATE VENTILATION. KEEP AWAY FROM OPEN FLAMES AND HIGH TEMPERATURES. _______________________________________________________________________________ SECTION XIII TRANSPORTATION REQUIREMENTS _______________________________________________________________________________ DEPARTMENT OF TRANSPORTATION CLASSIFICATION: NOT HAZARDOUS BY D.O.T. REGULATIONS DOT PROPER SHIPPING NAME: NOT APPLICABLE OTHER REQUIREMENTS: NOT APPLICABLE _______________________________________________________________________________ SECTION XIV OTHER REGULATORY CONTROLS _______________________________________________________________________________ THE COMPONENTS OF THIS PRODUCT ARE LISTED ON THE EPA/TSCA INVENTORY OF CHEMICAL SUBSTANCES PROTECTION OF STRATOSPHERIC OZONE (PURSUANT TO SECTION 611 OF THE CLEAN AIR ACT AMENDMENTS OF 1990): PER 40 CFR PART 82, THIS PRODUCT DOES NOT CONTAIN NOR WAS IT DIRECTLY MANUFACTURED WITH ANY CLASS I OR CLASS II OZONE DEPLETING SUBSTANCES. IN ACCORDANCE WITH SARA TITLE III, SECTION 313, THE ATTACHED ENVIRONMENTAL DATA SHEET (EDS) SHOULD ALWAYS BE COPIED AND SENT WITH THE MSDS. _______________________________________________________________________________ SECTION XV STATE REGULATORY INFORMATION _______________________________________________________________________________ 3 STATE LISTED COMPONENT CAS NO PERCENT STATE CODE _______________________________________________________________________________ BASED ON INFORMATION AVAILABLE, THIS PRODUCT DOES NOT CONTAIN ANY CHEMICAL SUBSTANCE LISTED ON A CHEMICAL SPECIFIC STATE LIST. _______________________________________________________________________________ SECTION XVI SPECIAL NOTES _______________________________________________________________________________ NEW PRODUCT. ORIGINAL MSDS ISSUE. _______________________________________________________________________________ THE INFORMATION CONTAINED IN THIS DATA SHEET IS BASED ON THE DATA AVAILABLE TO US AT THIS TIME, AND IS BELIEVED TO BE ACCURATE BASED UPON THAT DATA. IT IS PROVIDED INDEPENDENTLY OF ANY SALE OF THE PRODUCT, FOR PURPOSE OF HAZARD COMMUNICATION. IT IS NOT INTENDED TO CONSTITUTE PRODUCT PERFORMANCE INFORMATION, AND NO EXPRESS OR IMPLIED WARRANTY OF ANY KIND IS MADE WITH RESPECT TO THE PRODUCT, UNDERLYING DATA OR THE INFORMATION CONTAINED HEREIN. YOU ARE URGED TO OBTAIN DATA SHEETS FOR ALL PRODUCTS YOU BUY, PROCESS, USE OR DISTRIBUTE, AND ARE ENCOURAGED TO ADVISE THOSE WHO MAY COME IN CONTACT WITH SUCH PRODUCTS OF THE INFORMATION CONTAINED HEREIN. TO DETERMINE THE APPLICABILITY OR EFFECT OF ANY LAW OR REGULATION WITH RESPECT TO THE PRODUCT, YOU SHOULD CONSULT WITH YOUR LEGAL ADVISOR OR THE APPROPRIATE GOVERNMENT AGENCY. WE WILL NOT PROVIDE ADVICE ON SUCH MATTERS, OR BE RESPONSIBLE FOR ANY INJURY FROM THE USE OF THE PRODUCT DESCRIBED HEREIN. THE UNDERLYING DATA, AND THE INFORMATION PROVIDED HEREIN AS A RESULT OF THAT DATA, IS THE PROPERTY OF EQUIVA SERVICES, LLC AND IS NOT TO BE THE SUBJECT OF SALE OR EXCHANGE WITHOUT THE EXPRESS WRITTEN CONSENT OF EQUIVA SERVICES, LLC. _______________________________________________________________________________ ENVIRONMENTAL DATA SHEET EQUILON EDS: 61011E SHELL HYDRAULIC OIL 150 TELEPHONE NUMBER: 24 HOUR EMERGENCY ASSISTANCE GENERAL MSDS ASSISTANCE EQUIVA SERVICES: 877-276-7283 877-276-7285 CHEMTREC: 800-424-9300 NAME AND ADDRESS EQUILON ENTERPRISES PRODUCT STEWARDSHIP P.O. BOX 674414 HOUSTON, TX 77267-4414 PRODUCT CODE: 65240 _______________________________________________________________________________ SECTION I PRODUCT COMPOSITION _______________________________________________________________________________ NO. COMPOSITION CAS PERCENT =============================================================================== P SHELL HYDRAULIC OIL 150 MIXTURE 100 1 HYDROTREATED HEAVY NAPHTHENIC DISTILLATE 64742-52-5 >98 2 HITEC 545 MIXTURE <2 _______________________________________________________________________________ SECTION II SARA TITLE III INFORMATION _______________________________________________________________________________ NO. EHS RQ EHS TPQ SEC-313 313 CATEGORY 311/312 CATEGORY (*1) (*2) (*3) (*4) (*5) =============================================================================== BASED ON THE DATA AVAILABLE THIS PRODUCT IS NOT REGULATED BY SARA, TITLE III. _______________________________________________________________________________ *1 = REPORTABLE QUANTITY OF EXTREMELY HAZARDOUS SUBSTANCE, SEC 302 *2 = THRESHOLD PLANNING QUANTITY, EXTREMELY HAZARDOUS SUBSTANCE, SEC 302 *3 = TOXIC CHEMICAL, SEC 313 *4 = CATEGORY AS REQUIRED BY SEC 313 (40 CFR 372.65 C), MUST BE USED ON TOXIC RELEASE INVENTORY FORM 4 *5 = CATEGORY (FOR AGGREGATE REPORTING REQUIREMENTS UNDER SARA 311, 312) HEALTH: H-1 = IMMEDIATE (ACUTE) HEALTH HAZARD H-2 = DELAYED (CHRONIC) HEALTH HAZARD PHYSICAL: P-3 = FIRE HAZARD P-4 = SUDDEN RELEASE OF PRESSURE HAZARD P-5 = REACTIVE HAZARD _______________________________________________________________________________ SECTION III ENVIRONMENTAL RELEASE INFORMATION _______________________________________________________________________________ THIS PRODUCT IS COVERED BY EPA'S COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT (CERCLA) PETROLEUM EXCLUSION. THEREFORE, RELEASES TO AIR, LAND, OR WATER ARE NOT REPORTABLE UNDER CERCLA ("SUPERFUND"). HOWEVER, UNDER SECTION 311 OF EPA'S CLEAN WATER ACT (CWA), THIS (MATERIAL/PRODUCT) IS CONSIDERED AN OIL. AS SUCH, SPILLS INTO OR LEADING TO SURFACE WATERS THAT CAUSE A SHEEN MUST BE REPORTED TO THE NATIONAL RESPONSE CENTER, 800-424-8802. THIS PRODUCT IS AN OIL UNDER 49 CFR (DOT) PART 130. IF SHIPPED BY RAIL OR HIGHWAY IN A TANK WITH A CAPACITY OF 3,500 GALLONS OR MORE, IT IS SUBJECT TO THE REQUIREMENTS OF PART 130. MIXTURE SOLUTIONS IN WHICH THIS PRODUCT IS PRESENT AT 10% OR MORE MAY ALSO BE SUBJECT TO THIS RULE. _______________________________________________________________________________ SECTION IV RCRA INFORMATION _______________________________________________________________________________ IF THIS PRODUCT BECOMES A WASTE, IT WOULD NOT BE A HAZARDOUS WASTE BY RCRA CRITERIA (40 CFR 261). PLACE IN AN APPROPRIATE DISPOSAL FACILITY IN COMPLIANCE WITH LOCAL REGULATIONS. _______________________________________________________________________________ THE INFORMATION CONTAINED IN THIS DATA SHEET IS BASED ON THE DATA AVAILABLE TO US AT THIS TIME, AND IS BELIEVED TO BE ACCURATE BASED UPON THAT DATA. IT IS PROVIDED INDEPENDENTLY OF ANY SALE OF THE PRODUCT, FOR PURPOSE OF HAZARD COMMUNICATION. IT IS NOT INTENDED TO CONSTITUTE PRODUCT PERFORMANCE INFORMATION, AND NO EXPRESS OR IMPLIED WARRANTY OF ANY KIND IS MADE WITH RESPECT TO THE PRODUCT, UNDERLYING DATA OR THE INFORMATION CONTAINED HEREIN. YOU ARE URGED TO OBTAIN DATA SHEETS FOR ALL PRODUCTS YOU BUY, PROCESS, USE OR DISTRIBUTE, AND ARE ENCOURAGED TO ADVISE THOSE WHO MAY COME IN CONTACT WITH SUCH PRODUCTS OF THE INFORMATION CONTAINED HEREIN. TO DETERMINE THE APPLICABILITY OR EFFECT OF ANY LAW OR REGULATION WITH RESPECT TO THE PRODUCT, YOU SHOULD CONSULT WITH YOUR LEGAL ADVISOR OR THE APPROPRIATE GOVERNMENT AGENCY. WE WILL NOT PROVIDE ADVICE ON SUCH MATTERS, OR BE RESPONSIBLE FOR ANY INJURY FROM THE USE OF THE PRODUCT DESCRIBED HEREIN. THE UNDERLYING DATA, AND THE INFORMATION PROVIDED HEREIN AS A RESULT OF THAT DATA, IS THE PROPERTY OF EQUIVA SERVICES, LLC AND IS NOT TO BE THE SUBJECT OF SALE OR EXCHANGE WITHOUT THE EXPRESS WRITTEN CONSENT OF EQUIVA SERVICES, LLC. _______________________________________________________________________________ KAREN G. HAYNES --------------- EQUIVA SERVICES LLC P.O. BOX 674414 HOUSTON, TX 77267-4414 FOR ADDITIONAL INFORMATION ON THIS ENVIRONMENTAL DATA PLEASE CALL (877) 276-7285 FOR EMERGENCY ASSISTANCE PLEASE CALL EQUIVA SERVICES LLC: (877) 276-7283 CHEMTREC: (800) 424-9300 } 5 MATERIAL SAFETY DATA SHEET EQUILON MSDS: 71073E-02 01/04/99 SHELL SUPER PLUS MOTOR OIL 10W-30 TELEPHONE NUMBER: 24 HOUR EMERGENCY ASSISTANCE GENERAL MSDS ASSISTANCE EQUIVA SERVICES: 877-276-7283 877-276-7285 CHEMTREC: 800-424-9300 NAME AND ADDRESS EQUILON ENTERPRISES LLC PRODUCT STEWARDSHIP P.O. BOX 674414 HOUSTON, TX 77267-4414 _______________________________________________________________________________ SECTION I NAME _______________________________________________________________________________ PRODUCT: SHELL SUPER PLUS MOTOR OIL 10W-30 CHEM NAME: MIXTURE (SEE SECTION II-A) CHEM FAMILY: PETROLEUM HYDROCARBON; MOTOR OIL SHELL CODE: 50100 HEALTH HAZARD: 1 FIRE HAZARD: 1 REACTIVITY: 0 _______________________________________________________________________________ SECTION II-A PRODUCT/INGREDIENT _______________________________________________________________________________ NO. COMPOSITION CAS NO. PERCENT --- ----------- ------- ------- P SHELL SUPER PLUS MOTOR OIL 10W-30 1 HYDROTREATED HEAVY PARAFFINIC DISTILLATE 64742-54-7 0-90 2 SOLVENT DEWAXED HEAVY PARAFFINIC DISTILLATE 64742-65-0 0-90 3 ADDITIVES CONTAINING: MIXTURE 10-25 4A ZINC COMPOUND 4B CALCIUM ALKYL DITHIOPHOSPHATE 4C MAGNESIUM LONG-CHAIN ALKARYL SULFONATE 4D COPPER COMPOUND NFPA HAZARD RATING: HEALTH 0 FIRE 1 REACTIVITY 0 _______________________________________________________________________________ SECTION II-B ACUTE TOXICITY DATA _______________________________________________________________________________ NO. ACUTE ORAL LD50 ACUTE DERMAL LD50 ACUTE INHALATION LC50 --- --------------- ----------------- --------------------- P NOT AVAILABLE 1 >5.0 G/KG, RAT* >5.0 G/KG, RABBIT* 2 >5.0 G/KG, RAT* >5.0 G/KG, RABBIT* * BASED ON API STUDIES _______________________________________________________________________________ SECTION III HEALTH INFORMATION _______________________________________________________________________________ THE HEALTH EFFECTS NOTED BELOW ARE CONSISTENT WITH REQUIREMENTS UNDER THE OSHA HAZARD COMMUNICATION STANDARD (29 CFR 1910.1200). EYE CONTACT: LUBRICATING OILS ARE GENERALLY CONSIDERED NO MORE THAN MINIMALLY IRRITATING TO THE EYES, HOWEVER THIS PRODUCT CONTAINS A COMPONENT IDENTIFIED AS AN EYE IRRITANT. SKIN CONTACT: LUBRICATING OILS ARE GENERALLY CONSIDERED NO MORE THAN MILDLY IRRITATING TO THE SKIN. PROLONGED AND REPEATED CONTACT MAY RESULT IN VARIOUS SKIN DISORDERS SUCH AS DERMATITIS, FOLLICULITIS OR OIL ACNE. INHALATION: INHALATION OF VAPOR (GENERATED AT HIGH TEMPERATURES ONLY) OR OIL MIST FROM THIS PRODUCT MAY RESULT IN MILD IRRITATION OF THE UPPER RESPIRATORY TRACT. INGESTION: LUBRICATING OILS ARE GENERALLY CONSIDERED NO MORE THAN SLIGHTLY TOXIC IF SWALLOWED. SIGNS AND SYMPTOMS: IRRITATION AS NOTED ABOVE. AGGRAVATED MEDICAL CONDITIONS: PREEXISTING SKIN AND RESPIRATORY DISORDERS MAY BE AGGRAVATED BY EXPOSURE TO 1 THIS PRODUCT. OTHER HEALTH EFFECTS: THIS PRODUCT AND ITS COMPONENTS ARE NOT CLASSIFIED AS CARCINOGENS BY INTERNATIONAL AGENCY FOR RESEARCH ON CANCER (IARC), NATIONAL TOXOCOLOGY PROGRAM (NTP) OR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA). THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER HAS DETERMINED THERE IS SUFFICIENT EVIDENCE FOR THE CARCINOGENICITY IN EXPERIMENTAL ANIMALS OF USED MOTOR OILS. HANDLING PROCEDURES AND SAFETY PRECAUTIONS IN THE MSDS SHOULD BE FOLLOWED TO MINIMIZE EMPLOYEE'S EXPOSURE TO THE USED PRODUCT. _______________________________________________________________________________ SECTION IV OCCUPATIONAL EXPOSURE LIMITS _______________________________________________________________________________ COMP OSHA ACGIH NO. PEL/TWA PEL/CEILING TLV/TWA TLV/STEL OTHER --- ------- ----------- ------- -------- ----- P 5 MG/M3* NONE 5 MG/M3* 10 MG/M3* *OIL MIST, MINERAL _______________________________________________________________________________ SECTION V EMERGENCY AND FIRST AID PROCEDURES _______________________________________________________________________________ EYE CONTACT: FLUSH EYES WITH PLENTY OF WATER FOR 15 MINUTES WHILE HOLDING EYELIDS OPEN. GET MEDICAL ATTENTION. SKIN CONTACT: REMOVE CONTAMINATED CLOTHING/SHOES AND WIPE EXCESS FROM SKIN. FLUSH SKIN WITH WATER. FOLLOW BY WASHING WITH SOAP AND WATER. IF IRRITATION OCCURS, GET MEDICAL ATTENTION. DO NOT REUSE CLOTHING UNTIL CLEANED. INHALATION: REMOVE VICTIM TO FRESH AIR AND PROVIDE OXYGEN IF BREATHING IS DIFFICULT. GET MEDICAL ATTENTION. INGESTION: DO NOT INDUCE VOMITING. IF VOMITING OCCURS SPONTANEOUSLY, KEEP HEAD BELOW HIPS TO PREVENT ASPIRATION OF LIQUID INTO THE LUNGS. GET MEDICAL ATTENTION.* NOTE TO PHYSICIAN: *IF MORE THAN 2.0 ML PER KG HAS BEEN INGESTED AND VOMITING HAS NOT OCCURRED, EMESIS SHOULD BE INDUCED WITH SUPERVISION. KEEP VICTIM'S HEAD BELOW HIPS TO PREVENT ASPIRATION. IF SYMPTOMS SUCH AS LOSS OF GAG REFLEX, CONVULSIONS OR UNCONSCIOUSNESS OCCUR BEFORE EMESIS, GASTRIC LAVAGE USING A CUFFED ENDOTRACHEAL TUBE SHOULD BE CONSIDERED. _______________________________________________________________________________ SECTION VI SUPPLEMENTAL HEALTH INFORMATION _______________________________________________________________________________ NONE IDENTIFIED. _______________________________________________________________________________ SECTION VII PHYSICAL DATA _______________________________________________________________________________ BOILING POINT (DEG F): SPECFIC GRAVITY (H2O = 1): VAPOR PRESSURE (MM HG): NOT AVAILABLE 0.8927 <0.1 MELTING POINT (DEG F): SOLUBILITY IN WATER: VAPOR DENSITY (AIR = 1): -22 (POUR POINT) NEGLIGIBLE NOT AVAILABLE VISCOSITY: 9.6-11 (CST @ 212 DEG. F) EVAPORATION RATE (NORMAL BUTYL ACETATE = 1):NOT AVAILABLE APPEARANCE AND ODOR:DARK RED LIQUID. SLIGHT HYDROCARBON ODOR. PHYS/CHEM PROPERTIES: SEE ABOVE FOR DETAILS _______________________________________________________________________________ SECTION VIII FIRE AND EXPLOSION HAZARDS _______________________________________________________________________________ FLASH POINT AND METHOD: 401 DEG F (COC) FLAMMABLE LIMITS/PERCENT VOLUME IN AIR: LOWER: N/AV HIGHER: N/AV EXTINGUISHING MEDIA: USE WATER FOG, FOAM, DRY CHEMICAL OR CO2. DO NOT USE A DIRECT STREAM OF WATER. PRODUCT WILL FLOAT AND CAN BE REIGNITED ON SURFACE OF WATER. SPECIAL FIRE FIGHTING PROCEDURES AND PRECAUTIONS: 2 MATERIAL WILL NOT BURN UNLESS PREHEATED. DO NOT ENTER CONFINED FIRE-SPACE WITHOUT FULL BUNKER GEAR (HELMET WITH FACE SHIELD, BUNKER COATS, GLOVES AND RUBBER BOOTS), INCLUDING A POSITIVE-PRESSURE NIOSH-APPROVED SELF-CONTAINED BREATHING APPARATUS. COOL FIRE EXPOSED CONTAINERS WITH WATER. UNUSUAL FIRE AND EXPLOSION HAZARDS: NONE IDENTIFIED _______________________________________________________________________________ SECTION IX REACTIVITY _______________________________________________________________________________ STABLITY: STABLE HAZARDOUS POLYMERIZATION WILL NOT OCCUR CONDITIONS AND MATERIALS TO AVOID: AVOID HEAT, OPEN FLAMES AND OXIDIZING MATERIALS. HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION PRODUCTS ARE HIGHLY DEPENDENT ON THE COMBUSTION CONDITIONS. A COMPLEX MIXTURE OF AIRBORNE SOLID, LIQUID, PARTICULATES AND GASES WILL EVOLVE WHEN THIS MATERIAL UNDERGOES PYROLYSIS OR COMBUSTION. CARBON MONOXIDE AND OTHER UNIDENTIFIED ORGANIC COMPOUNDS MAY BE FORMED UPON COMBUSTION. _______________________________________________________________________________ SECTION X EMPLOYEE PROTECTION _______________________________________________________________________________ RESPIRATORY PROTECTION: IF EXPOSURE MAY OR DOES EXCEED OCCUPATIONAL EXPOSURE LIMITS (SECTION IV) USE A NIOSH-APPROVED RESPIRATOR TO PREVENT OVEREXPOSURE. IN ACCORD WITH 29 CFR 1910.134 USE EITHER AN ATMOSPHERE-SUPPLYING RESPIRATOR OR AN AIR-PURIFYING RESPIRATOR FOR ORGANIC VAPORS AND PARTICULATES. PROTECTIVE CLOTHING WEAR CHEMICAL RESISTANT GLOVES AND OTHER PROTECTIVE CLOTHING AS REQUIRED TO MINIMIZE SKIN CONTACT. WEAR SAFETY GOGGLES TO AVOID EYE CONTACT. TEST DATA FROM PUBLISHED LITERATURE AND/OR GLOVE AND CLOTHING MANUFACTURERS INDICATE THE BEST PROTECTION IS PROVIDED BY NITRILE GLOVES. ADDITIONAL PROTECTIVE MEASURES: NONE IDENTIFIED _______________________________________________________________________________ SECTION XI ENVIRONMENTAL PROTECTION _______________________________________________________________________________ SPILL OR LEAK PROCEDURES: MAY BURN ALTHOUGH NO READILY IGNITABLE. USE CAUTIOUS JUDGMENT WHEN CLEANING UP LARGE SPILLS. *** LARGE SPILLS *** WEAR RESPIRATOR AND PROTECTIVE CLOTHING AS APPROPRIATE. SHUT OFF SOURCE OF LEAK IF SAFE TO DO SO. DIKE AND CONTAIN. REMOVE WITH VACUUM TRUCKS OR PUMP TO STORAGE SALVAGE VESSELS. SOAK UP RESIDUE WITH AN ABSORBENT SUCH AS CLAY, SAND, OR OTHER SUITABLE MATERIALS; DISPOSE OF PROPERLY. FLUSH AREA WITH WATER TO REMOVE TRACE RESIDUE. *** SMALL SPILLS *** TAKE UP WITH AN ABSORBENT MATERIAL AND DISPOSE OF PROPERLY. _______________________________________________________________________________ SECTION XII SPECIAL PRECAUTIONS _______________________________________________________________________________ MINIMIZE SKIN CONTACT. WASH WITH SOAP AND WATER BEFORE EATING, DRINKING, SMOKING OR USING TOILET FACILITIES. LAUNDER CONTAMINATED CLOTHING BEFORE REUSE. PROPERLY DISPOSE OF CONTAMINATED LEATHER ARTICLES, INCLUDING SHOES, THAT CANNOT BE DECONTAMINATED. STORE IN A COOL, DRY PLACE WITH ADEQUATE VENTILATION. KEEP AWAY FROM OPEN FLAMES AND HIGH TEMPERATURES. _______________________________________________________________________________ SECTION XIII TRANSPORTATION REQUIREMENTS _______________________________________________________________________________ DEPARTMENT OF TRANSPORTATION CLASSIFICATION: NOT HAZARDOUS BY D.O.T. REGULATIONS DOT PROPER SHIPPING NAME: NOT APPLICABLE OTHER REQUIREMENTS: NOT APPLICABLE _______________________________________________________________________________ SECTION XIV OTHER REGULATORY CONTROLS _______________________________________________________________________________ 3 THE COMPONENTS OF THIS PRODUCT ARE LISTED ON THE EPA/TSCA INVENTORY OF CHEMICAL SUBSTANCES. PROTECTION OF STRATOSPHERIC OZONE (PURSUANT TO SECTION 611 OF THE CLEAN AIR ACT AMENDMENTS OF 1990): PER 40 CFR PART 82, THIS PRODUCT DOES NOT CONTAIN NOR WAS IT DIRECTLY MANUFACTURED WITH ANY CLASS I OR CLASS II OZONE DEPLETING SUBSTANCES. IN ACCORDANCE WITH SARA TITLE III, SECTION 313, THE ATTACHED ENVIRONMENTAL DATA SHEET (EDS) SHOULD ALWAYS BE COPIED AND SENT WITH THE MSDS. _______________________________________________________________________________ SECTION XV STATE REGULATORY INFORMATION _______________________________________________________________________________ THE FOLLOWING CHEMICALS ARE SPECIFICALLY LISTED BY INDIVIDUAL STATES; OTHER PROD UCT SPECIFIC HEALTH AND SAFETY DATA IN OTHER SECTIONS OF THE MSDS MAY ALSO BE AP PLICABLE FOR STATE REQUIREMENTS. FOR DETAILS ON YOUR REGULATORY REQUIREMENTS YO U SHOULD CONTACT THE APPROPRIATE AGENCY IN YOUR STATE. STATE LISTED COMPONENT CAS NO PERCENT STATE CODE _______________________________________________________________________________ ZINC COMPOUNDS NONE 2-3 MA, NJ COPPER COMPOUNDS NONE 1-2 MA, NJ CA = CALIFORNIA HAZ. SUBST. LIST; CA65C, CA65R, CA65C/R = CALIFORNIA SAFE DRINKING WATER AND TOXICS ENFORCEMENT ACT OF 1986 OR PROPOSITION 65 LIST; CT = CONNECTICUT TOXIC. SUBST. LIST; FL = FLORIDA SUBST. LIST; IL = ILLINOIS TOX. SUBST. LIST; LA = LOUISIANA HAZ. SUBST. LIST; MA = MASSACHUSETTS SUBST. LIST; ME = MAINE HAZ. SUBST. LIST; MN = MINNESOTA HAZ. SUBST. LIST; NJ = NEW JERSEY HAZ. SUBST. LIST; PA = PENNSYLVANIA HAZ. SUBST. LIST; RI = RHODE ISLAND HAZ. SUBST. LIST. _______________________________________________________________________________ SECTION XVI SPECIAL NOTES _______________________________________________________________________________ THIS MSDS HAS BEEN REVISED IN SECTIONS II-A, II-B, V, VI, VII, IX, XV AND EDS SECTIONS I AND II. _______________________________________________________________________________ THE INFORMATION CONTAINED IN THIS DATA SHEET IS BASED ON THE DATA AVAILABLE TO US AT THIS TIME, AND IS BELIEVED TO BE ACCURATE BASED UPON THAT DATA. IT IS PROVIDED INDEPENDENTLY OF ANY SALE OF THE PRODUCT, FOR PURPOSE OF HAZARD COMMUNICATION. IT IS NOT INTENDED TO CONSTITUTE PRODUCT PERFORMANCE INFORMATION, AND NO EXPRESS OR IMPLIED WARRANTY OF ANY KIND IS MADE WITH RESPECT TO THE PRODUCT, UNDERLYING DATA OR THE INFORMATION CONTAINED HEREIN. YOU ARE URGED TO OBTAIN DATA SHEETS FOR ALL PRODUCTS YOU BUY, PROCESS, USE OR DISTRIBUTE, AND ARE ENCOURAGED TO ADVISE THOSE WHO MAY COME IN CONTACT WITH SUCH PRODUCTS OF THE INFORMATION CONTAINED HEREIN. TO DETERMINE THE APPLICABILITY OR EFFECT OF ANY LAW OR REGULATION WITH RESPECT TO THE PRODUCT, YOU SHOULD CONSULT WITH YOUR LEGAL ADVISOR OR THE APPROPRIATE GOVERNMENT AGENCY. WE WILL NOT PROVIDE ADVICE ON SUCH MATTERS, OR BE RESPONSIBLE FOR ANY INJURY FROM THE USE OF THE PRODUCT DESCRIBED HEREIN. THE UNDERLYING DATA, AND THE INFORMATION PROVIDED HEREIN AS A RESULT OF THAT DATA, IS THE PROPERTY OF EQUIVA SERVICES, LLC AND IS NOT TO BE THE SUBJECT OF SALE OR EXCHANGE WITHOUT THE EXPRESS WRITTEN CONSENT OF EQUIVA SERVICES, LLC. _______________________________________________________________________________ ENVIRONMENTAL DATA SHEET EQUILON EDS: 71073E SHELL SUPER PLUS MOTOR OIL 10W-30 TELEPHONE NUMBER: 24 HOUR EMERGENCY ASSISTANCE GENERAL MSDS ASSISTANCE EQUIVA SERVICES: 877-276-7283 877-276-7285 CHEMTREC: 800-424-9300 NAME AND ADDRESS EQUILON ENTERPRISES PRODUCT STEWARDSHIP P.O. BOX 674414 HOUSTON, TX 77267-4414 4 PRODUCT CODE: 50100 _______________________________________________________________________________ SECTION I PRODUCT COMPOSITION _______________________________________________________________________________ NO. COMPOSITION CAS PERCENT =============================================================================== P SHELL SUPER PLUS MOTOR OIL 10W-30 MIXTURE 100 1 HYDROTREATED HEAVY PARAFFINIC DISTILLATE 64742-54-7 0-90 2 SOLVENT DEWAXED HEAVY PARAFFINIC DISTILL 64742-65-0 0-90 ATE 3 ADDITIVES CONTAINING MIXTURE 10-25 3A ZINC COMPOUND 3B CALCIUM ALKYL DITHIOPHOSPHATE 3C MAGNESIUM LONG-CHAIN ALKARYL SULFONAT E 3D COPPER COMPOUND _______________________________________________________________________________ SECTION II SARA TITLE III INFORMATION _______________________________________________________________________________ NO. EHS RQ EHS TPQ SEC-313 313 CATEGORY 311/312 CATEGORY (*1) (*2) (*3) (*4) (*5) =============================================================================== 3A YES ZINC COMPOUNDS 3D YES COPPER COMPOUNDS _______________________________________________________________________________ *1 = REPORTABLE QUANTITY OF EXTREMELY HAZARDOUS SUBSTANCE, SEC 302 *2 = THRESHOLD PLANNING QUANTITY, EXTREMELY HAZARDOUS SUBSTANCE, SEC 302 *3 = TOXIC CHEMICAL, SEC 313 *4 = CATEGORY AS REQUIRED BY SEC 313 (40 CFR 372.65 C), MUST BE USED ON TOXIC RELEASE INVENTORY FORM *5 = CATEGORY (FOR AGGREGATE REPORTING REQUIREMENTS UNDER SARA 311, 312) HEALTH: H-1 = IMMEDIATE (ACUTE) HEALTH HAZARD H-2 = DELAYED (CHRONIC) HEALTH HAZARD PHYSICAL: P-3 = FIRE HAZARD P-4 = SUDDEN RELEASE OF PRESSURE HAZARD P-5 = REACTIVE HAZARD _______________________________________________________________________________ SECTION III ENVIRONMENTAL RELEASE INFORMATION _______________________________________________________________________________ THIS PRODUCT IS COVERED BY EPA'S COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT (CERCLA) PETROLEUM EXCLUSION. THEREFORE RELEASES TO AIR, LAND, OR WATER ARE NOT REPORTABLE UNDER CERCLA ("SUPERFUND"). HOWEVER UNDER SECTION 311 OF EPA'S CLEAN WATER ACT (CWA), THIS PRODUCT IS CONSIDERED AN OIL. AS SUCH , SPILLS INTO OR LEADING TO SURFACE WATERS THAT CAUSE A SHEEN MUST BE REPORTED TO THE NATIONAL RESPONSE CENTER, 800-424-8802. THIS PRODUCT IS AN OIL UNDER 49 CFR (DOT) PART 130. IF SHIPPED BY RAIL OR HIGHWAY IN A TANK WITH A CAPACITY OF 3,500 GALLONS OR MORE, IT IS SUBJECT TO THE REQUIREMENTS OF PART 130. MIXTURE SOLUTIONS IN WHICH THIS PRODUCT IS PRESENT AT 10% OR MORE MAY ALSO BE SUBJECT TO THIS RULE. _______________________________________________________________________________ SECTION IV RCRA INFORMATION _______________________________________________________________________________ IF THIS PRODUCT BECOMES A WASTE, IT WOULD NOT BE A HAZARDOUS WASTE BY RCRA CRITERIA (40 CFR 261). PLACE IN AN APPROPRIATE DISPOSAL FACILITY IN COMPLIANCE WITH LOCAL REGULATIONS. _______________________________________________________________________________ THE INFORMATION CONTAINED IN THIS DATA SHEET IS BASED ON THE DATA AVAILABLE TO US AT THIS TIME, AND IS BELIEVED TO BE ACCURATE BASED UPON THAT DATA. IT IS PROVIDED INDEPENDENTLY OF ANY SALE OF THE PRODUCT, FOR PURPOSE OF HAZARD COMMUNICATION. IT IS NOT INTENDED TO CONSTITUTE PRODUCT PERFORMANCE INFORMATION, AND NO EXPRESS OR IMPLIED WARRANTY OF ANY KIND IS MADE WITH RESPECT TO THE PRODUCT, UNDERLYING DATA OR THE INFORMATION CONTAINED 5 HEREIN. YOU ARE URGED TO OBTAIN DATA SHEETS FOR ALL PRODUCTS YOU BUY, PROCESS, USE OR DISTRIBUTE, AND ARE ENCOURAGED TO ADVISE THOSE WHO MAY COME IN CONTACT WITH SUCH PRODUCTS OF THE INFORMATION CONTAINED HEREIN. TO DETERMINE THE APPLICABILITY OR EFFECT OF ANY LAW OR REGULATION WITH RESPECT TO THE PRODUCT, YOU SHOULD CONSULT WITH YOUR LEGAL ADVISOR OR THE APPROPRIATE GOVERNMENT AGENCY. WE WILL NOT PROVIDE ADVICE ON SUCH MATTERS, OR BE RESPONSIBLE FOR ANY INJURY FROM THE USE OF THE PRODUCT DESCRIBED HEREIN. THE UNDERLYING DATA, AND THE INFORMATION PROVIDED HEREIN AS A RESULT OF THAT DATA, IS THE PROPERTY OF EQUIVA SERVICES, LLC AND IS NOT TO BE THE SUBJECT OF SALE OR EXCHANGE WITHOUT THE EXPRESS WRITTEN CONSENT OF EQUIVA SERVICES, LLC. _______________________________________________________________________________ KAREN G. HAYNES --------------- EQUIVA SERVICES LLC P.O. BOX 674414 HOUSTON, TX 77267-4414 FOR ADDITIONAL INFORMATION ON THIS ENVIRONMENTAL DATA PLEASE CALL (877) 276-7285 FOR EMERGENCY ASSISTANCE PLEASE CALL EQUIVA SERVICES LLC: (877) 276-7283 CHEMTREC: (800) 424-9300 } 6 Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 APPENDIX D DRUM MANAGEMENT PROCEDURES 99 CHAPTER 10 DRUM HANDLING 100 CHAPTER 10 DRUM HANDLING 10.0 INTRODUCTION Accidents may occur during handling of drums and other hazardous waste containers. Hazards include detonations, fires, explosions, vapor generation, and physical injury. The most significant ways to improve the safety of drum handling activities at a site are to keep the operation as remote from workers as possible, to avoid sudden releases of chemicals if the operation cannot be remote, and to provide adequate safety gear and equipment to protect the worker if spillage or contact with the drums is unavoidable. Exhibit 10-1 outlines some basic safety precautions in drum handling. Regulations defining practices and procedures for safe handling of drums and other hazardous waste containers include: C OSHA regulations (29 CFR Part 1910. 120(j) and Part 1926) -- general requirements and standards for storing, containing, and handling chemicals and containers, and for maintaining equipment used for handling materials; C EPA regulations (40 CFR Parts 264 and 265) -- requirements for types of hazardous waste containers, maintenance of containers and containment structures, and design and maintenance of storage areas; and C DOT regulations (49 CFR Parts 171 through 178) -- requirements for containers and procedures for shipment of hazardous wastes. During hazardous waste operations, containers are handled during inspection, drum opening, sampling, and characterization. This chapter provides guidance for safely performing these procedures when handling drums and other containers. 10.1 INSPECTION Appropriate procedures for handling drums varies depending on the drum contents. Prior to handling, drums should be inspected visually to identify their contents. Information that may be helpful includes: C Symbols, words, or other marks on the drum indicating that its contents are hazardous; C Symbols, words, or other marks indicating that the drum contains discarded laboratory chemicals, reagents, or other potentially dangerous materials in small-volume individual containers; C Signs of deterioration such as corrosion, rust, and leaks; C Signs that the drum is under pressure; and C Configuration of the drumhead. For example, if the whole lid of the drum can be removed, then it was designed to contain solid material; if the lid has a bung, then the drum was intended for liquids. If the drumhead contains a liner, the drum may likely contain highly corrosive or otherwise hazardous materials. Noting the type of drum also may be useful for identifying potential hazards. Polyethylene or PVC-lined drums often contain strong acids or bases. If the lining is punctured, the substance usually quickly corrodes the steel, and may cause a significant leak or spill. Exotic metal drums (e.g., aluminum, nickel, stainless steel) are very strong and expensive, and are often used to store extremely dangerous materials. Single-walled drums used as a pressure vessel have fittings for both the storage product and for an inert gas. These drums may contain reactive, flammable, or explosive substances. Laboratory packs are used for disposal of expired chemicals and process samples from university laboratories, hospitals, and similar institutions. Individual containers within the lab pack often are not packed in absorbent material. They may contain incompatible materials, radioisotopes, or shock-sensitive, highly volatile, highly corrosive, or highly toxic exotic chemicals. 101 EXHIBIT 10-1 Safety Precautions for Drum Handling ACTIVITY: LOCATING DRUMS AND CONDUCTING INVENTORY POTENTIAL SAFETY HAZARD: Unknown location and contents of drums can lead to unsuspected hazards Safety Tips •Carefully review background data pertaining to the location and types of wastes on-site. •Conduct soil and ground-water sampling only after the geophysical survey is completed to minimize the possibility of puncturing drums. •During the random sampling of drums, which may be required for an inventory, spacing between drums should be adequate to allow for emergency evacuation if needed. •Use remotely operated, nonsparking tools for random sampling whenever possible. •Use direct-reading air monitoring equipment to detect hot spots where contamination may pose a risk to worker safety. ACTIVITY: DETERMINING DRUM INTEGRITY POTENTIAL SAFETY HAZARD: The process of visual inspections requires close contact with drums of unknown content Safety Tips •Approach drums cautiously. Conduct air monitoring to indicate levels of hazards that require withdrawal from the work area or use of additional safety equipment. •Any drum that is critically swollen should not be approached; it should be isolated using a barricade until the pressure can be relieved remotely. •Use of the grappler or other remotely operated equipment can eliminate the need for determining drum integrity prior to excavation, provided that rupture of the drum will not result in fire or unacceptable environmental impact. ACTIVITY: DRUM EXCAVATION AND HANDLING POTENTIAL SAFETY HAZARD: Exposure to toxic/hazardous vapors; rupture of drums Safety Tips •Where buried drums are suspected, conduct a geophysical survey before using any construction equipment in order to minimize the possibility of rupture. •Use a drum grappler where possible and cost-effective to minimize contact with drums. If a grappler is not available, pump or overpack drums of poor integrity before excavation. •Ground equipment prior to transferring wastes to new drums. •Use nonsparking hand tools and nonsparking bucket teeth on excavation equipment, and use plexiglass shields on vehicle cabs. •Where slings, yokes, or other accessories must be used, workers should back away from the work area after attaching the accessory and before the drum is lifted. •Critically swollen drums should not be handled until pressure can be relieved. •Use bars that fit over the teeth of excavation buckets to prevent drum puncture. •Where ionizing levels of radiation are detected, the Site Health and Safety Officer should be contacted; generally, the drum should be overpacked and isolated promptly. •Where explosive or shock-sensitive material is suspected, every effort should be made to handle the drum remotely. Gas cylinders should not be dragged during handling. •Use direct-reading air monitoring equipment when in close proximity to drums to detect any hot spots. EXHIBIT 10-1 Safety Precautions for Drum Handling 102 ACTIVITY: DRUM STAGING AND OPENING POTENTIAL SAFETY HAZARD: Release of toxic, hazardous vapors, rupture of drums Safety Tips •Stage gas cylinders in a cool, shaded area. •Stage potentially explosive or shock-sensitive wastes in a diked, fenced area. •Use remote drum opening methods where drums are unsound. •Conduct remote-operated drum opening from behind a barricade or behind a plexiglas shield if backhoe-mounted puncture is being used. •Isolate drum opening from staging and other activities if possible to prevent a chain reaction if an explosion or reaction does occur. •If drum opening cannot be isolated from staging, drums should be staged so as to: (1) minimize the possibility of chain reactions in the event of a fire or explosion; and (2) provide adequate space for emergency evacuation. •Use only nonsparking hand tools if drums are to be opened manually. •Remotely relieve the pressure of critically swollen drums before opening. •Clean up spills promptly to minimize mixing of incompatible materials. ACTIVITY: CONSOLIDATION AND RECONTAINERIZATION POTENTIAL SAFETY HAZARD: Mixing of incompatible wastes Safety Tips •Perform on-site compatibility testing on all drums. •Segregate wastes according to compatibility class following compatibility testing. •Clean up spills promptly to avoid mixing of incompatible wastes. •Intentional mixing of incompatible wastes such as acids and bases should be performed under controlled conditions in a reaction tank where temperature and vapor release can be monitored. •Monitor for incompatible reactions during consolidation using direct-reading air monitoring equipment. ACTIVITY: INTERIM STORAGE AND TRANSPORTATION POTENTIAL SAFETY HAZARD: Mixing of incompatible wastes Safety Tips •Segregate incompatible wastes using dikes during interim storage. •Maintain a weekly inspection schedule. •Allow adequate aisle space between drums to allow rapid exit of workers in case of emergency. •Keep explosives and gas cylinders in a cool, shaded, or roofed area. •Prevent contact of water reactive wastes with water. •Clean up spills or leaks promptly. •Have fire fighting equipment readily available within the storage area. •Ensure adherence to DOT regulations regarding transport of incompatible wastes and drum integrity. 103 Source:Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA/500/2-86/013). 104 Laboratory packs are a potential ignition source for fires at hazardous waste sites. Conditions in the immediate vicinity of the drums may provide information about drum contents and associated hazards. In addition, air monitoring should be conducted around the drums. If buried drums are suspected, ground-penetrating systems can be used to estimate the location and depth of the drums. After visual inspection, drums can be classified into preliminary hazard categories. They can be described as radioactive, leaking or deteriorated, bulging, and explosive or shock-sensitive. Until their contents are characterized, unlabelled drums should be handled in the same manner as drums that contain hazardous materials. It is also important to remember that drums are frequently mislabelled -- particularly drums that are reused. Therefore, a drum's label may not accurately describe its contents. Results of the drum inspection can be used to determine: (1) whether any hazards are present and the appropriate response; and (2) which drums need to be moved before they are opened and sampled. A plan should be developed specifying the extent of handling necessary and the appropriate procedures for handling. Plans should be revised as new information is obtained during drum handling. 10.2 DRUM EXCAVATION AND REMOVAL EQUIPMENT Drum excavation and removal equipment is used to perform several distinct and important functions, including: C Excavating to the depth of buried drums and removing surface cover over buried drums. C Excavating around buried drums to free them for removal. C Removing (lifting) drums from exposed pits and trenches. C Loading and transporting drums to onsite storage areas. C Sampling, segregating, bulking, storing, and recontainerizing (e.g., overpacking) drums. C Transporting offsite for appropriate storage, treatment, or disposal. The choice of equipment for drum handling is based on the inherent capabilities and limitations of the equipment, site-specific conditions that affect equipment performance, the necessity to protect worker safety, and costs. Generally, a combination of equipment and accessories is required for a particular job. 10.3 DRUM HANDLING The purpose of drum handling is to: (1) respond to obvious problems that might impair worker safety; (2) unstack and orient drums for sampling; and (3) if necessary, organize drums into different areas on-site to facilitate characterization and remedial action. Handling may or may not be necessary, depending on how the drums are positioned at a site. To avoid accidents, drums should only be handled when necessary. Prior to handling, all personnel should be warned about the hazards of handling and instructed to minimize handling as much as possible. In all phases of handling, personnel should be alert for new information about potential hazards and should respond to new hazards before continuing with routine handling operations. Empty overpack drums (larger drums in which smaller leaking or damaged drums are placed for storage or shipment) and an adequate volume of absorbent should be kept near areas where minor spills may occur. Where major spills may occur, a containment berm should be constructed prior to handling. If drum contents spill, personnel trained in spill response should isolate and contain the spill. The following procedures can be used to maximize worker safety during drum handling and movement: C Train personnel in proper lifting and moving techniques; C Select vehicles with sufficient rated load capacity to handle anticipated loads, and ensure that vehicles can operate smoothly on available road surfaces; C Air condition the cabs of vehicles to increase operator efficiency and protect the operator with heavy splash shields; C Supply operators with appropriate respiratory protective equipment when needed; 105 C Prepare overpacks before any attempt is made to move drums; C Before moving anything, determine the appropriate sequence for moving drums and other containers; C Exercise extreme caution in handling drums that are not intact and tightly sealed; and C Ensure that operators have a clear view of the roadway when carrying drums. Where necessary, have ground workers available to direct the operator's motion. Drums containing radioactive waste should not be handled until experts in handling radioactive materials have been consulted. If a drum is suspected to contain explosive or shock- sensitive waste, specialized assistance should be sought before handling is initiated. If handling is necessary, extreme caution should be used and all non-essential personnel should remain a safe distance from the handling area. In addition, continuous communication with the Site Health and Safety Officer and/or the command post should be maintained until handling operations are complete. Drums that may be under internal pressure can be identified by bulging or swelling. If a pressurized drum must be moved, whenever possible, the drum should be handled with a grappler unit constructed for explosive containment. Either move the bulged drum only as far as necessary to allow seating on firm ground, or carefully overpack the drum. Exercise extreme caution when working with or adjacent to potentially pressurized drums. Laboratory packs (lab packs) should be considered to hold explosive or shock-sensitive wastes until otherwise characterized. Prior to handling or transporting lab packs, all non- essential personnel should move a safe distance from the handling area. If handling is required, continuous communication with the Site Health and Safety Officer and/or the command post should be maintained until handling operations are complete. Once a lab pack has been opened, it should be inspected and classified according to the hazards of the wastes to ensure safe segregation of the lab packs' contents. If a drum containing a liquid cannot be moved without rupture, its contents should be immediately transferred to a sound drum. Leaking drums that contain sludges or semi- solids, open drums that contain liquid or solid waste, and deteriorated drums that can be moved without rupture should be placed in overpack containers. Prior to initiating subsurface excavation, ground-penetrating systems should be used to confirm the location and depth of drums. Soil should be removed with caution to minimize the potential for drum rupture. In addition, a dry chemical fire extinguisher should be available to control small fires. 10.4 DRUM OPENING Drums are usually opened and sampled in place during site investigations. However, remedial and emergency operations may require a separate drum opening area. Procedures for opening drums are the same, regardless of where the drums are opened. To maximize worker safety during drum opening, the following procedures should be instituted: C If a supplied-air respiratory protection system is used, place a bank of air cylinders outside the work area and supply air to the operators via airlines and escape SCBAs; C Keep personnel at a safe distance from the drums being opened; place explosion-resistant plastic shields between personnel and the drums for protection in case of detonation; locate controls for drum opening equipment, monitoring equipment, and fire suppression equipment behind the explosion-resistant plastic shield; C Conduct air monitoring during drum-opening activities; C Use non-sparking bronze-beryllium tools when possible; C Use remote-controlled devices for opening drums, when feasible; C Hang or balance the drum opening equipment to minimize worker exertion; C If the drum shows signs of swelling or bulging, perform all steps slowly and relieve excess pressure prior to opening; C Open exotic metal drums and polyethylene or polyvinyl chloride-lined drums through the bung by removal or drilling; C Do not open or sample individual containers within laboratory packs; C Reseal open bungs and drill openings as soon 106 as possible; and C Decontaminate equipment after each use to avoid mixing incompatible wastes. Exhibit 10-2 provides a summary assessment of several drum opening techniques, Exhibit 10-3 presents a sample drum characterization sheet, and Exhibit 10-4 illustrates two common examples of drum opening equipment. 10.5 DRUM SAMPLING Drum sampling can be hazardous to worker health and safety because it can involve direct contact with unidentified wastes. Prior to collecting samples, a sampling plan should be developed, including: (1) research about the waste; (2) identification of drums to be sampled; (3) selection of appropriate sampling device(s) and container(s); (4) determination of the number, volume, and locations of samples to be taken; and (5) development of procedures for opening drums, sampling, and sample packaging and transportation. A trained health and safety professional should determine the appropriate personal protection to be used during sampling, decontamination, and packaging of the sample. To maximize worker safety during manual sampling from a drum, the following techniques should be used: C Keep sampling personnel at a safe distance while drums are being opened and sample only after opening operations are complete; C Do not lean over other drums to reach the drum being sampled, unless absolutely necessary; C Cover drum tops with plastic sheeting or other suitable uncontaminated materials; C Never stand on drums -- use mobile steps or another platform to achieve the height necessary to safely sample from the drums; and C Obtain samples with glass rods or vacuum 10.6 CHARACTERIZATION The goal of characterization is to obtain data necessary to determine how to safely and efficiently package and transport the wastes for treatment and/or disposal. If wastes are bulked, they must be sufficiently characterized to determine which of them can be safely combined. Standard compatibility tests are simple, rapid, and cost-effective procedures used to segregate wastes into broad categories, including water reactive, oxidative, and radioactive. By identifying broad waste categories, compatible waste types can be safely bulked on-site without the risk of fore or explosion, and disposal options can be determined without exhaustive and costly analysis of each drum. In some cases, however, further analysis may be necessary to identify the waste materials more precisely. During the compatibility testing process, each drum is scanned for radioactivity as it is opened. If the scan is negative, a sample is taken to perform the compatibility test. (Solid samples should be taken from several different areas within the drum.) In addition, the contents of all drums should be described on the drum data sheet in terms of physical state, viscosity, and number of phases. A sample should be taken for each phase. Exhibit 10-5 provides a sample HAZCAT checklist for recording screening data. There are a number of published compatibility testing protocols; however, procedures must be tailored for site-specific conditions. Exhibit 10-6 presents a thorough protocol developed by the Chemical Manufacturers' Association (CMA). Based on the CMA protocol, wastes can be segregated into the following broad waste categories: Liquids: Radioactives, Peroxides and oxidizing agents, Reducing agents, and Water-reactive compounds. Water Insolubles: Low halogen/low PCB, Mixed halogen/high PCB, and High halogen/low PCB. Acids: Strong (pH<2), Weak (pH 2-7). Bases: Strong (pH>12) with or without cyanides or sulfides, and Weak (pH 7-12) with or without cyanides or sulfides. Solids: Radioactive and Non-radioactive. 107 EXHIBIT 10-2 Summary Assessment of Drum Opening Techniques Recommended Drum Opening Applications (for Sample Acquisition or Recontainerization) # of Drums to be Opened Physical Condition of Drums Waste Content of Drum <100 100-500 >500 Damaged or Bulging Structurally Sound Unknown Shock Sensitive/ Explosive Non- Hazardous Technique Restrictions/Disadvantages Bung Wrenches (Nonsparking) X X X Not recommended for unknown waste contents; full protective gear for worker. Manual Drum Deheader X X X Only if bung is impossible to open; used mainly for recontainerization vs. sample acquisition; unsafe if waste contents are unknown. Self-Propelled Drum Deheader (Electric or Pneumatic) X X X May require use of a dekinker or readjustment of the deheader if the chime is dented. Remotely Operated Pneumatic Wrench X X X X X X Requires direct contact with the drum during attachment of the wrench. Time- consuming setup. Remote Hydraulic Plunger Only in controlled area with spill containment. C Portable X X X X X1 X Most time-consuming hydraulic plunger methods. Requires direct contact with the drum to set up the plunger. C Self-Propelled (Electric or Pneumatic) X X X X X X Only suitable if the chime is free of dents. C Backhoe attached X X X X X1 X Use long boom-dipper arms (12 meters or 40 feet). C Conveyor X X X X X1 X Has not been used in the field to date. Backhoe Spike (Nonsparking) X X X X X X May damage drum; use long backhoe boom (>40 feet). Tube and Spear device for venting X X X X X Method applicable for venting of pressure, but not for drum sampling. 1 Plunger may be of nonsparking bronze or of stainless steel, which is more durable. Source:Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA/500/2-86/013). 108 EXHIBIT 10-3 Sample Drum Characterization Sheet SITE: DRUM #: SAMPLE #: Drum Size: 0 unknown 1 55 gal. 2 30 gal. 3 other specify Drum Opening: 0 unknown 1 ring top 2 closed top 3 open top 4 other specify Drum Type: 0 unknown 1 metal 2 plastic 3 fiber 4 glass 5 other specify Drum Color:PRI SEC 0 unknown 1 cream 2 clear 3 black 4 white 5 red 6 green 7 blue 8 brown 9 pink 10 orange 11 yellow 12 gray 13 purple 14 amber 15 green-blue Drum Contents Color: PRI SEC 0 unknown 1 cream 2 clear 3 black 4 white 5 red 6 green 7 blue 8 brown 9 pink 10 orange 11 yellow 12 gray 13 purple 14 amber 15 green-blue Drum Condition: 0 unknown 1 good 2 fair 3 poor Drum Marking Keywords: #1 #2 #3 Drum Contents State: PRI SEC 0 unknown 1 solid 2 liquid 3 sludge 4 gas 5 trash 6 dirt 7 gel Drum Content Amount: 0 unknown 1 full 2 part 3 empty Chemical Analysis: YES NO radiation ignitable water reactive cyanide oxidizer organic vapor ppm pH Real-time Instrument Readings Colorimetric tube Radiation PID FID Source: EPA Region VII Emergency Planning and Response Branch 109 EXHIBIT 10-4 Examples of Drum Opening Equipment 110 EXHIBIT 10-5 HAZCAT Checklist: Characterization Screening Data Screening Data YE S NO Criteria RADIOACTIVE G G $1 mR over background ACIDIC G G pH # 3 CAUSTIC G G pH $ 12 AIR REACTIVE G G Reaction of $ 10BF temp. change WATER REACTIVE G G Reaction of $ 10BF temp. change WATER SOLUBLE G G Dissolves in water WATER BATH OVA G G Reading = $10 ppm = Yes COMBUSTIBLE G G Catches fire when torched in water bath HALIDE G G Green flame when heated with copper INORGANIC G G WATER BATH OVA and COMBUSTIBLE = No ORGANIC G G INORGANIC = No ALCOHOL/ALDEHYDE G G WATER BATH OVA, WATER SOLUBLE, and COMBUSTIBLE = Yes CYANIDE G G Draeger tube over water bath $ 2 ppm FLAMMABLE G G Combustible = Yes, and SETA flashpoint # 140BF OXIDIZER G G Starch iodine paper shows positive reaction INERT OR OTHER G G Everything "No" except INORGANIC or ORGANIC PCB SCREEN (Chlor-N-Oil)G G G G G > 50 ppm < 50 ppm 100% Source: EPA Region VII Emergency Planning and Response Branch. This chart is provided only as an example; values may need to be modified as appropriate. 111 EXHIBIT 10-6 CMA COMPATIBILITY TESTING PROTOCOL Source:Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA/500/2-86/013). 112 E XHIBIT 10-6 (cont'd) CMA COMPATIBILITY TESTING PROTOCOL Water Insoluble Liquids Testing Source:Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA/500/2-86/013). 113 EXHIBIT 10-6 (cont'd) CMA COMPATIBILITY TESTING PROTOCOL Water Soluble Scan Source:Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA/500/2-86/013). This protocol also requires that a compatibility test be performed by mixing small samples of wastes that are intended to be bulked, making visual observations for precipitation, temperature 114 FURTHER GUIDANCE: For more information on drum handling, see: 1.Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities. (NIOSH/OSHA/USCG/EPA, 1985, NIOSH Publication 85-115). 2.Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA 500/2-86/013). 3.Guidance Document for Cleanup of Surface Tank and Drum Sites (U.S. EPA, Publication 9380.0-3). changes, or phase separation. When possible, materials should be characterized using an on-site laboratory to minimize the time before appropriate action can be taken to handle any hazardous materials. If samples must be analyzed off-site, samples should be packaged on-site in accordance with DOT regulations (49 CFR Parts 171-178) and shipped to the laboratory for analysis. Shamrock Environmental Corporation Health and Safety Plan Former Yorkshire Americas Co Site Lowell, NC September 2, 2009 APPENDIX E POTENTIAL CONTAMINANTS OF CONCERN SHIPMENT INFO.WEIGHT Pallet or Package #PROPOSED CONTAINER #ACTUAL CONTAINER #SHIPPED DATEProduct Name D-Drums, B-Bags, C-Container, O-Other MSDS Availabl e (lbs) (kgs) A- Actual, E- Estimate 16 Nydye Scarlet GN Crude 4D 877 398 A 17 Nydye Scarlet GN Crude 4D 607 275 A 30 Intralan Yellow 3RL, Nydye Scarlet GN Crude 3D + 1D Y/N 642 291 A 37 2-Amino-5-Nitrobenzoic Acid B Y - E 64 10 1,2,4-BN Chrome Base (Acetic Acid)2D Y - E 68 PAPP Base Crude 4D Y - E 69 PAPP Base Crude, MAAP BS 1D + 3D Y/N - E 75 11 N-Cyanoethyl-O-Chloroanaline 4D Y - E 76 11 N-Cyanoethyl-O-Chloroanaline 4D Y - E 77 11 N-Cyanoethyl-O-Chloroanaline 4D Y - E 78 11 N-Cyanoethyl-O-Chloroanaline 4D Y - E 79 11 N-Cyanoethyl-O-Chloroanaline 4D Y - E 80 11 N-Cyanoethyl-O-Chloroanaline 4D Y - E 81 11 N-Cyanoethyl-O-Chloroanaline 4D Y - E 82 11 N-Cyanoethyl-O-Chloroanaline 4D Y - E 83 11 N-Cyanoethyl-O-Chloroanaline, O-Toluidine 1D + 3D Y/Y - E 90 11 Ortho Toluidine 4D Y - E 92 11 2-Aminobenzotriflouride 4D Y - E 95 11 N-Cyanoethyl-N0Ethylaniline 4D Y - E 96 11 N-Cyanoethyl-N0Ethylaniline 4D Y - E 97 10 N-Cyanoethyl-N0Ethylaniline, M-Cresol 3D + 1D Y/Y - E 100 11 3 N N Diethylamino Acetanalide 99%B Y - E 101 11 3 N N Diethylamino Acetanalide 99%B Y - E 102 11 3 N N Diethylamino Acetanalide 99%B Y - E 103 11 3 N N Diethylamino Acetanalide 99%B Y - E 104 11 3 N N Diethylamino Acetanalide 99%B Y - E 108 11 Dimethyl ONCB Sulfonamide * D - E 109 11 Dimethyl ONCB Sulfonamide * D - E 110 11 Dimethyl ONCB Sulfonamide * D - E 111 11 Acetic anhydride, Sodium Hydrosulfite * 2D+2D Y/Y 945 429 A 113 11 3- (Diethylamine) Propylamine * 2D Y 481 218 A 114 11 Lecoquinizarine (Need Labels)* 4D Y 914 414 A 115 11 Lecoquinizarine (Need Labels)* 4D Y 945 429 A 116 11 Lecoquinizarine (Need Labels)* 4D Y 1041 472 A 117 11 Octowet 75 * 4D 2093 949 A 118 11 N, Ethylmetatoluidine, Epichlorohydrin * 1D+1D Y/Y 818 371 A 119 11 Methylamine Aqueous Solution * 3D 1375 624 A 120 11 3- Bis(acetoxyethyl) aminoacetanilide *4D Y 1747 792 A 121 11 Ammonium Hydroxide 20.75 BE * 2D 591 268 A 122 11 Aqua Ammonia 26% BE * 3D Y 1197 543 A 123 11 Trimethylamine 25% Solution * 4D Y 1803 818 A 124 11 Trimethylamine 25% Solution * 4D Y 1817 824 A 125 11 Trimethylamine 25% Solution * 4D Y 1806 819 A 126 11 Trimethylamine 25% Solution * 3D Y 1247 566 A 127 11 Trimethylamine 25% Solution * 3D Y 1368 620 A 128 11 Trimethylamine 25% Solution,Benzylalkhol * 3D+1D Y/Y 1423 645 A 129 11 Epichlorohydrin, Dimethylaminoprpylamin * 1D+2D Y/Y 741 336 A 130 11 Glycol Ether PNP * 4D 1639 743 A 131 11 3(Dimethylamino) Propylamine * 4D Y 1372 622 A 132 1,2-Butylene Oxide * 3D Y 1372 622 A 133 Glycol Ether PNP * 4D 1037 470 A 134 1,2-Butylene Oxide * 4D Y 1615 732 A 135 Glycol Ether PNP * 4D 1818 824 A 147 Red FTS Y 1519 689 A 159 Intrasil Orange 4RL Y 68 31 A 160 Intrazone Red G Y 646 293 A 161 Intrazone Red G Y 1158 525 A 162 Intralite Brill Scarlet 2GL Y 1017 461 A 163 Intracron Black VS-B Liquid 50%Y - E 164 Intracron Black VS-B Liquid 50%Y - E 165 Intracron Black VS-B Liquid 50%Y - E Kings Mountain, Master Pallet List - Lowell, N.C. Last Updated: 8.5.09 Notes: * - FLAMABLE MATERIALS C:\Documents and Settings\jhollingsworth.DOMAIN\Local Settings\Temporary Internet Files\OLK8E\IPP.xls1 SHIPMENT INFO.WEIGHT Pallet or Package #PROPOSED CONTAINER #ACTUAL CONTAINER #SHIPPED DATEProduct Name D-Drums, B-Bags, C-Container, O-Other MSDS Availabl e (lbs) (kgs) A- Actual, E- Estimate Kings Mountain, Master Pallet List - Lowell, N.C. Last Updated: 8.5.09 166 Intracron Black VS-B Liquid 50%Y - E 167 Nylanthrene Orange 3G Liquid 33%Y - E 171 Intracron Black VS-B Liquid 50%Y - E 173 Yoracryl Red BS Liquid 200%Y - E 174 Nylanthrene Red GN Liquid 33%Y - E 175 Serilene Black G-BC Liquid Y - E 176 Serilene Black G-BC Liquid Y - E 177 Sodium Sulfate Anhydrous, Sodium Tripolyphosate 1D+1D+ Y/Y/N/Y 748 339 A 185 Intrasperse Brill B-G Crude,Serilene Red HWF 85%2D+2D Y 920 417 A 188 Intralan Gray k-GL 200%4D 1016 461 A 189 Intralan Gray k-GL 200%4D 1021 463 A 190 Aquarian Org O, Common Salt 2D+2D Y/N/Y/N 351 159 A 195 Intralan Grey K-GL 200%4D 1021 463 A 197 Intrasil Bordeaux 3BSF Crude 4D Y 1080 490 A 202 Nylanthrene Blue 3BLF 4D Y 335 152 A 203 Nylanthrene Brill Red C- 3B Cone 6D Y 375 170 A 204 Direct Black BH-NB,Intralan Yellow 3RL, Serilene 2D+1D Y/Y/Y 710 322 A 205 Intrasil Blue FBLN-X,Intrasil Red MW, Stylacyl Red 1D+1D+ Y/Y/Y/Y 580 263 A 208 Nylanthrene Red B-2B Diluent 4D Y 598 271 A 216 Intrasil Navy H-RSN 200%6D Y - E 217 Intrasil Red 3BLS, Intrasil Yellow FRL, Intrasil Ora ybla 3D+2D+1D Y/N/N - E 220 Direct Black E-AB, Intrazone Fast Blue 5R 175%Y/Y 445 202 A 220 Altcofast Black KR-HPM 200%2D+1D+1D Y/Y/Y 445 202 A 223 Sol-Aqua-fast Red2BL, Direct Scarlet 4SWN,Direct 1D+1D+2D Y/Y/Y 448 203 A 223 Black E-AB - E 224 Nylanthrene Blue RRL, Nylanthrene Brill Yellow 4NGL 1D+1D+ Y/Y/Y/N - E 224 200%, Intrasil Brown 3R 150%, Intrasil Red 3RL 1D+1D - E 225 Nylanthrene Yellow FLW-S Crude, Intracid Red 2G Conc, 1D+1D+ Y/Y/Y/N - E 225 Nylanthrene Brill Yellow 4NGL 200%, Intralan Blue Crude 1D+1D - E 227 Intralan Brill Yellow 3GL New Crude, Intrasil Orange 4RL, 3D+1D Y/Y - E 227 Crude - E 228 Serilene Red HWF 85%, Intrasil Orange 4RL Crude 2D+2D Y/Y - E 230 Intrasil Orange 4RL Crude 4D Y - E 231 Supernylite Blue 3R 200%, Intralite Brill Blue L, 1D+1D+ Y/Y/Y/Y - E 231 Nylanthrene Blue RRL, Intrasil Yellow 5R Conc 1D+1D - E 236 Stylacyl Blue BR, Intrasil Red FTS, Intrasil Brown 1D+1D+2D N/Y/Y 502 228 A 236 UN-2RFL - E 238 Nylanthrene Blue 2RFF, Nylanthrene Red B-2BSA 200% 1D+1D+ Y/Y/Y/Y 490 222 A 238 Nylanthrene Blue LGGL 200%, Intrasil Black FTF 150% 1D+1D - E 240 Intralan Blue K-3GL Crude 4D Y 618 280 A 241 Red B2B Diluent, Intralan Gray K-GL 200%, 2D+1D+1D N/N/Y 769 349 A 241 Nylanthrene Blue 2RFF - E 242 Intralan Blue K-3GL Crude 4D Y 833 378 A 247 Red B-2BSA- Diluent 4D 429 195 A 248 Nylanthrene Rubine CSBL 200%, Intralan Yellow3RL, 3D+1D+ N/Y/NN 241 109 A 248 Intrasil Red RB Powder, Intralan Brown BRL 1D+1D - E 253 Intrasil Rubine CK-GFL, Intrasil Black 2BN 200%, 1D+1D+443 201 A 253 Intrasil Orange 2GR, Intrasil Yellow BRY- N- CONC 1D+1D - E 254 Seriplas Navy HRS, Intrasil Brown 2RFL Liquid 100%,359 163 A 254 Intracid Red 2G 115%, Intralite Red 5B Extra CONC - E 255 Intralan Yellow A-CA, Intrasperse Red YNB EX- 1D+1D+2D 272 123 A 255 CONC, Isolan Yellow NW 250% - E 259 Intracron Brill Red VS-4BL, Intracron Golden-Orange 1D+1D+2D 568 258 A 259 VS-3G 150%, Intrasil Red RB Liquid 50% - E 261 Intralite Blue 2GL Crude, Intralan Yellow HL, 1D+1D+473 215 A 261 Nylanthrene Orange A 200%, Serilene Black TLR 200% 1D+1D - E 263 Intracron Black LW Hi Conc 4D 1255 569 A 266 Intrasil Rubine CK-GRL 200%, Intrasil Black UN-JP 602 273 A 266 OHP 220% 1D+3D - E 268 Nylanthrene Rubine 5BLF, Serilene Crimson HWF,492 223 A 268 Intralan Red S CA New OHP 220% 2D+1D+1D - E Notes: * - FLAMABLE MATERIALS C:\Documents and Settings\jhollingsworth.DOMAIN\Local Settings\Temporary Internet Files\OLK8E\IPP.xls2 SHIPMENT INFO.WEIGHT Pallet or Package #PROPOSED CONTAINER #ACTUAL CONTAINER #SHIPPED DATEProduct Name D-Drums, B-Bags, C-Container, O-Other MSDS Availabl e (lbs) (kgs) A- Actual, E- Estimate Kings Mountain, Master Pallet List - Lowell, N.C. Last Updated: 8.5.09 271 Intralan Yellow NW Crude 3D 544 247 A 272 Intrasil Black RXNFS 200%, Intrasil Orange YBLH Liq. 1D+1D+508 230 A 272 50%, Nylanthrene Red 2BN 200%, Nylanthrene Ora 3G 1D+1D - E 273 Intralan Yellow Nw Crude 4D 417 189 A 274 Intralan Yellow NW Crude 4D 577 262 A 275 Styacyl Yellow RG, Intrasil Red FTS Presscake, 1D+1D+549 249 A 275 Intrasil Bordeaux 3BSF Liq., Intracron Orange 1D+1D - E 276 (BASF) Luvitec K17 Pulver 4D 390 177 A 277 Intrasil Bordeaux 3BSF Crude 4D 858 389 A 278 Azoanthrene Jet black K High Conc., Serilene Black 1D+1D+327 148 A 278 GL Liq. 100%, Nylanthrene Red C-RBS 200%, Nydye 1D+1D - E 278 Navy Blue M 200%- E 279 Direct Brill Green CBM-NB Crude, Nylathrene Blue 634 288 A 279 LGGL Crude, Intracron Red VS-RBL Crude 1D+1D+2D - E 281 Nylanthrene Red B-2B 200%, Intrasil Orange H2GFS 562 255 A 281 Crude, Nylanthrene Blue LGGL 2D+1D+1D - E 296 Intrasil Black OBN Crude 4D 1027 466 A 299 Intrasil Black OBN Crude 4D 992 450 A 301 Intrasil Black OBN Crude, Intrasil Orange RSE 2D+2D 1005 456 A 302 Intrasil Black OBN Crude 4D 1010 458 A 303 Intrasperse Red Violet RH New, Spectra Blue 3GK 621 282 A 303 Dispersion, Violet 23 Dispersion N3B 1D+1D+2D - E 304 Violet 23 Dispersion N3B, Acarmin Scarlet LDCN 2D+2D 1823 827 A 305 Intracron Golden-Orange, Intrasil Bordeaux 3BSF Liq. 2D+2D 1468 666 A 306 Orange YBLH Dry Presscake, Intrasil Yellow 4GNLS, 1D+1D 486 220 A 306 Serilene Black G-NB Liq., Intracron God-Orange VS-3G Cru. 1D+1D - E 307 Intralan Red S-G, Nylanthrene Blue GLF Crude,566 257 A 307 Intralan Bordeaux RLB 200%1D+1D+2D - E 308 Intralan Brown M-BL Liq., Superlite Fast Yellow EFC,782 355 A 308 Nylanthrene Rubine 5BLF 1D+2D+1D - E 310 CMC, Intrasil Brown 2RFL, Intrasil Bordeaux BRB 1D+1D 840 381 A 311 Intrasil Bordeaux 3BSF Liq.4D 825 374 A 312 Intrasperse Red Violet RH Crude, Intrasil Rubine CK-711 322 A 312 GFL Liq. 50%, Intrasil Blue M-GS 2D+1D+1D - E 313 Intrasil Brown 3R 150%, Nylanthrene Brill Yellow 4NGL 888 403 A 313 liq., Nylanthrene Brill Blue 2RFF Crude 1D+1D+2D - E 314 Intrasil Bordeaux 3BSF Liq., Nylanthrene Brill Blue 693 314 A 314 3BLF, Intrasil Navy M-Rex 300%2D+1D+1D - E 315 Nylanthrene Black C-MGF, Nylon Fast Black G-BW 2D+2D 525 238 A 316 Intrasil Orange H-2GFS, Stylacyl Yellow RG, Intralan 1D+1D 598 271 A 316 Yellow 2BRL SM 250%, Intrasil Rubine 2GFL 1D+1D - E 317 Intrasil Orange M-GH, Nylanthrene Orange A, Intrasil 1D+1D+2D 627 284 A 319 Intrasil Black M-Rex 300% Unfinished 4D 1020 463 A 320 Intrasil Black M-Rex 300% Unfinished, Intrasil Orange 871 395 A 320 RSE 3D+1D - E 321 Intralan Boudeaux 3R Crude 4D 541 245 A 322 Intralan Boudeaux 3R Crude 4D 557 253 A 324 Intrasil Orange YBHL, Nylanthrene Blue GLF Crude 1D+3D 566 257 A 325 Nylanthrene Brill Blue 2RFF Crude 4D 651 295 A 326 Intrasil Brown 2RFL Liq.100%, Supernylite Blue 3R 1D+1D 636 288 A 326 200%, Nydye Black EB 200%, Nylanthrene Orange 1D+1D - E 328 Intrasil Orange M-5GH Crude 4D 1361 617 A 332 Intrasil Blue M-GS, Intrasil Black RB-FS200%,1D+1D+676 307 A 332 Intrasil Bordeaux 3BSF, Intrasil Bordeaux 3BSF liq.1D+1D - E 333 Nylanthrene Brill Yellow CGL, Intrasil Orange H-2GFS, 1D+1D+382 173 A 333 Nylon Black G-CKP, Intrasperse Brill Blue B-Supra 1D+1D - E 336 Intrasil Black M-Rex 300% Unfinished 4D 1014 460 A 340 Intrasil Black M-Rex 300% Unfinished 4D 1030 467 A 341 Intralan Bordeaux 3R Crude 4D 542 246 A 342 Intrasil Black 2BN 200%, Nylanthrene Red B-2BSA 3D+1D 552 250 A 343 Intrasil Yellow SESR,Intralan Yellow 3RLCA Conc,1D+1D+810 367 A Notes: * - FLAMABLE MATERIALS C:\Documents and Settings\jhollingsworth.DOMAIN\Local Settings\Temporary Internet Files\OLK8E\IPP.xls3 SHIPMENT INFO.WEIGHT Pallet or Package #PROPOSED CONTAINER #ACTUAL CONTAINER #SHIPPED DATEProduct Name D-Drums, B-Bags, C-Container, O-Other MSDS Availabl e (lbs) (kgs) A- Actual, E- Estimate Kings Mountain, Master Pallet List - Lowell, N.C. Last Updated: 8.5.09 343 Intrasil Scarlet H-GP 2D - E 344 Serilene Yellow, Intrasil Orange M-5GH Crude 1D+3D 1114 505 A 347 Fuchsine GB 4D 1050 476 A 348 Serilene Black G-NB liq., Nylanthrene Brill Yellow 606 275 A 348 4NGL liq.,Citric Acid, Luvitec k-17 Putver - E 349 Intralan Bordeaux,Nylanthrene Rubine, Intralane Yellow,- E 349 2D Nylanthrene Yellow, 3D Intrasil Brill Yellow, - E 349 Intracron Brown, Intrasil Orange, Intrasil Red, - E 349 Nylanthrene Blue, Aquarine Orange (Small Drums Samples)341 155 A 350 Cinsperse SDP, Tween-65, Joncryl 9, Intracid Yellow 2G 1D each Y 1465 664 A 351 11 Amino J Pyrazolone MW 384, Reax B3A, Nylanthrene 1D+1D+ Y 1313 595 A 351 Red B-2BSA, Acid Blue BRL 1D+1D - E 352 Pluronic F68 Prill Surfactant 4D Y 997 452 A 353 Tetronic 1307 Surfactant Pastille, Pluronic F68 Prill 3D+1D - E 353 Surfactant 800 363 A 357 Brill Yellow 4NGL, Ethylenediaminrtetraacetic-acid,1D+1D+- E 357 Intramet Navy Blue 1D - E 358 Intralan Blue 3GL Crude, Intrasil Brill Yellow BRY-N 454 206 A 358 liq.,Lithium Hydroxide Monohydrate, Intralan Black - E 358 RBL Crude - E 362 3-box Nylanthrene Yellow 3RL (can), 1-box Intrasil Black EX-SF 294 133 A 362 300% unfinished, Direct Bordeaux GB 200%, Intrasil - E 362 Violet 175% Unfinished - E 367 VS-RP, Intrazone Red G-Crude - E 371 Unknown Chemical(not dye)- E 383 DE Acetate, Alpha Base, Yellow MS Free Acid 2D+1D+1D - E 386 11 Xylidines Mixed 4D 1883 854 A 387 11 Xylidines Mixed 4D 1973 895 A 408 Paraphenylene Diamine-2-Sulfonic Acid 6D Y 766 347 A 423 Paraphenylene Diamine-2-Sulfonic Acid 4D - E 460 4-nitro-pmp cowling crude 4D - E 461 4-nitro-pmp cowling crude 4D - E 462 4-nitro-pmp cowling crude 4D - E 463 5-nitro-bn coupling press cake 4D - E 464 5-nitro-bn coupling press cake 4D - E 465 10 maapbs 4D - E 466 10 maapbs 4D - E 467 10 maapbs 4D - E 468 10 maapbs 4D - E 469 10 maapbs 4D - E 470 10 maapbs 4D - E 471 10 maapbs 4D - E 472 10 1,2,4-bn chrome base 4D - E 473 10 1,2,4-bn chrome base 4D - E 474 10 1,2,4-bn chrome base 4D - E 475 10 1,2,4-bn chrome base 4D - E 476 10 1,2,4-bn chrome base 4D - E 477 10 1,2,4-bn chrome base 4D - E 478 10 1,2,4-bn chrome base 2D - E 479 10 1,2,4-bn chrome base 4D - E 480 10 1,2,4-bn chrome base 4D - E 481 Red CN Chloride 4D - E 482 Red CN Chloride 4D - E 483 Red CN Chloride 4D - E 484 10 ANDS base 100% basis (25kg)10 bags - E 485 10 ANDS base 100% basis (25kg)10 bags - E 486 10 ANDS base 100% basis (25kg)10 bags - E 487 10 ANDS base 100% basis (25kg)10 bags - E 488 10 ANDS base 100% basis (25kg)10 bags - E 489 10 ANDS base 100% basis (25kg)10 bags - E 490 10 ANDS base 100% basis (25kg)14 bags - E Notes: * - FLAMABLE MATERIALS C:\Documents and Settings\jhollingsworth.DOMAIN\Local Settings\Temporary Internet Files\OLK8E\IPP.xls4 SHIPMENT INFO.WEIGHT Pallet or Package #PROPOSED CONTAINER #ACTUAL CONTAINER #SHIPPED DATEProduct Name D-Drums, B-Bags, C-Container, O-Other MSDS Availabl e (lbs) (kgs) A- Actual, E- Estimate Kings Mountain, Master Pallet List - Lowell, N.C. Last Updated: 8.5.09 491 10 ANDS base 100% basis (25kg)10 bags - E 492 10 ANDS base 100% basis (25kg)10 bags - E 493 10 ANDS base 100% basis (25kg)10 bags - E 494 Emery 5717 1D - E 495 Emery 5717 4D - E 496 Emery 5704 2D - E 497 Emery 5704 4D 2165 982 A 498 Emery 5704 4D 2167 983 A 504 10 N-Phenyl J Acid Purch MW315 9 bags - E 506 10 Sodium Sulfate 49 bags 3247 1,473 A 507 10 S Nitroanthranilic Acid Purity 98.6%12 bags 515 234 A 508 10 Broenners Acid 1D - E 509 5-nitro-bn coupling press cake 1D - E 510 Para Nitro Aniline 12 bags - E 511 10 1-Acetamino-7-Naphthol 14 bags - E 512 10 Ands base 8 bags - E 513 10 J ACID Purity 90%8 bags - E 517 Y ACID Purity 98.75%3 bags - E 524 11 2,5-Dichloroaniline-4-sulfonic acid 28 bags - E 525 11 2,5-Dichloroaniline-4-sulfonic acid 28 bags - E 526 11 2,5-Dichloroaniline-4-sulfonic acid 28 bags - E 527 11 2,5-Dichloroaniline-4-sulfonic acid 28 bags - E 528 11 2,5-Dichloroaniline-4-sulfonic acid 28 bags - E 529 11 2,5-Dichloroaniline-4-sulfonic acid 28 bags - E 530 11 2,5-Dichloroaniline-4-sulfonic acid 28 bags - E 531 11 2,5-Dichloroaniline-4-sulfonic acid 28 bags - E 540 1-Amino-2-Brumo-4-Hydroxyanthraquiman 20 bags - E 541 1-Amino-2-Brumo-4-Hydroxyanthraquiman 20 bags - E 542 1-Amino-2-Brumo-4-Hydroxyanthraquiman 20bags - E 543 1-Amino-2-Brumo-4-Hydroxyanthraquiman 20 bags - E 545 - E 549 10 Monoethanol Amine 4D - E 550 Emery 5728 4D - E 551 Emery 5703 3D - E 552 Emery 5709 4D - E 553 - E 554 - E 564 4 chloroacetyl Acetanilide 5D E 565 N-Ethlt-m-toluidene 3D E 568 4-(Dimethylamino) Benzaldehyde 4D E 569 4-4 Thiodiphenol 2D E 570 Roma scarlet FDL 006710 4D E 571 A,ino J acid MW303 9B E 572 11 Phthalic Anhydride 5D E 573 11 p-hydroxyacetanilide 4D E 574 p-hydroxyacetanilide 4D E 575 Chloranil 2D E 576 11 3-(Diethylamino) Acetanilide 15B E 577 11 3-(Diethylamino) Acetanilide 15B E 578 11 3-(Diethylamino) Acetanilide 15B E 579 11 3-(Diethylamino) Acetanilide 15B E 580 11 3-(Diethylamino) Acetanilide 15B E 581 11 3-(Diethylamino) Acetanilide 15B E 582 11 3-(Diethylamino) Acetanilide 15B E 583 11 3-(Diethylamino) Acetanilide 15B E 584 11 3-(Diethylamino) Acetanilide 15B E 585 11 3-(Diethylamino) Acetanilide 15B E Cyclohexylamine - E (STPP),Sodium Perborate, Stadex #62 1D+1D - E Nylanthrene Black G-SC,Direct Black GX-NB Cone 1D+1D - E 1 Box Intrasil Brown 3R 150%, 1Box Navy HRSN - E Notes: * - FLAMABLE MATERIALS C:\Documents and Settings\jhollingsworth.DOMAIN\Local Settings\Temporary Internet Files\OLK8E\IPP.xls5 SHIPMENT INFO.WEIGHT Pallet or Package #PROPOSED CONTAINER #ACTUAL CONTAINER #SHIPPED DATEProduct Name D-Drums, B-Bags, C-Container, O-Other MSDS Availabl e (lbs) (kgs) A- Actual, E- Estimate Kings Mountain, Master Pallet List - Lowell, N.C. Last Updated: 8.5.09 New 90%, Sevron Red LMF, Nylanthrene Red B-2B 1D+1D+- E Navy G-RA - E RY, Intracid Red 2G Cone 1D+1D - E Intrasil Brown UN-2RFL, Sevron Red YCN 1D+1D - E Intrasil Yellow 2GW 200% unfinished, Supernylite Blue 1D+1D - E Black FTF 150%- E Phenol 99%- E N-Ethlt-m-toluidene 1D E methyl-pyrazolone E methyl-pyrazolone E 2,4-dinitrochlorobenzene 1D E Roma scarlet FDL 006710 2D E Phthalic Anhydride 1D E Diethyl Suifate 6.1.1D E 586 Domino Sugar 15B E 587 3-Bis(acetoxyethyl aminoacetanilide 4D E 588 P-Phenetidine 4D E 589 Lamepon 21B E 590 Intrasil Navy M-Rex 300% unfinished 24B E 591 Intralan Dark Blue M-BR Crude 20B E 592 Chrysazin 8B E 593 Chrysazin 18B E 594 Methoxymeta Base Sulfate 35B 2006 910 A 595 Methoxymeta Base Sulfate 35B 1728 784 A 596 Methoxymeta Base Sulfate 35B 1795 814 A 597 Methoxymeta Base Sulfate 35B 1731 785 A 598 Sulfuric Acid 3D 599 Sodium Hypochlorite 4D 600 PEG 600 Polyethylene Glycol 3D 601 Sulfuric Acid 4D 602 Sulfuric Acid 4D 603 PEG 600 Polyethylene Glycol 4D 604 (2 Drums) Glycol Ether DPM 4D (1 Drums) Sufuric Acid (1 Drums) PEG 600 Polyethylene Glycol 605 Sulfuric Acid 4D 606 Sulfuric Acid 4D 607 Sulfuric Acid 4D 608 Sulfuric Acid 4D 609 Sulfuric Acid 4D 610 Sulfuric Acid 4D 611 (2 Drums) PEG 600 Polyethylene Glycol 3D (1 Drums) Sulfuric Acid 612 P-Cresol 90% Solution 1D 613 P-Cresol 90% Solution 4D 614 P-Cresol 90% Solution 4D 615 P-Cresol 90% Solution 4D 616 P-Cresol 90% Solution 4D 617 P-Cresol 90% Solution 4D 618 P-Cresol 90% Solution 4D 619 P-Cresol 90% Solution 4D 620 PEG 600 Polyethylene Glycol 4D 621 Unknown (Stainless Drums)2D 622 TWEEN2 3D 623 PEG 600 Polyethylene Glycol 4D 624 PEG 600 Polyethylene Glycol 4D 625 PEG 600 Polyethylene Glycol 4D 626 PEG 600 Polyethylene Glycol 4D 627 Sulfuric Acid 4D 628 (2 Drums) Sulfuric Acid 3D (1 Drums) PEG 600 Polyethylene Glycol Notes: * - FLAMABLE MATERIALS C:\Documents and Settings\jhollingsworth.DOMAIN\Local Settings\Temporary Internet Files\OLK8E\IPP.xls6 SHIPMENT INFO.WEIGHT Pallet or Package #PROPOSED CONTAINER #ACTUAL CONTAINER #SHIPPED DATEProduct Name D-Drums, B-Bags, C-Container, O-Other MSDS Availabl e (lbs) (kgs) A- Actual, E- Estimate Kings Mountain, Master Pallet List - Lowell, N.C. Last Updated: 8.5.09 629 Sulfuric Acid 2D 630 No Markings (PEG 600 Polyethylene Glycol) 3D 631 (2 Drums) No Markings (Sulfuric Acid) 3D (1 Drum) No Markings (PEG 600 Polyethylene Glycol) 632 (1 Drum) Sulfuric Acid 3D (2 Drums) Dye 633 Dye 3D 634 Dye 4D 635 PEG 600 Polyethylene Glycol 4D 636 Glycol Ether DPM 4D 637 (1 Drum) Glycol Ether DPM 4D (1 Drum) Caustic Potash 45% (1 Drum) Overpack? (1 Drum) Drum unknown 638 Clear Tote (unknown liquid inside) 1 Tote 639 Clear Tote (unknown liquid inside) 1 Tote 640 Unknown (1 Drum) 1 Drum & 1 Small Jug Unknown (1 Small Jug 641 Glycol Ether TPM 3D 642 Glycol Ether DPM 4D 643 Glycol Ether DPM 3D 644 Glycol Ether DPM 4D 645 Glycol Ether DPM 3D Notes: * - FLAMABLE MATERIALS C:\Documents and Settings\jhollingsworth.DOMAIN\Local Settings\Temporary Internet Files\OLK8E\IPP.xls7 SITE SPECIFIC WORK PLAN KMV SITE 1602 N. Main St LOWELL, NC October 8, 2009 Table of Contents 1. Introduction 2. Agreed Site Services 3. Scope Of Work 4. Quality Assurance/ Quality Control 5. Reporting 6. Schedule 1. Introduction: A. Site Description The KMV Site, located at 1602 N Main St in Lowell, NC (“the Site”) is a former organic dye and pigment manufacturing facility whose owners filed for bankruptcy and subsequently ceased operations in 2004 as Yorkshire Americas. The 42-acre site (See Attachment 1) was purchased in total from the Bankruptcy Estate of Yorkshire Americas in total by KMV, Inc on or around June 23, 2006, for the purpose of establishing the facility as a Brownfield site with the eventual intent of developing the site as a multi-use development in a growing community. Historically, after a number of years of dye and surfactant manufacturing the facility was closed down where upon all employees were dismissed. All production operations including Receiving and Shipping ceased, equipment, raw materials, and manufactured stock was left at the facility and the facility secured. Concluding the purchase of the property and associated assets in 2006, KMV took possession and management of the site and hired a full-time Site Manager to arrange and provide for needed security as well as facilitate other services needed by KMV. At the time of the transition of ownership, the facility had and continues to contain thirty-five (35) constructed buildings (See Attachment 2) a number of above ground storage tanks which at one time contained various raw materials such as Sulfuric and Hydrochloric Acids, Sodium Hydroxide, Fuel Oils, as well as WWT sludges and treated water. Additionally, a facility inventory generated by KMV indicated that raw materials and manufactured products stored onsite in various sized steel and poly containers contained, acidic and base products, flammable and nonflammable materials, chemical intermediates, Maintenance and Wastewater Treatment chemicals as well as nonhazardous powdered and liquid dyes. The total and exact contents of all containers were unknown. B. Site Clean-Up Actions Initiated by KMV On or around July of 2009, KMV contracted the services of HAZ~MAT Environmental Services, Inc of Charlotte, NC for the purpose of addressing the removal of chemical products described above which were stored in vertical carbon steel and fiberglass tanks as well as 55-gallon poly drums. Approximately 30,000-gallons of raw materials were shipped during this period via Straight Bills- of-Laden to a receiving facility located in Newton, NC for the use as a product. C. EPA Enforcement Activity During the period in which the above services were being performed (August 31, 2009) the site was visited by the North Carolina Department of Environment and Natural Resources (NCDENR) along with enforcement personnel from Federal EPA Region IV. The site was inspected for environmental concerns pertaining to the presence of environmentally hazardous chemicals and conditions which were considered to be in violation of the Federal Resource Conservation and Recovery Act (RCRA) and or maybe considered an immediate threat to the soil and or groundwater. As a result of this visit Federal EPA out of Region IV elected to assign an On Scene Coordinator (OSC) to this site 2. Agreed Site Services: At the time of the above visit, a number of the (35) buildings contained identified and unidentified materials in various sized containers, a number of full and empty containers were noted to be located exterior to the onsite buildings, and several aboveground tanks contained acidic materials. Region IV EPA requested and KMV accepted that KMV will voluntarily perform activities to satisfy the following: A. Provide for Site security. B. Immediately provide for the segregation of non-compatible materials and/or wastes. C. Immediately clean up any spills of hazardous substances and/or used D. Immediately provide a plan for the prevention of releases into, or further migration of, chemicals, mixtures, or solutions into the environment (specifically address dye totes and building floors that exhibit spills of dyes and chemicals or used oil). E. Immediately identify all usable products destined for future use and/or sale. F. Repackage all materials and wastes that are currently in compromised containers within 28 days. G. Characterize and properly label all wastes on Site within 28 days. H. Provide an inventory of all usable products and wastes on Site (including the location and quantity of each) within 28 days. I. Describe the intent (whether sale of usable product or disposal of unusable wastes) of each substance, chemical, mixture, or solution on Site within 60 days. J. Provide for the sale and shipment off-site of all usable products by December 25, 2009, including providing the identity of each intended receiver and the designated destination for each usable product prior to shipment. K. Properly dispose of all wastes on Site by December 25, 2009. L. Perform structural integrity testing of all tanks with volumes in excess of 10,000 gallons, or provide previously performed structural integrity reports on all such tanks. KMV, Inc, has voluntarily elected to handle the requested service needs described herein, utilizing HAZ~MAT Environmental Services, Inc. out of Charlotte, NC for completion of same. 3. Active Scope of Work: A. Site has and will continue to be totally fenced to prevent the introduction of unauthorized personnel 24/7 as well as established patrols by local authorities. During the working days onsite, sign in sheets and a gate monitor has and will continue to be utilized to control vendors and unauthorized personnel from entering the site. B. Prepare and update as needed and or dictated of an active Health & Safety Plan (HASP) (See Attached HASP) to establish safety protocol while on site which will include but not be limited to personal air monitoring activities to be performed before and during any confined space entry into tanks and pits, and or occupation of any enclosed building that may indicate personnel hazards associated with various gases and low oxygen concerns. C. Upon daily arrival onsite, activate the above agreed to Health & Safety Plan and review with all personnel working at the site or areas defined in the plan, conducting safety meetings regarding activities to be conducted while onsite. D. Any and all drums, totes, buckets, pails, etc have and will continue to be collected from all buildings, structures and unoccupied grounds by trained personnel and proper equipment, stabilized at the point of collection, and transported to the established collection point (Bldg 3). E. Upon receipt at Bldg 3, all containers will be processed by Hazcat personnel who will perform onsite testing (See Exhibit 10-6 of the HASP attached) prior to final staging materials to characteristics of all containerized materials, segregating same by compatibility, and maintaining analytical data for disposal or processing purposes. F. Based on the hazcat results, containerized materials will be classified as a waste material or as a raw material suitable to be processed as a product. The items deemed to be a waste material will be further classed as hazardous requiring disposal at a permitted TSDF or nonhazardous requiring disposal at a permitted CERCLA facility suitable to receive the designated waste. G. Containerized materials will each be evaluated as to condition of the container to determine if the unit is suitable for storage in same or if it is to be shipped in the container, if it is suitable for shipping per DOT standards. If over-packing is indicated, this process will be handled in Bldg 3, using a constructed decon area to capture any residual materials. PPE utilized by personnel for this procedure will be dictated by the characteristics of the materials being handled as well as in compliance with the HASP. H. All waste materials will be staged collectively with their respective class of chemical until such time as sufficient quantities have been staged for a proper load. All containers in that grouping will then have a composite sample generated, where the sample will be submitted to a qualified lab for the generation of a full TCLP (Metals, Volatiles/Semi-volatiles, Pesticides / Herbicides).Based on the results a suitable disposal facility will be selected, approved and transported accordingly. EPA Region IV or designates will be provided a listing of all materials shipped off site for disposal, along with copies of manifest utilized. I. Containerized materials identified as raw materials for distribution by KMV will be staged in Bldg 3 for shipping purposes, flammables located in Bldg 10, nonhazardous materials in Bldg 4, etc. J. Containerized or bagged materials identified as commercial products suitable for shipping by KMV as a product are being segregated, repackaged if required to comply with DOT standards, labeled, and upon notification of acceptance by a receiver, a shipping container is provided, loaded and shipped offsite. All documents pertaining to the shipping of materials offsite are being maintained, including type of material, number and type of containers, and receiving company of each. All documents will be provided to EPA Region IV or designates. K. All empty buildings which have been identified as having powdered and or liquid chemicals on the floor which could present an environmental hazard if transferred to the exterior have been hazcated, brush-broom swept, pressure washed, and the rinsates disposed. Remaining buildings which have been identified as requiring these services, but currently are being used for container storage (Bldgs 3,4,10 & 18) will be cleaned as described above upon released. Until such time, portable containment booms have been established to prevent the loss of materials from within. Should entry or exit be required by mobile equipment or personnel, decon procedures will be implemented and rinsates contained. L. All aboveground storage units as well as any below grade pits and trenches as designated by the OSC, will be addressed by removing accumulated liquids and sludges and containerize same for identification and disposal. After each tank is emptied of solid materials, each unit will be pressure washed to render the unit “clean” which has been defined as “free of residual liquids and solids which will be considered satisfactory for recycling by others”. The manways of each tank will be left open to establish completion of service and each tank marked EMPTY on the tank side walls. M. Aboveground tanks such as the WWT units that are to remain onsite and are currently in use as well as any onsite unit in excess of 10,000-gallons which is to remain intact will receive structural integrity testing. KMV will provide previously performed structural integrity reports if available in lieu of new testing. N. All PPE and other debris generated during the course of this project will be collected, drummed and removed from the site. O. All materials generated during the above cleaning procedures will be properly profiled, transported and disposed at an EPA approved facility and in compliance with Federal and State EPA regulations. 4. Quality Assurance/ Quality Control Hazcat procedures will be fully documented and logged for later review by KMV and EPA Region IV or designates. Standard protocols are to be used to ensure validated results are obtained, leading to safe and reliable handling and disposal procedures are implemented. All samples submitted for analysis to an offsite laboratory will be collected via standard QA/QC protocol, containerized in glass containers and shipped or delivered using proper Chain-of-Custody formats. Copies of any and all results will be made available to EPA Region IV or designates. 5. Reporting: Upon conclusion of remaining removal activities, a written report will be provided to the EPA OSC which will detail operations performed, activities taken, and problems encountered (if any). The report will also include a good faith estimate of total costs or a statement of actual costs to complete this Scope of Work, a listing of quantities and types of materials removed off-Site or handled on-Site, a discussion of removal and disposal options considered for those materials, a presentation of the analytical results of all sampling and analysis performed, and accompanying appendices containing all relevant documentation generated during the removal action (e.g., manifests, invoices, bills, contracts and permits). 6. Schedule: On-Site Work is currently in effect and on schedule to be fully executed and in compliance as per the effective date of the Administrative Settlement Agreement and Order on Consent. Updates to the schedule will be provided at the conclusion of each week, providing volume counts of containers processed and transported offsite as waste and or products. Site Release and Prevention Plan Kings Mountains’ Venture 1602 North Main Street Lowell, North Carolina Purpose: To prevent and minimize a release or mitigation of chemicals onto the ground, or waters of the property. Scope: Design a plan of action with immediate and future tasks to achieve the purpose, specifically addressing the orange dye totes and dye and or other spills on building floors. Plan: Items A). No drums or totes containing liquid product and/or liquid waste should be stored out doors for the remainder of the project. All such containers shall be stored inside appropriate structures where the impact of a spill or leak can be minimized. In the case of such structures with floor trenches or drains, (Bldg. # 4,8, & 10) such drains shall be plugged of by an effective means to eliminate the possibility of leakage or spillage from entering the storm water system. B) The following buildings known to contain dye or other chemicals spills on their floors shall be de conned as soon as the building is free from material, or as soon as reasonable possible. The buildings agreed to undergo this procedure are: Building # 9 & 9A, 18, 3, 5, 4, and 8. The procedure for de con shall be as follows: • Remove debris from building floor. • Sweep and/or scrape floor where necessary. Retain floor sweepings in drum for disposal. Power wash floor, retain wash water, capture and determine appropriate disposal stream. C) Dealing with 70 cubic yard orange powder dye totes. • First asses each tote to determine if it contains a liquid, solid or is empty. • If empty move to pre determined storage are for empty totes. • If solid, move to temporary solids storage area outside building 32, for count and assessment of disposal. • If liquid, determine if dye or rainwater. This can be accomplished by a simple HAZCAT test developed by the EPA & KMV. 1.) Stir and check if liquid turns to a dye color. 2.) Check pH with strip to determine if neutral. 3.) Use 1 tablet Alka-Seltzer to determine if water. 4.) Observe for life forms such as tadpoles, lizards, etc. If the liquid passes all four above tests it can be assumed to be just rainwater and can be unloaded. If the liquid is assumed to be dye, follow the steps below. • Mark container as a known dye. • Set containment so dye does not spill to ground. • Pump or transfer tote into an appropriate container for disposal. • Remove tote to empty storage area once completed. D) Empty Drums, and liquid totes. All RCRA empty drums are to be moved to the storage containment area on the south west corner of the property that is fenced in. All empty vessels are to be stored here until such time as they are removed from the site for disposal. E) Above ground out door storage tanks. Base line UT testing will be completed on each above ground storage tank containing waste water. Calculations will be performed to insure structural integrity. These tanks will undergo a visual inspection on a weekly basis, until such time as the tanks are removed from service. The visual inspection shall be documented and forwarded to the appropriate personell. Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 13 5-001 4 Drums 550 2200 40 2160 445-03-4 2810 PGII 5 2-Amino-5-Chlorobenzotriflouride DOT:Toxic Liquids, Organic, N.O.S., (Aminochlorobenzenetrifluoride),//6.1//UN 2810, PGII Liquid HT Placard; Miscellaneous 9/ Combustible liquid Waste 5-002 4 drums 500 2000 43051-43-0 2924 5 Emery 5761 3(N,N-Bisacetoxyethyl) Aminobenzanilide DOT: Flammable Liquids, Corrosive,N.O.S.,(Contains Acetic Acid/Acetic Ahhydride), 3,UN2924 PG III (8) Liquid HT Placards;Flammable 3, Corrosive 8 Waste to PSC 3/16/10 14 5-003 4 drums 2224 44 2180 94-89-3 3276 5 N-(2-Cyanoethyl 1)-O-Chloroaniline DOT: Nitriles,Toxic,N.O.S., 6.1, PG III Liquid HT Placard; Toxic 6 14 5-004 4 drums 2013 48 1965 94-89-3 3276 5 N-(2-Cyanoethyl 1)-O-Chloroaniline DOT: Nitriles,Toxic,N.O.S., 6.1, PG III Liquid HT Placard; Toxic 6 14 5-005 4 drums 22022 55 1967 94-89-3 3276 5 N-(2-Cyanoethyl 1)-O-Chloroaniline DOT: Nitriles,Toxic,N.O.S., 6.1, PG III Liquid HT Placard; Toxic 6 14 5-006 4 drums 2013 35 1978 94-89-3 3276 5 N-(2-Cyanoethyl 1)-O-Chloroaniline DOT: Nitriles,Toxic,N.O.S., 6.1, PG III Liquid HT Placard; Toxic 6 14 5-007 4 drums 2019 37 1928 94-89-3 3276 5 N-(2-Cyanoethyl 1)-O-Chloroaniline DOT: Nitriles,Toxic,N.O.S., 6.1, PG III Liquid HT Placard; Toxic 6 14 5-008 4 drums 1786 64 1722 94-89-3 3276 5 N-(2-Cyanoethyl 1)-O-Chloroaniline DOT: Nitriles,Toxic,N.O.S., 6.1, PG III Liquid HT Placard; Toxic 6 14 5-009 4 drums 2004 48 1956 94-89-3 3276 5 1 Drum=N-(2-Cyanoethyl 1)-O-Chloroaniline DOT: Nitriles,Toxic,N.O.S., 6.1, PG III Liquid HT Placard; Toxic 6 14 95-53-4 1708 3 Drums= O-Toluidine, Pure Beneanine-2-Metyl DOT:RQ,Toluidines,Liquid,(O- Toluidide),//6.1//,UN1708, PG II Placard; Toxic 6 14 5-010 4 drums 2026 46 1980 94-89-3 3276 5 N-(2-Cyanoethyl 1)-O-Chloroaniline DOT: Nitriles,Toxic,N.O.S., 6.1, PG III Liquid HT Placard; Toxic 6 14 5-011 4 drums 1933 54 1879 94-89-3 3276 5 N-(2-Cyanoethyl 1)-O-Chloroaniline DOT: Nitriles,Toxic,N.O.S., 6.1, PG III Liquid HT Placard; Toxic 6 Waste 5-012 3 Drums 1440 40 1400 43051-43-0 2924 5 Emery 5761 3(N,N-Bisacetoxyethyl) Aminobenzanilide DOT: Flammable Liquids, Corrosive,N.O.S.,(Contains Acetic Acid/Acetic Ahhydride), 3,UN2924 PG III (8) Liquid HT Old # 105 Placards;Flammable 3, Corrosive 8 Waste 5-013 3 Drums 1440 40 1400 43051-43-0 2924 PGIII 5 1 drum Emery 5761 3(N,N-Bisacetoxyethyl) Aminobenzanilide DOT: Flammable Liquids, Corrosive,N.O.S.,(Contains Acetic Acid/Acetic Ahhydride), 3,UN2924 PG III (8) 2 drums Emery 5723 N-Cyanoethyl-N-Ethylaniline DOT:Not Regulated Liquid HT Placards; Flammable 3 Waste to PSC 3/16/10 Waste 5-014 4 Drums 1920 40 1880 43051-43-0 2924 5 Emery 5761 3(N,N-Bisacetoxyethyl) Aminobenzanilide DOT: Flammable Liquids, Corrosive,N.O.S.,(Contains Acetic Acid/Acetic Ahhydride), 3,UN2924 PG III (8) Liquid HT Placards;Flammable 3, Corrosive 8 Waste to PSC 3/16/10 Waste 5-015 3 Drums 1440 40 1400 19249-34-4 21615-36-1 2924 1993 5 1 Drum Emery 5704 N.N-Bisacetoxyethylaniline DOT: Flammable Liquids,Corrosive,N.O.S.,(Acetic Acid) UN2924 2 drums Emery 5713 DOT: Flammable Liquid, N.O.S. (Acetic Acid, Acetic Anhydride) Bisacetoxyethyl-M- Toludine Liquid HT Emery 5704 Placards: Flammable 3, Corrosive 8 Waste to PSC 3/16/10 14 5-016 4 drums 200 1947 58 1889 1300-78-8 1711 5 Xylidines, Mixed DOT:Xylidines, (Xylidines-Mixed),//6.1//, UN1711, PG II Liquid HT Placard: Toxic 6 Waste 5-017 3 Drums 480 1440 40 1400 21615-36-1 1993 5 Emery 5713 DOT: Flammable Liquid, N.O.S. (Acetic Acid, Acetic Anhydride) Bisacetoxyethyl-M- Toludine Liquid HT Placards: Flammable 3, Corrosive 8 Waste to PSC 3/16/10 13 5-018 4 drums 200 1947 1300-78-8 1711 5 Xylidines, Mixed DOT:Xylidines, (Xylidines-Mixed),//6.1//, UN1711, PG II Liquid HT Placard: Toxic 6 5-019 4 Drums 425 1723 96-53-4 UN 1708 5 O-Toluidine MW 107 DOT: RQ, Toluidine,Liquid,N.A.Liquid HT Old Pallet #90 Waste 5-021 3 Drums 440 1421 148-69-6 NA 5 Emery 5728 N-Cyanoethyl-N-Ethyl-Toluidine DOT: Not Regulated Liquid HT Old # 549 Waste to PSC 3/16/10 Waste 5-022 3 Drums 440 1400 529-65-7 NA 5 2 Drums Emery 5723 N-Cyanoethyl-N-Ethylaniline DOT: 1 Drum Emery 5728 N-Cyanoethyl-N-Ethyl-M-Toluidine DOT: Liquid HT Waste to PSC 3/16/10 5-023 4 Drums 440 1446 Proprietary NA 5 Pat Soft 1443 Base C00532L100 DOT: Not Regulated Liquid HT Old # 557 5-024 4 Drums 488 Proprietary NA 5 PAPP Base Crude Brilliant Yellow Powder Dye DOT: Not Regulated Powder HT 5-025 4 Drums 785 614-80-2 Proprietary NA 5 2 drums; 2-Acetylaminophenol 1 drum; Broenners Acid 1 drum; Intrasil Scarlet DOT: This Pallet not regulated Powder HT 5-026 4 Drums 275 1238 7757-82-6 NA 5 Intracon Black LW HI Concentration Powder dye DOT: Not Regulated Powder HT 5-027 4 Drums 694 Proprietary NA 5 MAAPBS Base (Crude Yellow) DOT: Not Regulated Powder HT Old #465 20 5-028 27 Boxes 33 lbs Each 1121 None NA 5 Chrysazin DOT: Not Regulated Powder HT 5-029 5 Cans 51 Kilo 701 88-45-9 NA 5 PPDOSA Para Phenylene Diamine 2 Sulfonic Acid DOT: Not Regulated Powder HT 5-030 5 Cans 54 net 868 40 828 85-44-9 2214 PG III 5 Phthalic Anhydride DOT: Phthalic Anhydride, N.A.,8, UN2214, PG III Powder HT Old # 572 5-031 10 Bags in Box 55 712 40 672 2582-30-1 NA 5 Aminoguanidin-bicarbonate 99% DOT: Not Regulated Powder HT Caution: Irritant 5-032 Tote 955 284 671 Proprietary NA 5 Masaja Base MFG Presscake DOT: Not Regulated Powder Plastic Sample 4-611 "Band before shipping" 5-033 Tote 976 284 692 Proprietary NA 5 Intrasil Red presscake DOT: Not Regulated Powder Plastic Sample 3-719 "Band before shipping" 5-034 Tote 618 284 334 Proprietary NA 5 Intrasil Red presscake DOT: Not Regulated Powder Plastic Sample 3-718 "Band before shipping" 5-035 Tote 631 284 347 Proprietary NA 5 Intrasil Red presscake DOT: Not Regulated Powder Plastic Sample 3-717 "Band before shipping" Total Gross 69591 KMV Inventory BLDG # 3 1 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 16 16 3-001 20 Bags 25 kg 1102 36 1166 135-11-5 3 NDCA - ANDS Base (2 Nadpasa) DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 17 17 3-002 15 Bags 50 lbs 797 47 750 7758-29-4 3 Sodium Tripolyposphate DOT: Not Regulated Powder HT Shipped to Jaychem 02/18/10 3-003 8 Bags 50 lbs / 495 # 495 01309-48-4 3 Magnesium Oxide DOT: Not Regulated Powder HT Technical DID NOT TAKE ON PREVIOUS LOAD 15 15 3-004 22 Bags 55 lbs 1210 39 1171 833-66-9 3 Schaffers Salt Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 19 3-005 9 Bags 25 kg 99-30-9 UN1661 PGII 3 2.6 Dichloro-4-Nitroaniline DOT: Nitroanilines,Solid,//6.1//UN166 1,PGII Powder HT Placard: Toxic 6 Shipped Shipped 3-006 17 Bags 50 lbs 904 68855-54-9 3 Diatomite Celaton Diatomacius Earth Powder HT Shipped to Shamrock 10/29/09 BOL # 102909 12 12 3-007 5 Bags 25 kg 55994-13-3 3 Mat Base DOT: Not Regulated Powder HT Shipped to Jaychem 10/30/09 17 17 3-008 20 Bags 25 kg 1157 47 1110 19433-93-3 3 3-Diethylamino-4- Methoxyacetanilide Not DOT Regulated Powder HT (P-110 Old #) Shipped to Jaychem 02/18/10 17 17 3-009 5 Bags 25 kg 316 46 270 119-63-1 3 4-Amino-N-Methyl Acetanilide Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 15 15 3-010 12 Cans 50 kg 1559 42 1517 101-11-1 3 EBASA N-Ethyl-N-Benzyl Aniline Sulfonic Acid DOT: Not Regulated Powder HT Old pallet #A-5 Shipped to Jaychem 12/08/09 16 16 3-011 12 Cans 50 kg 1570 32 1538 101-11-1 3 EBASA N-Ethyl-N-Benzyl Aniline Sulfonic Acid DOT: Not Regulated Powder HT Old Pallet # A-4 Shipped to Jaychem 12/08/09 KMV Inventory BLDG # 3 2 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 16 16 3-012 6 Cans 50 kg 556 38 518 101-11-1 3 EBASA N-Ethyl-N-Benzyl Aniline Sulfonic Acid DOT: Not Regulated Powder HT Old Pallet # A-3 Shipped to Jaychem 12/08/09 17 17 3-013 5 Cans 50 kg 595 45 550 785-30-8 3 (DABA) 4,4 Diaminobenzanilide DOT: Not Regulated Powder HT Shipped to Jaychem 02/18/10 17 17 3-014 5 Cans 50 kg 599 49 550 785-30-8 3 (DABA) 4,4 Diaminobenzanilide DOT: Not Regulated Powder HT Shipped to Jaychem 02/18/10 19 3-015 17 Bags 50 lbs 7758-99-8 UN 3077 RQ 3 Copper Sulfate DOT: Environmentally Hazardous Substance,Solid, N.O.S.,(Cupric Sulfate)//9//UN3077,PGIII, RQ Powder HT Placard: Marine Pollutant,Erg #171 3-016 28 Bags 50 lbs 01309-48-4 3 Magnesium Oxide Non-Hazardous Powder Not HT Technical Jaychem did not take on earlier loads 19 3-017 5.5 Bags 20 kg UN 3077 3 P-Phenylphenol DOT :Environmentally Hazardous Substance, Solid, N.O.S.//9/UN3077, PG III Powder HT 19 3-018 17 Bags 25 kg 80-46-6 UN 2430 3 (Para-Tertamylphenol) Amylphenol (Para-Tertiary) DOT: Alkyphenols, Solid, N.O.S.//8//UN 2430//PG III Powder HT Corrosive 8 Marine Pollutant 19 3-019 12 25 kilo 100-10-6 UN1661 PGII 3 Para Nitro Aniline DOT Shipping Name: Nitroanilines, Class 6.1, UN1661,PG. II Powder HT KMV Inventory BLDG # 3 3 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 15 15 3-020 8 Bags 50 lbs 400 36 364 N/A 3 Darco-Carbon Black Activated S-51 DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 3-021 49 Bags 22.68 kg 487-18-8 3 Dense Soda Ash DOT: Not Regulated Powder HT "Hold til Last" 16 16 3-022 10 Bags 25 kg 620 40 580 135-11-5 3 NDCA Base (2- Nadpasa) DOT:Not Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-023 13 Bags 25 kg 787 42 745 135-11-5 3 NDCA Base (2- Nadpasa) DOT:Not Regulated Powder HT Shipped to Jaychem 12/08/09 3-024 4 Drums 3 @ 200, 1 @ 204 148-87-8, 108-39-4 3 3 Drums Emery @ 200 kg DOT: Liquid HT "Break this Pallet" Waste 3-024 1 Drum M-Cresol @ 204 kg DOT: Waste to PSC 03/16/10 Shipped Shipped 3-025 15 Bags 25 lbs 469 N/A 3 Habor Lite Expanded Peallite (P.E.) DOT: Not Regulated Powder HT For Shamrock shipped 10/29/09 BOL # 102909 19 3-026 4 Drums Total 607 lbs 607 N/A UN 3261 3 P-Toluene Sulfonyl Chloride DOT: Corrosive solid, acidic, organic, n.o.s. (p- Toluenesulfonyl chloride)//8//UN 3261//PG III Powder HT Corrosive (6), Overpack 19 3-027 4 Drums Total 627 lbs 627 N/A UN 3261 3 P-Toluene Sulfonyl Chloride DOT: Corrosive solid, acidic, organic, n.o.s. (p- Toluenesulfonyl chloride)//8//UN 3261//PG III Powder HT Corrosive (6), Overpack 19 3-028 4 Drums Total 607 lbs 607 N/A UN 3261 3 P-Toluene Sulfonyl Chloride DOT: Corrosive solid, acidic, organic, n.o.s. (p- Toluenesulfonyl chloride)//8//UN 3261//PG III Powder HT Corrosive (6), Overpack KMV Inventory BLDG # 3 4 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 19 3-029 4 Drums Total 609 lbs 609 N/A UN 3261 3 P-Toluene Sulfonyl Chloride DOT: Corrosive solid, acidic, organic, n.o.s. (p- Toluenesulfonyl chloride)//8//UN 3261//PG III Powder HT Corrosive (6), Overpack 19 3-030 4 Drums Total 546 lbs 546 N/A UN 3261 3 P-Toluene Sulfonyl Chloride DOT: Corrosive solid, acidic, organic, n.o.s. (p- Toluenesulfonyl chloride)//8//UN 3261//PG III Powder HT Corrosive (6), Overpack 19 3-031 4 Drums Total 529 lbs 529 N/A UN 3261 3 P-Toluene Sulfonyl Chloride DOT: Corrosive solid, acidic, organic, n.o.s. (p- Toluenesulfonyl chloride)//8//UN 3261//PG III Solid HT Corrosive (6), Overpack 19 3-032 4 Drums Total 616 lbs 616 N/A UN 3261 3 P-Toluene Sulfonyl Chloride DOT: Corrosive solid, acidic, organic, n.o.s. (p- Toluenesulfonyl chloride)//8//UN 3261//PG III Solid HT Corrosive (6), Overpack 3-033 15 Bags 50 lbs N/A 3 Domino Pure Cane Sugar Non-Hazardous Solid HT Will not Import to India 17 17 3-034 4 Bags 55 Net p/bag 260 40 220 116-32-5 3 1-Amino-2-Bromo-4- Hydroxyanthraquinine Non-Hazardous Powder HT Small Pallet Shipped to Jaychem 02/18/10 12 12 3-035 4 Bags 55 Net p/bag 119-79-9, 119-28-8 3 Cleves Acid Mixed MW-22 Not DOT Regulated Powder HT Shipped to Jaychem 10/30/09 3-036 4 Drums Total 926 lbs 926 39 887 Proprietary 3 Orange Powder Dye DOT: Not Regulated Powder HT Sample # #(10-043) (10-041) (10-042) (10-044) KMV Inventory BLDG # 3 5 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 19 3-037 2 Drums Total 757 lbs 757 64-19-7 UN 3147 3 1,2,4 BN Chrome Base DOT Shipping Name: Dye Intermediate, Solid, Corrosive, N.O.S. (Acetic Acid)//8//, UN3147,PG III Powder HT Placard: Corrosive 16 16 3-038 4 Drums Total 981 lbs 981 37 944 91-91-8 3 (3-706) (3-707) (3-708) (3-705) Azo Fast Blue MCC-Salt DOT: Not Regulated 55% Powder HT Shipped to Jaychem 12/08/09 3-039 4 Drums Total 726 lbs 726 39 687 Proprietary 3 2 Drums Orange Powder Dye DOT: Not Regulated Powder /Liquid HT 3-039 2 Drums Red Liquid Dye DOT: Not Regulated 3-040 4 Drums Total 1041 lbs 1041 42 999 Proprietary 3 (10-058 P.D.) (10-057) Powder Dye (10- 056 P.D.) (10-055) P.D. DOT: Not Regulated Powder HT 3-041 4 Drums Total 740 lbs 740 44 696 Proprietary 3 3-042 Yellow Presscake DOT: Not Regulated Powder HT 3-041 7-703 Yellow Presscake DOT: Not Regulated 3-041 3-702 Intrasil Blue Presscake DOT: Not Regulated 3-041 3-704 Intrasil Blue Presscake DOT: Not Regulated 3-042 3 Drums Total 772 lbs 772 39 733 Proprietary 3 3-040 Intrasil Purple DOT: Not Regulated Powder HT 3-042 3-041 Intrasil Yellow DOT: Not Regulated 3-042 3-043 Intrasil Yellow DOT: Not Regulated 12 12 3-043 6 Drums Net 220 each 100-10-7 3 4-(Dimethylamino) Benzaldehyde Not DOT Regulated Solid HT Shipped to Jaychem 10/30/09 KMV Inventory BLDG # 3 6 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 12 12 3-044 4 Drums Net 440 each 148-69-6 3 Emery 5728 N- Cyanoethyl-N-Ethyl-M-Toluidine Not DOT Regulated Liquid HT Shipped to Jaychem 10/30/09 12 12 3-045 4 Drums Net 440 each 148-87-8 3 Emery 5723 N- Cyanoethyl-N-Ethylaniline Not DOT Regulated Liquid HT Shipped to Jaychem 10/30/09 12 12 3-046 22 Boxes Net 50 each 137-20-2 3 Geropon T-77 Sodium Methyl Oleoyl Taurate DOT: Not Regulated Powder HT Shipped to Jaychem 10/30/09 17 17 3-047 9 Bags 50 lbs 490 40 450 77-92-9 3 Citric Acid (Anhydrous) Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 19 3-048 6 Bags 25 kg / 358 # 358 37 321 99-30-9 UN1661 PGII 3 2.6 Dichloro-4-Nitroaniline DOT: Nitroanilines,Solid,//6.1//UN166 1,PGII Powder HT Placard: Toxic 16 16 3-049 10 Bags 25 kg / 614 # 614 46 568 135-11-15 3 ANDS Base (2-Nadpasa) DOT: Not Regulated Powder HT P-484 Shipped to Jaychem 12/08/09 15 15 3-050 15 Bags 25 kg / 923 # 923 35 988 Proprietary 3 DAVS Base Methoxy-Meta Base Sulfate (MMBS) Not DOT Regulated HT Shipped to Jaychem 12/08/09 15 15 3-051 14 Bags 25 kg / 810 # 810 37 773 Proprietary 3 DAVS Base Methoxy-Meta Base Sulfate (MMBS) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 19 3-052 24 Bags 25 kg / 1322 # 1322 7647-01-0 UN 3147 3 1 (2.5 Dichloro-4-Sulfophenyl) 3-Methyl-5-Pyrazolone DOT Shipping Name: Dye Intermediate, Solid, Corrosive, N.O.S.,//8//,UN3147.PGIII Powder HT Placard: Corrosive 15 15 3-053 20 Bags 25 kg / 1148 # 1148 37 1111 Proprietary 3 DAVS Methoxy Meta Base Sulfate (MMBS) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 KMV Inventory BLDG # 3 7 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 17 17 3-054 6 Bags 25 kilo / 371 # 371 38 333 N/A 3 1-Amino-2-Bromo-4- Hydroxyanthraquinine Non-Hazardous (Dye Intermediate) DOT: Not Regulated Powder HT Shipped to Jaychem 02/18/10 17 17 3-055 6 Bags 25 kilo / 371 # 371 49 222 N/A 3 1-Amino-2-Bromo-4- Hydroxyanthraquinine Non-Hazardous (Dye Intermediate) DOT: Not Regulated Powder HT Shipped to Jaychem 02/18/10 3-056 21 Bags Net 50 each / 1186 # 1186 39 1147 N/A 3 Nusience Dust Non-Hazardous DOT: Not Regulated Powder HT Sample for disposal 12 12 3-057 6 Bags 328 lbs 328 119-40-4 3 6-Aniline-1-Napthol-3-Sulfonic Acid DOT Shipping Name: Phenyl Jay Acid Powder HT Shipped to Jaychem 10/30/09 16 16 3-058 Bags 405 lbs 405 38 367 88-45-9 3 PPDOSA Para Phenylene Diamine-2- Sulfonic Acid Intermediate Powder DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-059 Bags 514 lbs 514 39 475 88-45-9 3 PPDOSA Para Phenylene Diamine-2- Sulfonic Acid Intermediate Powder DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 17 17 3-060 3 Bags Net 55 lbs / 278 lbs 278 42 236 119-4-0 3 Amino Delta Acid Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 KMV Inventory BLDG # 3 8 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 17 17 3-061 5 Bags 25 kg / 157 lbs 157 48 109 119-70-0 3 4, 4 Diamino Diphenyl Amine-2- Sulphonic Acid (F.G. Acid) Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 19 3-062 1 Drum, 2 Bags Net 50 / 259 lbs 259 7632-00-0 UN 1500 3 1 Drum Sodium Nitrate DOT Shipping Name: RQ, Sodium Nitrate N.A.//5.1//UN1500, PGIII Powder HT Placard: Oxidizer 5.1 19 3-062 UN1500 2 Bags Sodium Nitrate DOT DOT Shipping Name: RQ, Sodium Nitrate N.A.//5.1//UN1500, PGIII Powder HT Placard: Oxidizer 5.1 19 3-063 12 Bags Net 55 / 704 lbs 704 3052-89-4 UN 2213 3 Granuform Methanova DOT Shipping Name: Para Formaldehyde, N.A., //4.1//,UN2213, PGIII Powder HT Placard: Flammable Solid 4 15 15 3-064 60 Bags Net 25 lbs / 1522 lbs 1522 38 1484 1333-86-4 3 Raven 1020 Powder (Carbon Black) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-065 20 Bags Net 25 lbs / 570 lbs 570 39 531 1333-86-4 3 Raven 1020 Powder (Carbon Black) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 17 17 3-066 12 Bags 25 kg / 686 lbs 686 46 640 122-39-4 3 Dipenylamine Chips - 02579 DOT: Not Regulated in United States. Powder HT Placard :Toxic Not DOT Controlled in United States SEE MSDS Shipped to Jaychem 02/18/10 17 17 3-067 20 Bags 25 kg / 1195 lbs 1195 40 1155 122-39-4 3 Dipenylamine Chips - 02579 DOT: Not Regulated in United States. Powder HT Placard :Toxic Not DOT Controlled in United States SEE MSDS Shipped to Jaychem 02/18/10 17 17 3-068 20 Bags 25 kg / 1141 lbs 1141 41 1100 122-39-4 3 Dipenylamine Chips - 02579 DOT: Not Regulated in United States. Powder HT Placard :Toxic Not DOT Controlled in United States SEE MSDS Shipped to Jaychem 02/18/10 KMV Inventory BLDG # 3 9 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 19 3-069 27 Bags Net 55 lbs / 1534 lbs 1534 1806-26-4 UN 2430 3 Octyphenol, Flake DOT Shipping Name: Alkyl Phenol, Solid, N.O.S. (Octy Phenol),//8//,UN2430, PGII Powder HT Placard: Corrosive 8-Marine Pollutant 15 15 3-070 20 Bags Net 25 kg / 1166 lbs 1166 38 1128 N/A 3 NDC-A203 4- Amino A20 Benzene-4-Sulfonic Acid Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-071 25 Bags Net 55 lbs / 1662 lbs 1662 41 1621 Proprietary 3 (MMBS) Methoxy Meta Base Sulfate Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-072 16 Bags Net 24 kg / 940 lbs 940 36 904 Proprietary 3 D.A.V.S. Methoxy-Meta Base Sulfate (MMBS) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-073 19 Bags Net 24 kg / 1101 lbs 1101 36 1065 Proprietary 3 D.A.V.S. Methoxy-Meta Base Sulfate (MMBS) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-074 11 Bags Net 55 / 728 lbs 728 35 693 92-70-6 3 3 Hydroxy-2-Napthoic Acid 188 Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-075 9 Bags 25.2 kg / 552 lbs 552 37 515 536-41-0 3 4, 4 Diamino A20 Benzene Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 19 3-076 2 Bags 50.5 lbs / 1369 lbs 1369 5329-14-6 UN 2967 3 Sulfamic Acid DOT:Sulfamic Acid,//8//,UN2967, PG III Powder HT Placard: Corrosive 8 17 17 3-077 9 Bags Net 55 lbs / 526 lbs 526 40 486 102-56-7 3 2, 5 Dimethyloxy Aniline Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 17 17 3-078 7 Bags 25 kg / 412 lbs 412 43 369 130-13-2 3 Sodium Napthionate Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 17 17 3-079 8 Bags 25 kg / 468 lbs 468 46 422 50976-35-7 3 Amino J Acid Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 17 17 3-080 8 Bags 55 lbs / 436 lbs 436 45 391 92-15-9 3 Acetoacet-O-Anisidine Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 KMV Inventory BLDG # 3 10 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 19 3-081 6 Bags 50 lbs / 371 lbs 371 N/A UN 2430 3 Octyphenol, Flake DOT Shipping Name: Alkyl Phenol, Solid, N.O.S. (Octy Phenol),//8//,UN2430, PGII Powder HT Placard: Corrosive 8-Marine Pollutant 15 15 3-082 9 Bags 55 lbs 495 34 461 19433-93-3 3 3-Diethylamino-4- Methoxyacetanilide Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 17 17 3-083 7 Bags 25 kg / 490 lbs 490 38 452 N/A 3 H-Acid 85% Minimum DOT: Not Regulated Powder HT Shipped to Jaychem 02/18/10 15 15 3-084 25 kg / 324 lbs 324 32 292 87-02-5 3 Aminoazobenzene-4-Sulfonic Acid (MW277) Common Name: J Acid DOT Shipping Name: Chemicals N.O.S. Powder HT Shipped to Jaychem 12/08/09 17 17 3-085 1 Bag 1008 lbs 1008 40 968 Proprietary 3 Azo Red Pigment DOT: Not Regulated Powder HT Galaxy Chemical Corp. Shipped to Jaychem 02/18/10 15 15 3-086 28 Bags 25 kg / 1561 lbs 1561 42 1519 41295-98-1 3 2,5 Dichloroaniline-4-Sulfonic Acid, Sodium Salt Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-087 24 Bags 25 kg 1353 43 1310 41295-98-1 3 2,5 Dichloroaniline-4-Sulfonic Acid, Sodium Salt Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-088 24 Bags 25 kg / 1158 lbs 1158 42 1116 116-82-5 3 1-Amino-2-Bromo-4-Hydroxy Anthraquinone Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 19 3-089 18 Bags 30 lbs / 642 lbs 642 39 603 Proprietary, See MSDS 3077 3 Udet 950 DOT: Environmentally Hazardous Substance,solid,n.o.s.,Marine Pollutant(Alkylbenzene sulphonates,branched and straight chained),//9//,UN3077, PG III Powder HT Cleaning Powder, Manufactured by Whitco-Petro Placard; Marine Pollutant KMV Inventory BLDG # 3 11 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 19 3-090 16 Bags 30 lbs / 572 lbs 572 37 535 Proprietary, See MSDS 3077 3 Udet 950 DOT: Environmentally Hazardous Substance,solid,n.o.s.,Marine Pollutant(Alkylbenzene sulphonates,branched and straight chained),//9//,UN3077, PG III Powder HT Cleaning Powder, Manufactured by Whitco-Petro Placard; Marine Pollutant 19 3-091 6 Bags 30 lbs / 227 lbs 227 36 191 Proprietary, See MSDS 3077 3 Udet 950 DOT: Environmentally Hazardous Substance,solid,n.o.s.,Marine Pollutant(Alkylbenzene sulphonates,branched and straight chained),//9//,UN3077, PG III Powder HT Cleaning Powder, Manufactured by Whitco-Petro Placard; Marine Pollutant 17 17 3-092 57 Bags 50 lbs 2904 37 2867 N/A 3 Sodium Sulfate (Anhydrous) DOT: Not Regulated Powder HT Shipped to Jaychem 02/18/10 15 15 3-093 10 Bags 55 lbs 648 26 622 135-19-3 3 3(Diethylamino) Acetanilide (Biddle Sawyer) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-094 15 Bags Net 55 lbs 884 36 848 135-19-3 3 3(Diethylamino) Acetanilide (Biddle Sawyer) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 17 17 3-095 7 Bags No weight on bags 455 45 848 8061-15-6 3 Ligno Sulfonic Acid, Sodium Salt Dyquex Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 19 3-096 20 Bags 1134 38 1095 99-30-9 UN 1590 3 2.3 Dichloro-4-Niroaniline DOT Shipping Name: Dichloroanilines, Solid, 6.1, UN1590, PG II Powder HT Placard: Toxic 6, Marine Pollutant KMV Inventory BLDG # 3 12 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 15 15 3-097 15 Bags 55 lbs 880 39 841 135-19-3 3 3(Diethylamino) Acetanilide Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-098 26 Bags 1461 35 1426 41295-98-1 3 2,5 Dichloroaniline-4-Sulfonic Acid, Sodium Salt Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-099 15 Bags 55 lbs 873 37 836 135-19-3 3 3(Diethylamino) Acetanilide Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-100 15 Bags 55 lbs 885 41 844 135-19-3 3 3(Diethylamino) Acetanilide Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-101 15 Bags 55 lbs 894 33 861 135-19-3 3 3(Diethylamino) Acetanilide Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-102 15 Bags 55 lbs 885 41 844 135-19-3 3 3(Diethylamino) Acetanilide (Biddle Sawyer) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 19 3-103 10 Bags 55 lbs 620 42 578 7647-01-0 UN 3147 3 ANDS Base DOT Shipping Name: Dye Intermediate, Solid, Corrosive, N.O.S., (Hydrochloric Acid),//8//, UN 3147, PGIII Powder HT 15 15 3-104 27 Bags 125 kg 1513 40 1473 41295-98-1 3 2,5 Dichloroaniline-4-Sulfonic Acid, Sodium Salt Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-105 15 Bags Net 55 867 45 822 102-56-7 3 2,5 Dimethyl Oxyaniline Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 19 3-106 28 Bags 55 lbs 1550 41 1509 7647-01-0 UN3147 PG III 3 2,5 Dichloro-4-Sulfophenyl-Methyl- Pyrazolone DOT Shipping Name: Dye Intermediate, Solid, Corrosive, N.O.S., (Hydrochloric Acid)//8//UN 3147, PG III Powder HT KMV Inventory BLDG # 3 13 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 15 15 3-107 14 Bags 50 lbs 748 42 706 7783-20-2 3 Amonium Sulfate Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-108 15 Bags 891 41 850 N/A 3 3 (Diethyl Amino) Acetanilide Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-109 22 Bags 25 kg 1245 41 1204 41295-98-1 3 2,5 Dichloroaniline-4-Sulfonic Acid Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-110 22 Bags 25 kg 1233 35 1198 41295-98-1 3 2,5 Dichloroaniline-4-Sulfonic Acid Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 19 3-111 30 Bags 30 lbs 900 61 839 Proprietary, See MSDS 3077 3 Udet 950 DOT: Environmentally Hazardous Substance,solid,n.o.s.,Marine Pollutant(Alkylbenzene sulphonates,branched and straight chained),//9//,UN3077, PG III Powder HT Cleaning Powder, Manufactured by Whitco-Petro Placard; Marine Pollutant 19 3-112 20 Bags 55 lbs 1176 44 1132 97-39-2 UN 2811 3 1,3 Di-O-Tolylguanidine (DOTG) DOT Shipping Name: Poisonous Solid, N.O.S.,//6.1// UN 2811, (Di-O- Tolylguanidine),PGIII Powder HT Placard - Poison 19 3-113 10 Bags 55 lbs 623 47 576 7647-01-0 UN 3147 3 ANDS Base DOT Shipping Name: Dye Intermediate, Solid, Corrosive, N.O.S., (Hydrochloric Acid),//8//, UN 3147, PGIII Powder HT 20 3-114 14 Bags Net 55 841 49 792 135-9-13 3 3 (Diethyl Amino) Acetanilide Not DOT Regulated Powder HT Biddle Sawyer KMV Inventory BLDG # 3 14 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 17 17 3-115 8 Bags 25 kg 504 42 461 135-11-5 3 NDCA Base (2- Nadpasa) Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 17 17 3-116 14 Bags 25 kg 828 41 787 6375-16-8 3 3-N,N Diethyl Amino Acetanilide 99% Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 15 15 3-117 18 Bags 25 kg 1054 46 1008 19438-93-3 3 Diethylamino-4-Methoxy Acetanilide Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-118 23 Bags 25 kg 1396 37 1359 41295-98-1 3 2,5 Dichloroaniline-4-Sulfonic Acid Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-119 12 Bags 25 lbs 723 53 670 N/A 3 1-Amino-2-Bromo-4-Hydroxy Anthraquinone Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-120 12 Bags 25 lbs 657 44 613 N/A 3 1-Amino-2-Bromo-4-Hydroxy Anthraquinone Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 15 15 3-121 15 Bags 25 kg 859 41 818 N/A 3 AABNSA (61.6%) Amino 1-1 Azobenzene-4- Sulfonic Acid Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 17 17 3-122 4 Cans 55 lbs 423 40 583 137-43-3 3 Dimethyl ONCB Sulfonamide/MG Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 16 16 3-123 10 Cans 55 lbs 1126 41 1085 137-43-3 3 Dimethyl ONCB Sulfonamide/MG Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-124 10 Cans 55 lbs 1135 40 1095 137-43-3 3 Dimethyl ONCB Sulfonamide/MG Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 KMV Inventory BLDG # 3 15 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 16 16 3-125 4 55 gal. Lever Packs 1017 40 977 N/A 3 Kemalan Gray KGL 200% Drums Each / 246 G, Net 220 Not DOT Regulated Liquid HT Shipped to Jaychem 12/08/09 19 3-127 4 Drums Closed Top 2012 40 1972 N/A UN 1760 3 Acetyl MAAH DOT Shipping Name: Corrosive Liquid, N.O.S., (Acetic Acid) Corrosive Material,//8//, UN 1760, PG III Liquid HT 19 3-127 N/A 3-(Bisacetoxyet-Amino) 4- Methyoxyacetian Drums Each 490/40/450 3-128 4 55 gal. Lever Packs 768 40 728 N/A 3 Kemalan Gray KGL 200% Drums Each / 246 G, Net 220 Not DOT Regulated Liquid HT 16 16 3-129 4 55 gal. Lever Packs 1023 40 983 N/A 3 Kemalan Gray KGL 200% Drums Each / 246 G, Net 220 Not DOT Regulated Liquid HT Shipped to Jaychem 12/08/09 19 3-130 6 Cans Net 100 kg 1345 45 1300 7758-89-6 UN 2802 3 Cuppros Chloride Powder DOT:Copper Chloride,//8//,UN2802, PG III Powder HT Placard: Toxic, Marine Pollutant 19 3-131 3 Drums 1428 40 1388 96-24-2 UN 2689 3 3-Chloro-1, 2-Propanediol DOT Shipping Name: Gycerol Alpha Monochlorohydran,//3//, UN 2689, PG II Powder HT 17 3-132 4 Drums Closed Top 1083 40 1043 N/A 3 2 Drums 4-(Diethylamino) Benzaldehyde Not DOT Regulated Liquid HT 244#/40#/284# KMV Inventory BLDG # 3 16 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 19 3-132 118-12-7 UN 1993 2 Drums Fischers Base DOT Shipping Name: Combustible Liquid, N.O.S., (Trimethyl Methylenindoline),//3//, UN 1993, PG III Liquid HT 14 3-133 4 Drums 1891 45 1846 91-66-7 UN 2342 3 N,N-Diethylaniline DOT:N,N- Diethylaniline,N.O.S.,//6.1// UN3432,PG III Liquid HT Placard: Toxic 6 17 17 3-134 5 Fiber Cans Net 25 kg 355 35 320 140-49-8 3 4 Chloroacetyl Acetanilide AA Pheacylchloride Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 16 16 3-135 4 Drums 1991 36 1955 148-69-6 3 Emery 5728 N- Cyanoethyl-N-Ethyl-M-Toluidine Not DOT Regulated Liquid HT Shipped to Jaychem 12/08/09 16 16 3-136 4 Lever Packs 520 40 480 103-90-2 3 P-Hydroxyacetanilide Not DOT Regulated Drum - 110 Net Powder HT Shipped to Jaychem 12/08/09 16 16 3-137 4 Lever Packs 528 40 488 103-90-2 3 P-Hydroxyacetanilide Not DOT Regulated Drum - 110 Net Powder HT Shipped to Jaychem 12/08/09 16 16 3-138 4 Lever Pack Drums 1251 43 1208 Proprietary 3 Azo Blue 2B Crude DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-139 5 Cans, 1 Box 296 48 248 1131-18-6 3 1 Box PMAP 5-Amino-3-Methyl-1- Phenylpyrazole Net 44 Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 KMV Inventory BLDG # 3 17 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 16 16 3-139 N/A 1 Can Dimethyl ONCB Sulfonamide/M6 Net 16 Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-139 N/A 1 Can Yellow BRYN Coupler Net 15 Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-139 14580-22-4 1 Can 1-(2-Chlorophenyl)-3- Methyl-5-Pyrazolone Net 27 Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-139 N/A 1 Can Mixed Cleeves Acid DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-139 119-40-4 1 Can N-Phenyl, J-Acid Net 23 Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-140 4 Lever Pack Drums 501 52 449 N/A 3 1 Drum Benzanthrone Dye DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-140 N/A 3 1 Drum Azo Blue 2B Crude DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-140 17601-94-4 3 2 Drums 2-Amino 3 Bromo 5 Nitrobenzonitrile DOT: Not Regulated Net 50 Powder HT Shipped to Jaychem 12/08/09 16 16 3-141 4 Lever Pack Drums 764 44 720 127-68-4 3 1 Drum Sodium Nitrobenzene Sulfonate Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-141 N/A 3 1 Drum Puronic F68 Prill Surfacant DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 KMV Inventory BLDG # 3 18 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 16 16 3-141 N/A 3 1 Drum Octonet 75 Net 500/Tare 20 Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-141 N/A 3 1 Drum 3-Aminophenylurea Net 157 Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-142 3 Lever Pack Drums 635 37 598 Proprietary 3 1 Drum Serilene Yellow AG Presscake DOT: Not Regulated Powder HT Sample 3-142-B Shipped to Jaychem 12/08/09 16 16 3-142 3 1 Drum Red Presscake DOT: Not Regulated Powder HT Sample 3-142-A Shipped to Jaychem 12/08/09 16 16 3-142 3 1 Drum Intralan Yellow DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-143 17 Fiber Cans 1073 46 1027 735-30-8 3 4,4 Diaminobenzanilide (DABA) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-144 4 Fibers 1000 42 958 25711-72-2 3 3-Aminophenyl Urea Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 17 17 3-146 4 Lever Packs 1278 37 1241 N/A 3 Masaja Base MF6 Not DOT Regulated Liquid HT Shipped to Jaychem 02/18/10 16 16 3-147 4 Lever Packs 1207 57 1150 N/A 3 MAAPBS Net 330 Not DOT Regulated Liquid HT Shipped to Jaychem 12/08/09 16 16 3-148 5 Lever Packs 453 40 413 67599-13-7 3 1 Pack Azo Fast Red KB Powder (Stabilized) DOT: Not Regulated Net 10 Powder HT Shipped to Jaychem 12/08/09 16 16 3-148 Proprietary 3 2 Packs Fast Scarlet 26 Salt Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 3062-89-4 UN 2213 3 2 Packs Paraformaldehyde, NA, UN 2213 99% DOT:Para Formaldehyde, N.A., //4.1//,UN2213, PGIII Net 26 Powder HT Placard: Flammable Solid 4 KMV Inventory BLDG # 3 19 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 16 16 3-149 4 Open Top Drums 1384 35 1349 4346-51-4 3 4-Nitroaniline-2-Sulfonic Acid (Moist) Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-150 4 Open Top Drums 1017 60 957 100-10-7 3 4(Dimethylamino) Benzaldehyde 220 lbs Net Each Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 3-151 1 Over Pack 3 Glycol Ether DOT: Flammable Liquid,n.o.s.,(Glycol Ether),//3//, UN #1993, PG III Placard; Flammable Liquid 3 3-152 1 Over Pack 3 Emery 5749-A 40.6% Activity 0011830007 Corrosive 3-153 1 Over Pack 3 N-Cyandethyl-N-Ethylaniline Code 0011670007 3-154 1 Over Pack 112-15-2 3 Carbitol Acetate Hazardous Ingredients: Diethylent, Glycol Ethyl Ether May Form Explosive Peroxide Not DOT Regulated 3-155 1 Over Pack 3 Emery 5749-A 40.6 % Activity Regulated Ingredients: Acetic Acid, 3-(N-N Diethyl) Amminolacetanilide 3-156 1 Over Pack 3 Emery 5749-A 40.6 % Activity Regulated Ingredients: Acetic Acid, 3-(N-N Diethyl) Amminolacetanilide 3-157 1 Over Pack 3 Glycol Ether DPM Batch # 3019/02 KMV Inventory BLDG # 3 20 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments Waste 3-158 1 Over Pack UN 2076 3 P-Cresol 90% Solution DOT: RQ,Cresols,//6.1//,UN2076,PG II Waste to PSC 03/16/10 Waste 3-159 2 Over Packs 98-09-9 UN 2225 3 Benzene Sulfonyl Chloride DOT: Benzene Sulfonyl Chloride,//8//UN2225,PG III Liquid HT Placard; Corrosive Waste to PSC 3/16/10 3-160 Waste 3-161 2 Over Packs 98-09-9 UN 2225 3 Benzene Sulfonyl Chloride DOT: Benzene Sulfonyl Chloride,//8//UN2225,PG III Liquid HT Placard; Corrosive Waste to PSC 3/16/10 Waste 3-162 2 Over Packs 98-09-9 UN 2225 3 Benzene Sulfonyl Chloride DOT: Benzene Sulfonyl Chloride,//8//UN2225,PG III Liquid HT Placard; Corrosive Waste to PSC 3/16/10 Waste 3-163 2 Over Packs 98-09-9 UN 2225 3 Benzene Sulfonyl Chloride DOT: Benzene Sulfonyl Chloride,//8//UN2225,PG III Liquid HT Placard; Corrosive Waste to PSC 3/16/10 Waste 3-164 2 Over Packs 98-09-9 UN 2225 3 Benzene Sulfonyl Chloride DOT: Benzene Sulfonyl Chloride,//8//UN2225,PG III Liquid HT Placard; Corrosive Waste to PSC 3/16/10 Waste 3-165 2 Over Packs 98-09-9 UN 2225 3 Benzene Sulfonyl Chloride DOT: Benzene Sulfonyl Chloride,//8//UN2225,PG III Liquid HT Placard; Corrosive Waste to PSC 3/16/10 Waste 3-166 2 Over Packs 98-09-9 UN 2225 3 Benzene Sulfonyl Chloride DOT: Benzene Sulfonyl Chloride,//8//UN2225,PG III Liquid HT Placard; Corrosive Waste to PSC 3/16/10 Lab Pack Lab Pack 3-167 4 55 Gal. Drums 686 3 Lab Packs Broke for lab packing 10/29/09 HAZ~MAT Waste 3-168 1 Cubic Box 3 Dye Box 3 Non Hazardous Shipped to HAZ~MAT 11/11/09 HAZ~MAT Waste 3-169 1 Cubic Box 3 Cubic Box CY7 Non Hazardous Shipped to HAZ~MAT 11/11/09 KMV Inventory BLDG # 3 21 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments HAZ~MAT Waste 3-170 1 Cubic Box 3 Cubic Box CY6 Non Hazardous Shipped to HAZ~MAT 11/11/09 HAZ~MAT Waste 3-171 1 Cubic Box 3 Cubic Box CY5 Non Hazardous Shipped to HAZ~MAT 11/11/09 HAZ~MAT Waste 3-172 1 Cubic Box 3 Cubic Box CY4 Non Hazardous Shipped to HAZ~MAT 11/11/09 Lab Pack Lab Pack 3-173 4 55 Gal. Drums 699 3 Lab Packs Broke for lab packing 10/29/09 Lab Pack Lab Pack 3-174 1 Orange Bin 1057 3 Lab Packs Lab Pack Lab Pack 3-175 1 Orange Bin 883 3 Lab Packs Lab Pack Lab Pack 3-176 Skid of Buckets 259 3 Lab Packs Broke for Lab Packing 10/28/09 Lab Pack Lab Pack 3-177 4 55 Gal. Drums 666 3 Lab Packs Broke for lab packing 10/29/09 Lab Pack Lab Pack 3-178 (3) 55 Gal. Drums 1 Drum 547 3 Lab Packs Broke for lab packing 10/29/09 Lab Pack Lab Pack 3-179 4 55 Gal. Drums 1459 3 Lab Packs Broke for lab packing 10/29/09 Lab Pack Lab Pack 3-180 (2) 55 Gal. Drums (2) Buckets 520 3 Lab Packs Broke for Lab Packing 10/28/09 Lab Pack Lab Pack 3-181 4 55 Gal. Drums 708 3 Lab Packs Broke for lab packing 10/29/09 Lab Pack Lab Pack 3-182 4 55 Gal. Drums 386 3 Lab Packs Broke for lab packing 10/29/09 Lab Pack Lab Pack 3-183 4 55 Gal. Drums 956 3 Lab Packs Broke for Lab Packing 10/28/09 14 3-184 9 Cans 603 38 565 99-09-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT Placard: Toxic 6 KMV Inventory BLDG # 3 22 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 14 3-185 5 Cans Net110 540 40 500 106-47-8 2018 PGII 3 p-Chloroaniline DOT:Chloroaniline,Solid,(p- Chloroaniline),6.1, UN2018,PGII Powder HT Placard: Toxic 6 14 3-186 577 39 538 105-67-9 2261 3 1 Drum=2,4-Dimethyl Phenol DOT:RQ,Xylenol,N.A., //6.1//UN2261,PGII Liquid HT 14 99-59-2 3 Cans=Fast Scarlet R Base DOT Not Regulated Powder 17 17 3-187 1 Drum 3 Cans 632 37 595 27165-22-6 3 1 Can Fast Red 3GL Salt Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 17 17 3-187 3 1 Can Nylanthrene Orange Par Liquid Not DOT Regulated Powder HT Shipped to Jaychem 02/18/10 17 17 3-187 3 1 Can Nylanthrene Red B-28-5A Liquid 33% Not DOT Regulated Liquid HT Shipped to Jaychem 02/18/10 17 17 3-187 3 1 Drum Nylanthrene Red B-28-5A Liquid 33% Not DOT Regulated Liquid HT Shipped to Jaychem 02/18/10 Lab Pack Lab Pack 3-188 Drums / Buckets 712 3 2 Drums / Buckets / Pails (Greenville) Broke for Lab Packing 10/26/09 Lab Pack Lab Pack 3-189 4 Drums 1574 3 Marked as Unknown As Per: Dee Broke for Lab Packing 10/28/09 Lab Pack Lab Pack 3-190 Buckets / Pails 447 3 1 Pallet with Buckets / Pails of Lab Packs Broke for Lab Packing 10/26/09 Lab Pack Lab Pack 3-191 Buckets / Pails 801 3 1 Pallet with Buckets / Pails of Lab Packs Broke for Lab Packing 10/26/09 Lab Pack Lab Pack 3-192 N/A 465 3 1 Pallet Lab Packs - Mostly 5 Gal. Buckets Broke for Lab Packing 10/28/09 Lab Pack Lab Pack 3-193 N/A 411 3 1 Pallet Lab Packs - Mostly 5 Gal. Buckets Broke for Lab Packing 10/26/09 KMV Inventory BLDG # 3 23 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments Lab Pack Lab Pack 3-194 4 Drums 1661 3 Waste Amres C-20 Broke for Lab Packing 10/28/09 Lab Pack Lab Pack 3-195 4 Drums 1823 3 Waste Patsoft Broke for Lab Packing 10/28/09 Lab Pack Lab Pack 3-196 4 Drums 926 3 Ammonia? / Floor Sweepings / 2 Unknowns Broke for Lab Packing 10/28/09 17 17 3-197 4 Drums 1104 39 1065 N/A 3 1 Drum SAG 30 280 Net Not DOT Regulated Liquid HT Shipped to Jaychem 02/18/10 17 17 3-197 N/A 3 1 Drum Tektamer 38 AD 380 Net Not DOT Regulated Liquid HT Shipped to Jaychem 02/18/10 17 17 3-197 N/A 3 1 Drum Cobalt Sulfate Solution 94% Liquid HT Shipped to Jaychem 02/18/10 17 17 3-197 127-66-4 3 1 Drum Sodium M-Nitrobenzene Sulfunate Net 200 Not DOT Regulated Liquid HT Shipped to Jaychem 02/18/10 14 3-198 6 Cans 823 64 759 99-09-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT Placard; Toxic, Marine Pollutant 14 3-199 6 Cans 736 45 691 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT Placard; Toxic, Marine Pollutant 14 3-200 6 Cans 785 37 748 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline, 6.1,UN 1661, PGII Powder HT Placard; Toxic, Marine Pollutant 14 3-201 5 Cans 677 41 636 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT Placard; Toxic, Marine Pollutant 14 3-202 4 drums 710 33 677 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT Placard; Toxic, Marine Pollutant KMV Inventory BLDG # 3 24 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 14 3-203 6 Cans 795 36 759 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT Placard; Toxic, Marine Pollutant 14 3-204 4 Drums 588 45 543 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT OVERPACK Placard; Toxic, Marine Pollutant 14 3-205 6 Cans 789 44 745 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT Placard; Toxic, Marine Pollutant 14 3-206 6 Cans 818 48 770 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT Placard; Toxic, Marine Pollutant 14 3-207 4 Drums 595 55 540 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT OVERPACK Placard; Toxic, Marine Pollutant 14 3-208 6 Cans 800 35 765 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT Placard; Toxic, Marine Pollutant 20 3-209 4 Drums 40 68227-69-0 3 1 Drum Phenyl Ester Orthanilic Acid Net 239 Not DOT Regulated Powder HT 20 3-209 98-42-0 3 1 Drum 2-Methoxyaniline-5- Sulfonic Acid Not DOT Regulated Powder HT 20 3-209 1310-73-2 3 1 Drum Intranite DLS Not DOT Regulated Powder HT 20 3-209 127-68-4 3 1 Drum Sodium M-Nitrobenzene Sulfunate Not DOT Regulated Powder HT KMV Inventory BLDG # 3 25 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 16 16 3-210 5 Cans 445 54 401 13676-91-0 3 3 Cans 1,8-Bis (Phenylthio) Anthraquinone Not DOT Regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-210 3 2 Cans 2-Amino-Thiazole Powder HT Shipped to Jaychem 12/08/09 14 3-211 4 Drums 635 37 598 99-02-2 1661 PGII 3 3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT Placard; Toxic, Marine Pollutant 14 3-212 4 drums 778 64 714 99-02-2 1661 PGII 3 2 Drums=3-Nitroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Powder HT OVERPACK Placard; Toxic, Marine Pollutant 14 62-53-3 1547 PGII 1 Drum=AnilineOil, Amino Benzene DOT:RQ,Aniline,6.1,UN1547, PGII Liquid Placards; Toxic 6 14 88-17-5 2942 PGIII 1 Drum=AminoBenzotrifluoride DOT:2 Trifluoromethylaniline, 6.1,UN 2942, PGIII Liquid Placard; Toxic 6 14 3-213 4 Drums 1508 62 1446 102-27-2 2754 PGII 3 3 Drums= N-Ethyl-M-Toluidine, Pure DOT:N-Ethyl Toluidines,//6.1// UN2754, (N-Ethyl-M- Toluidine),PG II Powder HT Placard;Toxic 6 97-02-9 1596 PGII 1 Drum=2,4, Dinitroaniline DOT:Nitroanilines,N.A., 6.1,UN 1596,PGII Powder Placard;Toxic 6 14 3-214 4 Drums 1421 56 1365 118-75-2 2811 PGIII 3 2 Drums=Chloranil DOT: Toxic Solid,N.O.S.,(Chloranil)//6.1//U N2811, PG III Powder HT Placard;Toxic 6 KMV Inventory BLDG # 3 26 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 14 91-66-7 3432 PGIII 1 Drum=Dyestuff Intermediate, N,N,Diethylaniline DOT: N,N- Diethylaniline,N.O.S.,6.1,UN343 2,//PG III Liquid Placard;Toxic 6 14 823-40-50 2811 PGII 1 Drum= O-Tollyenediamine DOT:RQ, Toxic Solid,Organic,N.O.S.,(1,2- Toluenediamine),//6.1//UN281 1, PGII Solid Placard: Toxic 6 19 3-215 3 Drums 1509 44 1465 141-43-5 UN 2491 3 Monoethanolamine DOT: Ethanolamine, UN 2491, Class 8, PG. II Liquid HT Placard: Corrosive 8 3-216 4 Drums 536 41 495 17601-94-1 3 2 Drums 2-Amino 3 Bromo 5 Nitrobenzonitrile Not DOT Regulated Liquid HT 3-216 132-68-3 3 1 Drum Napthol AS-BO-11 50% (Azoic Coupling Component 4) Net 130 Not DOT Regulated Liquid HT 3-216 120-71-8 UN 2431 3 1 Drum P-Cresidine, Flake MW137 DOT: Anisidines, (5 Methylanisidine),//6.1//, UN 2431, PG III Liquid HT 16 16 3-217 4 Drums 648 40 608 Proprietary 3 1 Drum RSE Orange Coupler (Intrasil) Not DOT Regulated Powder HT Sample # 3-785 Shipped to Jaychem 12/08/09 16 16 3-217 3 1 Drum MAAPBS Not DOT Regulated Powder HT Sample # 3-784 Shipped to Jaychem 12/08/09 KMV Inventory BLDG # 3 27 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 16 16 3-217 3 1 Drum Yellow Intrasil Dye Not DOT Regulated Powder HT Sample # 3-775 Shipped to Jaychem 12/08/09 16 16 3-217 3 1 Drum Red Base Crude Not DOT Regulated Powder HT Sample # 3-777 Shipped to Jaychem 12/08/09 14 3-218 4 drums 1120 48 1062 108-42-9 2019 PGII 3 1 Drum-1-M,Chloroaniline DOT:Chloroaniline,Liquid,N.A.,6. 1,UN2019, PGII Liquid HT Placard; Toxic 6 14 87-62-7 1711 PG II 2,6-Xylidine DOT: Xylidine,liquid,6.1,UN1711,PGII Placard: Toxic 6 14 96-79-4 2239 PGIII 4 Chloro-Ortho-Toluidine DOT:Toxic Solid, N.O.S.,6.1,UN2239, PGIII Placard: Toxic 6 68955-53-3 2922 PG III Primene 81-R Amine DOT: Corrosive Liquid,Toxic,N.O.S.,(T-Alky- Amines),8,//6.1//UN2922, PG III Placard:Toxic 6, Corrosive 8 DO not have a license to import as per Smita David 19 3-219 4 Drums 1942 64 1879 28128-51-0 1760 3 3 Drums Acetyl MAAH DOT: Corrosive Liquid, N.O.S. (Contains Acetic Acid), Corrosive Material, //8//,UN 1760, PG III Chemical Name; 3-(Bisacetoxyet-Amino)-4- Methoxy-4-Getan Liquid HT Placard: Corrosive 8 KMV Inventory BLDG # 3 28 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 3-219 3 1 Drum Primene 81-R DOT: Corrosive Liquid,Toxic,N.O.S.,(T-Alky- Amines),8,//6.1//UN2922, PG III Liquid HT Placard: Corrosive 8/Toxic 6 DO not have a license to import as per Smita David 14 3-220 4 Drums 942 72 870 75-05-8 3276 3 3 drums=N-Cyanoethyl-o- Chloroaniline DOT: Nitriles, Toxic,,N.O.S.,(Cyanoethylchloro aniline, Acrylonitrile), 6.1,UN3276, PGIII Liquid HT Placards: Marine Pollutant, Keep away from foodstuffs. 14 2735 04 8 1 Drum=2,4 DimethOxyaniline DOT: Not regulated 16 16 3-221 4 Drums 933 26 907 Proprietary 3 1 Drum Imperon Red Bag DOT: Not regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-221 3 2 Drums 5-Nitro BN Coupling Presscake DOT: Not regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-221 3 1 Drum Neutral Cyanine Green GK 145% DOT: Not regulated Powder HT Shipped to Jaychem 12/08/09 20 3-222 5 Cans 446 38 458 842-18-2 3 1 Can G-Salt MW304 Not DOT Regulated Powder HT 20 3-222 134-32-7 3 1 Can Napthonic Acid Sodium MW245 Not DOT Regulated Powder HT 20 3-222 6375-47-9 3 3 Cans 3-Amino-4-Methoxy- Acetanilide Not DOT Regulated Powder HT KMV Inventory BLDG # 3 29 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 16 16 3-223 4 Drums 1048 44 1004 107-97-1 103-90-2 Proprietary N.A.3 2 Drums = Sarcosine DOT: Not Regulated 1 Drum= p-Hydroxyacetanilide DOT: Not regulated 1 Drum= Orangr RSE (Intrasil) DOT: Not regulated Powder HT Shipped to Jaychem 12/08/09 16 16 3-224 4 Drums 1352 49 1304 81-99-2 4316-74-9 2735-04-8 NA 3 2 Drums=1-Amino-2,4 Dibromoanthraquine (Calsak) DOT: Not regulated 1 Drum= 'n-Methyltaurine MW139 DOT: Not regulated 1 Drum=2,4-Dimethdxyaniline DOT: Not regulated Liquid HT Shipped to Jaychem 12/08/09 16 16 3-225 4 Drums 597 38 559 81-49-2 NA 3 1-Amino-2,4 Dibromoanthraquine (Calsak) DOT: Not regulated Liquid HT Shipped to Jaychem 12/08/09 19 3-226 4 Drums 1089 49 1040 121-18-6 6471-78-9 3147 3261 3 3 Drum= 4-Chloro-3- Nitrobenzene Sulfonic Acid (Isolated) DOT:Dye Intermediate,Solid, Corrosive,N.O.S.,(Chloro Nitro Benzene Sulfonic Acid),//8//,UN3147, PG III 1 Drum= p-Cresidine Sulfonic Acid (MW217) DOT:Corrosive Solid,Acidic,Organic,N.O.S.,(Di methylaniline Sulfonic Acid),//8//,UN3261, PGIII Solid HT 1 Overpack, Placards;Corrosive 8 Placards;Corrosive 8 KMV Inventory BLDG # 3 30 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 3-227 4 Drums 1118 34 1084 68227-69-0 NA 3 1 Drum=Phenyl Ester Orthanilic Acid DOT: Not Regulated Liquid HT 94-34-8 1 Drum= Emery 5722 N-Cyanoethyl-N-Methylamine DOT: Not Regulated 22031-33-0 1993 1 Drum= Emery 5731 N-Cyanoethyl-N-Acetoxyethyl Aniline DOT: Flammable Liquids,n.o.s.,(Acetic Acid),//3//,UN1993,PG III Placards: Flammable Liquid 148-87-8 1 Drum= Cyanoethyl-N- Ethylaniline (Purchased) DOT: Not Regulated 14 3-228 3 Drums 792 40 752 1817-73-8 1661 PGII 3 1 Drum=6-Bromo-2,4 Dintiroaniline DOT:Nitroaniline,6.1,UN 1661, PGII Liquid HT Placard: Toxic 6 14 91-67-8 2810 PGII 1 Drum= N,N-Diethyl-M-Toluidine DOT:Toxic Liquids,Organic,N.O.S., (Diethyl-M- Toluidine),//6.1//,UN2810,PG II Liquid Placard: Toxic 6 14 75-05-8 3276 PGIII 1 Drum= N-Cyanoethyl-O- Chloroaniline DOT:Nitriles,Toxic,N.O.S.,(Cyan oethyl,chloroaniline,Acrylonitril es), 6.1,UN3276,PGIII Liquid Placard; Toxic, Marine Pollutant KMV Inventory BLDG # 3 31 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 17 17 3-229 4 Drums 136 net 996 47 949 25711-72-2 NA 3 1 Drum= 3 Aminophenylurea DOT: Not Regulated Liquid HT Shipped to Jaychem 02/18/10 17 17 136 net 117-23-7 NA 1 Drum= 2-Chloro 6-Methylphenyl- Methyl-Pyrazolone DOT: Not Regulated Shipped to Jaychem 02/18/10 17 17 372 net 98-42-0 NA 2 Drums= 2-Methoxyaniline-5- Sulfonic Acid DOT; Not Regulated Shipped to Jaychem 02/18/10 14 3-330 3 Drums 2 Cans Net 200 1127 64 1063 85-44-9 2214 PG III 3 3 Drums= Phthalic Anhydride DOT: Phthalic Anhydride,N.A.,8,UN2214, PG III Liquid HT 14 Net 44 591-27-5 2512 PG III 1 Can= Meta Amino Phenol DOT:Aminophenol(M- ),N.A.,6.1,UN2512,PGIII Powder 14 95-89-2 1590 PG II 1 Can= (2.5- Dichloro Aniline) DOT:Dichloroanilines, Solid,6.1, UN1590,PG II Powder 14 3-331 2 Drums 462 41 421 95-89-2 1661.PGII 3 1 Drum= 2.6 Dichloro-4- Nitroaniline DOT: Nitroanilines,6.1,UN1661, PGII Liquid HT OVERPACK 14 97-02-9 1596 PGII 1 Drum= 2,4, Dinitroaniline DOT:Dinitroanilines,N.A., 6.1,UN1596,PGII Liquid OVERPACK Placard; Toxic 6 16 16 3-332 3 Drums 583 43 540 Proprietary NA 3 1 Drum= Yellow BRY-N Coupler DOT: Not Regulated Powder HT Shipped to Jaychem 12/08/09 KMV Inventory BLDG # 3 32 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 16 16 Proprietary NA 1 Drum= Violet BL Base DOT: Not Regulated Sample # 3-930 Shipped to Jaychem 12/08/09 16 16 Proprietary NA 1 Drum= Intrasil Red Dot: Not regulated Sample # 3-931 Shipped to Jaychem 12/08/09 3-333 3-334 2 Drums 1352 51 1301 95-51-2 2019 3 2-0-Chloroaniline DOT: DOT: Chloroaniline,Liquid,N.A., //6.1//,UN2019, PG II Liquid HT Placards; Toxic 6, Marine Pollutant Steel Overpacks 3-335 2 Drums 464 42 422 95-51-2 2019 3 1 Drum=2-0-Chloroaniline DOT: Chloroaniline,Liquid,N.A., //6.1//,UN2019, PG II Liquid HT Placards; Toxic 6, Marine Pollutant Steel Overpacks 62-53-3 2810 1 Drum= Phenyl Thanoamine DOT: Toxic Liquid, Organic, n.o.s.,(phenylethanolamine), //6.1//, UN 2810, PG II Liquid HT Placards; Toxic 6, Marine Pollutant Steel Overpacks 3-336 2 Drums 1204 36 1168 100-44-7 1738 3 Benzyl Chloride DOT: RQ, Benzyl Chloride,N.A.,//6.1//,UN1738, PGII Liquid HT Placards; Toxic 6, Marine Pollutant Steel Overpacks 3-337 2 Drums 1105 40 1055 100-44-7 1738 3 Benzyl Chloride DOT: RQ, Benzyl Chloride,N.A.,//6.1//,UN1738, PGII Liquid HT Placards; Toxic 6, Marine Pollutant Steel Overpacks 3-338 2 Drums 842 35 807 87-62-7 1711 3 2.6 Xylidine DOT: Xylidines, Solution, N.A.,//6.1//,UN1711,PGII Liquid HT Placards; Toxic 6, Marine Pollutant Steel Overpacks 3-339 2 Drums 625 42 583 102-27-2 2754 3 N-Ethyl-M-Toluidine DOT: N-Ethyl- Toluidide,N.A.,UN2754 Liquid HT Placards; Toxic 6, Marine Pollutant Steel Overpacks KMV Inventory BLDG # 3 33 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 100-47-0 2224 Benzonitrile DOT: Benzonitrile,N.A.,//6.1//, UN2224, PG II Liquid HT Placards; Toxic 6, Marine Pollutant Steel Overpacks 3-340 2 Drums 756 41 715 68-12-2 2265 3 2 Drums= Dimethyl Foramide DOT:RQ,n,n-Dimetyl Foramide,N.A.,//3//,UN2265, PG III Liquid HT Placard: Flammable Liquid 3 Moved to building 5 Overpacked 20 3-341 2 Drums 645 43 602 30693-53-9 NA 3 4-Nitroaniline-2-Sulfonic Acid DOT: Not Regulated Liquid HT Overpacked 20 3-342 2 Drums 1 Can 376 44 332 56280-59-2 NA 3 2 Drums= Red, C.N. Chloride Dye Intermediate DOT: Not Regulated Liquid HT Overpacked 20 92-14-8 NA 3 1 Can= Red 3B Aldehyde DOT: Not Regulated Liquid HT Overpacked 20 3-343 2 Drums 376 44 332 94-34-8 NA 3 N-Cyanoethyl-N-Methylaniline DOT: Not Regulated Liquid HT Overpacked 20 3-344 3 Drums 376 66 310 479-27-6 NA 3 3-1,8-Diaminonapthale DOT: Not Regulated Liquid HT Overpacked 20 3-345 3 Drums 354 40 314 479-27-6 NA 3 3-1,8-Diaminonapthale DOT: Not Regulated Liquid HT Overpacked 20 3-346 3 Drums 438 37 401 479-27-6 NA 3 3-1,8-Diaminonapthale DOT: Not Regulated Liquid HT Overpacked 20 3-347 2 Drums 298 45 253 479-27-6 NA 3 3-1,8-Diaminonapthale DOT: Not Regulated Liquid HT Overpacked 3-348 2 Drums 731 37 694 NA 3 Glycol Ether DB DOT: Not Regulated Liquid HT Placard: Flammable Liquid Poly overpacks Samples; 3-137 & 3-138 20 3-349 2 Drums 567 49 518 92-15-9 NA 3 Acetoacet-O-Aniside DOT: Not Regulated Liquid HT Poly Overpacks KMV Inventory BLDG # 3 34 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 3-350 2 Drums 734 47 687 NA 3 1 Drum=Diethyline Glycol Monobutyl Ether DOT: Not Regulated Liquid HT Sample # 3-740 Placard: Flammable 8 Poly overpack Moved to building # 5 4316-74-9 1 Drum=N-Methyltaurine DOT: Not Regulated Liquid HT Placard: Corrosive 8 Poly overpack Moved to building # 5 17 17 3-351 4 Drums 1544 42 1502 4316-78-8 NA 3 Sodium Sarcosinate DOT: Not Regulated Liquid HT Shipped to Jaychem 02/18/10 17 17 3-352 3 Drums 1202 39 1162 7277-87-4 NA 3 Amino-j Pyrazolone (MW- 384)(Calsak) DOT: Not Regulated Liquid HT Shipped to Jaychem 02/18/10 3-353 2 Drums 56 148-87-8 NA 3 1 Drum= N-Cyanoethyl-N- Ethylaniline DOT: Not Regulated Liquid HT Placard: Keep Away from Foodstuff Awaiting overpacks to complete 7277-87-4 NA 1 Drum=Amino-j Pyrazolone (MW- 384)(Calsak) DOT: Not Regulated 3-353, Awaiting overpacks to complete 17 17 3-354 4 Drums 723 32 691 Proprietary NA 3 Nylanthrene Blue G.F. Crude DOT: Not Regulated Powder HT Samples # 33-304/33-301/33-300/33- 303 Shipped to Jaychem 02/18/10 3-355 4 Drums 943 42 901 Proprietary NA 3 4 Drums= Orange press cake DOT: Not Regulated Powder HT Samples# 10-036/10-037/10-038/ 10-039 3-356 2 Drums 931 41 890 00064-17-5 1770 3 1 Drum= Aerosol, AY-65% Surfycant DOT: Flammable Liquid,n.o.s. (contains ethanol solution), //3//,UN1170, PG III Liquid HT Moved to building # 5 KMV Inventory BLDG # 3 35 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 1993 1 Drum= Fischers Base DOT:Combustible Liquid,N.O.S.,(Trimethyl Methylene Indoline),//3//, UN1993, PGIII Placards: Flammable/Corrosive Moved to building # 5 20 3-357 4 Drums 641 41 600 Proprietary NA 3 2 Drums= Orange Dye 1 Drum=Red Dye 1 Drum= Sol. Aquafast Red 2BL DOT: Not Regulated Powder HT Samples # 3-211/ 3-208/ 3-209/ 3-1018 20 3-358 3 Drums 351 39 312 Proprietary NA 3 2 Drums= Nylan Blue GLF Crude 1 Drum= Orange SD Dye DOT: Not Regulated Powder HT Samples # 18-504/ 18-503/ 3-604 20 3-359 4 Drums 496 41 455 Proprietary NA 3 2 Drums= Yellow Dye 1 Drum =Red Dye 1 Drum= Nitro Bin DOT: Not Regulated Powder HT Sample # 3-601/3-602/3-600/3-947 3-360 4 Drums 545 36 409 Proprietary NA 3 1 Drum= Red SD Dye 1 Drum=Orange SD Dye 2 Drums=Black SD Dye DOT: Not Regulated Powder HT Samples # 3-214/3-212/3-213/3-215 3-361 4 Drums 687 41 646 Proprietary NA 3 1 Drum =Red Dye 1 Drum= Blue Dye 2 Drums= Violet Dye DOT: Not Regulated Powder HT Samples # 3-204/3-205/3-206/3-207 3-362 4 Drums 851 53 798 108-39-4 2076 PGII 3 2 Drum= MC 99 DOT: RQ, Cresols,6.1,UN2076,PGII (8) Liquid HT Cresol samples 3-933 & 3-934 Waste to PSC 03/16/10 KMV Inventory BLDG # 3 36 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments NA 1 Drum=3M FC-353 Fabric Protector. (scotchguard) DOT: Not Regulated 3261 1 Drum= p-Nitrobenzoyl Chloride DOT: Corrosive Solid,Acidic,Organic, N.O.S.,(Nitrobenzoyl Chloride),UN3261 17 17 3-363 4 Drums 2010 60 1950 107-21-1 NA 3 4 Drums= Surfynol 104E, Surfacant, (ethylene glycol) DOT: Not Regulated Liquid HT Shipped to Jaychem 02/18/10 16 16 3-365 16 Cans 846 46 800 3 Assorted Powder Dyes Powder HT Shipped to Jaychem 12/08/09 3-366 17 Cans 493 46 449 3 Assorted Powder Dyes Powder HT 17 17 3-367 4 Drums 519 28 490 2664-63-3 NA 3 2 Drums=4,4 Thiodiphenol DOT: Not Regulated Liquid HT Shipped to Jaychem 12/08/09 1 Drum=Stylacyl Yellow RG MIS 1 Drum=Nylerene Seriline Red DOT: Not Regulated Powder HT 3-368 1 Drum 183 28 155 Proprietary NA 3 Nyrelene Seriline Red DOT: Not Regulated Powder HT 3-369 4 Drums 50 kg 647 42 605 108-77-0 3 Cyanuric Chloride (solid) DOT:Cyanuric Chloride,//8//,UN2670, PG II Powder HT Highly Toxic, Corrosive Overpack 3-370 4 Drums 50 kg 42 108-77-0 3 Cyanuric Chloride (solid) DOT:Cyanuric Chloride,//8//,UN2670, PG II Powder HT Highly Toxic, Corrosive Overpack 3-376 2 Drums 3 Adams Base Moist 2 Drums for Over Pack Not HT KMV Inventory BLDG # 3 37 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 3-377 2 Fiber Drums 3 3-Aminophenylurea Not DOT Regulated 5-Amino-2-Methylhydroxy-2- Methylbenzene Powder Not HT OVERPACK 3-378 2 Fiber Drums 3 5-Amino-2-Methylhydroxy-2- Methylbenzene Powder Not HT 2 OVERPACKS 3-379 2 Steel Drums 3 M-Hydroxy Diphenylamine Powder HT 2 Drums OVERPACK 3-380 2 Drums 3 1 Drum M-Hydroxy-Diphenyl Amine Powder Not HT OVERPACK 3-380 3 1 Drum 2-Amino-5-Nitrothiazole Powder Not HT OVERPACK 3-381 2 Drums 3 1 Drum Diethylamino Acetonilid Powder Not HT OVERPACK 3-381 3 1 Drum P-Hydroxyacetanilide Powder Not HT OVERPACK 3-382 2 Drums 3 N-Methyltaurine MW139 Not DOT Regulated Liquid Not HT OVERPACK 3-383 2 Drums 3 N-Methyltaurine MW139 Not DOT Regulated Liquid Not HT OVERPACK Waste 3-384 2 Drums 3 1 Drum Emery 5759 A Liquid Not HT OVERPACK Waste to PSC 3/16/10 3-384 3 1 Drum Emery 5731 R Liquid Not HT OVERPACK 3-385 2 Drums 3 1 Drum N-Cyanoethyl-O- Chloroaniline Liquid Not HT 3-385 3 1 Drum Ethylene Glycol Liquid Not HT 3-386 2 Drums 3 2-4-Dinitrochlorobenzene Emery 5704 Liquid Not HT OVERPACK Waste 3-387 2 Drums 1220 3 Emery 5704 Liquid Not HT OVERPACK Waste to PSC 3/16/10 3-388 2 Drums 3 P-Phenetidine Liquid Not HT OVERPACK 3-389 2 Drums 3 P-Phenetidine Liquid Not HT OVERPACK 3-390 2 Fiber Drums 3 P-Toulidine Flake RQ Toulidine, Solid, N.A. Liquid Not HT OVERPACK 3-391 1 Drum UN 1154 3 Dimethyl Amine Liquid Not HT OVERPACK KMV Inventory BLDG # 3 38 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 3-392 2 Fibre Drums Emery 5717 To be Overpacked 3-393 2 Fibre Drums Emery 5717 To be Overpacked 3-394 2 Drums 2,6-Dichloro-4-Nitroaniline To be Overpacked 3-395 2 Drums 2,6-Dichloro-4-Nitroaniline To be Overpacked Waste 3-396 2 Drums 1 Drum=Emery 5717 1 Drum=2,6-Dichloro-4- Nitroaniline To be Overpacked Emery Waste to PSC 3/16/10 3-397 2 Fibre Drums 9-10 Antrecenedine 1-4 Diamino- 2 Dihydroxy Dextrine To be Overpacked 3-398 2 Drums M-Hydroxy Diphenenylanine To be Overpacked 3-399 2 Drums M-Hydroxy Diphenenylanine To be Overpacked HAZ~MAT Waste 3-400 1 Cubic Yard Box 495 495 Dye CY # 9 10/29/09 Dye Samples for Solidification Non Hazardous Waste Shipped To HAZ~MAT 11/1109 HAZ~MAT Waste 3-401 1 Cubic Yard Box 628 628 Dye CY # 10 10/29/09 Dye Samples for Solidification Non Hazardous Waste Shipped To HAZ~MAT 11/1109 HAZ~MAT Waste 3-402 1 Cubic Yard Box 670 670 Dye CY # 11 10/30/09 Dye Samples for Solidification Non Hazardous Waste Shipped To HAZ~MAT 11/1109 HAZ~MAT Waste 3-403 1 Cubic Yard Box 688 688 Dye CY # 8 10/30/09 Dye Samples for Solidification Non Hazardous Waste Shipped To HAZ~MAT 11/1109 HAZ~MAT Waste 3-404 1 Cubic Yard Box 751 751 Dye CY # 6 10/28/09 Dye Samples for Solidification Non Hazardous Waste Shipped To HAZ~MAT 11/1109 HAZ~MAT Waste 3-405 1 Cubic Yard Box 604 604 Dye CY # 7 10/29/09 Dye Samples for Solidification Non Hazardous Waste Shipped To HAZ~MAT 11/1109 HAZ~MAT Waste 3-406 1 Cubic Yard Box 786 786 Dye CY # 12 10/29/09 Dye Samples for Solidification Non Hazardous Waste Shipped To HAZ~MAT 11/1109 HAZ~MAT Waste 3-407 1 Pallet Buckets 503 503 Assorted , Buckets, small containers and bottles. (1 Pallet) Non Hazardous Waste Shipped To HAZ~MAT 11/1109 HAZ~MAT Waste 3-408 1 Pallet 601 3 Assorted Buckets, Bottles Pallet 8 Non Hazardous Waste Shipped To HAZ~MAT 11/1109 KMV Inventory BLDG # 3 39 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments HAZ~MAT Waste 3-409 1 Pallet 443 3 Assorted Buckets, Bottles Pallet 10 Non Hazardous Waste Shipped To HAZ~MAT 11/1109 HAZ~MAT Waste 3-410 1 Pallet 450 3 Assorted Buckets, Bottles Pallet 9 Non Hazardous Waste Shipped To HAZ~MAT 11/1109 3-411 1 Tote 1016 1016 255 761 3 Intrazone Red G Press cake Powder None Orange dye Tote, Brought in when the yard was cleaned out. Sampled by BM 1/19/10 3-412 1 Tote 944 944 255 689 3 Intralite Brill Scarlet 2GL Press cake Powder None Orange dye Tote, Brought in when the yard was cleaned out. Sampled by BM 1/19/10 3-413 1 Tote 1038 1038 255 783 3 J Acid Powder None Orange dye Tote, Brought in when the yard was cleaned out. Sampled by BM 1/19/10 3-414 1 Tote 959 959 255 704 3 J Acid Powder None Orange dye Tote, Brought in when the yard was cleaned out. Sampled by BM 1/19/10 3-415 1 Tote 601 601 255 346 3 Yellow Press cake Powder None Orange dye Tote, Brought in when the yard was cleaned out. Sampled by BM 1/19/10 3-416 1 Tote 447 447 255 192 3 Brown Dye Powder None Orange dye Tote, Brought in when the yard was cleaned out. Sampled by BM 1/19/10 3-417 1 Tote 591 591 255 336 3 Black Dye Powder None Orange dye Tote, Brought in when the yard was cleaned out. Sampled by BM 1/19/10 3-418 1 Tote 536 536 255 281 3 Black Dye Powder None Orange dye Tote, Brought in when the yard was cleaned out. Sampled by BM 1/19/10 Waste xxx 3 10 drums used & New oil two cubic yard boxes of small containers of greas & oil. Liquid & Solid NA Brought in from Maintenance shops & fork lift repair shop. KMV Inventory BLDG # 3 40 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package (lbs.) Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments Total Gross 197493 Bldg 4 Waste 1 Pallet ## Packages Weight of Each Package (lbs.) CAS # UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 4-001 4 Drums 4 (3) Aqueous, (1) Aqueous with Solids pH6 - pH4 - pH6 - pH8 Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-002 3 Drums 4 Aqueous pH11 - pH11 - pH10 Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-003 2 Drums 4 Aqueous pH6 - pH?Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-004 4 Drums 4 Aqueous pH11 - pH6 - pH6 - pH6 Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-005 (2) Drums, (1) Over Pack 4 (2) Aqueous pH6 - pH6, (1) Over Pack pH6 Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-006 4 Drums 4 Aqueous pH6 - pH7 - pH8 - pH9 Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-007 1 Over Pack 4 Aqueous pH6 Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-008 4 Drums 4 Aqueous - ph6 - pH11.3 - H10.8 - pH6 Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-009 4 Drums 4 Aqueous pH6 - pH5 - pH6 - pH11.8 Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-010 4 Drums 4 Aqueous pH10 - pH6 - pH7 - pH6 Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-011 4 Drums 4 (3) Aqueous pH11.5 - pH11 - pH10, (1) Dye AD pH8 Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-012 4 Drums 4 (3) Aqueous pH6 - pH6 - pH9, (1) Non-Hazardous Solid (3) Liquidm (1) Solid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-013 2 Drums 4 Aqueous AP pH7 - pH6 Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-014 (3) Drums, (2) 5 Gal. Drum 4 (3) Aqueous AP, (2) 5 Gal. Drum Aqueous AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 Bldg 4 Waste 2 Pallet ## Packages Weight of Each Package (lbs.) CAS # UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 4-015 (1) Drum, (1) 5 Gal. Drum 4 Aqueous AP, Ph6 Latex Paint AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-016 1 Tote 4 Aqueous AP pH6 Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-017 1 Tote 4 Aqueous AP Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-018 1 Tote 4 Aqueous AP Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-019 4 Drums 4 Aqueous AP pH6 - pH7 - pH6 - pH6 Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-020 3 Drums 4 Aqueous AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-021 4 Drums 4 Aqueous AP Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-022 4 Drums 4 Aqueous AP Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-023 1 Tote 4 Aqueous AP Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-024 1 Tote 4 Aqueous AP Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-025 4 Drums 4 Brown Solid NH pH10 Solid Not HT 4-026 1 Over Pack 4 High Halogens HH Liquid Not HT 4-027 1 Over Pack 4 High Halogens HH Liquid Not HT 4-028 1 Over Pack 4 High Halogens HH Liquid Not HT 4-029 2 Over Packs 4 High Halogens HH Liquid Not HT 4-030 1 Drum 4 Brown Solid Solid No Skid 4-031 3 Drums 4 (2) Red Dye, (1) Black Dye AD Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 Bldg 4 Waste 3 Pallet ## Packages Weight of Each Package (lbs.) CAS # UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 4-032 1 Tote 4 Dye AD Liquid 4-033 4 Drums 4 Dye?Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-034 1 Tote 4 Dark Red Dye AD Liquid 4-035 1 Tote 4 Amber Clear pH7 Liquid 4-036 3 Drums 4 (1) Dye pH6 AD, (2) Red Dye and H2O Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-037 (5) Fiber Cans, (1) Plastic Jug 4 (5) Dye SD, (1) Purple Dye AD (5) Solid, (1) Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-038 3 Drums 4 (2) Blue Dye AD, (1) Purple Liquid Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-039 4 Drums 4 Non-Hazardous Solids HS Solid HT 4-040 4 Drums 4 Non-Hazardous Solids HS Solid HT 4-041 3 Drums 4 Non-Hazardous Solids HS Solid HT 4-042 2 Drums 4 Non-Hazardous Solids HS Solid No Skid 4-043 2 Drums 4 Non-Hazardous Solids HS, Non- Hazardous Solid Dye SD Solid HT 4-044 1 Tote 4 Solid Dye Brown SD Solid 4-045 4 Drums 4 Liquid Dye Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-046 1 Drum 4 Black Dye Liquid Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-047 (3) Drums, (1) Jug 4 Non-Hazardous Solid HS, ?????Solid ??? 4-048 (5) Drums, (1) ???, (1) Box 4 (1) Viscious Liquid HS, (2) Gray and White Powder HS, (3) Dye SD, (1) ???? Sulfate SD (6) Solid, (1) Liquid Not HT 4-049 4 Drums 4 Aqueous AP Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 Bldg 4 Waste 4 Pallet ## Packages Weight of Each Package (lbs.) CAS # UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 4-050 (1) Over Pack, (1) Drum 4 Aqueous AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-051 4 Drums 4 Aqueous AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-052 4 Drums 4 Aqueous AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-053 3 Drums 4 Aqueous AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-054 3 Drums 4 Aqueous AP Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-055 (1) Over Pack, (2) Drum 4 Dye AD Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-056 3 Drums 4 Brown Organic Liquid HH Liquid Not HT 4-057 2 Drums 4 Dye and Oil Dry, Aqueous AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-058 (3) Drums, (2) Pails 4 Non-Hazardous Solids, Trash, (2) Dye Aqueous Liquid HT 4-059 1 Lab Box 4 Furan Powder SA Solid Not HT 4-060 3 Drums 4 (1) Oil and H2O, (2) Dry Dye (1) Liquid, (2) Solid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-061 3 Drums 4 Isopar "2" Fluid, ??? Fluid, Arometic Petroleum Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-062 1 Tote 4 Oil and H20 LH Liquid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-063 (3) Drums, (1) Jug 4 Dye AD Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-064 2 Drums 4 Sodium Sulfate ???? HS, Solid Acidic Solid Not HT 4-065 3 Totes 4 Build #33 Tanks T-1/T-11 Dye Rinsates Liquid 4-066 4 Totes 4 Build #14 Tank #5 Dye Liquid Bldg 4 Waste 5 Pallet ## Packages Weight of Each Package (lbs.) CAS # UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 4-067 1 Drum 4 Sent to Build #3 No Skid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-068 1 Drum 4 No Label Sample #4-069 Liquid No Skid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-069 1 Tote 4 Dye AD from Floor Wash Build 33 Liquid 4-070 1 Tote 4 Dye AD from Floor Wash Build 33 Liquid 4-071 1 Tote 4 Dye AD from Floor Wash Build 33 Liquid 4-072 1 Tote 4 Dye AD from Floor Wash Build 33 Liquid 4-073 1 Drum 4 Dyed Diesel AP Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-074 1 Drum 4 AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-075 1 Tote 4 AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-076 3 Drums 4 AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-077 1 Tote 4 AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-078 1 Tote 4 AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-079 1 Tote 4 AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-080 1 Tote 4 AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-081 1 Tote 4 AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-082 1 Tote 4 AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 Bldg 4 Waste 6 Pallet ## Packages Weight of Each Package (lbs.) CAS # UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 4-083 1 Tote 4 AP Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-084 1 Tote 4 AD Red Dye Liquid HT 4-085 1 Tote 4 Blue Dye AD Liquid 4-086 1 Tote 4 Black Dye AD Liquid 4-087 1 Tote 4 Black Dye AD Liquid 4-088 1 Tote 4 Brown Dye AD Liquid 4-089 2 Drums 4 AP Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-090 3 Drums 4 Liquid Dye AD Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-091 2 Over Packs 4 AP Liquid No Skid Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-092 2 Drums 4 Blue Dye AD Dye AD Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-093 3 Drums 4 Dye AD Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-094 3 Drums 4 Dye AD Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-095 3 Drums 4 Aqueous AP Acetate AP Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-096 2 Drums 1 Jug 4 Aqueous AP Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-097 1 Drum 1 Jug 4 Orange Dye AD Dye AD Liquid Not HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 4-098 4 Drums 4 3 Blue Dye 1 Red Dye Liquid HT Waste shipped off site 11/16 & 17 Manifest # 111609 &44032 Building 10 1 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 10-001 N/A 10 KMLP - NF1, KMLP - NF2, KMLP - NF3, (2) 5 gal. Paint FP 100-120 Liquid HT Disposal 10-002 4 Drums 34590-94-8 10 Glycol Ether DPM Liquid Need New Skid 10-003 3 Drums 64-19-7 10 Acetic Acid (1), Flammable Fpipl 120 Liquid HT 13 10-004 4 Drums 1587 40 1547 106-88-7 UN-3022 10 1, 2 Butylene Oxide DOT: 1,2-Butylene Oxide,Stabalized,N.A./UN3022 Liquid HT 1 drum 390 gross,40 tare,350 net. These need new labels 10-005 2 Drums 1336-21-6 10 Ammonium Hydroxide Liquid HT 10-006 3 Drums N/A 10 Glycol Ether DPM Liquid HT 10-007 4 Drums 64-19-7 10 Acetic Acid (3), Flammable (1)Liquid HT 10-008 3 Drums N/A UN-1235 10 Methylamine Aqueous Solution Liquid HT 10-009 2 Drums 75-50-3 10 Surfynol 104 E Surfactant (1), Trimthyamine (1) Not DOT Regulated 13 10-010 3 Drums 1366 40 1326 106-88-7 UN-3022 10 2 Drums Butylene Oxide DOT:1,2-Butylene Oxide, Stabilized,N.A. Liquid HT Placard; Flammable Liquid Needs a new Label. Each drum 392 gross, 42 tare, 350 net Was 10-010 1366 40 1326 UN2023 1 Drum Epichlorohydrin DOT: RQ, Epichlorohydrin N.A. UN2023 Liquid HT Placards; Flammable/Poison 6/ Marine Pollutant Each drum 546 gross, 40 tare, 506 net1310-011 3 Drums 1244 40 1200 75-50-3 1297 10 Trimethylamine 25% DOT: Trimetylamine, Aqueous Solution//3//UN1297//PG II, //8// RQ (Trimethylamine) Liquid HT Placards:Flammable/ Corrosive Replace these. One drum net 396 13 10-012 4 Drums 1680 40 1640 109-55-7 UN-2734 10 3-Dimethylamino Propylamine DOT: Amines, Liquid, Corrosive, Flammable, N.O.S.,(N,N-Dimethyl- 1,3 propanediamine)//8//UN2734//PG II//3 Liquid HT Placard Flammable/ Corrosive 8 Each drum gross 410, Tare 40, Net 370 10-013 4 Drums 1819 1569-01-3 1993 10 Glycol Ether PNP Liquid HT 10-014 4 Drums 1040 1569-01-3 1993 10 Glycol Ether PNP Liquid HT 10-015 3 Drums N/A 1993 10 Flammable Liquid Liquid Not HT 10-016 3 Drums 988 141-43-5 2491 10 Monoethadamine LFG Liquid HT 10-017 2 Drums 817 102-27-2, 103-69-5 10 Ethylmetatoluidine Epichlorohydrin Liquid HT Building 10 2 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 13 10-018 4 Drums 1813 40 1773 75-50-3 1297 10 Trimethylamine 25% DOT: Trimetylamine, Aqueous Solution//3//UN1297//PG II, //8// RQ (Trimethylamine) Liquid HT Each drum 437 gross, 40 tare, 397 net 13 10-019 4 Drums 1802 40 1762 75-50-3 1297 10 Trimethylamine 25% DOT: Trimetylamine, Aqueous Solution//3//UN1297//PG II, //8// RQ (Trimethylamine) Liquid HT Each drum 437 gross, 40 tare, 397 net 13 10-020 3 Drums 1364 1366 40 1326 75-50-3 1297 10 Trimethylamine 25% DOT: Trimetylamine, Aqueous Solution//3//UN1297//PG II, //8// RQ (Trimethylamine) Liquid HT Each drum 437 gross, 40 tare, 397 net Waste 10-021 4 Drums 2150 40 2110 19249-34-4 2924 10 Emery 5704 N,N-Bisacetoxyethylaniline DOT:Flammable Liquid,Corrosive,N.O.S., (Acetic Acid) UN2924 Liquid HT Placards: Flammable Liquid 3, Corrosive 8 Waste to PSC 3/16/10 10-022 2 Drums 274 40 234 107-10-8 2684 PGIII 10 1 drum 3-(Diethylamino) Propylamine DOT: Diethylaminoproplyamine,N.A.,U N2684 PG III //3// Liquid HT Needs label & Placards Placard; Combustible Liquid One drum 376 gross, 24 tare, 352 net 10-022 67-64-1 1090 PGII 1 drum Acetone ACS Grade DOT: Acetone,3,UN1090,PG II 1 drum, 390 gross,40 tare,350 net 10-023 2 Drums 1384, 1715 10 Sodium Hybposulfite (1), Acidic Anhydride (1) - Solid? Liquid HT 10-024 3 Drums 741 109-55-7 2734 10 Epichorohydrim Dimethylaminopropylamin Liquid HT 13 10-025 2 Drums 1009 40 969 27059-08-1 2920 10 3 Bis (Acetoxyethyl) Aminoacetanilide DOT:Corrosive Liquid,Flammable,N.O.S.,(Acetic Acide, Acetic Anhydride) UN2920 Liquid Not HT Placard: Flammable Liquid 3, Corrosive 8. Drum 485 gross, 23 tare, 462 net. 13 10-026 4 Drums 1421 40 1381 75-50-3 1297 10 3 drums Trimethylamine 25% DOT: Trimetylamine, Aqueous Solution//3//UN1297//PG II, //8// RQ (Trimethylamine) Liquid HT 10-026 100-51-6 3278 PGIII 1 drum Benzyl Alcohol DOT:Toxic Liquid,Organic,N.O.S., 6.1, UN3278 PG III Needs a label or no label Placard;Toxic 6 Building 10 3 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments 13 10-027 4 Drums 1799 40 1759 75-50-3 1297 10 Trimethylamine 25% DOT: Trimetylamine, Aqueous Solution//3//UN1297//PG II, //8// RQ (Trimethylamine) Liquid HT Each drum 437 gross, 40 tare, 397 net Waste 10-028 3 Drums 540 40 500 43057-43-0 2924 PG III 10 Emery 5761 68% Active 3(N,N-Bisacetoxyethyl) Aminobenzanilide DOT: Flammable Liquids, Corrosive,N.O.S.,(Contains Acetic Acid/Acetic Ahhydride), 3,UN2924 PG III (8) Liquid Not HT Placard Flammable 3,/ Corrosive Waste to PSC 3/16/10 10-029 1 Over Pack 2920 10 Acetic Acid Liquid No Skid 10-030 1 Over Pack 2920 10 Acetic Acid Liquid No Skid 10-031 1 Over Pack 2920 10 Acetic Acid Liquid No Skid 10-032 1 Over Pack 2920 10 Acetic Acid Liquid No Skid 10-033 1 Over Pack 2920 10 Acetic Acid Liquid No Skid 10-034 1 Over Pack 2920 10 Acetic Acid Liquid No Skid 10-035 2 Over Packs 1235 10 Monoethylamine Liquid Not HT 10-036 2 Over Packs 1268 10 Petroleum Distilates Liquid Not HT 10-037 2 Over Packs 1268 10 Petroleum Distilates Liquid Not HT 10-038 1 over Pack, 1 Drum 1924-34-4 1268 10 (1) Flammable NF, (1) Emery 5704 N,N-Bisacetoxyethylaniline DOT:Flammable Liquid,Corrosive,N.O.S., (Acetic Acid) UN2924 Liquid HT Emery 5704 Placards: Flammable Liquid 3, Corrosive 8 10-039 1 Drum 1950 10 Open Head Drum w/Aerosoles (spray paint) Cans Not HT 10-040 1 Over Pack 10 Flammable Liquid PH 6 Liquid HT 10-041 4 Drums 1635 1569-01-3 1993 10 Glycol Ether PNP Liquid HT 10-042 1 Over Pack 1135 10 Ethylene Chlorhydrin Liquid Not HT 10-042 3 Drums 10 3 Drums= Hazcat Flammables, Unknown, Class NF, Sample Numbers NF 3-770,3-757,3-766 Liquid Not HT Waste Moved to building 10 from building 3 0n 10/28 Building 10 4 Proposed Cont. # Actual Cont. # Pallet ## Packages Weight of Each Package Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package Chemical State Pallet Type Comments Building 18 1 Proposed Cont. # Actual Cont. #Pallet ## Packages Weight of Each Package (lbs ) Gross Tare Net CAS #UN # & PG Group #BLDG #Description & Type of Package Chemical State Pallet Type Comments 12 12 18-001 (3) 5 Gal. Drums 182 7647 TSRN 14-5 18 Nylanthrene Brill Yellow, 4NGL 200%, Nylanthrene Blue RRL, Red RB N-28 Heel Powder HT Shipped to Jaychem 10/30/09 12 12 18-002 (4) 55 Gal. Drums 177, 28, 27, 150 7647 TSRN 14-5 18 Nylanthrene Rubine A Crude, Intralene Blue, Intralene Yellow, Intracede Red 2G Conc Powder HT Shipped to Jaychem 10/30/09 12 12 18-003 (4) 55 Gal. Drums 165, 49, 46, 53 7647 TSRN 14-5 18 Nylanthrene Direct Brill Green (1), Blue 3BLF (3)Powder HT Shipped to Jaychem 10/30/09 12 12 18-004 (4) 55 Gal. Drums 220, 110, 63, 104 7647 TSRN 14-5 18 Nylanthrene Intralan Yellow, Red RB Poulter, Black RE NFS, Stalacyl Red RB Powder HT Shipped to Jaychem 10/30/09 12 12 18-005 (4) 55 Gal. Drums 170, 275 9004 TSRN 53-9 18 Nylanthrene Brill Yellow CGL, Intrasil Bordeaux 3 BSF, Nylanthrene Brill Blue 3 BLF, Nylon Black G-CKP Powder HT Shipped to Jaychem 10/30/09 12 12 18-006 (4) 55 Gal. Drums 7647 7757 TSRN 14-5 18 Nylanthrene Serilene Red, Sol- Aqua-Fast Red 2 BL, Black 2BN, Serilene Red HWF 85% Liquid HT Shipped to Jaychem 10/30/09 12 12 18-007 4 Drums 3351/05-1 112/34-5 TSRN 05-1 18 Altco Fast Black KR-HPM 200%, Nylanthrene Red B-2 BSA, Nylanthrene Orange A Liquid HT Shipped to Jaychem 10/30/09 12 12 18-008 4 Drums 111-46-6 18 Intrasil Bordeaux 3 BSF Liquid, Intralan Yellow 2 BRL-SM 250%, Intrachrome Black WA ex Conc, Intralan Black RBL 200% 1 Liquid, 3 Powder HT Shipped to Jaychem 10/30/09 12 12 18-009 3 Drums 7732/18-5 18 Intralite Blue L Brill, Nylanthrene Blue RRL, Intrasil Yellow 5R Conc Powder HT Shipped to Jaychem 10/30/09 12 12 18-010 4 Drums 111-46-6 18 Serilene Black G-NB, Nylanthrene Rubine 5 BLF, Orange Y BLH Dry Presscake, Yellow 4 NGLS Liquid, Powder, Solid, Powder HT Shipped to Jaychem 10/30/09 12 12 18-011 4 Drums 105859/97- 0, 68555-86- 2, 6359-95-1 18 Intrasil Black RXNFS 200%, Nylanthrene Orange 3G, Nylanthrene Red 2BN 200%, Stylacyl Yellow RG Powder HT Shipped to Jaychem 10/30/09 12 12 18-012 4 Drums 112-34-5, 7732-18-5 18 Intralan Brown M-BL-Liquid, Bordeaux BRB, Intrasil Red RB- Liquid 50%, Supernylite Blue CMC (2) Liquids, (2) Solids HT Shipped to Jaychem 10/30/09 Building 18 2 Proposed Cont. # Actual Cont. #Pallet ## Packages Weight of Each Package (lbs ) Gross Tare Net CAS #UN # & PG Group #BLDG #Description & Type of Package Chemical State Pallet Type Comments 12 12 18-013 (4) 55 Gal. Drums 7647-14-5, 7757-82-6 18 Intracron Red VS-RBL Crude, Intracron Golden Orange VS- 3G, (2) Superlite Fast Yellow EFC OMP200 Solids HT Shipped to Jaychem 10/30/09 12 12 18-014 (4) 55 Gal. Drums 7647-14-5 18 (3) Intralan Brill Yellow 3GL New Crude, Nylanthrene Blue LGGL Crude HT Shipped to Jaychem 10/30/09 12 12 18-015 2 Drums 9004-53-9, 7757-82-6 18 Stadex #62, Sodium Sulfate Anhydrous Solids HT Shipped to Jaychem 10/30/09 12 12 18-016 4 Drums 9004-53-9 18 Red B-2BSA Diluent Solids HT Shipped to Jaychem 10/30/09 12 12 18-017 4 Drums 497-19-8, 9069-80-1 18 Azdanthrene Jet Black K High Conc, Nydye Navy Blue M 200%, Serilyene Black GL Liquid 100%, Nylanthrene Red C- RBS 200% (1) Liquidm (3) Powder HT Shipped to Jaychem 10/30/09 12 12 18-018 4 Drums 9004-53-9 18 Nylon Fast Black G-BW- OHP220, Nylanthrene Black C- MGF, Nylon Black AS, Nylanthrene Black C-5X- OHP220 Powder HT Shipped to Jaychem 10/30/09 12 12 18-019 4 Drums 18 Kemalan Grey KGL 200%Powder HT Shipped to Jaychem 10/30/09 12 12 18-020 4 Drums 9003 11-6 18 Pluronic F-68 Prill Surfactant Powder HT Shipped to Jaychem 10/30/09 12 12 18-021 4 Drums 1310-66-2, 9004-68-9, 497-19-8 18 Nylanthrene Orange C-3G, Nydye Black EB 200%, Supernylite Blue 3R 200%, Intrasil Brown 2RFL Liquid 100% (3) Powder, (1) Liquid HT Shipped to Jaychem 10/30/09 12 12 18-022 4 Drums 9004-68-9, 7732-18-5 18 Nylanthrene Rubine 2 RFF, Bordeaux 3 BSK Liquid 50%, Yellow ? (tag not legible), ? (1) Liquid, (3) Solids HT Shipped to Jaychem 10/30/09 12 12 18-023 4 Drums 9004-53-9 18 (2) Nylanthrene Rubine 5BFL, Intralan Red S-CA New OHP 220, Sirelene Crimson HWF OHP220 Powder HT Shipped to Jaychem 10/30/09 12 12 18-024 4 Drums 7732-18-5 18 (3) Intrasol Bordeaux 3 BSF Liquid, (1) Drum has no label ?Liquid Shipped to Jaychem 10/30/09 12 12 18-025 4 Drums 6459-96-4, 111-46-6 18 Intrasil Red FTS-Presscake, Yellow RG-Stylacyl, Orange VS 3G, Intrasil Bordeaux 3 BSF Liquid (1) Liquid, (3) Powder HT Shipped to Jaychem 10/30/09 12 12 18-026 (4) 35 Gal. Drums 18 Luvitec K-17 Pulver (Polyvinyl byrrolidon) German Made Powder HT Shipped to Jaychem 10/30/09 Building 18 3 Proposed Cont. # Actual Cont. #Pallet ## Packages Weight of Each Package (lbs ) Gross Tare Net CAS #UN # & PG Group #BLDG #Description & Type of Package Chemical State Pallet Type Comments 12 12 18-027 4 Drums 34590-94-8 18 (2) Luvitec K-17 Pulver, Serilene Black G-NB Liquid (label not legible to read CAS #), Nylanthrene Brill Yellow 4 NGL Liquid 50% (2) Powder, (2) Liquids HT Shipped to Jaychem 10/30/09 12 12 18-028 4 Drums 105859-94-8 18 Intrasperse Red YNB Ex Conc, Red (No label on it), Lt. Blue FFRL (No label on it), Intralan Yellow A-CA OHP220 Powder HT Shipped to Jaychem 10/30/09 12 12 18-029 4 Drums 11111-34-5, 9003 11 - 6 18 (3) BASF Tetronic 1307 Surfactant Pastille, (1) BASF Pluronic F-68 Prill Surfactant Powder HT Shipped to Jaychem 10/30/09 12 12 18-030 4 Drums 9004-53-9, 105859-97-0 18 (2) Nylanthrene Red B-2B 200% X, Intrasil Orange H2GFS Crude, Blue LGEF (No label on it) Powder HT Shipped to Jaychem 10/30/09 12 12 18-031 4 Drums 105859-97- 0, 6428-60- 0, 9004-53- 9, 7647-14-5 18 Serilene Black TLR 200%, Intralite Blue 2GL Crude, Intralan Yellow HL, Nylanthrene Orange A 200% Powder HT Shipped to Jaychem 10/30/09 18-032 (2) 55 Gal. Drums Net 450 800 29 771 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 20 & 14 "Moved to BLDG #3" Waste to PSC 03/16/10 18-034 (3) 50 Gal. Drums Net 450 1513 48 1465 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 13/6/17 "Moved to BLDG #3" Waste to PSC 03/16/10 18-035 (3) 50 Gal. Drums Net 450 1490 30 1460 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 31/23/26 "Moved to BLDG #3" Waste to PSC 03/16/10 18-036 (3) 50 Gal. Drums Net 450 1553 39 1494 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums #9/8/5 "Moved to BLDG #3" Waste to PSC 03/16/10 18-037 (2) 50 Gal. Drums Net 450 1091 42 1049 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 37 & 22 "Moved to BLDG #3" Waste to PSC 03/16/10 18-038 (3) 50 Gal. Drums Net 450 1545 47 1498 106-44-5 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 27/24/25 "Moved to BLDG #3" Waste to PSC 03/16/10 18-039 (3) 50 Gal. Drums Net 450 1176 41 1135 106-44-5 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 32/7/38 "Moved to BLDG #3" Waste to PSC 03/16/10 Building 18 4 Proposed Cont. # Actual Cont. #Pallet ## Packages Weight of Each Package (lbs ) Gross Tare Net CAS #UN # & PG Group #BLDG #Description & Type of Package Chemical State Pallet Type Comments 18-040 (3) 50 Gal. Drums Net 450 1515 53 1462 106-44-5 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 28/34/35 "Moved to BLDG #3" Waste to PSC 03/16/10 10 10 18-041 (4) 55 Gal. Drums Net 123 7732-18-5, 147-14-8, 26264-58-4, 3351-05-1 18 Violet 23 Dispersion N3B, Pigment Blue 15:3 3G-K Disp., Intrasperse Red Violet RM New 90%, Intrazone Fast Blue 5R Crude Powder HT Shipped to Jaychem 10/16/09 10 10 18-042 (4) 55 Gal. Drums Net 123 800972- 5653P 18 (2) Nylanthrene Red B-2B Diluent, (2) Drums (No Labels)Powder HT Shipped to Jaychem 10/16/09 18-044 1 Plastic Tote 731 7732-18-5 18 Anapn Base Fin Presscake Solids Tote Moved to building 3 Week of 11/16/09 18-045 4 Drums 157 7647-14-5 18 Nylanthrene Yellow FLWS Crude Powder HT Moved to building 3 Week of 11/16/09 12 12 18-046 4 Drums Net 170 9084-06-4, 7647-15-5, 7757-14-5 18 (2) Nylanthrene Brill Yellow 4NGL Crude, Intrazone Red G Crude, Intracron Turquoise VS- RP Powder HT Shipped to Jaychem 10/30/09 12 12 18-047 6 Drums Net 40 8061-51-6, 57-50-1, 8061-51-6, 9004-53-9 18 Intrasil Red RB Powder, Intralan Yellow 3 RL, Nylanthrene Rubine C5BL 200%, Intralan Brown BRL, Nylanthrene Rubine 5 BLF, Eicron Golden Orange VS3G Powder HT Shipped to Jaychem 10/30/09 18-048 5 Mixed Drums 68608-26-4, 800972- 6146, 000060-00-4 18 Intranet Navy Blue RLL 400%, (2) 0773 Seriprint Red TB-LS, Nylanthrene Brill Yellow 4 NGL 50% Liquid, (1) Drum (Label not legible to read) (3) Liquids, (2) Powders Moved to building 3 Week of 11/16/09 10 10 18-049 4 Drums Net 204 7647-14-5, 57-50-1 18 Nydye Scarlet GN Crude (55 Gal. Drum), Intralan Yellow 3 RL OMP220 (1) 55 Gal. Drum (2) Small Drums Powder Shipped to Jaychem 10/16/09 10 10 18-050 4 Drums 7647-14-5 18 Nydye Scarlet GN Crude Powder HT Shipped to Jaychem 10/16/09 10 10 18-051 4 Drums 150, 31, 136 1400- 5163P, 3618- 72-2, 8061- 51-6 18 Intralite Red 5-B Extra Conc, Intracid Red 2G 115% (Floxine G), Seriplas Navy HRS, Intrasil Brown 2 RFL Liquid 100% (1) Liquid, (3) Powder HT Shipped to Jaychem 10/16/09 10 10 18-052 6 Drums 12239-34-8 18 Intrasil Navy H-RSN 200%Powder HT Shipped to Jaychem 10/16/09 Building 18 5 Proposed Cont. # Actual Cont. #Pallet ## Packages Weight of Each Package (lbs ) Gross Tare Net CAS #UN # & PG Group #BLDG #Description & Type of Package Chemical State Pallet Type Comments 18-053 6 Drums 9004-53-5, 8061-51-6 18 Intracid Fast Red 3GP, Intracil GAR (Tag not legible), Intrasil Red MW, Intrasil Red 3 BLS, Intrasil Violet FRL 175%, Icron Blue KDC RP Powder HT Moved to building 3 Week of 11/16/09 10 10 18-054 4 Drums 7647-14-5 18 Nydye Scarlet GN Crude Powder - (3) 55 Gal. Drums, (1) 30 Gal. Small Drum HT Shipped to Jaychem 10/16/09 10 10 18-055 4 Drums 9004-53-9, 8061-51-6, 68512-35-6 18 Intracid Red 2G Conc, Stalacyl Red RY, Intrasil Red MW, Intrasil Blue FBLW-X Powder HT Shipped to Jaychem 10/16/09 10 10 18-056 4 Drums 105859-97- 0, 7732-18- 9, 128-95-0 18 Intrasil Blue M-GS, Intrasil Rubine CK-GFL Liquid 50%, (2) Intrasperse Red Violet RH Crude (1) Liquid, (3) Powder HT Shipped to Jaychem 10/16/09 10 10 18-057 4 Drums 438 (Liquid) 7647-14-5, 34590-94-8 18 Intrasil Brown 3R 150%, Nylanthrene Brill Blue 2 RFF Crude, Intrasil Brown 3R, Nylanthrene Brill Yellow 4 NGL Liquid 50% (3) Powder, (1) Liquid HT Shipped to Jaychem 10/16/09 10 10 18-058 4 Drums 8061-51-6 18 Intrasil Navy ABBA, Intrasil Red FTS, Intrasil Brown UN 2 RF2, Intrasil Brown BRL Powder HT Shipped to Jaychem 10/16/09 10 10 18-059 4 Drums 7647-14-5 18 (2) Intralan Bordeaux RLB 200%, Intralan Red S-G, Nylanthrene Blue C-GLF Powder HT Shipped to Jaychem 10/16/09 10 10 18-060 4 Drums 7647-14-5, 3618-72-2, 9004-53-9 18 Nylanthrene Red B-2BSA 200%, Nylanthrene Blue LGGL 200%, Intrasil Black FTF 150%, Nylanthrene Brill Blue 2 RFF Powder HT Shipped to Jaychem 10/16/09 10 10 18-061 4 Drums 8061-51-6 18 Direct Black BN-NB SUPRA, Serilene Navy G-RA, Intralan Yellow 2BRL-SM 250% Powder HT Shipped to Jaychem 10/16/09 Building 18 6 Proposed Cont. # Actual Cont. #Pallet ## Packages Weight of Each Package (lbs ) Gross Tare Net CAS #UN # & PG Group #BLDG #Description & Type of Package Chemical State Pallet Type Comments 10 10 18-061 4 Drums 7732-18-6, 7647-14-5 18 Intrasil Brill Yellow BRY-N Liquid, Intralan Blue K-3GL Crude, Intralan Black RBL Crude, Lithium Hydroxide Monohydrate (Broken Bags) (1) Liquid, (2) Powder, (1) Solid Shipped to Jaychem 10/16/09 18-063 2 Drums Can't Read 18 Supralate WN, Ethylene Glycol (Labels not legible to read)Liquid HT Moved to building 3 Week of 11/16/09 18-064 4 Drums 50-00-0 18 Antimigrant SB-D Solids HT Moved to building 3 Week of 11/16/09 10 10 18-065 4 Drums 7732-18-5, 7647-14-5 18 Cinsperse SDP, Tween 65- Polysorbate G5, Joncryl 91, Intracid Yellow 2G Solids HT Shipped to Jaychem 10/16/09 10 10 18-066 4 Drums 800972- 5102P, 105859-97- 0, 26264-58- 4, 11-46-6 18 Intrasil Black RB-FS 200%, Intrasil Blue M-GS, Intrasil Bordeaux 3BSF, Intrasil Bordeaux 3BSF Liquid (3) Solids, (1) Liquid HT Shipped to Jaychem 10/16/09 18-067 4 Drums 50-28-4 18 DAXAD 31, Bioban DXN, Sorbitol Powder Tech, One unknown corrosive label faded (2) Liquids, (2) Solids HT Moved to building 3 Week of 11/16/09 18-068 4 Drums No CAS #'s 18 Ethal NP 9.5, (2) Tetronic 1307 Surfactant Pastill, Lodex 10 All Non DOT Regulated (1) Liquid, (3) Solids HT Moved to building 3 Week of 11/16/09 18-069 4 Drums 476 No CAS #'s 18 (2) Bioban DXN, Glycerin 99.5% Min USP, Lodex 10 (3) Liquids, (1) Solid HT Moved to building 3 Week of 11/16/09 20 18-070 4 Drums 1888100- 51088 18 (2) Intralan Yellow 3RL Crude, Intralan Yellow 3RL Conc, Sado (3) Liquids, (1) Solid HT Moved to building 3 Week of 11/16/09 20 18-073 4 Drums 7647-14-5 18 (2) Nylanthrene Blue GLF Crude C-Chamber, Phosphoric Acid 85%, One drum unknown-no label Moved to building 3 Week of 11/16/09 10 10 18-078 6 Boxes Total Net 294 8012-95-1, 8061-51-6, 7758-29-4, 800972- 5101P 18 (3) Nylanthrene Yellow 3RL (Can), Intrasil Violet FRL 175% Unfinished, Direct Bordeaux 6B 200%, Intrasil Black EX-SF 300% Unfinished Powder HT Shipped to Jaychem 10/16/09 20 18-089 4 Drums 9004-65-9 18 (1) Red B-2BSA Diluent, (3) Drums have no labels Powder HT Moved to building 3 Week of 11/16/09 Building 18 7 Proposed Cont. # Actual Cont. #Pallet ## Packages Weight of Each Package (lbs ) Gross Tare Net CAS #UN # & PG Group #BLDG #Description & Type of Package Chemical State Pallet Type Comments 20 18-090 (2) Drums, (2) Cardboard Boxes, (2) Plastic Cans No CAS #'s 18 Aquariant Orange O V12 928, Carbon AP PEG 200 08003, Sodium Phosphate CDI Basic, Common Salt, Intrasil Brown 3R 150% Powder HT Moved to building 3 Week of 11/16/09 20 18-091 13 7732-18-5, 80-61-81-8, 60-00-4, 1310-66-2, 9004-53-9, 112-34-5, 7732-18-5, 7757-82-6, 26284-58-4 18 (2) Platic Containers - Intrasil Brill Yellow Bry-N Liquid, (1) 5 Gal Drum - Intrasil Red FTS, (1) 5 Gal. Drum - Nylan Blue B-AR 200%, (1) 7.5 Gal. Drum - Aquarine Orange O, (1) 7.5 Gal Drum - Intralan Bordeaux 3 R Conc, (1) 5 Gal. Pale - Nylan Rubine 5 BLF, (1) 5 Gal. Pale - Nylan Yellow B-Gill Liquid 27%, (1) 5 Gal. Pale - Intrasil Brill Yellow BRY-N Liquid, (1) Small Plastic Bucket - Nylan B Yellow 4NGL 200, (1) Small Plastic Bucket - Intralan Yellow 2BRL, (1) 5 Gal. Pale - Intracron Brown VS-GR, (1) 5 Gal. Drum - Intrasil Orange 2 GR Moved to building 3 Week of 11/16/09 18 18 18-092 1 Tote Net 2200 2399 130 2269 112-34-5 18 Nylanthrene Red GN. Liquid 33%Liquid Good Shipped to Jaychem 02/18/10 20 18-093 1 Tote 897 130 767 111-46-6 18 Serilene Black G-BC Liquid Liquid Good 18 18 18-094 1 Tote 2382 130 2252 17095-24-8 18 Intracron Black VS-B Liquid 50%Liquid Good Shipped to Jaychem 02/18/10 20 18-095 1 Tote 1100 1313 130 1183 111-46-6 18 Serilene Black G-BC Liquid Liquid Good Empty 18-096 1 Tote 1066 130 936 17095-24-8 18 Intracron Black VS-B Liquid 50%Liquid Good Emptied into 18-098 18 18 18-097 1 Tote 1600 2013 130 1883 17095-24-8 18 Intracron Black VS-B Liquid 50%Liquid Good Shipped to Jaychem 02/18/10 20 18-098 1 Tote 1506 130 1376 No CAS #'s 18 No Label - Liquid Pigment Orange/ Light Brown Color Liquid Good 18 18 18-099 1 Tote 2387 130 2257 17095-24-8 18 Intracron Black VS-B Liquid 50%Liquid Good Shipped to Jaychem 02/18/10 18-100 1 Tote 1289 130 1159 112-34-5 18 Nylanthrene Orange 3G Liquid 33%Liquid Good 18-101 1 Drum (Plastic)569 18 Nylanthrene Brill Yellow Liquid Liquid On HT Pallet Building 18 8 Proposed Cont. # Actual Cont. #Pallet ## Packages Weight of Each Package (lbs ) Gross Tare Net CAS #UN # & PG Group #BLDG #Description & Type of Package Chemical State Pallet Type Comments 18 18 18-102 1 Tote 1783 130 1653 11-46-6 18 Intrasil Brown 3R Milled Paste Liquid Good 20 18-103 1 Tote 1596 130 1466 64-19-7 18 Yoracryl Red BS Liquid 200%Liquid Good 18 18 18-104 1 Tote 2212 130 2082 111-46-6 18 Serilene Black G-BC Liquid Liquid Good Shipped to Jaychem 02/18/10 18 18 18-105 1 Tote 1822 130 1692 18 No Label - Black Liquid Liquid Good Shipped to Jaychem 02/18/10 Shipped 18-106 1 Tote 2700 130 2570 11-46-5, 05859-97 18 Intrasil Navy 3RFS Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 Shipped 18-107 1 Tote 2230 130 2100 111-46-6 18 Intrasil Rubine CK-GFL Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 Shipped 18-108 1 Tote 2355 130 2225 111-46-6 18 Serilene Black G-BC Liquid Liquid Good Shipped to Bert Moore 12/09/09 Shipped 18-109 1 Tote 1110 130 980 18 No Label - Blue Liquid Liquid Good Shipped to Bert Moore 12/09/09 Shipped 18-110 1 Tote 1777 130 1647 111-46-6 18 Intrasil Navy H-RS Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 18 18 18-111 1 Tote 2184 130 2054 111-46-6, 105859-97-0 18 Serilene Black G-BC Liquid Liquid Good Shipped to Jaychem 02/18/10 18 18 18-112 1 Tote 2210 130 2080 Not Legible 18 Intracron Black VS-B Liquid 50%Liquid Good Shipped to Jaychem 02/18/10 Shipped 18-113 1 Tote 2879 130 2749 111-46-6 18 Intrasil Navy H-RS Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 Shipped 18-114 1 Tote 2308 130 2178 7732-18-5 18 Intrasil Red RB Liquid 50%Liquid Good Shipped to Bert Moore 12/09/09 18 18 18-115 1 Tote 2092 130 1962 7732-18-5 18 Intrasil Red RB Liquid 50%Liquid Good Shipped to Jaychem 02/18/10 18 18 18-116 1 Tote 2227 130 2097 800972- 5360P, 800972- 5598P 18 Intrasil Brown 2 RFL Liquid 100%Liquid Good Shipped to Jaychem 02/18/10 18 18 18-117 1 Tote 2432 130 2302 111-46-6, 105859-97-0 18 Serilene Black G-BC Liquid Liquid Good Shipped to Jaychem 02/18/10 Shipped 18-118 1 Tote 2806 130 2676 800972- 5360P 18 Intrasil Brown 2 RFL Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 20 18-119 1 Tote 945 130 815 No Label 18 No Label - Violet Color Liquid Liquid Good 18 18 18-120 1 Tote 2480 130 2350 111-46-6, 105859-97-0 18 Intrasil Navy 3RFS Milled Paste Liquid Good Shipped to Jaychem 02/18/10 Shipped 18-121 1 Tote 2825 130 2695 800972- 5360P 18 Intrasil Brown 2 RFL Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 Shipped 18-122 1 Tote 2874 130 2744 11-46-6, 05859-97-0 18 Intrasil Brown 3R Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 18 18 18-123 1 Tote 2399 130 2269 800972- 5360P 18 Intrasil Brown 2 RFL Milled Paste Liquid Good Shipped to Jaychem 02/18/10 Shipped 18-124 1 Tote 2546 130 2416 111-46-6 18 Intrasil Rubine 2 BLS Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 Empty 18-125 1 Tote 1514 130 1384 7732-18-5 18 Intrasil Red RB Liquid 50%Liquid Good Emptied into 18-095/019 Building 18 9 Proposed Cont. # Actual Cont. #Pallet ## Packages Weight of Each Package (lbs ) Gross Tare Net CAS #UN # & PG Group #BLDG #Description & Type of Package Chemical State Pallet Type Comments Shipped 18-126 1 Tote 2664 130 2534 111-46-6 18 Intrasil Rubine 2 BLS Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 Shipped 18-127 1 Tote 2423 130 2293 111-46-5 18 Serilene Black G-BC Liquid Liquid Good Shipped to Bert Moore 12/09/09 18 18 18-128 1 Tote 2431 130 2301 111-46-6, 105859-97-0 18 Serilene Black G-BC Liquid Liquid Good Shipped to Jaychem 02/18/10 Shipped 18-129 1 Tote 2577 130 2447 111-46-6, 105859-97-0 18 Intrasil Orange H2GFS Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 Shipped 18-130 1 Tote 1959 130 1829 111-46-6, 105859-97-0 18 Intrasil Orange H2GFS Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 18 18 18-131 1 Tote 2294 130 2164 No Label 18 No Label - Brown Color Liquid Liquid Good Shipped to Jaychem 02/18/10 Shipped 18-132 1 Tote 1691 130 1561 111-46-6, 105859-97-0 18 Intrasil Rubine 2 BLS Milled Paste Liquid Good Shipped to Bert Moore 12/09/09 18-133 1 Tote 1456 130 1326 Not Legible 18 Label Faded - Can't Read - Red Rubine Liquid Liquid Good Waste 18-134 (3) 50 Gal. Drums Net 450 2915 52 2863 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 18/12/19 "Moved to BLDG #3" Waste tp PSC 3/16/10 Waste 18-135 (3) 50 Gal. Drums Net 450 1300 46 1259 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 10/15/11 "Moved to BLDG #3" Waste tp PSC 3/16/10 Waste 18-136 (3) 50 Gal. Drums Net 450 1488 36 1452 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 33/16/21 "Moved to BLDG #3" Waste tp PSC 3/16/10 Waste 18-137 (3) 50 Gal. Drums Net 450 1520 40 1480 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 36/29/30 "Moved to BLDG #3" Waste tp PSC 3/16/10 Waste 18-138 (2) 50 Gal. Drums Net 450 1064 33 1031 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 2 & 4 "Moved to BLDG #3" Waste tp PSC 3/16/10 Waste 18-139 (2) 50 Gal. Drums Net 450 1263 45 1218 106-44-6 2076 PG II 18 P-Cresol 90% Solution DOT:RQ, Cresol,//6.1//UN2076,PG II Liquid HT Drums # 1 & 3 "Moved to BLDG #3" Waste tp PSC 3/16/10 Load 10 Load 12 Load 13 Load 14 Load 15 Load 16 Load 17 Load 18 Load 19 Load 20 Load 21 Load Color Codes for Master Pallet List Building 3 Waste 1 11/1/2009 SEC Inventory Summary pg 1 of 4 Container #Size Material Location SEC Code 3-551 30df 2-Amino-4-chlorophenol L57 6T TSO 3-333 5df 2-Amino-5,6-dichlorobenzothiozole L57 7T TSO 3-209 55dm 3(N,N-Bis-3-Acetoxyethyl-1) Amino Acetanilide L57 7B TLO 3-1031 10df 35% Hydrogen Peroxide L70 2B OX 3-222 30df 4-Amino-1-Diphenyl amine-4-sulfonic Acid L70 7T CSAO 18-017 55df Acetic Acid L70 7B CLAO 18-018 55df Acetic Acid L70 7B CLAO 18-040 55df Acetic Acid L70 7B CLAO 18-054 55df Acetic Acid L70 7B CLAO 18-502 55df Acetic Acid L70 6B CLAO 18-003 55df Acetic Acid L70 6B CLAO 18-057 55df Acetic Acid L70 6B CLAO 18-055 55df Acetic Acid L70 6B CLAO 5-049 55df Acetic Acid L70 5T CLAO 10-086 55df Acetic Acid L70 5T CLAO 3-020 85df OP Acetic Acid L70 5B CLAO 10-081 85df OP Acetic Acid L70 5B CLAO 22-006 55df Acid L59 6T CLAI 18-501 55df Acid L59 1T CLAI 3-727 55df Acid L59 1T CLAI 3-747 55df Acid L59 0T CLAI 3-829 55df Acid L59 0T CLAI 3-834 30df Acid L59 0T CLAI 10-040 55df Ammonia L76 7T NH 10-020 55df Ammonia L76 5T NH 10-021 55df Ammonia L76 5T NH 10-022 55df Ammonia L76 5T NH 5-078 20df Ammonia L76 2T NH 3-938 55df Ammonia L74 5B NH 18-011 55df Caustic L76 6T AC 8-076 55dm Caustic L76 2T AC 8-077 55dm Caustic L76 2T AC 5-073 55dm Caustic L74 6T AC 3-833 55df Caustic L74 6T AC 3-332 55df Caustic L76 7T AC N-3500 250g Tote Caustic-Filtrate Adjustment L76 7B AC 18-603 250g Tote Corrosive Liquid Basic Organic L76 4T CLBO 3-920 10df Corrosive Liquid Basic Organic L74 6T CLBO 8-066 55df Corrosive Solids Acidic Inorganic L59 6T CSAI 3-1042 55df Corrosive Solids Acidic Inorganic L59 6T CSAI 3-1043 55df Corrosive Solids Acidic Inorganic L59 6T CSAI 3-715 85dm OP Corrosive Solids Basic Inorganic L74 6T SC 5-038 85df OP Cyanoethyl-o-chloroaniline,Acrylonitrile L57 6B TSO 5-036 85df OP Cyanoethyl-o-chloroaniline,Acrylonitrile L57 6B TSO 5-037 85df OP Cyanoethyl-o-chloroaniline,Acrylonitrile L57 5T TSO 5-034 85df OP Cyanoethyl-o-chloroaniline,Acrylonitrile L57 5B TSO 5-035 85df OP Cyanoethyl-o-chloroaniline,Acrylonitrile L57 5B TSO 5-039 85df OP Cyanoethyl-o-chloroaniline,Acrylonitrile L57 7T TSO 5-040 85df OP Cyanoethyl-o-chloroaniline,Acrylonitrile L57 7T TSO 3-1037 55df Debris & PPE with Sodium Hydroxide L76 6T SC Building 3 Waste 2 11/1/2009 SEC Inventory Summary pg 1 of 4 3-1038 55df Debris & PPE with Sodium Hydroxide L76 6T SC 3-1021 55df Lime Solids L74 5B CSBI 3-012 5df Lithium Hydroxide L76 6T SC 3-709 250g Tote Muriatic Acid L59 3B CLAI 5-082 55dm N-Ethyl-N-Toluidine L57 7B TLO 3-933 55df Non-Hazardous Liquid (Pump - WWT)C40 7T AP 3-941 55df Non-Hazardous Liquid (Pump - WWT)C40 7B AP 3-942 55df Non-Hazardous Liquid (Pump - WWT)C40 7B AP 3-943 55df Non-Hazardous Liquid (Pump - WWT)C40 7B AP 3-944 55df Non-Hazardous Liquid (Pump - WWT)C40 7B AP 3-911 55dm Non-Hazardous Liquid (Solidification)C42 7B AD 3-1033 55df Non-Hazardous Liquid (Solidification)C42 7B AD 3-897 55df Non-Hazardous Liquid (Solidification)C42 7B AD NHPU1 55df Non-Hazardous Liquid (Solidification)C42 6B AD NHPU2 55df Non-Hazardous Liquid (Solidification)C42 6B AD 5-074 55df Oil Dry with Gasoline L57 7B TSO 5-075 55df Oil Dry with Gasoline L57 7B TSO 3-916 5df Organic Acid L70 7T CLAO 3-001 85dm OP Organic Acid L70 5T CLAO 3-794 30df Organic Solid L70 6T CSAO 3-797 20f Organic Solid L70 6T CSAO 3-579 30df Organic Solid L70 6T CSAO 8-130 55df Oxalic Acid (1X50# Bag)L70 6T CSAO 9-023 55dm Oxidizer L70 3T OX 18-022 55df Oxidizer L70 3T OX 3-1014 55df Patsoft for Solidification L72.5 2T SL 3-1015 55df Patsoft for Solidification L72.5 2T SL 3-1016 55df Patsoft for Solidification L72.5 2T SL 3-1017 55df Patsoft for Solidification L72.5 2T SL 3-920 55df Patsoft for Solidification L72.5 2B SL 3-921 55df Patsoft for Solidification L72.5 2B SL 3-922 55df Patsoft for Solidification L72.5 2B SL 3-923 55df Patsoft for Solidification L72.5 2B SL 3-726 250g Tote Phosphoric Acid L59 1B CLAI 3-854 55df Sludges/Solids For Solidification L72.5 7T SL 3-836 55df Sludges/Solids For Solidification L72.5 7T SL 8-001 55df Sludges/Solids For Solidification L72.5 7T SL 22-009 55dm Sludges/Solids For Solidification L72.5 7T SL 9-200 55df Sludges/Solids For Solidification L72.5 7B SL 33-400 55df Sludges/Solids For Solidification L72.5 7B SL 3-210 55df Sludges/Solids For Solidification L72.5 7B SL 5-076 55df Sludges/Solids For Solidification L72.5 7B SL 3-832 5df Sludges/Solids For Solidification L72.5 6T SL 3-828 55dm Sludges/Solids For Solidification L72.5 6T SL 3-769 55dm Sludges/Solids For Solidification L72.5 6T SL 3-568 30df Sludges/Solids For Solidification L72.5 6T SL 13-001 55df Sludges/Solids For Solidification L72.5 6B SL 17-001 55df Sludges/Solids For Solidification L72.5 6B SL P-051 55dm Sludges/Solids For Solidification L72.5 6B SL 17-002 55dm Sludges/Solids For Solidification L72.5 6B SL Building 3 Waste 3 11/1/2009 SEC Inventory Summary pg 1 of 4 3-781 55dm Sludges/Solids For Solidification L72.5 5T SL 3-780 55dm Sludges/Solids For Solidification L72.5 5T SL 3-755 55df Sludges/Solids For Solidification L72.5 5T SL 3-756 55df Sludges/Solids For Solidification L72.5 5T SL 3-762 55dm Sludges/Solids For Solidification L72.5 5B HH 3-763 55dm Sludges/Solids For Solidification L72.5 5B HH 3-764 55dm Sludges/Solids For Solidification L72.5 5B HH 3-765 55dm Sludges/Solids For Solidification L72.5 5B HH 10-083 85dm OP Sludges/Solids For Solidification L72.5 4T HH 10-085 85dm OP Sludges/Solids For Solidification L72.5 4T HH 10-082 85dm OP Sludges/Solids For Solidification L72.5 4B HH 10-084 85dm OP Sludges/Solids For Solidification L72.5 4B HH 3-896 5df Sludges/Solids For Solidification L72.5 4B HH 3-946 55dm Sludges/Solids For Solidification L72.5 3T SL 3-932 55df Sludges/Solids For Solidification L72.5 3T SL 3-935 55df Sludges/Solids For Solidification L72.5 3T SL 3-936 55df Sludges/Solids For Solidification L72.5 3T SL 3-732 55df Sludges/Solids For Solidification L72.5 3B HS 3-733 55df Sludges/Solids For Solidification L72.5 3B HS 3-734 55df Sludges/Solids For Solidification L72.5 3B HS 3-735 55df Sludges/Solids For Solidification L72.5 3B HS 3-570 55df Sludges/Solids For Solidification L72.5 1B SL 3-945 55df Sludges/Solids For Solidification L72.5 1B SL 3-103 55df Sludges/Solids For Solidification L72.5 1B SL X 5df Soda Ash L76 2T SC 3-1036 250g Tote Sodium Hydroxide L76 6B AC 3-1035 250g Tote Sodium Hydroxide L76 5B AC 18-600 250g Tote Sodium Hydroxide L76 4B AC 18-601 250g Tote Sodium Hydroxide L76 3B AC 3-1039 250g Tote Sodium Hydroxide L74 7T AC 3-1040 250g Tote Sodium Hydroxide L74 7B AC 3-722 250g Tote Sodium Hydroxide L74 6B AC 5-004 250g Tote Sodium Hydroxide (Product)L76 3T AC 5-007 250g Tote Sodium Hydroxide (Product)L76 2B AC 3-1034 250g Tote Sodium Hydroxide Liquid L76 1T AC 5-053 250g Tote Sodium Hydroxide Liquid L76 1B AC 3-748 55df Sodium Hypochlorite (Weak)L70 3B OX 3-749 55df Sodium Hypochlorite (Weak)L70 3B OX 3-750 55df Sodium Hypochlorite (Weak)L70 3B OX 3-751 55df Sodium Hypochlorite (Weak)L70 3B OX 9-021 55df Sodium Hypochlorite (Weak)L70 3T OX 5-041 5df Sodium Nitrite L70 3T OX 3-B07 5df Sodium Nitrite L70 3T OX 18-506 30df Sodium Perborate L70 3T Corr/OX 3-1041 5df Spill Pads with Sulfuric Acid L59 7T CSAI 9-032 30df Sulfamic Acid L59 7T CSAI 3-788 330g Tote Sulfuric Acid L57 2B CLAI 3-1044 5df Sulfuric Acid L59 7T CLAI Building 3 Waste 4 11/1/2009 SEC Inventory Summary pg 1 of 4 3-017 85df OP Sulfuric Acid L59 7T CLAI 9-001 250g Tote Sulfuric Acid L59 7B CLAI 3-1045 250g Tote Sulfuric Acid L59 6B CLAI 3-1048 250g Tote Sulfuric Acid L59 5T CLAI 3-1049 250g Tote Sulfuric Acid L59 5B CLAI 3-1046 250g Tote Sulfuric Acid L59 4T CLAI 3-1047 250g Tote Sulfuric Acid L59 4B CLAI 3-729 250g Tote Sulfuric Acid L59 2B CLAI 3-376 330g Tote Sulfuric Acid L59 0B CLAI 3-716 30df Sulfuric Acid with Lime L59 1T CLAI/CSAI P-070 10f Tannic Acid L70 7T CSAO 5-027 20f Tannic Acid L70 7T CSAO 3-929 20f Tannic Acid L70 7T CSAO 5-213 20f Tannic Acid L70 7T CSAO 3-928 5df Tannic Acid L70 7T CSAO 5-210 10# Box Tannic Acid L70 7T CSAO 3-218 30df Tannic Acid L70 7T CSAO 3-981 5f Tannic Acid L70 6T CSAO 3-035 55df OP Toxic Solid L57 7T TSO 3-795 30df Toxic Solid L57 6T TSO 5-083 55df Triethanolamine L76 2T FL Corr Building 33 1 Proposed Container Actual Container Pallet ## Packages Weight of Each Package Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package 33-001 1 Orange Dye Bin 537 255 282 N.A.33 Press cake with trash mixed in 33-002 1 Orange Dye Bin 1455 255 1200 N.A.33 Floor sweepings 33-003 1 Orange Dye Bin 1255 255 1000 N.A.33 Floor Sweepings 33-004 1 Orange Dye Bin 552 255 297 Proprietary N.A.33 Press Cake Yellow 33-005 1 Orange Dye Bin 600 255 345 Proprietary N.A.33 Press Cake Gray 33-006 1 Orange Dye Bin 415 255 160 Proprietary N.A.33 Press Cake Gray 33-007 1 Orange Dye Bin 1434 255 1179 N.A.33 Possible press cake ? 33-008 1 Orange Dye Bin 798 255 543 N.A.33 Floor Sweepings 33-009 1 Orange Dye Bin 2666 255 2411 N.A.33 Press cake with white water Possible waste 20 33-010 1 Orange Dye Bin 1307 255 1052 Proprietary N.A.33 Press Cake Purple 33-011 1 Orange Dye Bin 1150 255 895 Proprietary N.A.33 Press Cake Purple 33-012 1 Orange Dye Bin 940 255 685 Proprietary N.A.33 Press Cake Purple 33-013 1 Orange Dye Bin 807 255 552 Proprietary N.A.33 Press Cake Purple 33-014 1 Orange Dye Bin 612 255 357 Proprietary N.A.33 Press Cake Red/Yellow 33-015 1 Orange Dye Bin 999 255 744 Proprietary N.A.33 Press Cake Red 33-016 1 Orange Dye Bin 1458 255 1203 Proprietary N.A.33 Press Cake Red 33-017 1 Orange Dye Bin 345 255 90 Proprietary N.A.33 Purple dye, 33-018 1 Orange Dye Bin 295 255 40 N.A.33 Garbage Building 33 2 Proposed Container Actual Container Pallet ## Packages Weight of Each Package Gross Tare Net CAS #UN # & PG Group # BLDG #Description & Type of Package 33-019 1 Orange Dye Bin 753 255 498 Proprietary N.A.33 Press Cake Purple 33-020 1 Orange Dye Bin 1343 255 1088 Proprietary N.A.33 Press Cake Purple 20 33-021 1 Orange Dye Bin 1205 255 950 Proprietary N.A.33 Press Cake Purple 33-022 1 Orange Dye Bin 630 255 375 Proprietary N.A.33 Press Cake Purple 33-023 1 Orange Dye Bin 1408 255 1153 Proprietary N.A.33 Press Cake Purple Appendix B Building Condition Survey Request for Proposal Pg. 1 of 3 REQUEST FOR PROPOSALS FOR ASSESSMENT OF BUILDING MATERIALS AND CONDITION OF SITE STRUCTURES AT THE FORMER CROMPTON AND KNOWLES SITE LOWELL, NC INTRODUCTION Geosyntec is requesting proposals from at least three contractors to perform building materials assessment services (asbestos, lead-based paint, and other hazardous building materials [HBM]), and physical condition assessment at the Former Crompton and Knowles Site located at 1602 North Main Street in Lowell, NC (referred to herein as the Site). The Site is a former textile dye manufacturing facility with an area of 17 acres and has been abandoned since 2004. Currently, 25 buildings remain, along with five large wastewater treatment tanks, associated piping, several smaller outbuildings, and other site infrastructure (e.g., parking lots, electrical infrastructure, lighting, etc.). This work will be performed under subcontract to Geosyntec, pursuant to our prime contract with the North Carolina Department of Environmental Quality (NCDEQ) to perform environmental assessment and remediation services at the Site, and under access granted by the current property owner, Lowell Investments I LLC. The scope of work below describes the services to be performed and general Site information to support the assessment of present buildings and structures at the Site. The field activities include: (i) an asbestos- containing materials (ACM) survey; (ii) a survey and inventory of other potentially HBM; (iii) a lead-based paint survey, and (iv) a physical conditions assessment of Site buildings. The objectives of these activities are to: identify the presence and locations of ACM/HBM/lead-based paint; evaluate hazards associated with potential demolition of Site structures; characterize building materials for potential landfill acceptance and evaluate suitability for use as fill on-Site; and to assess the structural condition and stability of Site structures to evaluate whether they pose potential hazards to Site workers or future occupants. A mandatory pre-bid site visit is planned for March 1st at 9:00 AM to allow contractors to view the Site. Please indicate planned attendance to David Hanley via email at DHanley@Geosyntec.com or phone at (704) 227-0846. Proposals should contain, at a minimum, a description of the proposed work, schedule, and cost. Proposals should be submitted to David Hanley via email on or before March 7th. Selection of a contractor is expected to take place by March 12th, and work will commence in early in mid to late March. SCOPE OF WORK The Subcontractor shall provide all equipment, personnel, and materials necessary to perform the assessment of Site structures. The anticipated area to be evaluated consists of 25 buildings, five large wastewater treatment tanks and associated piping, any remaining small outbuildings, and other remaining infrastructure on the site property which may contain ACM/HBM/lead-based paint. The total area of the 25 remaining major buildings is approximately 79,000 square feet (which does not include several other small outbuildings). An annotated brochure associated with a previous estate sale for the Site which includes a Site plan showing the locations of Site buildings and a table with building descriptions and approximate dimensions are provided as Attachment 1. The Scope of work includes the following items: • The Subcontractor shall conduct an ACM inspection by State of North Carolina accredited asbestos building inspectors. Surveys should include visual assessment of the interior and exterior of each Pg. 2 of 3 structure to identify materials suspected of containing asbestos (suspect ACM) such as thermal system insulation, surfacing materials, and miscellaneous materials. Suspect materials should be physically assessed for friability and evidence of damage or degradation. Samples of suspect ACM are to be collected for laboratory analysis. Bulk sample collection will be conducted in general accordance with the sampling protocols outlined in USEPA 40 CFR 763.86. Roofing/exterior samples will be collected during the survey. The rental of lift equipment may be necessary to gain access to the roof and elevated structures and should be include in fee proposal. Sample collection will result in some isolated damage to building materials; however, attempts should be made to limit such damage to the extent necessary for sample collection. Inspector will not be responsible for repair or touch-up of sample locations. Sampling will not include suspect materials which cannot be safely accessed. A laboratory accredited by the National Voluntary Laboratory Accreditation Program (NVLAP), shall analyze bulk material samples by visual estimation using Polarized Light Microscopy (PLM). If PLM results merit verification by point count analysis, Inspector will contact the client for authorization if additional costs will be incurred. • The Subcontractor shall conduct a HBM survey that consists of an inventory of potential polychlorinated biphenyl (PCB)-containing (e.g., transformers, capacitors, light ballasts), mercury- containing (e.g., fluorescent and high intensity lighting, thermostats, switches/meters/relays), chlorofluorocarbon-containing (e.g., fire extinguishers, HVAC equipment, coolers/refrigerators, and lead-containing materials (e.g., piping, flashing, circuit boards, batteries) based on visible observation of the Site. Subcontractor will visually assess the interior and exterior spaces of the building and perform a limited lead-containing paint (LCP) survey that will consist of the collection of paint chip samples from various painted components. Representative building component surfaces that may be sampled include, but are not necessarily limited to, woodwork/molding, door jambs and trim, window sills and sashes, cabinets, walls, ceilings, counter tops, stair railings, floors, radiators, balcony railings, and baseboards. The paint chip samples will be submitted to a laboratory participating in the Environmental Lead Laboratory Accreditation Program (ELLAP) for total lead content analysis. Limited LCP sampling should result in damage to no more than a small area (approximately 2 square inches) of the painted surface at each sample location. Inspector will not be responsible for re-painting sampled surfaces. • The limited physical condition assessment will be conducted with the purpose of identifying potentially-unsafe conditions that may require consideration during subsequent Site activities. This assessment should be limited to evaluating each building in its current state for whether it can be safely occupied by Site workers (for assessment activities which may include, but not be limited to drilling, floor slab removal, soil excavation, etc.) or future occupants. Field observation of each building shall be performed by a North Carolina Professional Engineer and include a high level visual observation and be non-destructive in nature. Basic hand tools should be used to poke and pry to see structure behind hidden architectural cladding only. Photos to depict the conditions along with a site plan should be included in the report. The report should present results of evaluations related to the structural stability of the building and a recommendation for potential repairs/demolition to take place prior to environmental assessment activities. If major renovations Pg. 3 of 3 are necessary in order to occupy the building, an order of magnitude should be given for the required renovations. The Subcontractor shall produce a report detailing the procedures and results of these activities. The report shall include annotated maps showing the conditions of Site buildings and the extent of ACM-, HBM-, and lead-based paint impacted areas, an inventory of surveyed materials/samples collected, photographic documentation of sampling, and relevant laboratory reports. General Requirements: • Site related work area shall be cleaned to Geosyntec’s satisfaction prior to site departure. • Work is anticipated to be conducted between the hours of 7:00 AM and 7:00 PM during weekdays. • Geosyntec is not responsible for increases to the project estimated duration or for project cancellation due to weather. • Subcontractor is responsible for the Health and Safety of its employees, as required by OSHA. The minimum personal protection required for the work to be performed is anticipated to be level “D” which may include at a minimum: safety glasses, hard hats, safety shoes, hearing protection, and high-visibility clothing (vests, or similar). The Subcontractor shall be responsible for determining the level of protection for its staff and for providing all required personal protective equipment. The Subcontractor is responsible for implementing a Health and Safety Plan in accordance with 29 CFR Part 1910.120. Subcontractor personnel will also be made aware of requirements set forth in the Site-Specific Job Hazard Analysis developed by Geosyntec. Geosyntec will brief site personnel at a tail gate meeting to be held prior to initiating work. Table of Contents Topic Page Overview ……………... 3 Plant Layout ……………...4 Build List ……………...5 Tanks ……………...6 Pumps ……………...7 Filter Presses ……………...8 Boilers ……………...8 Dryers ……………...9 Grinders/Mills ……………...11 Blenders ……………...11 Air Compressors ……………...12 Other Equipment ……………...12 Office Layout ……………...13 Lab Layout ……………...14 Blender Bldg (#4) ……………...15 Process Bldg (#5) ……………...16 Process Bldg (#9) ……………...17 Secondary Spray Dryer (Bldg #14)……………...18 Primary Spray Dryer (Bldg # 33) ……………...19 Selected Drawings ……………...20 Waste Water Treatment Plant ……………... 23 Overview Date 6/21/05 Contacts Bankruptcy Trustee: P. Wayne Sigmon Gray, Layton, Kersh, Solomon, Sigmon, Furr & Smith 516 South New Hope Road Gastonia, NC 28053 Financial Manager for Trustee: Edward P. Bowers, C.P.A., C.I.R.A. Middleswarth, Bowers & Co., LLP 219-A Wilmot Drive Gastonia, NC 28054 Phone: 704-867-2394 Fax: 704-867-5303 Site Coordinator for Trustee: William J. Shortreed Advanced Resource Technologies, Inc. Columbia Office: 42 Running Fox Road Columbia, SC 29223 Phone: 803-462-9260 Fax: 803-865-6049 Cell: 803-518-7344 Facility Location/Description: The total site area is approximately 38 acres, of which approximately 10 acres is within the fenced boundaries of the facility operating area. The operating area is mostly paved and consists of 19 buildings, equipment and a state-of-the-art, computerized waste water treatment plant currently permitted for 400M gallons/day discharge. All offered equipment was operational up to the time the facility shut down in October, 2004. The Estate will entertain bids for this equipment. The bidder can offer individually or in combination for the equipment, building(s), property and/or parcels of property. Buildings Building Number Building Description Length (ft) Width (ft) Height (ft) Total Area (sq. ft) 1 Administration Offices 80 45 13 3,600 2 Quality Assurance Laboratories 100 50 13 5,000 3 Shipping/Receiving/Warehouse 150 100 17 15,0004 Grinding/Blending/Milling 80 50 27 4,000 5 Synthesis/Filterpress/Ovens 110 100 25 11,000 6 Boiler Room 50 45 17 2,250 7 Locker Room/Lunch Room 50 45 11 2,250 8 Warehouse 50 50 22 2,500 9 Synthesis/Liquid Packout 80 60 25 4,800 10 Warehouse/Whiteners 50 50 23 2,500 11 Training Room 65 40 13 2,600 12 Filterpress 50 60 23 3,000 13 Maintenance 100 70 12 7,00014 Secondary Spray Dryer/Sandmills 55 45 39 2,475 15 Laboratory Flammable Storage 12 12 12 144 16 Bulk Receiving 12 12 10 144 17 Waste Treatment Laboratory 25 25 15 625 18 Warehouse 90 75 19 6,75021 Forklift Shop 30 30 16 90022 Clarifier Pump House 25 15 12 375 24 Sludge Filterpress (Condo)35 25 19 875 26 Flammable Storage 60 15 12 900 27 Security Office 10 10 10 100 28 Waste Treatment Control Room 42 16 15 672 29 Neutralization Tank Pump House 24 15 15 360 30 Lift Station Switch Gear 20 14 15 280 31 Sludge Thickener Pump House 20 20 15 400 32 Upflow Filter pump House 15 12 11 180 33 Primary Spray Dryer 30 38 94 Multi Level 34 Waste Treatment Equipment Room 36 35 14 1,260 35 Engineering Trailer 60 24 14 1,440 Manufacturing Tank Information Building Number Tank Number Tank Dia (ft) Volume (Gal)Tank Material Agitator Type Drive HP 5 1 10 5800 FRP Gate 2 spd 15/7.5 5 2 6 1250 FRP Bar 2 spd 5/2.5 5 2A 4 375 FRP Prop Lightning .87 5 2B 4 375 SS Prop Lightning .87 5 2C 4 375 SS Prop Lightning .87 5 3 8 3000 FRP Bar 2 spd 10/5 5 4 8 3000 FRP Gate 2 spd 10/5 5 5 8 3000 FRP Gate 2 spd 10/5 5 5A 6 1250 FRP Pitched Bar 2 spd 5/2.5 5 5B 6 1250 FRP Pitched Bar 2 spd 5/2.5 5 5C 4 375 FRP Prop Lightning .87 5 5D 4 375 FRP Prop Lightning .87 5 6 10 5800 FRP Gate 2 spd 15/7.5 5 7 10 5800 FRP Gate 2 spd 15/7.5 5 8 10 5800 FRP Gate 2 spd 15/7.5 5 9 10 5800 FRP Gate 2 spd 15/7.5 5 10 10 5800 FRP Gate 2 spd 15/7.5 5 11 8 3000 FRP Gate 2 spd 10/5 5 12 10 5800 FRP Gate 2 spd 15/7.5 5 13 8 3000 FRP Bar 2 spd 10/5 5 15 8 3000 SS Blade 100 5 16 500 SS Pitched Blade 2 spd 5/2.5 8 1 5 500 SS Prop Lightning .87 9 1 8 3000 SS Gate V/S 7.5 9 2 8 3000 SS Paddle Wheel 2 spd 60/27 9 3 8 3000 FRP Bar 10 9 4 8 3000 FRP Gate 5 9 5 1000 Glass Bar 2 spd 5/2.5 9 6 1000 SS Pitched Paddle 7.5 9 7 8 3000 BRICK Gate 2 spd 10/5 9 8 8 3000 FRP Gate 2 spd 10/5 9 9 8 3000 FRP Gate 10 9 10 6 1250 FRP Bar 5 9 11 8 3000 FRP Gate 7.5 9 12 8 3000 FRP Bar 5 9 12A 4 375 SS Prop Lightning .87 9 13 10 5800 FRP Gate 2 spd 15/7.5 9 14 8 3000 FRP Bar 2 spd 10/5 9 15 10 5800 FRP Gate 2 spd 15/7.5 9 16 10 5800 FRP Gate 2 spd 15/7.5 9 17 10 5800 SS Pitched Paddle 10 9 18 6 1250 FRP Bar 2 spd 5/2.5 9 19 10 5800 FRP Gate 2 spd 1517.5 9 19A 4 375 SS Prop Lightning .87 10 1 12 8500 SS Prop 63 rpm 7.5 10 2 12 8500 SS Prop 63 rpm 7.5 14 1 8 3000 SS Bar V/S 15 14 2 8 3000 FRP Bar V/S 15 14 3 8 3000 SS Bar V/S 25 14 4 8 3000 SS Bar V/S 15 14 5 7' x 7' Sq. 3000 SS Bar 7.5 14 6 7' x 7' Sq. 3000 SS Bar 7.5 14 Cowles 8 3000 SS Blade 2 spd 100/50 Manufacturing Pump Information Building Number Use Brand Model HP Type GPM/Head 5 Caustic B5 Worthington 1 Centrifugal 5 Caustic B9 Worthington 1 Centrifugal 5 Caustic Scrubber LaBour A50-LV 7.5 Centrifugal 5 Caustic Scrubber LaBour A50-LV 7.5 Centrifugal 5 General Moyno 1 L6 2 Prog. Cavity Variable5 General Moyno 1L6 2 Prog. Cavity Variable5 General Moyno 1L6 2 Prog. Cavity Variable5 General Moyno 1L6 2 Prog. Cavity Variable5 General Moyno 1L6 2 Prog. Cavity Variable5 General LaBour A05-LVA 5 Centrifugal 90/60 5 General LaBour A20-LVA 10 Centrifugal 200/92 5 General LaBour A20-LVA 10 Centrifugal 200/92 5 General LaBour A20-LVA 10 Centrifugal 200/92 5 General LaBour A20-LVA 10 Centrifugal 200/92 5 General LaBour A20-LVA 10 Centrifugal 200/92 5 General Worthington CNG-104 10 Centrifugal 130/115 5 General Worthington CNG-104 10 Centrifugal 130/115 5 General Worthington CNG-104 10 Centrifugal 130/115 5 General Worthington CNG-104 10 Centrifugal 130/115 5 General Versamatic E2KS5T5T9 Air Diaphragm Variable5 HCI B5 March TE-7K-MD 3/4 Mag Drive 5 HCI B9 March TE-7K-MD 3/4 Mag Drive 5 NSA T-14 Wilden M2 Air Diaphragm Variable5 NSA T-16 Wilden M2 Air Diaphragm Variable9 Amine Scrubber LaBour AA8-LV HB 3 Centrifugal 5 Amine Scrubber LaBour AA8-LV HB 3 Centrifugal 5 Amine Tank Wilden M2 Air Diaphragm Variable5 Caustic Scrubber LaBour A50-LV 7.5 Centrifugal 5 Caustic Scrubber LaBour A50-LV 7.5 Centrifugal 5 General LaBour DZT-14 10 Centrifugal 50/106 5 General Moyno 1L6 2 Prog. Cavity Variable5 General Moyno 1L6 2 Prog. Cavity Variable5 General Moyno 1L6 2 Prog. Cavity Variable5 General Moyno 1L6 2 Prog. Cavity Variable5 General LaBour A05-LVA 5 Centrifugal 90/60 5 General LaBour A20-LVA 10 Centrifugal 200/92 5 General LaBour A20-LVA 10 Centrifugal 200/92 5 General Worthington CNG-104 10 Centrifugal 130/115 5 General Worthington CNG-104 10 Centrifugal 130/115 5 General Versamatic El KA5T5T9 Air Diaphragm Variable5 General Versamatic E2KS5T5T9 Air Diaphragm Variable5 General Versamatic E2KS5T5T9 Air Diaphragm Variable5 General Versamatic E2KS5T5T9 Air Diaphragm Variable5 Liquid Packout Moyno 1L6 2 Prog. Cavity Variable5 Press 7 Moyno 2L10 10 Prog. Cavity Variable5 T-5 Wilden M8 Air Diaphragm Variable5 T-6 Wilden M2 Air Diaphragm Variable14 Liquid Packout EMBA Air Diaphragm Variable14 Sandmill Moyno 2L6 Prog. Cavity Variable14 Sandmill Moyno 2L6 Prog. Cavity Variable14 Sandmill Moyno 2L6 Prog. Cavity Variable14 Sandmill Moyno 2L6 Prog. Cavity Variable14 Sandmill Moyno 2L6 Prog. Cavity Variable14 Spray Dryer Moyno 2L4 3/4 Prog. Cavity Variable14 Transfer Moyno 2L6 Prog. Cavity Variable14 Transfer Moyno 2L6 Prog. Cavity Variable14 Transfer Moyno 2L6 Prog. Cavity Variable14 Transfer Widen M8 Air Diaphragm Variable Filterpress Information Building Number Filterpress Number Brand Type Plate Size (in)Number of Plates Capacity (ft3) 5 1 Shriver Plate & Frame 42 42 60 5 2 Shriver Plate & Frame 42 42 60 5 3 Shriver Plate & Frame 42 40 58 5 4 Shriver Plate & Frame 42 42 60 5 5 Shriver Plate & Frame 42 48 70 5 6 Independent Plate & Frame 42 58 84 5 7 Shriver Plate & Frame 42 58 84 5 8 Shriver Plate & Frame 42 58 84 5 9 Shriver Chamber 42 60 87 5 10 Independent Chamber 42 54 78 12 1 Shriver Chamber 42 56 68 12 2 Homemade Plate & Frame 42 67 96 12 3 Independent Plate & Frame 42 63 90 12 4 Independent Chamber 42 53 65 12 5 Independent Plate & Frame 42 52 74 12 6 Homemade Plate & Frame 36 44 45 12 7 Trent Chamber 48 85 160 24 Sludge Micronics Chamber 48 88 100 Boilers Building Boiler Type Size Fuel 2 Reimers Element 30 KW Electric 6 Cleaver Brooks Firetube 150 HP Nat Gas 6 Superior Firetube 400 HP Nat Gas 6 Continental Firetube 300 HP Nat Gas Dryers Building Dryer Type Capacity Heat Source 14 See Below 33 See Below 5 3-Bay Proctor & Swartz 694,000 lbs/yr Steam 5 8-Bay In-House Design 1,041,000 Ibs/yr Steam 5 2-Bay In-House Design 173,500 lbs/yr Steam 5 3-Bay In-House Design 694,000 lbs/yr Steam Primary Spray Dryer (Bldg 33): Supplier: Niro Atomiser, Ltd. Type: Tall form, cocurrent, nozzle TFD - 0080 - N Operating Data: Feed solids content 30% Residual moisture content 1% Amount of feed 890 kg/hr Water evaporative capacity 620 kg/hr Product capacity 270 kg/hr Inlet air temperature 400°c Outlet air temperature 120°c Power consumption 20 kw Heat consumption 700,000 kcal/hr Fuel consumption (nat gas) 85 Nm3/hr Compressed air for instruments 4 Nm3/hr Compressed air for bag filter 17Nm3/hr Product temperature 100°c Air rate from single exhaust fan 6,600 kg/hr Mechanical Data: Drying system Co-current Atomization Nozzle (Delavan SDX) Feed system Moyno 4-step pump Via 12.5mm pipe Burner type Maxon type NP 11 5:1 turn down ratio Fuel Natural Gas Material of construction Stainless steel Explosion protection Explosion vents on chamber and bag filter Product discharge From chamber (rotary valve, via sieve, direct to Sales Packages Chamber diameter 3.15 m Bustle diameter 4.5 m Total height(Dryer only) 20.229 m Secondary Spray Dryer (Bldg 14): Type: Bowen AA-6 Atomizing Disk Spray Machine Capacity: 11,500 lb/day Heat Source: Natural Gas Grinders/Mills: Type: Screen Size Mikro 2DH Hammer Mill 0.027 Mikro 2DH Hammer Mill 0.027 CB Redhead 30P Sandmill 45 Mesh CB Redhead 30P Sandmill 45 Mesh CB Redhead 30P Sandmill 45 Mesh CB Redhead 30P Sandmill 45 Mesh CB Redhead 30P Sandmill 45 Mesh CB Redhead 30P Sandmill 45 Mesh Blenders: Size (ft3) Type Drive HP/RPM 200 Ribbon Gear 30/34 40 Double Cone Gear 7.5/21 30 Ribbon Chain 7.5/47 200 Ribbon Dual Chain 10-10/21100 Double Cone Gear 10/ 250 Double Cone Gear 25/7 200 Ribbon Chain 30/26 Air Compressors Building Brand Type Size (HP) Use 2 Speedaire Recip 3 Instrument Air for Lab Equipment 4 Speedaire Recip 5 Blender Brakes 4 Quincy Recip 10 Air Pumps, Dust Collectors 5 Worthington Recip 40 Filterpress Blowdown 5 Worthington Recip 50 Filterpress Blowdown 5 Joy Screw 15 Controls, Bulk Storage, Air Pumps 6 Quincy Recip 3 Superior Boiler 6 Continental Boiler 10 Worthington Screw 75 Filterpress Blowdown B12 12 Gardner Denver Screw 25 Pumps, Controls, Valves B9 13 Ingersol Rand Recip 10 Shop Air 14 Joy Screw 25 Spray Dryer, V/S Controls 21 Twistair Recip 7.5 Forklift Shop 24 Quincy Recip 10 Sludge Press Blowdown 28 Quincy Screw 10 W/T Control Valves Other • 500M gallon/day computer controlled Waste Water Treatment Plant constructed in 2000 • 700 heavy duty plastic bins construction with removable lids sized 4’ x 5’ x 29” high. Bins designed with fork lift slots and stackable. Useable for multiple purposes . . . for small bulk product or parts management. • 100 polyethylene “tote” bins (275-300 gallon) • 370 KW diesel powered generator, designed to maintain the Waste Water Treatment Plant on-line • 55 KW diesel powered generator (Bldg 31) • Sahara Drum Warming Oven, Benco Products, Cleve, OH; Model # CS8C-CS Size-6’ x 6’ x 10’ high; Construction-SS; Max Temp-400F; Heat-Steam to 200 psig. (behind Bldg 5) • 1900 Gallon (5’ diameter x 13’ long) SS jacketed, horizontal dryer with paddle blades and heavy duty gear drive. Appendix C USEPA SESD Procedure for Groundwater Sampling (SESDPROC-301-R3) COPY SESD Operating Procedure Page 2 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 Revision History The top row of this table shows the most recent changes to this controlled document. For previous revision history information, archived versions of this document are maintained by the SESD Document Control Coordinator on the SESD local area network (LAN). History Effective Date SESDPROC-301-R3, Groundwater Sampling, replaces SESDPROC-301-R2. General: Corrected any typographical, grammatical and/or editorial errors. Title Page: Changed author from Donald Hunter to Jonathan Vail. Changed Enforcement and Investigations Branch Chief from Archie Lee to Danny France. Revision History: Changes were made to reflect the current practice of only including the most recent changes in the revision history. Section 2.3: Item 4 was revised to reflect practice of using individual single-use preservative vials instead of preservatives prepared by ASB. March 6, 2013 SESDPROC-301-R2, Groundwater Sampling, replaces SESDPROC-301-R1. October 28, 2011 SESDPROC-301-R1, Groundwater Sampling, replaces SESDPROC-301-R0. November 1, 2007 SESDPROC-301-R0, Groundwater Sampling, Original Issue February 05, 2007 COPY SESD Operating Procedure Page 3 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 TABLE OF CONTENTS 1 General Information ..............................................................................................................6 1.1 Purpose..........................................................................................................................6 1.2 Scope/Application ........................................................................................................6 1.3 Documentation/Verification ........................................................................................6 1.4 References .....................................................................................................................6 1.5 General Precautions.....................................................................................................8 1.5.1 Safety ..................................................................................................................8 1.5.2 Procedural Precautions .....................................................................................8 2 Special Sampling Considerations .......................................................................................10 2.1 Volatile Organic Compounds (VOC) Analysis........................................................10 2.2 Special Precautions for Trace Contaminant Groundwater Sampling ..................10 2.3 Sample Handling and Preservation Requirements .................................................11 2.4 Quality Control ..........................................................................................................12 2.5 Records........................................................................................................................12 3 Groundwater Sampling Methods – Purging .....................................................................13 3.1 General ........................................................................................................................13 3.2 Purging Methods and Strategies...............................................................................13 3.2.1 Traditional Multiple Volume Purge ...............................................................13 3.2.1.1 Purging and Purge Adequacy...............................................................13 3.2.1.1.1 Purge Volume Determination ..............................................13 3.2.1.1.2 Chemical Parameter Stabilization Criteria .........................15 3.2.1.1.3 Purge Adequacy Considerations .........................................16 3.2.2 “Tubing-in-Screened-Interval” Method.........................................................16 3.2.2.1 Purge Criteria .......................................................................................17 3.2.2.1.1 Placement of Pump Tubing or Intake ................................17 3.2.2.1.2 Conditions of Pumping........................................................17 3.2.2.1.3 Stability of Chemical Parameters .......................................17 COPY SESD Operating Procedure Page 4 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 3.3 Equipment Considerations for Purging ...................................................................17 3.3.1 Wells without Plumbing or In-Place Pumps .................................................18 3.3.1.1 Purging with Pumps.............................................................................18 3.3.1.1.1 Peristaltic Pumps ..................................................................18 3.3.1.1.2 Submersible Pumps ..............................................................19 3.3.1.2 Purging with Bailers ............................................................................20 3.3.2 Wells with In-Place Plumbing ........................................................................20 3.3.2.1 Continuously Running Pumps ............................................................20 3.3.2.2 Intermittently or Infrequently Running Pumps ..................................21 3.3.3 Temporary Monitoring Wells .........................................................................21 3.3.3.1 General Considerations .......................................................................21 3.3.3.2 Purging When Water Level Is Within Limit of Suction .....................21 3.3.3.3 Purging When Water Level Is Greater Than Limit of Suction ..................22 3.3.3.4 Considerations for Direct Push Groundwater Sampling ...................22 3.4 Field Care of Purging Equipment ............................................................................22 3.5 Investigation Derived Waste .....................................................................................23 4 Groundwater Sampling Methods – Sampling ...................................................................24 4.1 General ........................................................................................................................24 4.2 Sampling Wells with In-Place Plumbing ................................................................24 4.3 Sampling Wells without Plumbing, Within the Limit of Suction ..........................24 4.3.1 Equipment Available .......................................................................................24 4.3.1.1 Peristaltic Pump, Direct from Pump Head Tubing ............................24 4.3.1.2 Peristaltic Pump/Vacuum Jug .............................................................25 4.3.1.3 RediFlo2® Electric Submersible Pump (with Teflon® Tubing) ................26 4.3.1.4 Bailers….. .............................................................................................26 4.4 Sampling Wells without Plumbing, Exceeding the Limit of Suction ....................26 4.5 Micro-Purge or No-Purge Sampling Procedures ....................................................27 4.5.1 Sampling with Pumps ....................................................................................27 4.5.2 HydraSleevesTM ..............................................................................................27 4.5.3 Passive Diffusion Bags ...................................................................................28 4.5.4 General Considerations for Micro-Purge or No-Purge Sampling ....................... 28 COPY SESD Operating Procedure Page 5 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 4.6 Sample Preservation ..................................................................................................28 4.7 Special Sample Collection Procedures .....................................................................29 4.7.1 Trace Organic Compounds and Metals ........................................................29 4.7.2 Order of Sampling with Respect to Analytes ...............................................29 4.7.3 Filtering ............................................................................................................29 4.8 Specific Sampling Equipment Quality Assurance Techniques ..............................31 4.9 Auxiliary Data Collection ..........................................................................................31 4.9.1 Well Pumping Rate – Bucket/Stop Watch Method .....................................31 COPY SESD Operating Procedure Page 6 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 1 General Information 1.1 Purpose This document describes general and specific procedures, methods and considerations to be used and observed when collecting groundwater samples for field screening or laboratory analysis. 1.2 Scope/Application The procedures contained in this document are to be used by field personnel when collecting and handling groundwater samples in the field. On the occasion that SESD field personnel determine that any of the procedures described are either inappropriate, inadequate or impractical and that another procedure must be used to obtain a groundwater sample, the variant procedure will be documented in the field logbook, along with a description of the circumstances requiring its use. Mention of trade names or commercial products in this operating procedure does not constitute endorsement or recommendation for use. 1.3 Documentation/Verification This procedure was prepared by persons deemed technically competent by SESD management, based on their knowledge, skills and abilities and has been tested in practice and reviewed in print by a subject matter expert. The official copy of this procedure resides on the SESD Local Area Network (LAN). The Document Control Coordinator (DCC) is responsible for ensuring the most recent version of the procedure is placed on the LAN and for maintaining records of review conducted prior to its issuance. 1.4 References Columbia Analytical Services, Lab Science News, Passive Diffusion Devices & Polyethylene Diffusion Bag (PDB) Samplers. International Air Transport Authority (IATA). Dangerous Goods Regulations, Most Recent Version Puls, Robert W., and Michael J. Barcelona. 1989. Filtration of Ground Water Samples for Metals Analysis. Hazardous Waste and Hazardous Materials 6(4), pp.385-393. Puls, Robert W., Don A. Clark, and Bert Bledsoe. 1992. Metals in Ground Water: Sampling Artifacts and Reproducibility. Hazardous Waste and Hazardous Materials 9(2), pp. 149-162. SESD Guidance Document, Design and Installation of Monitoring Wells, SESDGUID- 001, Most Recent Version COPY SESD Operating Procedure Page 7 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 SESD Operating Procedure for Control of Records, SESDPROC-002, Most Recent Version SESD Operating Procedure for Sample and Evidence Management, SESDPROC-005, Most Recent Version SESD Operating Procedure for Logbooks, SESDPROC-010, Most Recent Version SESD Operating Procedure for Field Sampling Quality Control, SESDPROC-011, Most Recent Version SESD Operating Procedure for Field pH Measurement, SESDPROC-100, Most Recent Version SESD Operating Procedure for Field Specific Conductance Measurement, SESDPROC-101, Most Recent Version SESD Operating Procedure for Field Temperature Measurement, SESDPROC-102, Most Recent Version SESD Operating Procedure for Field Turbidity Measurement, SESDPROC-103, Most Recent Version SESD Operating Procedure for Groundwater Level and Well Depth Measurement, SESDPROC-105, Most Recent Version SESD Operating Procedure for Management of Investigation Derived Waste, SESDROC- 202, Most Recent Version SESD Operating Procedure for Pump Operation, SESDPROC-203, Most Recent Version SESD Operating Procedure for Field Equipment Cleaning and Decontamination, SESDPROC-205, Most Recent Version SESD Operating Procedure for Field Equipment Cleaning and Decontamination at the FEC, SESDPROC-206, Most Recent Version SESD Operating Procedure for Potable Water Supply Sampling, SESDPROC-305, Most Recent Version The Interstate Technology & Regulatory Council, Technology Overview of Passive Sampler Technologies, Prepared by The Interstate Technology & Regulatory Council Diffusion Sampler Team, March 2006. United States Environmental Protection Agency (US EPA). 1975. Handbook for Evaluating Water Bacteriological Laboratories. Office of Research and Development (ORD), Municipal Environmental Research Laboratory, Cincinnati, Ohio. COPY SESD Operating Procedure Page 8 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 US EPA. 1977. Sampling for Organic Chemicals and Microorganisms in the Subsurface. EPA-600/2-77/176. US EPA. 1978. Microbiological Methods for Monitoring the Environment, Water and Wastes. ORD, Municipal Environmental Research Laboratory, Cincinnati, Ohio. US EPA. 1981. "Final Regulation Package for Compliance with DOT Regulations in the Shipment of Environmental Laboratory Samples," Memo from David Weitzman, Work Group Chairman, Office of Occupational Health and Safety (PM-273), April 13, 1981. US EPA. 1995. Ground Water Sampling - A Workshop Summary. Proceedings from the Dallas, Texas November 30 – December 2, 1993 Workshop. ORD, Robert S. Kerr Environmental Research Laboratory. EPA/600/R-94/205, January 1995. US EPA. Analytical Support Branch Laboratory Operations and Quality Assurance Manual. Region 4 SESD, Athens, GA, Most Recent Version US EPA. Safety, Health and Environmental Management Program Procedures and Policy Manual. Region 4 SESD, Athens, GA, Most Recent Version 1.5 General Precautions 1.5.1 Safety Proper safety precautions must be observed when collecting groundwater samples. Refer to the SESD Safety, Health and Environmental Management Program (SHEMP) Procedures and Policy Manual and any pertinent site-specific Health and Safety Plans (HASP) for guidelines on safety precautions. These guidelines should be used to complement the judgment of an experienced professional. Address chemicals that pose specific toxicity or safety concerns and follow any other relevant requirements, as appropriate. 1.5.2 Procedural Precautions The following precautions should be considered when collecting groundwater samples. • Special care must be taken not to contaminate samples. This includes storing samples in a secure location to preclude conditions which could alter the properties of the sample. Samples shall be custody sealed during long-term storage or shipment. • Always sample from the anticipated cleanest, i.e., least contaminated location, to the most contaminated location. This minimizes the opportunity for cross-contamination to occur during sampling. • Collected samples must remain in the custody of the sampler or sample custodian until the samples are relinquished to another party. COPY SESD Operating Procedure Page 9 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 • If samples are transported by the sampler, they will remain under his/her custody or be secured until they are relinquished. • Shipped samples shall conform to all U.S. Department of Transportation (DOT) rules of shipment found in Title 49 of the Code of Federal Regulations (49 CFR parts 171 to 179), and/or International Air Transportation Association (IATA) hazardous materials shipping requirements found in the current edition of IATA’s Dangerous Goods Regulations. • Documentation of field sampling is done in a bound logbook. • Chain-of-custody documents shall be filled out and remain with the samples until custody is relinquished. • All shipping documents, such as air bills, bills of lading, etc., shall be retained by the project leader and placed in the project files. COPY SESD Operating Procedure Page 10 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 2 Special Sampling Considerations 2.1 Volatile Organic Compounds (VOC) Analysis Groundwater samples for VOC analysis must be collected in 40 ml glass vials with Teflon® septa. The vial may be either preserved with concentrated hydrochloric acid or they may be unpreserved. Preserved samples have a two-week holding time, whereas unpreserved samples have only a seven-day holding time. In the great majority of cases, the preserved vials are used to take advantage of the extended holding time. In some situations, however, it may be necessary to use the unpreserved vials. For example, if the groundwater has a high amount of dissolved limestone, i.e., is highly calcareous, there will most likely be an effervescent reaction between the hydrochloric acid and the water, producing large numbers of fine bubbles. This will render the sample unacceptable. In this case, unpreserved vials should be used and arrangements must be confirmed with the laboratory to ensure that they can accept the unpreserved vials and meet the shorter sample holding times. The samples should be collected with as little agitation or disturbance as possible. The vial should be filled so that there is a meniscus at the top of the vial and absolutely no bubbles or headspace should be present in the vial after it is capped. After the cap is securely tightened, the vial should be inverted and tapped on the palm of one hand to see if any undetected bubbles are dislodged. If a bubble or bubbles are present, the vial should be topped off using a minimal amount of sample to re-establish the meniscus. Care should be taken not to flush any preservative out of the vial during topping off. If, after topping off and capping the vial, bubbles are still present, a new vial should be obtained and the sample re-collected. Samples for VOC analysis must be collected using either stainless steel or Teflon® equipment, such as: • Bailers must be constructed of stainless steel or Teflon® • RediFlo2® submersible pumps used for sampling should be equipped with Teflon® sample delivery tubing • Peristaltic pump/vacuum jug assemblies should be outfitted with Teflon® tubing from the water column to the transfer cap, which should also be constructed of Teflon® 2.2 Special Precautions for Trace Contaminant Groundwater Sampling • A clean pair of new, non-powdered, disposable gloves will be worn each time a different location is sampled and the gloves should be donned immediately prior to sampling. The gloves should not come in contact with the media being sampled and should be changed any time during sample collection when their cleanliness is compromised. • Sample containers for samples suspected of containing high concentrations of contaminants shall be stored separately. COPY SESD Operating Procedure Page 11 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 • Sample collection activities shall proceed progressively from the least suspected contaminated area to the most suspected contaminated area if sampling devices are to be reused. Samples of waste or highly contaminated media must not be placed in the same ice chest as environmental (i.e., containing low contaminant levels) or background samples. • If possible, one member of the field sampling team should take all the notes and photographs, fill out tags, etc., while the other members collect the samples. • Clean plastic sheeting will be placed on the ground at each sample location to prevent or minimize contaminating sampling equipment by accidental contact with the ground surface. • Samplers must use new, verified certified-clean disposable or non-disposable equipment cleaned according to procedures contained in SESD Operating Procedure for Field Equipment Cleaning and Decontamination (SESDPROC-205) or SESD Operating Procedure for Field Equipment Cleaning and Decontamination at the FEC (SESDPROC-206) for collection of samples for trace metals or organic compound analyses. 2.3 Sample Handling and Preservation Requirements 1. Groundwater samples will typically be collected from the discharge line of a pump or from a bailer, either from the pour stream of an up-turned bailer or from the stream from a bottom-emptying device. Efforts should be made to reduce the flow from either the pump discharge line or the bailer during sample collection to minimize sample agitation. 2. During sample collection, make sure that the pump discharge line or the bailer does not contact the sample container. 3. Place the sample into appropriate, labeled containers. Samples collected for VOC, acidity and alkalinity analysis must not have any headspace. All other sample containers must be filled with an allowance for ullage. 4. All samples requiring preservation must be preserved as soon as practically possible, ideally immediately at the time of sample collection. If preserved VOC vials are used, these will be preserved with concentrated hydrochloric acid by ASB personnel prior to departure for the field investigation. For all other chemical preservatives, SESD will use the appropriate chemical preservative generally stored in an individual single-use vial as described in the SESD Operating Procedure for Field Sampling Quality Control (SESDPROC-011). The adequacy of sample preservation will be checked after the addition of the preservative for all samples except for the samples collected for VOC analysis. If additional preservative is needed, it should be added to achieve adequate preservation. Preservation requirements for groundwater samples are found in the USEPA Region 4 Analytical Support Branch Laboratory Operations and Quality Assurance Manual (ASBLOQAM). COPY SESD Operating Procedure Page 12 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 2.4 Quality Control If possible, a control sample should be collected from a location not affected by the possible contaminants of concern and submitted with the other samples. This control sample should be collected as close to the sampled area as possible and from the same water-bearing formation. Equipment blanks should be collected if equipment is field cleaned and re-used on-site or if necessary to document that low-level contaminants were not introduced by pumps, bailers or other sampling equipment. 2.5 Records Information generated or obtained by SESD personnel will be organized and accounted for in accordance with SESD records management procedures found in SESD Operating Procedure for Control of Records, SESDPROC-002. Field notes, recorded in a bound field logbook, will be generated, as well as chain-of-custody documentation in accordance with SESD Operating Procedure for Logbooks, SESDPROC-010 and SESD Procedure for Sample and Evidence Management, SESDPROC-005. COPY SESD Operating Procedure Page 13 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 3 Groundwater Sampling Methods – Purging 3.1 General Purging is the process of removing stagnant water from a well, immediately prior to sampling, causing its replacement by groundwater from the adjacent formation that is representative of actual aquifer conditions. In order to determine when a well has been adequately purged, field investigators should monitor, at a minimum, the pH, specific conductance and turbidity of the groundwater removed during purging and, in the case of permanent monitoring wells, observe and record the volume of water removed. There are several purging strategies that may be used, depending on specific conditions encountered for given well sampling situations. When a specific well is characterized, based on the field investigators experience and knowledge, as having fairly typical water levels, depths and purge volumes, as determined according to the procedures in Section 3.2.1, below, SESD will normally use the multiple volume purging procedures and equipment described in Sections 3.2.1 and 3.3 of this procedure for purging the well. When the traditional multiple volume purge method is considered and it is determined that excessive quantities of IDW would be generated using this method, it may be appropriate, under very limited and specific circumstances, to use an alternate method that reduces the time and amount of purge water to be removed prior to sampling the well. The field project leader will select the alternate method only after careful consideration of the conditions presented by the well and the impact these conditions have on all aspects of the sampling event (time required to sample, quantities of IDW requiring management, etc.). The alternate purge procedures or sampling strategies available are the “Tubing-in-Screened Interval” method and the MicroPurge or No-Purge methods. These are described and discussed in Sections 3.2.2 and 4.5 of this operating procedure, respectively. 3.2 Purging Methods and Strategies 3.2.1 Traditional Multiple Volume Purge 3.2.1.1 Purging and Purge Adequacy 3.2.1.1.1 Purge Volume Determination Prior to initiating the purge, the amount of water standing in the water column (water inside the well riser and screen) should be determined, if possible. To do this, the diameter of the well should be determined and the water level and total depth of the well should be measured and recorded. Specific methodology for obtaining these measurements is found in SESD Operating Procedure for Groundwater Level and Well Depth Measurement (SESDPROC-105). COPY SESD Operating Procedure Page 14 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 Once this information is obtained, the volume of water to be purged can be determined using one of several methods. One is the equation: V = 0.041 d2h Where: h = depth of water in feet d = diameter of well in inches V = volume of water in gallons Alternatively, the volume of standing water in the well and the volume of three water columns may be determined using a casing volume per foot factor for the appropriate diameter well, similar to that in Table 3.2.1. The water level is subtracted from the total depth, providing the length of the water column. This length is multiplied by the appropriate factor in the Table 3.2.1, corresponding to either the single well volume or the triple well volume, to determine both the single well volume and triple well volumes, in gallons, for the well in question. Other acceptable methods include the use of nomographs or other equations or formulae. TABLE 3.2.1: WELL CASING DIAMETER VOLUME FACTORS Casing Diameter (inches) Gallons/ft, One Water Column Gallons/ft, Three Water Columns 1 0.04 0.12 2 0.16 0.48 3 0.37 1.11 4 0.65 1.98 5 1.02 3.06 6 1.47 4.41 7 1.99 5.97 8 2.61 7.83 9 3.30 9.90 10 4.08 12.24 11 4.93 14.79 12 5.87 17.61 With respect to volume, an adequate purge is normally achieved when three to five well volumes have been removed. The field notes should reflect the single well volume calculations or determinations, according to one of the above methods, and a reference to the appropriate COPY SESD Operating Procedure Page 15 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 multiplication of that volume, i.e., a minimum three well volumes, clearly identified as a purge volume goal. 3.2.1.1.2 Chemical Parameter Stabilization Criteria With respect to the ground water chemistry, an adequate purge is achieved when the pH and specific conductance of the ground water have stabilized and the turbidity has either stabilized or is below 10 Nephelometric Turbidity Units (NTUs) (twice the Primary Drinking Water Standard of 5 NTUs). Although 10 NTUs is normally considered the minimum goal for most ground water sampling objectives, lower turbidity has been shown to be easily achievable in most situations and reasonable attempts should be made to achieve these lower levels. (Note: Because groundwater temperature is subject to rapid changes when collected for parameter measurement, its usefulness is subject to question for the purpose of determining parameter stability. As such, it has been removed from the list of parameters used for stability determination. Even though temperature is not used to determine stability during well purging, it is still advisable to record the sample temperature, along with the other groundwater chemistry parameters during well purging, as it may be needed to interpret other chemical parameter results in some situations.) Stabilization occurs when, for at least three consecutive measurements, the pH remains constant within 0.1 Standard Unit (SU) and specific conductance varies no more than approximately 5 percent. Other parameters, such as dissolved oxygen (DO), may also be used as a purge adequacy parameter. Normal goals for DO are 0.2 mg/L or 10% saturation, whichever is greater. DO measurements must be conducted using either a flow-through cell or an over-topping cell to minimize or reduce any oxygenation of the sample during measurement. Oxidation Reduction Potential (ORP) should not be used as a purge stabilization parameter but may be measured during purging to obtain the measurement of record for ORP for the sampling event. There are no set criteria for establishing how many total sets of measurements are adequate to document stability of parameters. If the calculated purge volume is small, the measurements should be taken frequently enough to provide a sufficient number of measurements to evaluate stability. If the purge volume is large, measurements taken every 15 minutes, for example, may be sufficient. See the SESD Operating Procedures for Field pH Measurement (SESDPROC-100), Field Specific Conductance Measurement (SESDPROC-101), Field Temperature Measurement (SESDPROC-102), Field Turbidity Measurement (SESDPROC-103), Field Measurement of Dissolved Oxygen (SESDPROC-106) and Field Measurement of Oxidation-Reduction Potential (SESDPROC-113) for procedures for conducting these measurements. COPY SESD Operating Procedure Page 16 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 If, after three well volumes have been removed, the chemical parameters have not stabilized according to the above criteria, additional well volumes (up to five well volumes), should be removed. If the parameters have not stabilized within five volumes, it is at the discretion of the project leader whether or not to collect a sample or to continue purging. If, after five well volumes, pH and conductivity have stabilized and the turbidity is still decreasing and approaching an acceptable level, additional purging should be considered to obtain the best sample possible, with respect to turbidity. The conditions of sampling should be noted in the field log. 3.2.1.1.3 Purge Adequacy Considerations In some situations, even with slow purge rates, a well may be pumped or bailed dry (evacuated). In these situations, this generally constitutes an adequate purge and the well can be sampled following sufficient recovery (enough volume to allow filling of all sample containers). It is not necessary that the well be evacuated three times before it is sampled. The pH, specific conductance, temperature, and turbidity should be measured and recorded, during collection of the sample from the recovered volume, as the measurements of record for the sampling event. For wells with slow recovery, attempts should be made to avoid purging them to dryness. This can be accomplished, for example, by slowing the purge rate. As water enters a well that has been purged to dryness, it may cascade down the sand pack and/or the well screen, stripping volatile organic constituents that may be present and/or introducing soil fines into the water column. It is particularly important that wells be sampled as soon as possible after purging. If adequate volume is available immediately upon completion of purging, the well must be sampled immediately. If not, sampling should occur as soon as adequate volume has recovered. If possible, sampling of wells which have a slow recovery should be scheduled so that they can be purged and sampled in the same day, after adequate volume has recovered. Wells of this type should, unless it is unavoidable, not be purged at the end of one day and sampled the following day. 3.2.2 “Tubing-in-Screened-Interval” Method The “Tubing-in-Screen” method, sometimes referred to as the “Low Flow” method, is used primarily when calculated purge volumes for the traditional purging method are excessive and present issues related to timely completion of the project and/or management of investigation derived waste. COPY SESD Operating Procedure Page 17 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 3.2.2.1 Purge Criteria 3.2.2.1.1 Placement of Pump Tubing or Intake The peristaltic pump tubing or intake point of the submersible pump is placed in the approximate mid-portion of the screened interval of the well. By definition, this method cannot be applied for purging with a bailer. 3.2.2.1.2 Conditions of Pumping Prior to initiation of pumping, a properly decontaminated well sounder should be lowered into the well being sampled to monitor the static water level prior to and during the purging process. Ideally, there should be only a slight and stable drawdown of the water column after pumping begins. If this condition cannot be met, then one of the other methods should be employed. 3.2.2.1.3 Stability of Chemical Parameters As with the traditional purging method described in Section 3.2.1, it is important that all chemical parameters be stable as defined in Section 3.2.1.1 prior to sampling. 3.3 Equipment Considerations for Purging Monitoring well purging is accomplished by using in-place plumbing and dedicated pumps or by using portable pumps/equipment when dedicated systems are not present. The equipment utilized by Branch personnel will usually consist of peristaltic pumps and variable speed electric submersible pumps, but may also include bladder pumps or inertial pumps. The pump of choice is usually a function of the well diameter, the depth to water, the depth of the well and the amount of water that is to be removed during purging. Whenever the head difference between the sampling location and the water level is less than the limit of suction and the volume to be removed is reasonably small, a peristaltic pump should be used for purging. For wells where the water level is below the limit of suction (approximately 25’ to 30’, and/or where there is a large volume of water to be purged), the variable speed electric submersible pump would be the pump of choice. SESD Operating Procedure for Pump Operation (SESDPROC-203) contains the use and operating instructions for all pumps commonly used during SESD ground water investigations. Bailers may also be used for purging in appropriate situations, however, their use is discouraged. Bailers tend to disturb any sediment that may be present in the well, creating or increasing sample turbidity. Bailers, if improperly used, may also strip volatile organic compounds from the water column being sampled. If a bailer is used, it should be a closed-top Teflon® bailer. COPY SESD Operating Procedure Page 18 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 3.3.1 Wells Without Plumbing or In-Place Pumps For permanent monitoring wells, the depth to water (water level) and depth of the well (total depth) should be determined before purging. Caution should be exercised during this procedure to prevent cross-contamination between wells. This is a critical concern when samples for trace organic compounds or metals analyses are collected. See SESD Operating Procedure for Field Equipment Cleaning and Decontamination (SESDPROC- 205) for cleaning procedures for well sounders. After cleaning, the well sounding device should be protected to keep it clean until its next use. 3.3.1.1 Purging with Pumps 3.3.1.1.1 Peristaltic Pumps The following step-by-step procedures describe the process of purging with a peristaltic pump: 1. Cut a length of standard-cleaned (SESD Operating Procedure for Field Equipment Cleaning and Decontamination at the FEC (SESDPROC-206)) Teflon® tubing, equal to the well depth plus an additional five to ten feet. Enough tubing is needed to run from the ground surface up to the top of the well casing and back down to the bottom of the well. This will allow for operation of the pump at all possible water level conditions in the well. 2. Place one end of the tubing into the vacuum side of the peristaltic pump head. Proper sizing of the Teflon® and Silastic® or Tygon® tubing should allow for a snug fit of the Teflon® tubing inside the flexible tubing mounted in the pump head. 3. Run a short section of tubing (does not have to be Teflon®) from the discharge side of the pump head to a graduated bucket. 4. Place the free end of the Teflon® tubing into the well until the end of the tubing is just below the surface of the water column. 5. Secure the Teflon® tubing to the well casing or other secure object using electrician's tape or other suitable means. This will prevent the tubing from being lost in the well should the tubing detach from the pump head. 6. Turn on the pump to produce a vacuum on the well side of the pump head and begin the purge. Observe pump direction to ensure that a vacuum is being applied to the purge line. If the purge line is being pressurized, either switch the tubing at the pump head or reverse the polarity of the cables on the pump or on the battery. COPY SESD Operating Procedure Page 19 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 7. If the pumping rate exceeds the recovery rate of the well, continue to lower the tubing into the well, as needed, until the drawdown stabilizes or the well is evacuated to dryness. If the pump is a variable speed peristaltic pump, and the water level in the well is being drawn down, reduce the speed of the pump in an attempt to stabilize the drawdown. If the well can be purged without evacuating the well to dryness, a sample with greater integrity can be obtained. 8. For wells which are not evacuated to dryness, particularly those with recovery rates equal to or very nearly equal to the purge rate, there may not be a complete exchange and removal of stagnant water in that portion of the water column above the tubing intake. For this reason, it is important that the tubing intake be placed in the very uppermost portion of the water column while purging. Standard field measurements should frequently be taken during this process to verify adequacy of the purge and readiness for sampling, as described in Section 3. 3.3.1.1.2 Submersible Pumps When a submersible pump is used for well purging, the pump itself is lowered into the water column. The pump must be cleaned as specified in SESD Operating Procedure for Field Equipment Cleaning and Decontamination (SESDPROC-205). The pump/hose assembly used in purging should be lowered into the top of the standing water column and not deep into the column. This is done so that the purging will "pull" water from the formation into the screened area of the well and up through the casing so that the entire static volume can be removed. If the pump is placed deep into the water column, the water above the pump may not be removed, and the subsequent samples, particularly if collected with a bailer, may not be representative of the aquifer conditions. It is recommended that the pump not be lowered more than three to five feet into the water column. If the recovery rate of the well is faster than the pump rate and no observable draw down occurs, the pump should be raised until the intake is within one foot of the top of the water column for the duration of purging. If the pump rate exceeds the recovery rate of the well, the pump will have to be lowered, as needed, to accommodate the drawdown. After the pump is removed from the well, the hose and the pump should be cleaned as outlined in SESD Operating Procedure for Field Equipment Cleaning and Decontamination (SESDPROC-205). COPY SESD Operating Procedure Page 20 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 3.3.1.2 Purging with Bailers Standard-cleaned (SESD Operating Procedure for Field Equipment Cleaning and Decontamination (SESDPROC-205) or SESD Operating Procedure for Field Equipment Cleaning and Decontamination at the FEC (SESDPROC-206)), closed top Teflon® bailers with Teflon® coated stainless steel leaders and new nylon rope are lowered into the top of the water column, allowed to fill, and removed. It is critical that bailers be slowly and gently immersed into the top of the water column, particularly during final stages of purging, to minimize turbidity and disturbance of volatile organic constituents. The use of bailers for purging and sampling is discouraged because the correct technique is highly operator dependent and improper use may result in an unrepresentative sample. 3.3.2 Wells With In-Place Plumbing Wells with in-place plumbing are commonly found at municipal water treatment plants, industrial water supplies, private residences, etc. Many permanent monitoring wells at active facilities are also equipped with dedicated, in-place pumps. The objective of purging wells with in-place pumps is the same as with monitoring wells without in-place pumps, i.e., to ultimately collect a ground water sample representative of aquifer conditions. Among the types of wells identified in this section, two different approaches are necessary. A permanent monitoring well with an in-place pump should, in all respects, be treated like a monitoring well without a pump. One limitation is that in most cases the in-place pump is “hard” mounted, that is, the pump is suspended in the well at a pre-selected depth and cannot be moved up or down during purging and sampling. In these cases, well volumes are calculated, parameters are measured and the well is sampled from the pump discharge, after volume removal and parameter conditions have been met. In the case of the other types of wells, i.e., municipal, industrial and residential supply wells, however, not enough is generally known about the construction aspects of the wells to apply the same criteria as used for monitoring wells, i.e., 3 to 5 well volumes. The volume to be purged in these situations, therefore, depends on several factors: whether the pumps are running continuously or intermittently and whether or not any storage/pressure tanks are located between the sampling point and the pump. The following considerations and procedures should be followed when purging wells with in-place plumbing under the conditions described. 3.3.2.1 Continuously Running Pumps If the pump runs more or less continuously, no purge (other than opening a valve and allowing it to flush for a few minutes) is necessary. If a storage tank is present, a spigot, valve or other sampling point should be located between the COPY SESD Operating Procedure Page 21 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 pump and the storage tank. If not, locate the valve closest to the tank. Measurements of pH, specific conductance, temperature, and turbidity are recorded at the time of sampling. 3.3.2.2 Intermittently or Infrequently Running Pumps If the pump runs intermittently or infrequently, best judgment should be utilized to remove enough water from the plumbing to flush standing water from the piping and any storage tanks that might be present. Generally, under these conditions, 15 to 30 minutes will be adequate. Measurements of pH, specific conductance, temperature and turbidity should be made and recorded at intervals during the purge and the final measurements made at the time of sampling should be considered the measurements of record for the event. 3.3.3 Temporary Monitoring Wells 3.3.3.1 General Considerations Procedures used to purge temporary ground water monitoring wells differ from permanent wells because temporary wells are installed for immediate sample acquisition. Wells of this type may include standard well screen and riser placed in boreholes created by hand augering, power augering, or by drilling. They may also consist of a rigid rod and screen that is pushed, driven, or hammered into place to the desired sampling interval, such as a direct push Wellpoint®, a Geoprobe® Screen Point 15/16 sampler or a Hydropunch® sampler. As such, the efforts to remove several volumes of water to replace stagnant water do not necessarily apply because stagnant water is not present. It is important to note, however, that the longer a temporary well is in place and not sampled, the more stagnant the water column becomes and the more appropriate it becomes to apply, to the extent possible, standard permanent monitoring well purging criteria to it to re-achieve aquifer conditions. In cases where the temporary well is to be sampled immediately after installation, purging is conducted primarily to mitigate the impacts of installation. In most cases, temporary well installation procedures disturb the existing aquifer conditions, resulting primarily in increased turbidity. Therefore, the goal of purging is to reduce the turbidity and remove the volume of water in the area directly impacted by the installation procedure. Low turbidity conditions in these types of wells that are completed within the limit of suction are typically and routinely achieved by the use of low-flow/low stress purging techniques using variable speed peristaltic pumps. 3.3.3.2 Purging When Water Level Is Within Limit of Suction In situations where the elevation of the top of the water column is within the limit of suction (no greater than about 25 feet head difference between the pump and the water level), a variable speed peristaltic pump may be used to purge COPY SESD Operating Procedure Page 22 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 temporary wells. Enough tubing is deployed to reach the bottom of the temporary well screen. At the onset of purging, the tubing is slowly lowered to the bottom of the screen and is used to remove any formation material which may have entered the well screen during installation. This is critical to ensuring rapid achievement of low turbidity conditions. After the formation material is removed from the bottom of the screen, the tubing is slowly raised through the water column to near the top of the column. The tubing can be held at this level to determine if the pump rate is drawing down the water level in the well. If the water level remains the same, secure the tubing at the surface to maintain this pumping level. If drawdown is observed on initiation of pumping, reduce the pump speed and attempt to match the drawdown of the well. Sustained pumping at these slow rates will usually result in a relatively clear, low turbidity sample. If the drawdown stabilizes, maintain that level, however, if it continues to lower, "chase" the water column until the well is evacuated. In this case, the recovered water column may be relatively free of turbidity and can be sampled. It may take several episodes of recovery to provide enough volume for a complete sample. 3.3.3.3 Purging When Water Level Is Greater Than Limit of Suction In situations where the elevation of the water table is greater than the limit of suction, peristaltic pumps cannot be used to purge temporary wells. If the temporary well is a ScreenPoint15® sampler with small diameter probe rod riser, the only practical choices for water removal are a small diameter bailer, a small diameter bladder pump or an inertial pump. If the well is to be used strictly for VOC screening, it may be acceptable to use the bailer to bail as much sediment from the well as possible prior to sampling. If metals are the analytes of concern, the bladder pump is the best choice for lowering the turbidity of the water column prior to sampling, followed next by the inertial pump. For larger diameter temporary wells, two-inch diameter or greater, bailers and the Grundfos® RediFlo2 may be used although excessive silt or other “fines” may present problems with the operation of the pump. 3.3.3.4 Considerations for Direct Push Groundwater Sampling With many of the direct push sampling techniques, purging is either not practical or possible, therefore, no purging is conducted. The sampling device is simply pushed or driven to the desired depth and opened and the sample is collected and retrieved. As a result, some samples collected in this way may not be satisfactory or acceptable for certain analyses, i.e., the subject procedure may yield a turbid sample that is not appropriate for metals analyses. 3.4 Field Care of Purging Equipment New plastic sheeting should be placed on the ground surface around the well casing to prevent contamination of the pumps, hoses, ropes, etc., in the event they accidentally COPY SESD Operating Procedure Page 23 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 come into contact with the ground surface or, for some reason, they need to be placed on the ground during the purging event. It is preferable that hoses used in purging that come into contact with the ground water be kept on a spool or contained in a large wash tub lined with plastic sheeting, both during transportation and during field use, to further minimize contamination by the transporting vehicle or the ground surface. Careful consideration shall be given to using submersible pumps to purge wells which are excessively contaminated with oily compounds, because it may be difficult to adequately decontaminate severely contaminated pumps under field conditions. When wells of this type are encountered, alternative purging methods, such as bailers, should be considered. 3.5 Investigation Derived Waste Purging generates quantities of purge water or investigation derived waste (IDW), the disposition of which must be considered. See SESD Operating Procedure for Management of Investigation Derived Waste (SESDPROC-202) for guidance on management or disposal of this waste. COPY SESD Operating Procedure Page 24 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 4 Groundwater Sampling Methods – Sampling 4.1 General Sampling is the process of obtaining, containerizing, and preserving (if required) a ground water sample after the purging process is complete. Non-dedicated pumps for sample collection generally should not be used. Many pumps are made of materials such as brass, plastic, rubber, or other elastomeric products which may cause chemical interferences with the sample. Their principle of operation may also render them unacceptable as a sample collection device. It is recognized that there are situations, such as industrial or municipal supply wells or private residential wells, where a well may be equipped with a dedicated pump from which a sample would not normally be collected. Discretion should always be used in obtaining a sample. 4.2 Sampling Wells With In-Place Plumbing Samples should be collected following purging from a valve or cold water tap as near to the well as possible, preferably prior to any storage/pressure tanks or physical/chemical treatment system that might be present. Remove any hose that may be present before sample collection and reduce the flow to a low level to minimize sample disturbance, particularly with respect to volatile organic constituents. Samples should be collected directly into the appropriate containers as specified in the ASBLOQAM. It may be necessary to use a secondary container, such as a clean 8 oz. or similar size sample jar or a stainless steel scoop, to obtain and transfer samples from spigots with low ground clearance. Also, refer to the discussion in the SESD Operating Procedure for Potable Water Supply Sampling (SESDPROC-305), Sec. 4.2, Potable Water Samples Collected from Wells with In-Place Plumbing. Potable well measurements for pH, specific conductance and turbidity and possibly temperature, if warranted, should be recorded at the time of sample collection. 4.3 Sampling Wells Without Plumbing, Within the Limit of Suction 4.3.1 Equipment Available The pump of choice for sampling ground water within the limit of suction is the variable-speed peristaltic pump. Its use is described in the following sections. Other acceptable alternatives that may be used under these conditions are the RediFlo2® electric submersible pump (with Teflon® tubing) and a closed-top Teflon® bailer. 4.3.1.1 Peristaltic Pump, Direct from Pump Head Tubing Samples for some constituents, primarily inorganic analytes such as metals and cyanide, may be collected directly from the pump head tubing. This method is acceptable under the following conditions: • The pump head tubing must be changed between sampling locations; COPY SESD Operating Procedure Page 25 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 • The pump head tubing must be either be certified clean according to SESD’s internal quality control program described in Section 3.2 of the SESD Operating Procedure for Field Sampling Quality Control (SESDPROC-011) or • An equipment rinsate blank is collected by pumping de-ionized water through a piece of the tubing. 4.3.1.2 Peristaltic Pump/Vacuum jug It is not acceptable to collect samples for organic compound analyses through the flexible tubing used in the pump head. When collecting samples for organic compound analyses it is necessary to use a vacuum container, placed between the pump and the well for sample collection. The following step-by-step procedures describe the process of sampling with a peristaltic pump and vacuum jug (see note following these procedures for collection of VOC samples): 1. Disconnect the purge tubing from the pump. Make sure the tubing is securely attached to the protective casing or other secure object. 2. Insert the tubing into one of the ferrule nut fittings of a Teflon® vacuum container transfer cap assembly. 3. Place a suitable length of Teflon® tubing between the remaining transfer cap assembly ferrule nut fitting and the vacuum side of the flexible tubing in the peristaltic pump head. Securely hand-tighten both fittings. 4. Turn the pump on. Water should begin to collect in the transfer container (typically a 1-liter sample container) within a few minutes. If water does not begin to flow into the container within several minutes, check the transfer cap fittings and make sure the assembly is tightly attached to the container. It may be necessary to tighten the ferrule nuts with a wrench or pliers to achieve a vacuum in the system, particularly when approaching the maximum head difference between the pump and water table (limit of suction). 5. When the transfer container is nearly full, turn off the pump, remove the transfer cap assembly, and pour the sample into the appropriate containers. Because the 1-liter containers used by the Branch are rinsed with nitric acid during cleaning, they cannot be used for collecting samples to be analyzed for nitrogen sensitive parameters. 6. If additional sample volume is needed, replace the transfer cap assembly, turn the pump on, and collect additional volume. The use of Teflon® valves or ball check devices to retain the water column in the sample delivery tubing during the transfer phase, when large volumes of sample are required, is acceptable. These devices, however, must be constructed so that they may be completely disassembled and cleaned according to the procedures in SESD COPY SESD Operating Procedure Page 26 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 Operating Procedure for Field Equipment Cleaning and Decontamination (SESDPROC-205). 7. When sampling is completed, all Teflon® tubing should be discarded. NOTE: Samples for volatile organic compound analyses cannot be collected using this method. If samples for VOC analyses are required, they must be collected with a Teflon® or stainless steel bailer or by other approved methods, such as the “soda straw” method. The “soda straw” method involves allowing the tubing to fill, by either lowering it into the water column (A) or by filling it via suction applied by the pump head (B). If method (A) is used, the tubing is removed from the well after filling and the captured sample is allowed to drain into the sample vial. If method (B) is used, after running the pump and filling the tubing with sample, the pump speed is reduced and the direction reversed to push the sample out of the tubing into the vials. Avoid completely emptying the tubing when filling the sample vials when using method (B) to prevent introducing water that was in contact with the flexible pump head tubing. Either method is repeated, as necessary, until all vials are filled. 4.3.1.3 RediFlo2® Electric Submersible Pump (with Teflon® Tubing) After purging has been accomplished with RediFlo2® electric submersible pump, the sample may be obtained directly from the pump discharge, provided that Teflon® tubing was used for the sample delivery line. The discharge rate of the pump should be reduced during volatile organic compound sample collection to minimize sample disturbance. Note, if the RediFlo2® electric submersible pump is used for sampling, the pump must undergo a full external and internal cleaning. In addition, pump rinsate blanks must be collected, at the appropriate frequency, to demonstrate that the pump has been adequately cleaned between wells. 4.3.1.4 Bailers New bailer rope should be attached to the bailer via a Teflon® coated stainless steel wire. (If a bailer was used to purge the well, it may also be used to sample the well and new bailer rope is not required between purging and sampling). The bailer should be gently immersed in the top of the water column until just filled. At this point, the bailer should be slowly removed and the contents emptied into the appropriate sample containers. 4.4 Sampling Wells without Plumbing, Exceeding the Limit of Suction All methods described previously in Section 4.3.2.1.3, RediFlo2® Electric Submersible Pumps, and Section 4.3.2.1.4, Bailers, are suitable sample methods where the water table is too deep to consider the use of a peristaltic pump for sampling. COPY SESD Operating Procedure Page 27 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 4.5 Micro-Purge or No Purge Sampling Procedures The Micro-Purge or No Purge sampling procedures are usually employed when it necessary to keep purge volumes to an absolute minimum. Among the Micro-Purge or No Purge procedures that might be employed are: • Low pump rate sampling with peristaltic or submersible pumps (typical Micro-Purge sampling), • HydraSleeveTM or • Passive diffusion bag (PDB) sampling The use of these procedures is acceptable only when the site hydrogeology is well understood, with respect to the hydraulic conductivity of geologic materials within the well screen interval. The underlying assumption, when employing these procedures, is that the formation in which the well is screened has a high hydraulic conductivity (K>10-5 cm/sec, for example), resulting in a state of equilibrium existing between the water standing in the screened interval and the formation water in which the well is screened. In this situation, the well is considered to be in a perpetually “purged” state and purging is not required. These procedures are generally impractical for SESD to implement because of the general lack of hydrogeologic information for the sampled wells and the real necessity, in some cases, that the pumps be pre-deployed to overcome issues related to turbidity resulting from pump placement prior to sampling. 4.5.1 Sampling with Pumps The peristaltic pump tubing or intake point of the submersible pump is placed in the approximate mid-portion of the screened interval of the well or other interval selected by the field team leader. If turbidity and its impact on metals analyses are a concern, a period of time sufficient should be allowed to mitigate effects of pump or tubing placement. After it has been determined that sampling may proceed, the pump is turned on and operated at a rate that does not cause significant drawdown of the water column, as measured using a water level sounder. During sampling, sufficient water to supply enough volume for the analytes of concern and the purge parameters is pumped. Purging should continue until purge parameters stabilize, generally three consecutive stable sets of readings, before samples are collected. 4.5.2 HydraSleevesTM HydraSleeevesTM are grab sampling devices that are deployed in a closed configuration then opened in the desired interval for sample collection. The following is a summary of its operation: 1. Sampler placement - Reusable weight is attached and the HydraSleeveTM is lowered and placed at the desired position in the well screen. In-situ water pressure keeps the reed valve closed, preventing water from entering the sampler. Well is allowed to return to equilibrium. COPY SESD Operating Procedure Page 28 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 2. Sample collection - The reed valve opens to allow filling when the sampler is moved upward faster than 1 foot per second, either in one continuous upward pull or by cycling the sampler up and down to sample a shorter interval. There is no change in water level, and only minimal agitation during collection. 3. Sample retrieval - When the flexible sleeve is full, the reed valve closes and the sampler can be recovered without entry of extraneous overlying fluids. Samples are removed by puncturing the sleeve with the pointed discharge tube and draining the contents into containers for sampling or field measurement. 4.5.3 Passive Diffusion Bags Passive diffusion bag (PDB) samplers are bags comprised of low-density polyethylene (LDPE) plastic and containing analyte-free water, preferably with no headspace. The bags are deployed, with stainless steel weights, to the desired sample interval and are allowed to equilibrate with the water at the point of deployment in the well. A deployment period of a minimum of 14 days is recommended to ensure equilibration prior to removal. After 14 days, the bags and opened with a puncture device or other cutting implement and the contents transferred to containers for sampling or field measurement. 4.5.4 General Considerations for Micro-Purge or No-Purge Sampling When using the Micro-Purge method, it may be advisable to deploy the tubing or pump in advance of sample collection. Introducing the tubing or pump into the screened interval is likely to dislodge sediment and other fines that have settled or bridged on the well screen material and the gravel pack media behind the screen. If sampling is conducted immediately, turbidity issues may render this method impractical from a parameter stability standpoint. HydraSleevesTM and PDBs must be evaluated for appropriateness for analytes of concern. 4.6 Sample Preservation After sample collection, all samples requiring preservation must be preserved as soon as practical. Consult the ASBLOQAM for the correct preservative for the particular analytes of interest. All samples preserved using a pH adjustment (except VOCs) must be checked, using pH strips, to ensure that they were adequately preserved. This is done by pouring a small volume of sample over the strip. Do not place the strip in the sample. Samples requiring reduced temperature storage should be placed on ice immediately. COPY SESD Operating Procedure Page 29 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 4.7 Special Sample Collection Procedures 4.7.1 Trace Organic Compounds and Metals Special sample handling procedures should be instituted when trace contaminant samples are being collected. All sampling equipment, including pumps, bailers, water level measurement equipment, etc., which comes into contact with the water in the well must be cleaned in accordance with the cleaning procedures described in the SESD Operating Procedure for Field Equipment Cleaning and Decontamination (SESDPROC-205) or SESD Operating Procedure for Field Equipment Cleaning and Decontamination at the FEC (SESDPROC-206). Pumps should not be used for sampling unless the interior and exterior portions of the pump and the discharge hoses are thoroughly cleaned. Blank samples should be collected to determine the adequacy of cleaning prior to collection of any sample using a pump other than a peristaltic pump. 4.7.2 Order of Sampling with Respect to Analytes In many situations when sampling permanent or temporary monitoring wells, an adequate purge, with respect to turbidity, is often difficult to achieve. Removal and insertion of equipment after the purge and prior to actual sampling may negate the low turbidities achieved during purging and elevate turbidity back to unacceptable levels. For this reason, it is important that special efforts be used to minimize any disturbance of the water column after purging and to collect the aliquot for metals first. Therefore, the preferred order of sampling is metals first, followed by other inorganic analytes, extractable organic compounds and volatile organic compounds. 4.7.3 Filtering As a standard practice, ground water samples will not be filtered for routine analysis. Filtering will usually only be performed to determine the fraction of major ions and trace metals passing the filter and used for flow system analysis and for the purpose of geochemical speciation modeling. Filtration is not allowed to correct for improperly designed or constructed monitoring wells, inappropriate sampling methods, or poor sampling technique. When samples are collected for routine analyses and are filtered, both filtered and non-filtered samples will be submitted for analyses. Samples for organic compounds analysis should not be filtered. Prior to filtration of the ground water sample for any reason other than geochemical speciation modeling, the following criteria must be demonstrated to justify the use of filtered samples for inorganic analysis: 1. The monitoring wells, whether temporary or permanent, have been constructed and developed in accordance with the SESD Guidance Document, Design and Installation of Monitoring Wells (SESDGUID-001). COPY SESD Operating Procedure Page 30 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 2. The ground water samples were collected using sampling techniques in accordance with this section, and the ground water samples were analyzed in accordance with USEPA approved methods. 3. Efforts have been undertaken to minimize any persistent sample turbidity problems. These efforts may consist of the following: • Redevelopment or re-installation of permanent ground water monitoring wells. • Implementation of low flow/low stress purging and sampling techniques. 4. Turbidity measurements should be taken during purging and sampling to demonstrate stabilization or lack thereof. These measurements should be documented in the field notes. If the ground water sample appears to have either a chemically-induced elevated turbidity, such as would occur with precipitate formation, or a naturally elevated colloid or fine, particulate-related turbidity, filtration will not be allowed. If filtration is necessary for purposes of geochemical modeling or other pre-approved cases, the following procedures are suggested: 1. Accomplish in-line filtration through the use of disposable, high capacity filter cartridges (barrel-type) or membrane filters in an in-line filter apparatus. The high capacity, barrel-type filter is preferred due to the higher surface area associated with this configuration. If a membrane filter is utilized, a minimum diameter of 142 mm is suggested. 2. Use a 5 μm pore-size filter for the purpose of determining the colloidal constituent concentrations. A 0.1 μm pore-size filter should be used to remove most non-dissolved particles. 3. Rinse the cartridge or barrel-type filter with 500 milliliters of the solute (groundwater to be sampled) prior to collection of sample. If a membrane filter is used, rinse with 100 milliliters of solute prior to sample collection. Potential differences could result from variations in filtration procedures used to process water samples for the determination of trace element concentrations. A number of factors associated with filtration can substantially alter "dissolved" trace element concentrations; these include filter pore size, filter type, filter diameter, filtration method, volume of sample processed, suspended sediment concentration, suspended sediment grain-size distribution, concentration of colloids and colloidally-associated trace elements, and concentration of organic matter. Therefore, consistency is critical in the comparison of short-term and long-term results. Further guidance on filtration may be obtained from the following: 1) Metals in Ground Water: Sampling Artifacts and Reproducibility; 2) Filtration of Ground Water Samples for Metals Analysis; and 3) Ground Water Sampling - A Workshop Summary. See Section 1.4, References, for complete citation for these documents. COPY SESD Operating Procedure Page 31 of 31 SESDPROC-301-R3 Groundwater Sampling Groundwater Sampling(301)_AF.R3 Effective Date: March 6, 2013 Bacterial Sampling Whenever wells (normally potable wells) are sampled for bacteriological parameters, care must be taken to ensure the sterility of all sampling equipment and all other equipment entering the well. Further information regarding bacteriological sampling is available in the following: 1) Sampling for Organic Chemicals and Microorganisms in the Subsurface; 2) Handbook for Evaluating Water Bacteriological Laboratories; and 3) Microbiological Methods for Monitoring the Environment, Water and Wastes. See Section 1.4, References, for complete citation for these documents. 4.8 Specific Sampling Equipment Quality Assurance Techniques All equipment used to collect ground water samples shall be cleaned as outlined in the SESD Operating Procedure for Field Equipment Cleaning and Decontamination (SESDPROC-205) or SESD Operating Procedure for Field Equipment Cleaning and Decontamination at the FEC (SESDPROC-206) and repaired, if necessary, before being stored at the conclusion of field studies. Cleaning procedures utilized in the field or field repairs shall be thoroughly documented in field records. 4.9 Auxiliary Data Collection During ground water sample collection, it is important to record a variety of ground water related data. Included in the category of auxiliary data are water levels measured according to the SESD Operating Procedure for Groundwater Level and Well Depth Measurement (SESDPROC-105), well volume determinations (Section 3.1.1, Purging and Purge Adequacy), pumping rates during purging (see below), and occasionally, drillers or boring logs. This information should be documented in the field records. 4.9.1 Well Pumping Rate – Bucket/Stop Watch Method The pumping rate for a pump can be determined by collecting the discharge from the pump in a bucket of known volume and timing how long it takes to fill the bucket. The pumping rate should be in gallons per minute. This method shall be used primarily with pumps with a constant pump rate, such as gasoline-powered or electric submersible pumps. Care should be taken when using this method with some battery-powered pumps. As the batteries' charge decreases, the pump rate also decreases so that pumping rate calculations using initial, high pump rates may be erroneously high. If this method is used with battery-powered pumps, the rate should be re-checked frequently to ensure accuracy of the pumping rate calculations. COPY Appendix D USEPA SESD Procedure for Soil Gas Sampling (SEDPROC-307-R3) COPY _____________________________________________________________________________________ SESD Operating Procedure Page 2 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 Revision History The top row of this table shows the most recent changes to this controlled document. For previous revision history information, archived versions of this document are maintained by the SESD Document Control Coordinator on the SESD local area network (LAN). History Effective Date SESDPROC-307-R3, Soil Gas Sampling, replaces SESDPROC-307-R2 General: Corrected any typographical, grammatical, and/or editorial errors. Throughout the document mention of quality system or SESD quality system was replaced with Field Branches Quality System or FBQS. Cover Page: Changed the Author from Tim Slagle to TBD. Changed the Enforcement and Investigations Branch Chief from Archie Lee to Acting Chief John Deatrick. Changed the FQM from Liza Montalvo to Bobby Lewis. Revision History: Changes were made to reflect the current practice of only including the most recent changes in the revision history. May 14, 2014 SESDPROC-307-R2, Soil Gas Sampling, replaces SESDPROC-307-R1 September 8, 2010 SESDPROC-307-R1, Soil Gas Sampling, replaces SESDPROC-307-R0 November 1, 2007 SESDPROC-307-R0, Soil Gas Sampling, Original Issue February 05, 2007 COPY _____________________________________________________________________________________ SESD Operating Procedure Page 3 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 TABLE OF CONTENTS 1 General Information 1.1 Purpose .............................................................................................................. 4 1.2 Scope/Application ............................................................................................. 4 1.3 Documentation/Verification ............................................................................. 4 1.4 References .......................................................................................................... 4 1.5.1 Safety .......................................................................................................... 5 1.5.2 Procedural Precautions ............................................................................. 6 2 Special Sampling Considerations ............................................................................ 7 2.1 Special Considerations for Sampling .............................................................. 7 2.2 Special Precautions for Soil Gas Sampling ..................................................... 7 2.3 Sample Handling Requirements ...................................................................... 7 2.4 Quality Control ................................................................................................. 8 2.5 Records .............................................................................................................. 8 3 Geoprobe® PRT System Installation ..................................................................... 9 3.1 General ............................................................................................................... 9 3.2 PRT System Installation Procedures .............................................................. 9 3.3 Decommissioning PRT Sample Locations .................................................... 10 4 Geoprobe® Permanent Soil Gas Implant Installation ....................................... 12 4.1 General ............................................................................................................. 12 4.2 Installation of Permanent Soil Gas Sampling Implants (Typical) ............. 12 5 Sampling PRT and Permanent Soil Gas Installations ........................................ 15 COPY _____________________________________________________________________________________ SESD Operating Procedure Page 4 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 1 General Information 1.1 Purpose This document describes general and specific procedures, methods and considerations to be used and observed when collecting soil gas samples for field screening or laboratory analysis. 1.2 Scope/Application The procedures contained in this document are to be used by field personnel when collecting and handling soil gas samples in the field. On the occasion that SESD field personnel determine that any of the procedures described in this section are inappropriate, inadequate or impractical and that another procedure must be used to obtain a soil gas sample, the variant procedure will be documented in the field log book, along with a description of the circumstances requiring its use. Mention of trade names or commercial products does not constitute endorsement or recommendation for use. 1.3 Documentation/Verification This procedure was prepared by persons deemed technically competent by SESD management, based on their knowledge, skills and abilities and has been tested in practice and reviewed in print by a subject matter expert. The official copy of this procedure resides on the SESD Local Area Network (LAN). The Document Control Coordinator (DCC) is responsible for ensuring the most recent version of the procedure is placed on LAN and for maintaining records of review conducted prior to its issuance. 1.4 References Geoprobe® Systems Tools and Equipment Catalog, Kejr Engineering, Inc., Salinas, Kansas, 1997. International Air Transport Authority (IATA). Dangerous Goods Regulations, Most Recent Version SESD Operating Procedure for Control of Records, SESDPROC-002, Most Recent Version SESD Operating Procedure for Equipment Inventory and Management, SESDPROC-104, Most Recent Version SESD Operating Procedure for Field Equipment Cleaning and Decontamination, SESDPROC-205, Most Recent Version COPY _____________________________________________________________________________________ SESD Operating Procedure Page 5 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 SESD Operating Procedure for Field Sampling Quality Control, SESDPROC-011, Most Recent Version SESD Operating Procedure for Logbooks, SESDPROC-010, Most Recent Version SESD Operating Procedure for Packaging, Marking, Labeling and Shipping of Environmental and Waste Samples, SESDPROC-209, Most Recent Version SESD Operating Procedure for Sample and Evidence Management, SESDPROC-005, Most Recent Version The Yellow Field Book©, Kejr Engineering, Inc., Salinas, Kansas, 2000. US EPA. 1999. Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air, Second Edition, Compendium Method TO-15, Determination of Volatile Organic Compounds (VOCs) in Air Collected in Specially Prepared Canisters and Analyzed by Gas Chromatography/Mass Spectrometry (GC/MS); Center for Environmental Research Information, Office of Research and Development, Cincinnati, OH; EPA/625/R-96/010b US EPA. Analytical Support Branch Laboratory Operations and Quality Assurance Manual. Region 4 SESD, Athens, GA, Most Recent Version US EPA. April 13, 1981. Final Regulation Package for Compliance with DOT Regulations in the Shipment of Environmental Laboratory Samples. Memo from David Weitzman, Work Group Chairman, Office of Occupational Health and Safety (PM-273) US EPA. Safety, Health and Environmental Management Program Procedures and Policy Manual. Region 4 SESD, Athens, GA, Most Recent Version Geoprobe Systems, Direct Push Installation of Devices for Active Soil Gas Sampling & Monitoring, Technical Bulletin No. MK3098, Prepared May, 2006. 1.5 General Precautions 1.5.1 Safety Proper safety precautions must be observed when collecting soil gas samples. Refer to the SESD Safety, Health and Environmental Management Program (SHEMP) Procedures and Policy Manual and any pertinent site-specific Health and Safety Plans (HASP) for guidelines on safety precautions. These guidelines should be used to complement the judgment of an experienced professional. COPY _____________________________________________________________________________________ SESD Operating Procedure Page 6 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 Address chemicals that pose specific toxicity or safety concerns and follow any other relevant requirements, as appropriate. 1.5.2 Procedural Precautions The following precautions should be considered when collecting soil gas samples.  Special care must be taken not to contaminate samples. This includes storing samples in a secure location to preclude conditions which could alter the properties of the sample. Samples shall be custody sealed during long-term storage or shipment.  Collected samples are in the custody of the sampler or sample custodian until the samples are relinquished to another party.  If samples are transported by the sampler, they will remain under his/her custody or be secured until they are relinquished.  Shipped samples shall conform to all U.S. Department of Transportation (DOT) and/or International Air Transportation Association (IATA) hazardous materials shipping requirements.  Documentation of field sampling is done in a bound logbook.  Chain-of-custody documents shall be filled out and remain with the samples until custody is relinquished.  All shipping documents, such as air bills, bills of lading, etc., shall be retained by the project leader and stored in a secure place. COPY _____________________________________________________________________________________ SESD Operating Procedure Page 7 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 2 Special Sampling Considerations 2.1 Special Considerations for Sampling The tubing used as part of either of the described sampling systems should be Teflon® or stainless steel. As most soil gas sampling will be conducted to investigate the presence or extent of organic compounds, Teflon® tubing is required to ensure the integrity of the sample. 2.2 Special Precautions for Soil Gas Sampling  A clean pair of new, non-powdered, disposable gloves will be worn each time a different location is sampled and the gloves should be donned immediately prior to sampling. The gloves should be changed any time during sample collection when their cleanliness is compromised.  If possible, one member of the field sampling team should take all the notes and photographs, fill out tags, etc., while the other members collect the samples.  Use O-rings on all tooling, adapters and probe rods to ensure that the entire sampling train is air-tight. This is necessary to prevent soil ingress during installation and to maintain sample integrity by ensuring that no ambient air is introduced into the sample during collection.  When using the Post-Run Tubing (PRT) sampling system, excavate a small depression around the rods after driving the distance of the intended open interval. Fill the depression with bentonite crumbles (not pellets) and hydrate with tap water to ensure sealing at the ground surface. Special care should be taken to keep the rod string aligned with the push axis of the probe machine. 2.3 Sample Handling Requirements 1. Soil gas samples will typically be collected by directly filling evacuated, specially-prepared stainless steel canisters (SUMMA or SilcoSteel® canisters), after sample delivery line purging. 2. The canister will be labeled and identified according to SESD Operating Procedure for Packaging, Marking, Labeling and Shipping of Environmental and Waste Samples (SESDPROC-209). COPY _____________________________________________________________________________________ SESD Operating Procedure Page 8 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 2.4 Quality Control Quality control sampling for soil gas sampling investigations will consist of collection of the following types of samples, as appropriate.  Control Sample: If applicable to the study or investigation, a control sample should be collected from a location not affected by the possible contaminants of concern and submitted with the other samples.  Field Blank: A canister field blank, prepared prior to the investigation by ASB personnel, should also be submitted with the sample set during the investigation.  Equipment rinsate blank: Equipment rinsate blanks should be collected if equipment, such as PRT adapters, probe rod or other sampling equipment is field cleaned and re-used to document that low-level contaminants were not introduced into the sample by the decontaminated equipment.  Field Split: Field split samples, at a minimum frequency of one for every twenty samples, should be collected. Split samples are collected by attaching the center leg of a Swagelok® “T” to the end of the sample tubing. The remaining legs of the “T” are connected to two sample containers which are opened and filled simultaneously. 2.5 Records Information generated or obtained by SESD personnel will be organized and accounted for in accordance with SESD records management procedures found in the SESD Operating Procedure for Control of Records (SESDPROC-002). Field notes, recorded in a bound field logbook, will be generated, as well as chain-of-custody documentation according to the procedures found in SESD Operating Procedure Logbooks (SESDPROC-010) and SESD Operating Procedure for Sample and Evidence Management (SESDPROC-005). COPY _____________________________________________________________________________________ SESD Operating Procedure Page 9 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 3 Geoprobe® PRT System Installation 3.1 General Single event or grab sampling may be conducted using the Post-Run Tubing System (PRT). Using this system, soil gas samples can be collected quickly and with a high degree of assurance that the samples are representative of the targeted depth, i.e., using this method, there is no leakage at probe rod joints that will compromise the integrity of the sample. The downhole components of the PRT system include:  Sample delivery tubing  Probe rods  PRT Adapter  Expendable point holder  Expendable point O-ring seals are used on the PRT Adapter, the expendable point holder and at all rod joints. The O-rings prevent soil ingress which can prevent air-tight docking of the PRT adapter. 3.2 PRT System Installation Procedures The following procedures are used to collect soil gas samples using the Geoprobe® PRT system. The PRT system is available for 1.0-inch, 1.25-inch and 1.5-inch diameter probe rod. In SESD practice, 1.25-inch rods are used. All parts or accessories used in the PRT system must be selected with the appropriate diameter probe rod in mind to ensure compatibility of all components. 1. Place O-ring on PRT expendable point holder and attach to initial section of probe rod. 2. Place O-ring on expendable point and press into expendable point holder. 3. Add drive cap to probe rod and push PRT system into ground the distance of the intended open-interval. Take special care to assure that the rods are in line with the push axis of the probe machine. Dig a small depression around the rod string. Fill the depression with bentonite crumbles (not pellets) and hydrate with tap water. 4. At the desired sampling depth, attach a point popper to an extension rod and insert extension rod string into rods so that the point popper rests on the expendable COPY _____________________________________________________________________________________ SESD Operating Procedure Page 10 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 point. Using the rod puller, and taking special care to maintain probe alignment with the rods, begin pulling the rods while maintaining pressure on the extension rods. The extension rods should drop when the pull is started, indicating that the expendable point has been ejected. The rods can then be pulled to expose the desired open sampling interval. 5. Using a properly decontaminated water level sounder, check, if conditions warrant, to make sure groundwater is not present prior to proceeding with Step 6. 6. Secure the PRT adapter to a length of tubing sufficient to reach from the sampling interval to the surface, with several feet of excess tubing extending beyond the top of the probe rod to facilitate sampling. The adapter is secured tightly to the tubing using electrical tape. This will not compromise the integrity of the sample to be collected, as the sample is pulled directly through the adapter and is never exposed to the tape. 7. Run the tubing and adapter into the probe rod and, using steady downward pressure, turn the tubing counter-clockwise to dock the adapter into the top of the expendable point holder. Tug gently on the tubing to ensure that the adapter engaged with the expendable point holder. Continue rotating tubing until the adapter is firmly seated. Failure to dock could indicate that soil intruded during the push or that the expendable point was lost during the push. 8. At this point, the PRT system has been installed and is ready for sampling. If the sample can not be collected immediately, the end of the tubing should be capped with a stainless steel Swagelok® cap. Sampling is conducted using one of the procedures described in Section 5, Sampling PRT and Permanent Soil Gas Installations 3.3 Decommissioning PRT Sample Locations Because it is impractical to pump grout through the PRT adapter on the lead probe rod, the entire string of rod must be removed before decommissioning can commence. The following methods are available, depending on conditions related to sample depth and post-removal probe hole wall stability: 1. Direct Placement of Pellets or Grout - If the sampling depth was fairly shallow, on the order of ten feet or less, grouting/sealing the open hole can be accomplished by directly placing bentonite pellets, hydrated in lifts or pouring a 30% solids bentonite grout mixture from the surface. The acceptable maximum depth for this option is somewhat dependent on the stability of the hole and these methods may be used at slightly greater depths if the holes do not collapse after removal of the rod. COPY _____________________________________________________________________________________ SESD Operating Procedure Page 11 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 2. Re-entry Grouting - For locations where sampling was conducted at somewhat greater depths or where the surficial formations tend to collapse, the only viable option for grout placement may be to re-probe the entire depth with an expendable point. After reaching the original sample depth, the expendable point is ejected and the hole is grouted by directly injecting grout through the inside of the rod string, as it is removed. Use of this option is dependent on the relative degree of hole stability. COPY _____________________________________________________________________________________ SESD Operating Procedure Page 12 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 4 Geoprobe® Permanent Soil Gas Implant Installation 4.1 General Long-term soil gas sampling may be conducted using permanent soil gas sampling implants installed with the Geoprobe®. Stainless steel implants may be installed at any depth achievable by the Geoprobe® and may be installed using 1.0-inch, 1.25-inch or 1.5-inch diameter probe rod. In SESD practice, 1.25-inch probe rods are used. The implants may be installed in custom lengths, configured using a wide assortment of available implant lengths and connections. The implant screens are double-woven stainless steel mesh with 0.0057-inch (0.15 mm) pore openings. Permanent soil gas sampling implants may also be installed using 2.125-inch diameter rods utilizing an advancing thin-walled corer to facilitate placement of the implant (see Geoprobe Systems, Direct Push Installation of Devices for Active Soil Gas Sampling & Monitoring, Technical Bulletin No. MK3098 for details of this application). 4.2 Installation of Permanent Soil Gas Sampling Implants (Typical) The following procedures are used by to install a permanent soil gas sampling implant using the Geoprobe®. These are the general procedures which are used with 1.25-inch diameter probe rod. 1. Attach O-ring to implant point anchor. 2. Press implant point anchor into point holder and attach to first section of probe rod. 3. Push implant point anchor to the desired depth for implant installation. Using O- rings on all rod joints will prevent soil intrusion. 4. When the desired depth has been reached, attach the implant to the sample delivery tubing. This is accomplished by loosening or removing the Swagelok® fitting and pressing the tubing into the implant. When the end of the tubing is sufficiently engaged in the end of the implant, the Swagelok® fitting is tightened to secure the tubing in the implant. The Swagelok® tightening recommendation is 1 and ¼ turns after finger-tightening. It is critical that the tubing be securely attached to the implant so that it does not pull off during subsequent steps of the installation. 5. Feed the tubing into the probe rod until the implant reaches the implant point anchor. At this point, cut the tubing to allow enough tubing to remain for sampling, usually three to four feet. COPY _____________________________________________________________________________________ SESD Operating Procedure Page 13 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 6. Rotate the tubing and implant counter-clockwise, threading the implant into the anchor. If there was any soil intrusion during the push, the implant may not dock. If the implant does not dock, it is possible to salvage the installation by removing the implant and sealing the small hole on the bottom of the implant, if present, with foil or with a small sheet metal screw, then returning the implant to the hole. 7. After the implant has been docked, use a pull cap and pull the probe rod approximately one foot, exposing the implant. Observe the tubing to make sure that anchor remained in place and is not being pulled with the rod. 8. If the implant remained in place, slowly pour a measured amount of 60-100 mesh glass beads down the inside of the probe rod. The glass beads are used as a filter pack around the implant. The implant should be covered with beads to approximately six inches above the top of the implant. The volume of beads should be calculated based on the length of implant used. While pouring the beads, it is advisable to gently shake the tubing to prevent the beads from bridging inside the probe rod. 9. After placing the beads, the implant is sealed using a flowable mixture of the glass beads and fine-powdered bentonite. To accomplish this, two to three feet of rod is pulled and the mixture is slowly poured into the rod above the bead-packed implant. As with the bead placement, similar care should be taken to avoid bridging of this mixture. After placement of the bead/bentonite seal, hydrate by pouring one gallon of de-ionized water above the seal. 10. After placement and hydration of the seal, the rod string is removed and the resultant annular space is grouted using one of the following procedures, which are dependent on the depth and stability of the open hole. a. If the resultant open hole is shallow (ten feet or less) and the hole walls are stable, the hole may either be filled with bentonite pellets, hydrated in lifts or grouted using a 30% solids bentonite grout, poured from the surface. b. If the hole is deeper than ten to fifteen feet, better results may be obtained by using a tremie pipe to place a pumpable grout. ½-inch PVC tremie pipe or Geoprobe nylon grout tubing is threaded down the annulus to the top of the bead/bentonite seal. The tremie is pulled off the bottom to prevent jetting out the seal and grout is pumped until the annulus is filled. Procedures are similar to those for well annular seals described in SESDGUID-101, Section 2.3.5. 11. For permanent or long-term installations the tubing should be protected by an appropriate surface completion, such as a flush vault or well protective casing, similar to well protective casings, as described in SESDGUID-101. The finish COPY _____________________________________________________________________________________ SESD Operating Procedure Page 14 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 should be performed after 24 hours of grout curing. 12. After installation is complete the soil gas implant is sampled using one of the methods described in Section 5, Sampling PRT and Permanent Soil Gas Installations. COPY _____________________________________________________________________________________ SESD Operating Procedure Page 15 of 15 SESDPROC-307-R3 Soil Gas Sampling Soil Gas Sampling(307)_AF.R3 Effective Date: May 14, 2014 5 Sampling PRT and Permanent Soil Gas Installations Soil gas samples may be collected from PRT and permanent soil gas implant installations using one of several methods, listed below. Canister sampling is the most common method utilized by SESD.  Canister Sampling for Laboratory Analysis – After installation is complete and immediately prior to sampling, a flow-limiting device, consisting of a sintered stainless steel filter and a critical orifice, is attached at the sampling end of the tubing. After the device is connected to the Teflon® tubing, it is necessary to remove all stagnant or ambient air from the sample string. This volume, equal to approximately three times the volume of the sample string, should be estimated or calculated and attention must be given to not over-purging the estimated or calculated volume of the tubing and sample interval prior to sampling. Line purging can be accomplished using a low-flow pump, such as a personal air sampling pump, or a TVA1000. After all stagnant/ambient air has been removed, the purging pump is removed and an evacuated canister is attached using a Swagelok® or other suitable secure connection. After connection, the valve on the canister is opened, pulling soil gas from the implant into the canister. Typically the sample is collected over a one-hour period, at which time the canister valve is closed and the canister tagged with pertinent sampling information. Alternatively, in some situations a mass-flow controller will be required to collect a sample over a specified, longer period of time period. This type of sampler is typically out-fitted with a gauge that will display the canister vacuum during the sampling period. When using this type of device, it is advisable to check the canister vacuum throughout the sampling period to verify filling Gauge pressure/vacuum reading should be recorded in the project logbook.  Real-time Field Analytical Methods – Real-time analytical measurements may be obtained from PRT or soil gas implant installations using appropriate instrumentation. The soil gas to be analyzed may be drawn directly into the instrument by the instrument pump or the instrument may be placed in line and the sample drawn into the instrument using a suitable pump connected to the discharge side of the instrument. Results may be qualitative, such as those obtained with flame ionization or photoionization detectors, or they may be quantitative, for instruments which can be calibrated to specific compounds. COPY Appendix E USEPA SESD Procedure for Soil Sampling (SESDPROC-300-R3) COPY ______________________________________________________________________________________ SESD Operating Procedure Page 2 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 Revision History The top row of this table shows the most recent changes to this controlled document. For previous revision history information, archived versions of this document are maintained by the SESD Document Control Coordinator on the SESD local area network (LAN). History Effective Date SESDPROC-300-R3, Soil Sampling, replaces SESDPROC-300-R2. General: Corrected any typographical, grammatical and/or editorial errors. Title Page: Updated the author from Fred Sloan to Kevin Simmons. Updated the Enforcement and Investigations Branch Chief from Archie Lee to Acting Chief, John Deatrick. Section 1.5.1: Added “The reader should” to last sentence of the paragraph. Section 1.5.2: Omitted “When sampling in landscaped areas,” from first sentence of eighth bullet. Section 3.2.4: In the first paragraph, first sentence, added “(rapidly form bubbles).” Omitted “(rapidly form bubbles)” from second paragraph, second sentence. Any reference to “Percent Moisture and Preservation Compatibility (MOICA)” or “Percent Moisture” was changed to “Percent Solids”, both in the text and in Table 1. August 21, 2014 SESDPROC-300-R2, Soil Sampling, replaces SESDPROC-300-R1. December 20, 2011 SESDPROC-300-R1, Soil Sampling, replaces SESDPROC-300-R0. November 1, 2007 SESDPROC-300-R0, Soil Sampling, Original Issue February 05, 2007 COPY ______________________________________________________________________________________ SESD Operating Procedure Page 3 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 TABLE OF CONTENTS 1 General Information ................................................................................................. 5 1.1 Purpose................................................................................................................ 5 1.2 Scope/Application .............................................................................................. 5 1.3 Documentation/Verification .............................................................................. 5 1.4 References ........................................................................................................... 5 1.5 General Precautions........................................................................................... 6 1.5.1 Safety ............................................................................................................ 6 1.5.2 Procedural Precautions ............................................................................... 6 2 Special Sampling Considerations ............................................................................ 8 2.1 Special Precautions for Trace Contaminant Soil Sampling ........................... 8 2.2 Sample Homogenization .................................................................................... 8 2.3 Dressing Soil Surfaces........................................................................................ 9 2.4 Quality Control .................................................................................................. 9 2.5 Records................................................................................................................ 9 3 Method 5035 ............................................................................................................ 10 3.1 Soil Samples for Volatile Organic Compounds (VOC) Analysis ................. 10 3.2 Soil Sampling (Method 5035) .......................................................................... 10 3.2.1 Equipment .................................................................................................. 10 3.2.2 Sampling Methodology - Low Concentrations (<200 µg/kg) ................... 10 3.2.3 Sampling Methodology - High Concentrations (>200 µg/kg) .................. 11 3.2.4 Special Techniques and Considerations for Method 5035 ....................... 12 4 Manual Soil Sampling Methods ............................................................................. 15 4.1 General .............................................................................................................. 15 4.2 Spoons ............................................................................................................... 15 4.2.1 Special Considerations When Using Spoons ............................................ 15 4.3 Hand Augers ..................................................................................................... 15 4.3.1 Surface Soil Sampling ............................................................................... 16 4.3.2 Subsurface Soil Sampling .......................................................................... 16 4.3.3 Special Considerations for Soil Sampling with the Hand Auger ............. 16 5 Direct Push Soil Sampling Methods ..................................................................... 17 5.1 General .............................................................................................................. 17 5.2 Large Bore® Soil Sampler .............................................................................. 17 5.3 Macro-Core® Soil Sampler ............................................................................. 17 5.4 Dual Tube Soil Sampling System ................................................................... 18 5.5 Special Considerations When Using Direct Push Sampling Methods ........ 18 6 Split Spoon/Drill Rig Methods ............................................................................... 20 6.1 General .............................................................................................................. 20 6.2 Standard Split Spoon ....................................................................................... 20 6.3 Continuous Split Spoon ................................................................................... 20 6.4 Special Considerations When Using Split Spoon Sampling Methods ......... 21 7 Shelby Tube/Thin-Walled Sampling Methods ..................................................... 22 7.1 General .............................................................................................................. 22 COPY ______________________________________________________________________________________ SESD Operating Procedure Page 4 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 7.2 Shelby Tube Sampling Method....................................................................... 22 7.3 Special Considerations When Using Split Spoon Sampling Methods ......... 22 8 Backhoe Sampling Method .................................................................................... 23 8.1 General .............................................................................................................. 23 8.2 Scoop-and-Bracket Method ............................................................................ 23 8.3 Direct-from-Bucket Method ........................................................................... 23 8.4 Special Considerations When Sampling with a Backhoe ............................. 23 TABLES Table 1: Method 5035 Summary .................................................................................. 14 COPY ______________________________________________________________________________________ SESD Operating Procedure Page 5 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 1 General Information 1.1 Purpose This document describes general and specific procedures, methods and considerations to be used and observed when collecting soil samples for field screening or laboratory analysis. 1.2 Scope/Application The procedures contained in this document are to be used by field personnel when collecting and handling soil samples in the field. On the occasion that SESD field personnel determine that any of the procedures described in this section are inappropriate, inadequate or impractical and that another procedure must be used to obtain a soil sample, the variant procedure will be documented in the field logbook and subsequent investigation report, along with a description of the circumstances requiring its use. Mention of trade names or commercial products in this operating procedure does not constitute endorsement or recommendation for use. 1.3 Documentation/Verification This procedure was prepared by persons deemed technically competent by SESD management, based on their knowledge, skills and abilities and have been tested in practice and reviewed in print by a subject matter expert. The official copy of this procedure resides on the SESD local area network (LAN). The Document Control Coordinator (DCC) is responsible for ensuring the most recent version of the procedure is placed on the LAN, and for maintaining records of review conducted prior to its issuance. 1.4 References International Air Transport Authority (IATA). Dangerous Goods Regulations, Most Recent Version SESD Operating Procedure for Field Equipment Cleaning and Decontamination, SESDPROC-205, Most Recent Version SESD Operating Procedure for Field Equipment Cleaning and Decontamination at the FEC, SESDPROC-206, Most Recent Version SESD Operating Procedure for Field Sampling Quality Control, SESDPROC-011, Most Recent Version COPY ______________________________________________________________________________________ SESD Operating Procedure Page 6 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 SESD Operating Procedure for Field X-Ray Fluorescence (XRF) Measurement, SESDPROC-107, Most Recent Version SESD Operating Procedure for Logbooks, SESDPROC-010, Most Recent Version SESD Operating Procedure for Sample and Evidence Management, SESDPROC-005, Most Recent Version Title 49 Code of Federal Regulations, Pts. 171 to 179, Most Recent Version US EPA Test Methods for Evaluating Solid Waste, Physical/Chemical Methods SW-846, Most Recent Version (Method 5035) US EPA. Safety, Health and Environmental Management Program (SHEMP) Procedures and Policy Manual. Region 4 SESD, Athens, GA, Most Recent Version 1.5 General Precautions 1.5.1 Safety Proper safety precautions must be observed when collecting soil samples. Refer to the SESD Safety, Health and Environmental Management Program (SHEMP) Procedures and Policy Manual and any pertinent site-specific Health and Safety Plans (HASP) for guidelines on safety precautions. These guidelines, however, should only be used to complement the judgment of an experienced professional. The reader should address chemicals that pose specific toxicity or safety concerns and follow any other relevant requirements, as appropriate. 1.5.2 Procedural Precautions The following precautions should be considered when collecting soil samples:  Special care must be taken not to contaminate samples. This includes storing samples in a secure location to preclude conditions which could alter the properties of the sample. Samples shall be custody sealed during long-term storage or shipment.  Collected samples are in the custody of the sampler or sample custodian until the samples are relinquished to another party.  If samples are transported by the sampler, they will remain under his/her custody or be secured until they are relinquished.  Shipped samples shall conform to all U.S. Department of Transportation (DOT) rules of shipment found in Title 49 of the Code of Federal Regulations (49 CFR parts 171 to 179), and/or International Air Transportation Association COPY ______________________________________________________________________________________ SESD Operating Procedure Page 7 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 (IATA) hazardous materials shipping requirements found in the current edition of IATA’s Dangerous Goods Regulations.  Documentation of field sampling is done in a bound logbook.  Chain-of-custody documents shall be filled out and remain with the samples until custody is relinquished.  All shipping documents, such as air bills, bills of lading, etc., shall be retained by the project leader in the project files.  Sampling in landscaped areas: Cuttings should be placed on plastic sheeting and returned to the borehole upon completion of the sample collection. Any ‘turf plug’ generated during the sampling process should be returned to the borehole.  Sampling in non-landscaped areas: Return any unused sample material back to the auger, drill or push hole from which the sample was collected. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 8 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 2 Special Sampling Considerations 2.1 Special Precautions for Trace Contaminant Soil Sampling  A clean pair of new, non-powdered, disposable gloves will be worn each time a different sample is collected and the gloves should be donned immediately prior to sampling. The gloves should not come in contact with the media being sampled and should be changed any time during sample collection when their cleanliness is compromised.  Sample containers with samples suspected of containing high concentrations of contaminants shall be handled and stored separately.  All background samples shall be segregated from obvious high-concentration or waste samples. Sample collection activities shall proceed progressively from the least suspected contaminated area to the most suspected contaminated area. Samples of waste or highly-contaminated media must not be placed in the same ice chest as environmental (i.e., containing low contaminant levels) or background samples.  If possible, one member of the field sampling team should take all the notes and photographs, fill out tags, etc., while the other member(s) collect the samples.  Samplers must use new, verified/certified-clean disposable or non-disposable equipment cleaned according to procedures contained in the SESD Operating Procedure for Field Equipment Cleaning and Decontamination (SESDPROC-205), for collection of samples for trace metals or organic compound analyses. 2.2 Sample Homogenization 1. If sub-sampling of the primary sample is to be performed in the laboratory, transfer the entire primary sample directly into an appropriate, labeled sample container(s). Proceed to step 4. 2. If sub-sampling the primary sample in the field or compositing multiple primary samples in the field, place the sample into a glass or stainless steel homogenization container and mix thoroughly. Each aliquot of a composite sample should be of the same approximate volume. 3. All soil samples must be thoroughly mixed to ensure that the sample is as representative as possible of the sample media. Samples for VOC analysis are not homogenized. The most common method of mixing is referred to as quartering. The quartering procedure should be performed as follows: COPY ______________________________________________________________________________________ SESD Operating Procedure Page 9 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014  The material in the sample pan should be divided into quarters and each quarter should be mixed individually.  Two quarters should then be mixed to form halves.  The two halves should be mixed to form a homogenous matrix. This procedure should be repeated several times until the sample is adequately mixed. If round bowls are used for sample mixing, adequate mixing is achieved by stirring the material in a circular fashion, reversing direction, and occasionally turning the material over. 4. Place the sample into an appropriate, labeled container(s) by using the alternate shoveling method and secure the cap(s) tightly. The alternate shoveling method involves placing a spoonful of soil in each container in sequence and repeating until the containers are full or the sample volume has been exhausted. Threads on the container and lid should be cleaned to ensure a tight seal when closed. 2.3 Dressing Soil Surfaces Any time a vertical or near vertical surface is sampled, such as achieved when shovels or similar devices are used for subsurface sampling, the surface should be dressed (scraped) to remove smeared soil. This is necessary to minimize the effects of contaminant migration interferences due to smearing of material from other levels. 2.4 Quality Control If possible, a control sample should be collected from an area not affected by the possible contaminants of concern and submitted with the other samples. This control sample should be collected as close to the sampled area as possible and from the same soil type. Equipment blanks should be collected if equipment is field cleaned and re-used on-site or if necessary to document that low-level contaminants were not introduced by sampling tools. SESD Operating Procedure for Field Sampling Quality Control (SESDPROC-011) contains other procedures that may be applicable to soil sampling investigations. 2.5 Records Field notes, recorded in a bound field logbook, as well as chain-of-custody documentation will be generated as described in the SESD Operating Procedure for Logbooks (SESDPROC-010) and the SESD Operating Procedure for Sample and Evidence Management (SESDPROC-005). COPY ______________________________________________________________________________________ SESD Operating Procedure Page 10 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 3 Method 5035 The procedures outlined here are summarized from Test Methods for Evaluating Solid Waste, Physical/Chemical Methods SW-846, Method 5035. 3.1 Soil Samples for Volatile Organic Compounds (VOC) Analysis If samples are to be analyzed for VOCs, they should be collected in a manner that minimizes disturbance of the sample. For example, when sampling with an auger bucket, the sample for VOC analysis should be collected directly from the auger bucket (preferred) or from minimally disturbed material immediately after an auger bucket is emptied into the pan. The sample shall be containerized by filling an En Core® Sampler or other Method 5035 compatible container. Samples for VOC analysis are not homogenized. Preservatives may be required for some samples with certain variations of Method 5035. Consult the method or the principal analytical chemist to determine if preservatives are necessary. 3.2 Soil Sampling (Method 5035) The following sampling protocol is recommended for site investigators assessing the extent of VOCs in soils at a project site. Because of the large number of options available, careful coordination between field and laboratory personnel is needed. The specific sampling containers and sampling tools required will depend upon the detection levels and intended data use. Once this information has been established, selection of the appropriate sampling procedure and preservation method best applicable to the investigation can be made. 3.2.1 Equipment Soil for VOC analyses may be retrieved using any of the SESD soil sampling methods described in Sections 4 through 8 of this procedure. Once the soil has been obtained, the En Core® Sampler, syringes, stainless steel spatula, standard 2-oz. soil VOC container, or pre-prepared 40 mL vials may be used/required for sub-sampling. The specific sample containers and the sampling tools required will depend upon the data quality objectives established for the site or sampling investigation. The various sub-sampling methods are described below. 3.2.2 Sampling Methodology - Low Concentrations (<200 µg/kg) When the total VOC concentration in the soil is expected to be less than 200 µg/kg, the samples may be collected directly with the En Core® Sampler or syringe. If using the syringes, the sample must be placed in the sample container (40 mL pre-prepared vial) immediately to reduce volatilization losses. The 40 mL vials should contain 10 mL of organic-free water for an un-preserved sample or approximately COPY ______________________________________________________________________________________ SESD Operating Procedure Page 11 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 10 mL of organic-free water and a preservative. It is recommended that the 40 mL vials be prepared and weighed by the laboratory (commercial sources are available which supply preserved and tared vials). When sampling directly with the En Core® Sampler, the vial must be immediately capped and locked. A soil sample for VOC analysis may also be collected with conventional sampling equipment. A sample collected in this fashion must either be placed in the final sample container (En Core® Sampler or 40 mL pre-prepared vial) immediately or the sample may be immediately placed into an intermediate sample container with no head space. If an intermediate container (usually 2-oz. soil jar) is used, the sample must be transferred to the final sample container (En Core® Sampler or 40 mL pre-prepared vial) as soon as possible, not to exceed 30 minutes. NOTE: After collection of the sample into either the En Core® Sampler or other container, the sample must immediately be stored in an ice chest and cooled. Soil samples may be prepared for shipping and analysis as follows: En Core® Sampler - the sample shall be capped, locked, and secured in the original foil bag. All foil bags containing En Core® samplers are then placed in a plastic bag and sealed with custody tape, if required. Syringe - Add about 3.7 cc (approximately 5 grams) of sample material to 40-mL pre-prepared containers. Secure the containers in a plastic bag. Do not use a custody seal on the container; place the custody seal on the plastic bag. Note: When using the syringes, it is important that no air is allowed to become trapped behind the sample prior to extrusion, as this will adversely affect the sample. Stainless Steel Laboratory Spatulas - Add between 4.5 and 5.5 grams (approximate) of sample material to 40 mL containers. Secure the containers in a plastic bag. Do not use a custody seal on the container; place the custody seal on the plastic bag. 3.2.3 Sampling Methodology - High Concentrations (>200 µg/kg) Based upon the data quality objectives and the detection level requirements, this high level method may also be used. Specifically, the sample may be packed into a single 2-oz. glass container with a screw cap and septum seal. The sample container must be filled quickly and completely to eliminate head space. Soils\sediments containing high total VOC concentrations may also be collected as described in Section 3.2.2, Sampling Methodology - Low Concentrations, and preserved using 10 mL methanol. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 12 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 3.2.4 Special Techniques and Considerations for Method 5035 Effervescence If low concentration samples effervesce (rapidly form bubbles) from contact with the acid preservative, then either a test for effervescence must be performed prior to sampling, or the investigators must be prepared to collect each sample both preserved or un-preserved, as needed, or all samples must be collected unpreserved. To check for effervescence, collect a test sample and add to a pre-preserved vial. If preservation (acidification) of the sample results in effervescence then preservation by acidification is not acceptable, and the sample must be collected un-preserved. If effervescence occurs and only pre-preserved sample vials are available, the preservative solution may be placed into an appropriate hazardous waste container and the vials triple rinsed with organic free water. An appropriate amount of organic free water, equal to the amount of preservative solution, should be placed into the vial. The sample may then be collected as an un-preserved sample. Note: the amount of organic free water placed into the vials will have to be accurately measured. Sample Size While this method is an improvement over earlier ones, field investigators must be aware of an inherent limitation. Because of the extremely small sample size and the lack of sample mixing, sample representativeness for VOCs may be reduced compared to samples with larger volumes collected for other constituents. The sampling design and objectives of the investigation should take this into consideration. Holding Times Sample holding times are specified in the Analytical Support Branch Laboratory Operations and Quality Assurance Manual (ASBLOQAM), Most Recent Version. Field investigators should note that the holding time for an un-preserved VOC soil/sediment sample on ice is 48 hours. Arrangements should be made to ship the soil/sediment VOC samples to the laboratory by overnight delivery the day they are collected so the laboratory may preserve and/or analyze the sample within 48 hours of collection. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 13 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 Percent Solids Samplers must ensure that the laboratory has sufficient material to determine percent solids in the VOC soil/sediment sample to correct the analytical results to dry weight. If other analyses requiring percent solids determination are being performed upon the sample, these results may be used. If not, a separate sample (minimum of 2 oz.) for percent solids determination will be required. The sample collected for percent solids may also be used by the laboratory to check for preservative compatibility. Safety Methanol is a toxic and flammable liquid. Therefore, methanol must be handled with all required safety precautions related to toxic and flammable liquids. Inhalation of methanol vapors must be avoided. Vials should be opened and closed quickly during the sample preservation procedure. Methanol must be handled in a ventilated area. Use protective gloves when handling the methanol vials. Store methanol away from sources of ignition such as extreme heat or open flames. The vials of methanol should be stored in a cooler with ice at all times. Shipping Methanol and sodium bisulfate are considered dangerous goods, therefore shipment of samples preserved with these materials by common carrier is regulated by the U.S. Department of Transportation and the International Air Transport Association (IATA). The rules of shipment found in Title 49 of the Code of Federal Regulations (49 CFR parts 171 to 179) and the current edition of the IATA Dangerous Goods Regulations must be followed when shipping methanol and sodium bisulfate. Consult the above documents or the carrier for additional information. Shipment of the quantities of methanol and sodium bisulfate used for sample preservation falls under the exemption for small quantities. The summary table on the following page lists the options available for compliance with SW846 Method 5035. The advantages and disadvantages are noted for each option. SESD’s goal is to minimize the use of hazardous material (methanol and sodium bisulfate) and minimize the generation of hazardous waste during sample collection. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 14 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 Table 1: Method 5035 Summary OPTION PROCEDURE ADVANTAGES DISADVANTAGES 1 Collect two 40 mL vials with ≈ 5 grams of sample, and one 2 oz. glass jar w/septum lid for screening, % moisture and preservative compatibility. Screening conducted by lab. Presently a 48-hour holding time for unpreserved samples. Sample containers must be tared. 2 Collect three En Core® samplers, and one 2 oz. glass jar w/septum lid for screening, % solids. Lab conducts all preservation/preparation procedures. Presently a 48- hour holding time for preparation of samples. 3 Collect two 40 mL vials with 5 grams of sample and preserve w/methanol or sodium bisulfate, and one 2-oz. glass jar w/septum lid for screening, % solids . High level VOC samples may be composited. Longer holding time. Hazardous materials used in the field. Sample containers must be tared. 4 Collect one 2-oz. glass jar w/septum lid for analysis, % solids (high level VOC only). Lab conducts all preservation/preparation procedures. May have significant VOC loss. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 15 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 4 Manual Soil Sampling Methods 4.1 General These methods are used primarily to collect surface and shallow subsurface soil samples. Surface soils are generally classified as soils between the ground surface and 6 to 12 inches below ground surface. The most common interval is 0 to 6 inches; however, the data quality objectives of the investigation may dictate another interval, such as 0 to 3 inches for risk assessment purposes. The shallow subsurface interval may be considered to extend from approximately 12 inches below ground surface to a site-specific depth at which sample collection using manual collection methods becomes impractical. If a thick, matted root zone, gravel, concrete, etc. is present at or near the surface, it should be removed before the sample is collected. The depth measurement for the sample begins at the top of the soil horizon, immediately following any removed materials. When compositing, make sure that each composite location (aliquot) consist of equal volumes, i.e., same number of equal spoonfuls. 4.2 Spoons Stainless steel spoons may be used for surface soil sampling to depths of approximately 6 inches below ground surface where conditions are generally soft and non-indurated, and there is no problematic vegetative layer to penetrate. 4.2.1 Special Considerations When Using Spoons  When using stainless steel spoons, consideration must be given to the procedure used to collect the volatile organic compound sample. If the soil being sampled is cohesive and holds its in situ texture in the spoon, the En Core® Sampler or syringe used to collect the sub-sample for Method 5035 should be plugged directly from the spoon. If, however, the soil is not cohesive and crumbles when removed from the ground surface for sampling, consideration should be given to plugging the sample for Method 5035 directly from the ground surface at a depth appropriate for the investigation Data Quality Objectives. 4.3 Hand Augers Hand augers may be used to advance boreholes and collect soil samples in the surface and shallow subsurface intervals. Typically, 4-inch stainless steel auger buckets with cutting heads are used. The bucket is advanced by simultaneously pushing and turning using an attached handle with extensions (if needed). COPY ______________________________________________________________________________________ SESD Operating Procedure Page 16 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 4.3.1 Surface Soil Sampling When conducting surface soil sampling with hand augers, the auger buckets may be used with a handle alone or with a handle and extensions. The bucket is advanced to the appropriate depth and the contents are transferred to the homogenization container for processing. Observe precautions for volatile organic compound sample collection found in Section 3, Method 5035. 4.3.2 Subsurface Soil Sampling Hand augers are the most common equipment used to collect shallow subsurface soil samples. Auger holes are advanced one bucket at a time until the sample depth is achieved. When the sample depth is reached, the bucket used to advance the hole is removed and a clean bucket is attached. The clean auger bucket is then placed in the hole and filled with soil to make up the sample and removed. The practical depth of investigation using a hand auger depends upon the soil properties and depth of investigation. In sand, augering is usually easily performed, but the depth of collection is limited to the depth at which the sand begins to flow or collapse. Hand augers may also be of limited use in tight clays or cemented sands. In these soil types, the greater the depth attempted, the more difficult it is to recover a sample due to increased friction and torqueing of the hand auger extensions. At some point these problems become so severe that power equipment must be used. 4.3.3 Special Considerations for Soil Sampling with the Hand Auger  Because of the tendency for the auger bucket to scrape material from the sides of the auger hole while being extracted, the top several inches of soil in the auger bucket should be discarded prior to placing the bucket contents in the homogenization container for processing.  Observe precautions for volatile organic compound (VOC) sample collection found in Section 3, Method 5035. Collect the VOC sample directly from the auger bucket, if possible.  Power augers, such as the Little Beaver® and drill rigs may be used to advance boreholes to depths for subsurface soil sampling with the hand auger. They may not be used for sample collection. When power augers are used to advance a borehole to depth for sampling, care must be taken that exhaust fumes, gasoline and/or oil do not contaminate the borehole or area in the immediate vicinity of sampling.  When moving to a new sampling location, the entire hand auger assembly must be replaced with a properly decontaminated hand auger assembly. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 17 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 5 Direct Push Soil Sampling Methods 5.1 General These methods are used primarily to collect shallow and deep subsurface soil samples. Three samplers are available for use within the Division’s direct push tooling inventory. All of the sampling tools involve the collection and retrieval of the soil sample within a thin-walled liner. The following sections describe each of the specific sampling methods that can be accomplished using direct push techniques, along with details specific to each method. While SESD currently uses the sample tooling described, tooling of similar design and materials is acceptable. If gravel, concrete, etc. is present at or near the surface, it should be removed before the sample is collected. The depth measurement for the sample begins at the top of the soil horizon, immediately following any removed materials. Turf grass is not typically removed prior to sampling with these devices. 5.2 Large Bore® Soil Sampler The Large Bore® (LB) sampler is a solid barrel direct push sampler equipped with a piston-rod point assembly used primarily for collection of depth-discrete subsurface soil samples. The sample barrel is approximately 30-inches (762 mm) long and has a 1.5-inch (38 mm) outside diameter. The LB® sampler is capable of recovering a discrete sample core 22 inches x 1.0 inch (559 mm x 25 mm) contained inside a removable liner. The resultant sample volume is a maximum of 283 mL. After the LB® sample barrel is equipped with the cutting shoe and liner, the piston-rod point assembly is inserted, along with the drive head and piston stop assembly. The assembled sampler is driven to the desired sampling depth, at which time the piston stop pin is removed, freeing the push point. The LB® sampler is then pushed into the soil a distance equal to the length of the LB® sample barrel. The probe rod string, with the LB® sampler attached, is then removed from the subsurface. After retrieval, the LB® sampler is then removed from the probe rod string. The drive head is then removed to allow removal of the liner and soil sample. 5.3 Macro-Core® Soil Sampler The Macro-Core® (MC) sampler is a solid barrel direct push sampler equipped with a piston-rod point assembly used primarily for collection of either continuous or depth- discrete subsurface soil samples. Although other lengths are available, the standard MC® sampler has an assembled length of approximately 52 inches (1321 mm) with an outside diameter of 2.2 inches (56 mm). The MC® sampler is capable of recovering a discrete sample core 45 inches x 1.5 inches (1143 mm x 38 mm) contained inside a removable liner. The resultant sample volume is a maximum of 1300 mL. The MC® sampler may be used COPY ______________________________________________________________________________________ SESD Operating Procedure Page 18 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 in either an open-tube or closed-point configuration. Although the MC® sampler can be used as an open-barrel sampler, in SESD usage, the piston point is always used to prevent the collection of slough from the borehole sides. 5.4 Dual Tube Soil Sampling System The Dual Tube 21 soil sampling system is a direct push system for collecting continuous core samples of unconsolidated materials from within a sealed outer casing of 2.125-inch (54 mm) OD probe rod. The samples are collected within a liner that is threaded onto the leading end of a string of 1.0-inch diameter probe rod. Collected samples have a volume of up to 800 mL in the form of a 1.125-inch x 48-inch (29 mm x 1219 mm) core. Use of this method allows for collection of continuous core inside a cased hole, minimizing or preventing cross-contamination between different intervals during sample collection. The outer casing is advanced, one core length at a time, with only the inner probe rod and core being removed and replaced between samples. If the sampling zone of interest begins at some depth below ground surface, a solid drive tip must be used to drive the dual tube assembly and core to its initial sample depth. 5.5 Special Considerations When Using Direct Push Sampling Methods  Liner Use and Material Selection – Direct Push Soil Samples are collected within a liner to facilitate removal of sample material from the sample barrel. The liners may only be available in a limited number of materials for a given sample tool, although overall, liners are available in brass, stainless steel, cellulose acetate butyrate (CAB), polyethylene terepthalate glycol (PETG), polyvinyl chloride (PVC) and Teflon®. For most SESD investigations, the standard polymer liner material for a sampling tool will be acceptable. When the study objectives require very low reporting levels or unusual contaminants of concern, the use of more inert liner materials such as Teflon® or stainless steel may be necessary.  Sample Orientation – When the liners and associated sample are removed from the sample tubes, it is important to maintain the proper orientation of the sample. This is particularly important when multiple sample depths are collected from the same push. It is also important to maintain proper orientation to define precisely the depth at which an aliquot was collected. Maintaining proper orientation is typically accomplished using vinyl end caps. Convention is to place red caps on the top of the liner and black caps on the bottom to maintain proper sample orientation. Orientation can also be indicated by marking on the exterior of the liner with a permanent marker.  Core Catchers – Occasionally the material being sampled lacks cohesiveness and is subject to crumbling and falling out of the sample liner. In cases such as these, the use of core catchers on the leading end of the sampler may help COPY ______________________________________________________________________________________ SESD Operating Procedure Page 19 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 retain the sample until it is retrieved to the surface. Core catchers may only be available in specific materials and should be evaluated for suitability. However, given the limited sample contact that core-catchers have with the sample material, most standard core-catchers available for a tool system will be acceptable.  Decontamination – The cutting shoe and piston rod point are to be decontaminated between each sample, using the procedures specified for the collection of trace organic and inorganic compounds found in Field Equipment and Decontamination – SESDPROC-205, most recent version. Within a borehole, the sample barrel, rods, and drive head may be subjected to an abbreviated cleaning to remove obvious and loose material, but must be cleaned between boreholes using the procedures specified for downhole drilling equipment in Field Equipment and Decontamination – SESDPROC-205, most recent version.  Decommissioning – Boreholes must be decommissioned after the completion of sampling. Boreholes less than 10 feet deep that remain open and do not approach the water table may be decommissioned by pouring 30% solids bentonite grout from the surface or pouring bentonite pellets from the surface, hydrating the pellets in lifts. Boreholes deeper than 10 feet, or any borehole that intercepts groundwater, must be decommissioned by pressure grouting with 30% solids bentonite grout, either through a re-entry tool string or through tremie pipe introduced to within several feet of the borehole bottom.  VOC Sample Collection – Observe precautions for volatile organic compound sample collection found in Section 3 of this procedure. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 20 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 6 Split Spoon/Drill Rig Methods 6.1 General Split spoon sampling methods are used primarily to collect shallow and deep subsurface soil samples. All split spoon samplers, regardless of size, are basically split cylindrical barrels that are threaded on each end. The leading end is held together with a beveled threaded collar that functions as a cutting shoe. The other end is held together with a threaded collar that serves as the sub used to attach the spoon to the string of drill rod. Two basic methods are available for use, including the smaller diameter standard split spoon, driven with the drill rig safety hammer, and the larger diameter continuous split spoon, advanced inside and slightly ahead of the lead auger during hollow stem auger drilling. The following sections describe each of the specific sampling methods, along with details specific to each method. If gravel, concrete, etc. is present at or near the surface, it should be removed before the sample is collected. The depth measurement for the sample begins at the top of the soil horizon, immediately following any removed materials. Turf grass is not typically removed prior to sampling with these devices. 6.2 Standard Split Spoon A drill rig is used to advance a borehole to the target depth. The drill string is then removed and a standard split spoon is attached to a string of drill rod. Split spoons used for soil sampling must be constructed of stainless steel and are typically 2.0-inches OD (1.5-inches ID) and 18-inches to 24-inches in length. Other diameters and lengths are common and may be used if constructed of the proper material. After the spoon is attached to the string of drill rod, it is lowered into the borehole. The safety hammer is then used to drive the split spoon into the soil at the bottom of the borehole. After the split spoon has been driven into the soil, filling the spoon, it is retrieved to the surface, where it is removed from the drill rod string and opened for sample acquisition. 6.3 Continuous Split Spoon The continuous split spoon is a large diameter split spoon that is advanced into the soil column inside a hollow stem auger. Continuous split spoons are typically 3 to 5 inches in diameter and either 5 feet or 10 feet in length, although the 5-foot long samplers are most common. After the auger string has been advanced into the soil column a distance equal to the length of the sampler being used it is returned to the surface. The sampler is removed from inside the hollow stem auger and the threaded collars are removed. The split spoon is then opened for sampling. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 21 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 6.4 Special Considerations When Using Split Spoon Sampling Methods  Always discard the top several inches of material in the spoon before removing any portion for sampling. This material normally consists of borehole wall material that has sloughed off of the borehole wall after removal of the drill string prior to and during inserting the split spoon.  Observe precautions for volatile organic compound sample collection found in Section 3, Method 5035. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 22 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 7 Shelby Tube/Thin-Walled Sampling Methods 7.1 General Shelby tubes, also referred to generically as thin-walled push tubes or Acker thin-walled samplers, are used to collect subsurface soil samples in cohesive soils and clays during drilling activities. In addition to samples for chemical analyses, Shelby tubes are also used to collect relatively undisturbed soil samples for geotechnical analyses, such as hydraulic conductivity and permeability, to support hydrogeologic characterizations at hazardous waste and other sites. If gravel, concrete, etc. is present at or near the surface, it should be removed before the sample is collected. The depth measurement for the sample begins at the top of the soil horizon, immediately following any removed materials. Turf grass is not typically removed prior to sampling with this device. 7.2 Shelby Tube Sampling Method A typical Shelby tube is 30 inches in length and has a 3.0-inch OD (2.875-inch ID) and may be constructed of steel, stainless steel, galvanized steel, or brass. They also typically are attached to push heads that are constructed with a ball-check to aid in holding the contained sample during retrieval. If used for collecting samples for chemical analyses, it must be constructed of stainless steel. If used for collecting samples for standard geotechnical parameters, any material is acceptable. To collect a sample, the tube is attached to a string of drill rod and is lowered into the borehole, where the sampler is then pressed into the undisturbed material by hydraulic force. After retrieval to the surface, the tube containing the sample is then removed from the sampler head. If samples for chemical analyses are needed, the soil contained inside the tube is then removed for sample acquisition. If the sample is collected for geotechnical parameters, the tube is typically capped, maintaining the sample in its relatively undisturbed state, and shipped to the appropriate geotechnical laboratory. 7.3 Special Considerations When Using Split Spoon Sampling Methods Observe precautions for volatile organic compound sample collection found in Section 3, Method 5035. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 23 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014 8 Backhoe Sampling Method 8.1 General Backhoes may be used in the collection of surface and shallow subsurface soil samples. The trenches created by excavation with a backhoe offer the capability of collecting samples from very specific intervals and allow visual correlation with vertically and horizontally adjacent material. If possible, the sample should be collected without entering the trench. Samples may be obtained from the trench wall or they may be obtained directly from the bucket at the surface. The following sections describe various techniques for safely collecting representative soil samples with the aid of a backhoe. The depth measurement for the sample begins at the top of the soil horizon. 8.2 Scoop-and-Bracket Method If a sample interval is targeted from the surface, it can be sampled using a stainless steel scoop and bracket. First a scoop and bracket are affixed to a length of conduit and is lowered into the backhoe pit. The first step is to take the scoop and scrape away the soil comprising the surface of the excavated wall. This material likely represents soil that has been smeared by the backhoe bucket from adjacent material. After the smeared material has been scraped off, the original stainless steel scoop is removed and a clean stainless steel scoop is placed on the bracket. The clean scoop can then be used to remove sufficient volume of soil from the excavation wall to make up the required sample volume. 8.3 Direct-from-Bucket Method It is also possible to collect soil samples directly from the backhoe bucket at the surface. Some precision with respect to actual depth or location may be lost with this method but if the soil to be sampled is uniquely distinguishable from the adjacent or nearby soils, it may be possible to characterize the material as to location and depth. In order to ensure representativeness, it is also advisable to dress the surface to be sampled by scraping off any smeared material that may cross-contaminate the sample. 8.4 Special Considerations When Sampling with a Backhoe  Do not physically enter backhoe excavations to collect a sample. Use either procedure 8.2, Scoop-and-Bracket Method, or procedure 8.3, Direct-from- Bucket Method to obtain soil for sampling.  Smearing is an important issue when sampling with a backhoe. Measures must be taken, such as dressing the surfaces to be sampled (see Section 2.3), to mitigate problems with smearing. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 24 of 24 SESDPROC-300-R3 Soil Sampling Soil Sampling(300)_AF.R3 Effective Date: August 21, 2014  Paint, grease and rust must be removed and the bucket decontaminated prior to sample collection.  Observe precautions for volatile organic compound sample collection found in Section 3, Method 5035. COPY Appendix F USEPA SESD Procedure for Field Equipment Cleaning and Decontamination (SESDPROC-205-R3) COPY SESD Operating Procedure Page 2 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 Revision History The top row of this table shows the most recent changes to this controlled document. For previous revision history information, archived versions of this document are maintained by the SESD Document Control Coordinator on the SESD local area network (LAN). History Effective Date SESDPROC-205-R3, Field Equipment Cleaning and Decontamination, replaces SESDPROC-205-R2. Cover Page: The author was changed to Brian Striggow. SESD’s reorganization was reflected in the authorization section by making John Deatrick the Chief of the Field Services Branch. The FQM was changed from Bobby Lewis to Hunter Johnson. Revision History: Changes were made to reflect the current practice of only including the most recent changes in the revision history. General: Corrected any typographical, grammatical and/or editorial errors. Section 1.4: Differentiate between Liquinox® and Luminox® detergents. Section 3.4: Restore solvent rinse as alternative cleaning method. Section 3.7: Added section on cleaning of 12 Volt electric submersible pumps. Section 3.8: Added section on cleaning of bladder pumps. Section 3.9: Added language on cleaning and transport of SP15/16 screens Section 3.10: Added section on cleaning of rental pumps December 18, 2015 SESDPROC-205-R2, Field Equipment Cleaning and Decontamination, replaces SESDPROC-205-R1. December 20, 2011 SESDPROC-205-R1, Field Equipment Cleaning and Decontamination, replaces SESDPROC-205-R0. November 1, 2007 SESDPROC-205-R0, Field Equipment Cleaning and Decontamination, Original Issue February 05, 2007 COPY SESD Operating Procedure Page 3 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 TABLE OF CONTENTS 1 General Information ................................................................................................. 4 1.1 Purpose................................................................................................................ 4 1.2 Scope/Application .............................................................................................. 4 1.3 Documentation/Verification .............................................................................. 4 1.4 Definitions ........................................................................................................... 4 1.5 References ........................................................................................................... 5 1.6 General Precautions........................................................................................... 6 1.6.1 Safety ............................................................................................................ 6 1.6.2 Procedural Precaution ................................................................................ 6 2 Introduction to Field Equipment Cleaning and Decontamination ...................... 7 2.1 General ................................................................................................................ 7 2.2 Handling Practices and Containers for Cleaning Solutions .......................... 7 2.3 Disposal of Cleaning Solutions .......................................................................... 8 2.4 Sample Collection Equipment Contaminated with Concentrated Materials8 2.5 Sample Collection Equipment Contaminated with Environmental Media .. 8 2.6 Handling of Decontaminated Equipment ........................................................ 9 3 Field Equipment Decontamination Procedures ................................................... 10 3.1 General .............................................................................................................. 10 3.2 Specifications for Decontamination Pads ...................................................... 10 3.3 "Classical Parameter" Sampling Equipment ............................................... 11 3.4 Sampling Equipment used for the Collection of Trace Organic and Inorganic Compounds ..................................................................................... 11 3.5 Well Sounders or Tapes................................................................................... 12 3.6 Redi-Flo2® Pump ............................................................................................ 12 3.6.1 Purge Only (Pump and Wetted Portion of Tubing or Hose) ................... 12 3.6.2 Purge And Sample ..................................................................................... 13 3.6.3 Redi-Flo2® Ball Check Valve ................................................................... 14 3.7 Mega-Monsoon® and GeoSub® Electric Submersible Pump ..................... 14 3.8 Bladder Pumps ................................................................................................. 15 3.9 Downhole Drilling Equipment ........................................................................ 15 3.9.1 Introduction ............................................................................................... 15 3.9.2 Preliminary Cleaning and Inspection ....................................................... 15 3.9.3 Drill Rig Field Cleaning Procedure.......................................................... 16 3.9.4 Field Decontamination Procedure for Drilling Equipment .................... 16 3.9.5 Field Decontamination Procedure for Direct Push Technology (DPT) Equipment .................................................................................................. 17 3.10 Rental Pumps ................................................................................................... 18 COPY SESD Operating Procedure Page 4 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 1 General Information 1.1 Purpose This document describes general and specific procedures, methods and considerations to be used and observed when cleaning and decontaminating sampling equipment during the course of field investigations. 1.2 Scope/Application The procedures contained in this document are to be followed when field cleaning sampling equipment, for both re-use in the field, as well as used equipment being returned to the Field Equipment Center (FEC). On the occasion that SESD field investigators determine that any of the procedures described in this section are either inappropriate, inadequate or impractical and that other procedures must be used to clean or decontaminate sampling equipment at a particular site, the variant procedure will be documented in the field logbook, along with a description of the circumstances requiring its use. Mention of trade names or commercial products in this operating procedure does not constitute endorsement or recommendation for use. 1.3 Documentation/Verification This procedure was prepared by persons deemed technically competent by SESD management, based on their knowledge, skills and abilities and have been tested in practice and reviewed in print by a subject matter expert. The official copy of this procedure resides on the SESD Local Area Network (LAN). The Document Control Coordinator (DCC) is responsible for ensuring the most recent version of the procedure is placed on LAN and for maintaining records of review conducted prior to its issuance. 1.4 Definitions • Decontamination: The process of cleaning dirty sampling equipment to the degree to which it can be re-used, with appropriate QA/QC, in the field. • Deionized water: Tap water that has been treated by passing through a standard deionizing resin column. At a minimum, the finished water should contain no detectable heavy metals or other inorganic compounds (i.e., at or above analytical detection limits) as defined by a standard inductively coupled Argon Plasma Spectrophotometer (ICP) (or equivalent) scan. Deionized water obtained by other methods is acceptable, as long as it meets the above analytical criteria. Organic-free water may be substituted for deionized water. • Detergent shall be a standard brand of phosphate-free laboratory detergent such as Liquinox® or Luminox®. Liquinox® is a traditional anionic laboratory detergent and is used for general cleaning and where there is COPY SESD Operating Procedure Page 5 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 concern for the stability of the cleaned items in harsher cleaners. Luminox® is a specialized detergent with the capability of removing oils and organic contamination. It is used in lieu of a solvent rinse step in cleaning of equipment for trace contaminant sampling. Where not specified in these procedures, either detergent is acceptable. • Drilling Equipment: All power equipment used to collect surface and sub-surface soil samples or install wells. For purposes of this procedure, direct push is also included in this definition. • Field Cleaning: The process of cleaning dirty sampling equipment such that it can be returned to the FEC in a condition that will minimize the risk of transfer of contaminants from a site. • Organic-free water: Tap water that has been treated with activated carbon and deionizing units. At a minimum, the finished water must meet the analytical criteria of deionized water and it should contain no detectable pesticides, herbicides, or extractable organic compounds, and no volatile organic compounds above minimum detectable levels as determined by the Region 4 laboratory for a given set of analyses. Organic-free water obtained by other methods is acceptable, as long as it meets the above analytical criteria. • Tap water: Water from any potable water supply. Deionized water or organic-free water may be substituted for tap water. 1.5 References SESD Operating Procedure for Management of Investigation Derived Waste, SESDPROC-202, Most Recent Version SESD Operating Procedure for Equipment Cleaning and Decontamination at the FEC, SESDPROC-206, Most Recent Version US EPA. Safety, Health and Environmental Management Program Procedures and Policy Manual. Region 4 SESD, Athens, GA, Most Recent Version COPY SESD Operating Procedure Page 6 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 1.6 General Precautions 1.6.1 Safety Proper safety precautions must be observed when field cleaning or decontaminating dirty sampling equipment. Refer to the SESD Safety, Health and Environmental Management Program (SHEMP) Procedures and Policy Manual and any pertinent site-specific Health and Safety Plans (HASPs) for guidelines on safety precautions. These guidelines, however, should only be used to complement the judgment of an experienced professional. Address chemicals that pose specific toxicity or safety concerns and follow any other relevant requirements, as appropriate. At a minimum, the following precautions should be taken in the field during these cleaning operations: • When conducting field cleaning or decontamination using laboratory detergent, safety glasses with splash shields or goggles, and latex gloves will be worn. • No eating, smoking, drinking, chewing, or any hand to mouth contact should be permitted during cleaning operations. 1.6.2 Procedural Precaution Prior to mobilization to a site, the expected types of contamination should be evaluated to determine if the field cleaning and decontamination activities will generate rinsates and other waste waters that might be considered RCRA hazardous waste or may require special handling. COPY SESD Operating Procedure Page 7 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 2 Introduction to Field Equipment Cleaning and Decontamination 2.1 General The procedures outlined in this document are intended for use by field investigators for cleaning and decontaminating sampling and other equipment in the field. These procedures should be followed in order that equipment is returned to the FEC in a condition that will minimize the risk of transfer of contaminants from a site. Sampling and field equipment cleaned in accordance with these procedures must meet the minimum requirements for the Data Quality Objectives (DQOs) of the study or investigation. If deviations from these procedures need to be made during the course of the field investigation, they will be documented in the field logbook along with a description of the circumstances requiring the use of the variant procedure. Cleaning procedures for use at the Field Equipment Center (FEC) are found in SESD Operating Procedure for Equipment Cleaning and Decontamination at the FEC (SESDPROC-206). 2.2 Handling Practices and Containers for Cleaning Solutions Improperly handled cleaning solutions may easily become contaminated. Storage and application containers must be constructed of the proper materials to ensure their integrity. Following are acceptable materials used for containing the specified cleaning solutions: • Detergent must be kept in clean plastic, metal, or glass containers until used. It should be poured directly from the container during use. • Tap water may be kept in tanks, hand pressure sprayers, squeeze bottles, or applied directly from a hose. • Deionized water must be stored in clean, glass or plastic containers that can be closed prior to use. It can be applied from plastic squeeze bottles. • Organic-free water must be stored in clean glass or Teflon® containers prior to use. It may be applied using Teflon® squeeze bottles, or with the portable system. COPY SESD Operating Procedure Page 8 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 2.3 Disposal of Cleaning Solutions Procedures for the safe handling and disposition of investigation derived waste (IDW); including used wash water and rinse water are in SESD Operating Procedure for Management of Investigation Derived Waste (SESDPROC-202). 2.4 Sample Collection Equipment Contaminated with Concentrated Materials Equipment used to collect samples of concentrated materials from investigation sites must be field cleaned before returning from the study. At a minimum, this should consist of washing with detergent and rinsing with tap water. When the above procedure cannot be followed, the following options are acceptable: 1. Leave with facility for proper disposal; 2. If possible, containerize, seal, and secure the equipment and leave on-site for later disposal; 3. Containerize, bag or seal the equipment so that no odor is detected and return to the SESD. It is the project leader’s responsibility to evaluate the nature of the sampled material and determine the most appropriate cleaning procedures for the equipment used to sample that material. 2.5 Sample Collection Equipment Contaminated with Environmental Media Equipment used to collect samples of environmental media from investigation sites should be field cleaned before returning from the study. Based on the condition of the sampling equipment, one or more of the following options must be used for field cleaning: 1. Wipe the equipment clean; 2. Water-rinse the equipment; 3. Wash the equipment in detergent and water followed by a tap water rinse. 4. For grossly contaminated equipment, the procedures set forth in Section 2.4 must be followed. Under extenuating circumstances such as facility limitations, regulatory limitations, or during residential sampling investigations where field cleaning operations are not feasible, equipment can be containerized, bagged or sealed so that no odor is detected and returned to the FEC without being field cleaned. If possible, FEC personnel should be notified that equipment will be returned without being field cleaned. It is the project leader’s COPY SESD Operating Procedure Page 9 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 responsibility to evaluate the nature of the sampled material and determine the most appropriate cleaning procedures for the equipment used to sample that material. 2.6 Handling of Decontaminated Equipment After decontamination, equipment should be handled only by personnel wearing clean gloves to prevent re-contamination. In addition, the equipment should be moved away (preferably upwind) from the decontamination area to prevent re-contamination. If the equipment is not to be immediately re-used it should be covered with plastic sheeting or wrapped in aluminum foil to prevent re-contamination. The area where the equipment is kept prior to re-use must be free of contaminants. COPY SESD Operating Procedure Page 10 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 3 Field Equipment Decontamination Procedures 3.1 General Sufficient equipment should be transported to the field so that an entire study can be conducted without the need for decontamination. When equipment must be decontaminated in the field, the following procedures are to be utilized. 3.2 Specifications for Decontamination Pads Decontamination pads constructed for field cleaning of sampling and drilling equipment should meet the following minimum specifications: • The pad should be constructed in an area known or believed to be free of surface contamination. • The pad should not leak. • If possible, the pad should be constructed on a level, paved surface and should facilitate the removal of wastewater. This may be accomplished by either constructing the pad with one corner lower than the rest, or by creating a sump or pit in one corner or along one side. Any sump or pit should also be lined. • Sawhorses or racks constructed to hold equipment while being cleaned should be high enough above ground to prevent equipment from being splashed. • Water should be removed from the decontamination pad frequently. • A temporary pad should be lined with a water impermeable material with no seams within the pad. This material should be either easily replaced (disposable) or repairable. At the completion of site activities, the decontamination pad should be deactivated. The pit or sump should be backfilled with the appropriate material designated by the site project leader, but only after all waste/rinse water has been pumped into containers for disposal. See SESD Operating Procedure for Management of Investigation Derived Waste (SESDPROC-202) for proper handling and disposal of these materials. If the decontamination pad has leaked excessively, soil sampling may be required. COPY SESD Operating Procedure Page 11 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 3.3 "Classical Parameter" Sampling Equipment "Classical Parameters" are analyses such as oxygen demand, nutrients, certain inorganic compounds, sulfide, flow measurements, etc. For routine operations involving classical parameter analyses, water quality sampling equipment such as Kemmerers, buckets, dissolved oxygen dunkers, dredges, etc., may be cleaned with the sample water or tap water between sampling locations as appropriate. Flow measuring equipment such as weirs, staff gages, velocity meters, and other stream gauging equipment may be cleaned with tap water between measuring locations, if necessary. Note: The procedures described in Section 3.3 are not to be used for cleaning field equipment to be used for the collection of samples undergoing trace organic or inorganic constituent analyses. 3.4 Sampling Equipment used for the Collection of Trace Organic and Inorganic Compounds For samples undergoing trace organic or inorganic constituent analyses, the following procedures are to be used for all sampling equipment or components of equipment that come in contact with the sample: 3.4.1 Standard SESD Method 1. An optional Liquinox® detergent wash step may be useful to remove gross dirt and soil. 2. Clean with tap water and Luminox® detergent using a brush, if necessary, to remove particulate matter and surface films. 3. Rinse thoroughly with tap water. 4. Rinse thoroughly with organic-free water and place on a clean foil-wrapped surface to air-dry. 5. Wrap the dry equipment with aluminum foil or bag in clean plastic. If the equipment is to be stored overnight before it is wrapped in foil, it should be covered and secured with clean, unused plastic sheeting. 3.4.2 Alternative Solvent Rinse Method The historical solvent rinse method of cleaning equipment for trace contaminant sampling remains an acceptable method. 1. Clean with tap water and Liquinox® detergent using a brush, if necessary, to remove particulate matter and surface films. Equipment may be steam cleaned (Liquinox® detergent and high pressure hot water) as an alternative to COPY SESD Operating Procedure Page 12 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 brushing. Sampling equipment that is steam cleaned should be placed on racks or saw horses at least two feet above the floor of the decontamination pad. PVC or plastic items should not be steam cleaned. 2. . Rinse thoroughly with tap water. 3. Rinse thoroughly with deionized water. 4. Rinse with an appropriate solvent (generally isopropanol). 5. Rinse with organic-free water and place on a clean foil-wrapped surface to air-dry. 4. Wrap the dry equipment with aluminum foil. If the equipment is to be stored overnight before it is wrapped in foil, it should be covered and secured with clean, unused. 3.5 Well Sounders or Tapes The following procedures are recommended for decontaminating well sounders (water level indicators) and tapes. Unless conditions warrant, it is only necessary to decontaminate the wetted portion of the sounder or tape. 1. Wash with Liquinox® detergent and tap water. 2. Rinse with tap water. 3. Rinse with deionized water. 3.6 Redi-Flo2® Pump CAUTION – Do not wet the controller. Always disconnect power from the pump when handling the pump body. The Redi-Flo2® pump and any associated connected hardware (e.g., check valve) should be decontaminated between each monitoring well. The following procedures are required, depending on whether the pump is used solely for purging or used for purging and sampling. 3.6.1 Purge Only (Pump and Wetted Portion of Tubing or Hose) 1. Disconnect power and wash exterior of pump and wetted portion of the power lead and tubing or hose with Liquinox® detergent and water solution. COPY SESD Operating Procedure Page 13 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 2. Rinse with tap water. 3. Final rinse with deionized water. 4. Place pump and reel in a clean plastic bag and keep tubing or hose contained in clean plastic or galvanized tub between uses. 3.6.2 Purge And Sample Grundfos Redi-Flo2® pumps are extensively decontaminated and tested at the FEC to prevent contamination from being transmitted between sites. The relevant sections of SESDPROC-206, Field Equipment Cleaning and Decontamination at the FEC, should be implemented in the field where a high risk of cross-contamination exists, such as where NAPL or high-concentration contaminants occur. In most cases, the abbreviated cleaning procedure described below will suffice, provided that sampling proceeds from least to most contaminated areas. 1. Disconnect and discard the previously used sample tubing from the pump. Remove the check valve and tubing adapters and clean separately (See Section 3.6.3 for check valve). Wash the pump exterior with detergent and water. 2. Prepare and fill three containers with decontamination solutions, consisting of Container #1, a tap water/detergent washing solution. Luminox® is commonly used. An additional pre-wash container of Liquinox® may be used; Container #2, a tap water rinsing solution; and Container #3, a deionized or organic-free water final rinsing solution. Choice of detergent and final rinsing solution for all steps in this procedure is dependent upon project objectives (analytes and compounds of interest). The containers should be large enough to hold the pump and one to two liters of solution. An array of 2’ long 2” PVC pipes with bottom caps is a common arrangement. The solutions should be changed at least daily. 3. Place the pump in Container #1. Turn the pump on and circulate the detergent and water solution through the pump and then turn the pump off. 4. Place the pump in Container #2. Turn the pump on and circulate the tap water through the pump and then turn the pump off. 5. Place the pump in Container #3. Turn the pump on and circulate deionized or organic-free water through the pump and then turn the pump off. COPY SESD Operating Procedure Page 14 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 6. Disconnect power and remove pump from Container #3. Rinse exterior and interior of pump with fresh deionized or organic-free water. 7. Decontaminate the power lead by washing with detergent and water, followed by tap water and deionized water rinses. This step may be performed before washing the pump if desired. 8. Reassemble check valve and tubing adapters to pump. ALWAYS use Teflon® tape to prevent galling of threads. Firm hand-tightening of fittings or light wrench torque is generally adequate. 9. Place the pump and reel in a clean plastic bag. 3.6.3 Redi-Flo2® Ball Check Valve 1. Remove the ball check valve from the pump head. Check for wear and/or corrosion, and replace as needed. During decontamination check for free-flow in forward direction and blocking of flow in reverse direction. 2. Using a brush, scrub all components with detergent and tap water. 3. Rinse with deionized water. 4. Rethread the ball check valve to the Redi-Flo2® pump head. 3.7 Mega-Monsoon® and GeoSub® Electric Submersible Pump As these pumps have lower velocities in the turbine section and are easier to disassemble in the field than Grundfos pumps, the outer pump housing should be removed to expose the impeller for cleaning prior to use and between each use when used as a sampling pump for trace contaminant sampling. 1. Remove check valves and adapter fittings and clean separately. 2. Remove the outer motor housing by holding the top of the pump head and unscrewing the outer housing from its O-ring sealed seat. 3. Clean all pump components per the provisions of section 3.4. Use a small bottle brush for the pump head passages 4. Wet the O-ring(s) on the pump head with organic-free water. Reassemble the outer pump housing to the pump head. 5. Clean cable and reel per Section 3.4. 6. Conduct final rinse of pump with organic-free water over pump and through pump turbine. COPY SESD Operating Procedure Page 15 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 3.8 Bladder Pumps Bladder pumps are presumed to be intended for use as purge-and-sample pumps. The Geotech® bladder pump and Geoprobe Systems® mechanical bladder pump can be cleaned similarly. 1. Discard any tubing returned with the pump. 2. Completely disassemble the pump, being careful to note the initial position of and retain any springs and loose ball checks. 3. Discard pump bladder. 4. Clean all parts as per the standard cleaning procedure in Section 3.4. 5. Install a new Teflon® bladder and reassemble pump. 3.9 Downhole Drilling Equipment These procedures are to be used for drilling activities involving the collection of soil samples for trace organic and inorganic constituent analyses and for the construction of monitoring wells to be used for the collection of groundwater samples for trace organic and inorganic constituent analyses. 3.9.1 Introduction Cleaning and decontamination of all equipment should occur at a designated area (decontamination pad) on the site. The decontamination pad should meet the specifications of Section 3.2 of this procedure. Tap water brought on the site for drilling and cleaning purposes should be contained in a pre-cleaned tank. A steam cleaner and/or high pressure hot water washer capable of generating a pressure of at least 2500 PSI and producing hot water and/or steam, with a detergent compartment, should be obtained. 3.9.2 Preliminary Cleaning and Inspection Drilling equipment should be clean of any contaminants that may have been transported from off-site to minimize the potential for cross-contamination. The drilling equipment should not serve as a source of contaminants. Associated drilling and decontamination equipment, well construction materials, and equipment handling procedures should meet these minimum specified criteria: COPY SESD Operating Procedure Page 16 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 • All downhole augering, drilling, and sampling equipment should be sandblasted before use if painted, and/or there is a buildup of rust, hard or caked matter, etc., that cannot be removed by steam cleaning (detergent and high pressure hot water), or wire brushing. Sandblasting should be performed prior to arrival on site, or well away from the decontamination pad and areas to be sampled. • Any portion of the drilling equipment that is over the borehole (kelly bar or mast, backhoe buckets, drilling platform, hoist or chain pulldowns, spindles, cathead, etc.) should be steam cleaned (detergent and high pressure hot water) and wire brushed (as needed) to remove all rust, soil, and other material which may have come from other sites before being brought on site. • Printing and/or writing on well casing, tremie tubing, etc., should be removed before use. Emery cloth or sand paper can be used to remove the printing and/or writing. Most well material suppliers can provide materials without the printing and/or writing if specified when ordered. Items that cannot be cleaned are not acceptable and should be discarded. • Equipment associated with the drilling and sampling activities should be inspected to insure that all oils, greases, hydraulic fluids, etc., have been removed, and all seals and gaskets are intact with no fluid leaks. 3.9.3 Drill Rig Field Cleaning Procedure Any portion of the drill rig, backhoe, etc., that is over the borehole (kelly bar or mast, backhoe buckets, drilling platform, hoist or chain pulldowns, spindles, cathead, etc.) should be steam cleaned (detergent and high pressure hot water) between boreholes. 3.9.4 Field Decontamination Procedure for Drilling Equipment The following is the standard procedure for field cleaning augers, drill stems, rods, tools, and associated equipment. This procedure does not apply to well casings, well screens, or split-spoon samplers used to obtain samples for chemical analyses, which should be decontaminated as outlined in Section 3.4 of this procedure. 1. Wash with tap water and detergent, using a brush if necessary, to remove particulate matter and surface films. Steam cleaning (high pressure hot water with detergent) may be necessary to remove matter that is difficult to remove with the brush. Drilling equipment that is steam cleaned should be placed on racks or saw horses at least two feet above the floor of the decontamination pad. Hollow-stem augers, drill COPY SESD Operating Procedure Page 17 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 rods, etc., that are hollow or have holes that transmit water or drilling fluids, should be cleaned on the inside with vigorous brushing. 2. Rinse thoroughly with tap water. 3. Remove from the decontamination pad and cover with clean, unused plastic. If stored overnight, the plastic should be secured to ensure that it stays in place. 3.9.5 Field Decontamination Procedure for Direct Push Technology (DPT) Equipment 1. Certain specific procedures for the decontamination of DPT tools are described in the various sampling procedures, but the following general guidelines apply: 2. Prior to return to the Field Equipment Center, all threaded tool joints should be broken apart and the equipment cleaned per the provisions of Section 2.5, Sample Collection Equipment Contaminated with Environmental Media of this procedure. 3. Equipment that contacts the sample media and is cleaned in the field for reuse should be cleaned per the provisions of Section 3.4, Sampling Equipment used for the Collection of Trace Organic and Inorganic Compounds of this procedure. This would include piston sampler points and shoes, screen point sampler screens and sheaths, and the drive rods when used for groundwater sampling. 4. Equipment that does not directly contact the sample media and is cleaned in the field for reuse can generally be cleaned per the provisions of Section 3.7.4, Field Decontamination Procedure for Drilling Equipment of this procedure. 5. Stainless steel SP15/16 well screens require special care as the narrow slots are difficult to clean under even controlled circumstances and galvanic corrosion can release chrome from the screen surface. As soon as possible after retrieval, the screen slots should be sprayed from the outside to break loose as much material as possible before it can dry in place. To prevent galvanic corrosion, the screens must be segregated from the sampler sheaths, drive rods, and other carbon steel during return transport from the field. COPY SESD Operating Procedure Page 18 of 18 SESDPROC-205-R3 Field Equipment Cleaning and Decontamination Effective Date: December 18, 2015 3.10 Rental Pumps Completing a groundwater sampling project may require the use of rental pumps. Rental pumps are acceptable where they are of suitable stainless steel and Teflon® construction. These pumps should be cleaned prior to use using the procedures specified herein and a rinse-blank collected prior to use. COPY Appendix G USEPA SESD Procedure for Logbooks (SESDPROC-010-R5) COPY _____________________________________________________________________________________ SESD Operating Procedure Page 2 of 9 SESDPROC-010-R4 Logbooks Logbooks(010)_AF.R4 Effective Date: May 30, 2013 Revision History The top row of this table shows the most recent changes to this controlled document. For previous revision history information, archived versions of this document are maintained by the SESD Document Control Coordinator on the SESD local area network (LAN). History Effective Date SESCPROC-010-R5, Logbooks, replaces SESDPROC- 010-R4 General: Corrected any typographical, grammatical and/or editorial errors. Title Page: Changed author from Liza Montalvo to Hunter Johnson. Changed Enforcement and Investigation Branch Chief from Archie Lee to Danny France. Changed Ecological Assessment Branch Chief from Bill Cosgrove to John Deatrick. Changed Field Quality Manager from Liza Montalvo to Bobby Lewis. Revision History: Changes were made to reflect the current practice of only including the most recent changes in the revision history Section 1.2: Added the following statement: “Requirements for SESD records, which include field logbooks, are outlined in the SESD Operating Procedure for Control of Records (SESDPROC-002).” Section 1.4: Updated references Section 2.1: Added “bound” to the first sentence. Replaced the last sentence of the first paragraph with the following language: “All pertinent field activity information will be recorded contemporaneously when observed or collected to prevent a loss of information.” Added the second paragraph partially comprised of language from the omitted paragraph from Section 2.2. Section2.2: Omitted the first paragraph. Added the following language to the first line (formerly the second paragraph): “The following requirements apply to all logbooks:” Added Items 1 and 2 and omitted Item 4. Renumbered items as appropriate. Added “End of Notes” to the second sentence in item 6 (formerly item 5). Also added the last sentence which states: “Field investigators will draw a diagonal line through blank or unused portions of pages/forms May 30, 2013 COPY _____________________________________________________________________________________ SESD Operating Procedure Page 3 of 9 SESDPROC-010-R4 Logbooks Logbooks(010)_AF.R4 Effective Date: May 30, 2013 that are located prior to the “End of Notes” entry and initial them.” Added “and SESD-generated forms” to Item 7 (formerly item 6). SESCPROC-010-R4, Logbooks, replaces SESDPROC-010-R3 October 8, 2010 SESCPROC-010-R3, Logbooks, replaces SESDPROC- 010-R2 November 1, 2007 SESCPROC-010-R2, Logbooks, Replaces SESDPROC-010-R1 September 25, 2007 SESDPROC-010-R1, Logbooks, Replaces Field Records (Logbooks) SESDPROC-010-R0 August 10, 2007 SESDPROC-010-R0, Field Records (Logbooks), Original Issue February 5, 2007 COPY _____________________________________________________________________________________ SESD Operating Procedure Page 4 of 9 SESDPROC-010-R4 Logbooks Logbooks(010)_AF.R4 Effective Date: May 30, 2013 TABLE OF CONTENTS 1 General Information ................................................................................................. 5 1.1 Purpose............................................................................................................... 5 1.2 Scope/Application ............................................................................................. 5 1.3 Documentation/Verification ............................................................................. 5 1.4 References .......................................................................................................... 5 2 Field Records and Documentation Procedures ...................................................... 6 2.1 General ............................................................................................................... 6 2.2 Field Data Integrity and Accountability ......................................................... 6 2.3 Logbook Entry Information ............................................................................ 7 2.3.1 General Information Required in All Logbooks ....................................... 7 2.3.2 Information Required for Sample Collection ........................................... 7 2.3.3 Information Required for Field Measurements ....................................... 8 2.3.4 Additional Information for Inclusion ....................................................... 9 COPY _____________________________________________________________________________________ SESD Operating Procedure Page 5 of 9 SESDPROC-010-R4 Logbooks Logbooks(010)_AF.R4 Effective Date: May 30, 2013 1 General Information 1.1 Purpose This procedure is to be used by field investigators when documenting pertinent and factual information in logbooks related to field investigations involving sampling and measurement procedures and/or other data collection events. 1.2 Scope/Application This document describes the various types of information that should be included in the field logbooks used to document field investigations conducted by SESD. Requirements for SESD records, which include field logbooks, are outlined in the SESD Operating Procedure for Control of Records (SESDPROC-002). Mention of trade names or commercial products does not constitute endorsement or recommendation for use. 1.3 Documentation/Verification The procedures found within this document were prepared by persons deemed technically competent by SESD management, based on their knowledge, skills and abilities. The official copy of this procedure resides on the SESD local area network (LAN). The Document Control Coordinator is responsible for ensuring the most recent version of the procedure is placed on the LAN and for maintaining records of review conducted prior to its issuance. 1.4 References SESD Operating Procedure for Control of Records, SESDPROC-002, Most Recent Version SESD Field Branches Quality Management Plan, SESDPLAN-001, Most Recent Version COPY _____________________________________________________________________________________ SESD Operating Procedure Page 6 of 9 SESDPROC-010-R4 Logbooks Logbooks(010)_AF.R4 Effective Date: May 30, 2013 2 Field Records and Documentation Procedures 2.1 General Dedicated bound logbooks will be used for field data collection including but not limited to sampling, measurements and observations. Logbook entries should be objective, factual, and free of personal feelings or other terminology which might prove inappropriate. All pertinent field activity information will be recorded contemporaneously when observed or collected to prevent a loss of information. To facilitate accurate and complete documentation of field sampling and measurement activities, SESD-generated forms may be used. In order to be utilized, SESD-generated forms must be bound prior to use and adhere to all requirements outlined in this procedure. In cases where unbound pages/forms are necessary due to project requirements or practicality, approval must be obtained from both the Field Quality Manager and Management. In these cases, the Field Quality Manager and Management will dictate the steps that will be taken to ensure credibility, traceability and defensibility of information collected. Any deviations from the quality assurance project plan that occur while in the field will be noted in the logbook(s). Logbook entries that may be considered privileged or confidential information will be handled in accordance with the relevant sections of SESD Operating Procedure for Control of Records (SESDPROC-002). The logbooks will be placed in the SESD project file upon transmittal of the final report to the project requestor. 2.2 Field Data Integrity and Accountability The following requirements apply to all logbooks: 1. The project’s unique identifier (unique identification number(s)) will be included on each page. 2. Field personnel will date and number each page. Numbering will be conducted by utilizing a format that incorporates both the current page number and the total number of pages (e.g. “page x of y” or “x/y”, where “x” is the current page number and “y” is the total number of pages). 3. Observations, data and calculations will be recorded at the time they are made. 4. Unless prohibited by environmental conditions, pens with permanent ink will be used to record all data. When environmental conditions do not make it feasible to use permanent ink, entries should be made using a non-smear lead pencil (e.g., 2H or 3H). Upon returning from the field, the project leader will photocopy the penciled section of the logbook and certify, in writing, that the photocopied record is a true copy of the original logbook entry. The photocopy will be included in the project file. COPY _____________________________________________________________________________________ SESD Operating Procedure Page 7 of 9 SESDPROC-010-R4 Logbooks Logbooks(010)_AF.R4 Effective Date: May 30, 2013 5. Entries will be legible and contain pertinent, accurate and inclusive documentation of project activities. 6. Upon completion of the field investigation, the end of project entries in the logbook and/or bound forms will be clearly indicated. This may be accomplished by noting “End” or “End of Notes” on the last page of notes and dating and initialing the notation. Field investigators will draw a diagonal line through blank or unused portions of pages/forms that are located prior to the “End of Notes” entry and initial them. 7. In order to demonstrate continuity of the project and to preclude questioning of the integrity of the data collection process, pages and SESD-generated forms should not be removed from bound logbooks under any circumstances. 8. Data or other information that has been entered incorrectly will be corrected by drawing a line through the incorrect entry and initialing and dating the lined-through entry. Under no circumstances should the incorrect material be erased, made illegible or obscured so that it cannot be read. 9. If pre-printed adhesive labels are used in logbooks or bound forms to facilitate organization of information entry, the field investigator who is responsible for taking notes will sign the label with the signature beginning on the label and ending on the page of the logbook such that the label cannot be removed without detection. 2.3 Logbook Entry Information 2.3.1 General Information Required in All Logbooks The following information will be included either on the front cover or the first page of all logbooks: 1. Project name 2. Project location 3. Project identification number 4. Project leader (full name) 5. Sample team leader (full name) and initials 6. Sample team member(s) (full name) and initials 2.3.2 Information Required for Sample Collection In addition to the information listed in Section 2.3.1, the following information will be included in all logbooks when samples are collected: 1. Applicable SESD Operating Procedures for field sampling 2. Date and time of collection 3. Station identification 4. Sample identification COPY _____________________________________________________________________________________ SESD Operating Procedure Page 8 of 9 SESDPROC-010-R4 Logbooks Logbooks(010)_AF.R4 Effective Date: May 30, 2013 5. Method of collection 6. Number and type of containers 7. Sample collection equipment 8. SESD equipment identification number, if applicable 9. Physical description of sample 10. Matrix sampled 11. Sample team member duties (calibration, collection, deployment, etc.) 12. Sample preservation (including ice), if applicable 13. Conditions that may adversely impact quality of samples, if applicable (rain, wind, smoke, dust, extreme temperature, etc.) 14. GPS coordinates (Non-logging GPS units), if applicable 15. Location of electronic data file backups, if applicable 16. Monitoring of condition of ice in coolers or sampler 17. Other pertinent information. 2.3.3 Information Required for Field Measurements In addition to the information listed in Section 2.3.1, the following information will be included in all logbooks when measurements are conducted: 1. Applicable SESD Operating Procedures for field measurement 2. Date and time of measurement or deployment 3. Sample identification, if appropriate 4. Station identification 5. Sample measurement equipment 6. SESD sample measurement equipment identification number 7. Manufacturer name, lot number and expiration date of all buffers and standards* 8. Calibration information, including before and after calibration readings* 9. Meter end check information 10. Deployment depth and total depth, if applicable 11. Pinger identification number and frequency for deployed equipment, if applicable 12. Time of retrieval for deployed equipment, if applicable 13. Physical description of matrix 14. Sample team member duties (calibration, collection, deployment, etc.) 15. Measurement values for non-logging equipment 16. GPS coordinates (non-logging GPS units), if applicable 17. Location of electronic data file backups, if applicable 18. Ambient air temperature, where applicable 19. Conditions that may adversely impact quality of measurement (Ex. temperature extremes) 20. Maintenance performed, if applicable COPY _____________________________________________________________________________________ SESD Operating Procedure Page 9 of 9 SESDPROC-010-R4 Logbooks Logbooks(010)_AF.R4 Effective Date: May 30, 2013 21. Meter malfunctions, if applicable 22. Other pertinent information * Entry of calibration information in logbooks is only required for calibrations conducted in the field. All calibrations conducted at the Field Equipment Center or SESD laboratory will be recorded in the appropriate equipment tracking logbook. 2.3.4 Additional Information for Inclusion The following information may be included in logbooks as appropriate: 1. Maps/sketches 2. Photographic or videographic log 3. Process diagrams COPY Appendix H USEPA SESD Procedure for Sample and Evidence Management (SESDPROC-005- R2) COPY __________________________________________________________________________________ SESD Operating Procedure Page 2 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 Revision History This table shows changes to this controlled document over time. The most recent version is presented in the top row of the table. Previous versions of the document are maintained by the SESD Document Control Coordinator. History Effective Date SESDPROC-005-R2, Sample and Evidence Management, replaces SESDPROC-005-R1 General: Corrected any typographical, grammatical, and/or editorial errors. General: Replaced all references to FORMS with the generic term sample custody software program. The specific sections are listed below: Section 3.3 Section 3.4 Section 4.2 Section 5 Title Page: Changed the EIB Branch Chief from Antonio Quinones to Danny France. Changed the EAB Branch Chief from Bill Cosgrove to John Deatrick (Acting). Changed the Field Quality Manager from Laura Ackerman to Bobby Lewis. Revision History: In the last sentence, changed Field Quality Manager to Document Control Coordinator. Section 1.2: Added the following statement - Mention of trade names or commercial products in this operating procedure does not constitute endorsement or recommendation for use. Section 1.3: Changed requirement so that the DCC is responsible for ensuring the most recent version of the procedure is placed on the SESD LAN and for maintaining records of review conducted prior to its issuance. Deleted reference to the H: drive. Section 2.2 Changed requirement for comments on sample label to make comments optional. Section 2.2.2 Removed requirement for printed copies of photographs in the official file. Section 3.3 Removed different custody requirements for criminal investigations so that all projects are treated consistently. Section 3.4 Removed statement in the fourth paragraph regarding retention of paper air bills in the official project file to reduce unnecessary paperwork. The air bill number or shipment tracking number is recorded on the chain of custody. January 29, 2013 COPY __________________________________________________________________________________ SESD Operating Procedure Page 3 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 SESDPROC-005-R1, Sample and Evidence Management, replaces SESDPROC-005-R0 General Updated referenced procedures to reflect most recent version. Replaced “shall” with “will”. Cover Page: Changed title for Antonio Quinones from Environmental Investigation Branch to Enforcement and Investigations Branch. Changed Bill Cosgrove’s title from Acting Chief to Chief. Section 1.3 Updated information to reflect that procedure is located on the H: drive of the LAN. Section 1.4 Added reference for the SESD Operating Procedure for Control of Records. Alphabetized and revised the referencing style for consistency. Section 2.2.3 Added that Confidential Business Information will be handled in accordance with SESD Operating Procedure for Control of Records. November 1, 2007 SESDPROC-005-R0, Sample and Evidence Management, Original Issue February 05, 2007 COPY __________________________________________________________________________________ SESD Operating Procedure Page 4 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 TABLE OF CONTENTS 1 General Information ................................................................................................. 5 1.1 Purpose ................................................................................................................ 5 1.2 Scope/Application ............................................................................................... 5 1.3 Documentation/Verification .............................................................................. 5 1.4 References ........................................................................................................... 5 2 Sample and Evidence Identification ........................................................................ 6 2.1 Introduction ....................................................................................................... 6 2.2 Sample and Evidence Identification Procedures ............................................. 7 2.2.1 Sample Identification .................................................................................... 7 2.2.2 Photograph, Digital Still Image and Video Identification .......................... 7 2.2.3 Identification of Physical Evidence .............................................................. 8 3 Chain-of-Custody Procedures ............................................................................... 10 3.1 Introduction ...................................................................................................... 10 3.2 Sample Custody ................................................................................................ 10 3.3 Documentation of Chain-of-Custody .............................................................. 10 3.4 Transfer of Custody with Shipment ............................................................... 12 4 Receipt for Samples Form (CERCLA/RCRA/TSCA) ......................................... 14 4.1 Introduction ...................................................................................................... 14 4.2 Receipt for Samples Form ............................................................................... 14 5 Sample Custody Management Software ............................................................... 16 COPY __________________________________________________________________________________ SESD Operating Procedure Page 5 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 1 General Information 1.1 Purpose This document describes general and specific procedures, methods and considerations to be used and observed by SESD field investigators when handling and managing samples and other types of evidence after their collection and during delivery to the laboratory. 1.2 Scope/Application The procedures contained in this document are to be used by field investigators when handling and managing samples and other evidence collected to support SESD field investigations. On the occasion that SESD field investigators determine that any of the procedures described in this section are either inappropriate, inadequate or impractical and that another procedure must be used, the variant procedure will be documented in the field log book, along with a description of the circumstances requiring its use. Mention of trade names or commercial products in this operating procedure does not constitute endorsement or recommendation for use. 1.3 Documentation/Verification This procedure was prepared by persons deemed technically competent by SESD management, based on their knowledge, skills and abilities and have been tested in practice and reviewed in print by a subject matter expert. The official copy of this procedure resides on the SESD Local Area Network (LAN). The Document Control Coordinator is responsible for ensuring the most recent version of the procedure is placed on the LAN and for maintaining records of review conducted prior to its issuance. 1.4 References SESD Operating Procedure for Control of Records, SESDPROC-002, Most Recent Version SESD Operating Procedure for Packing, Marking, Labeling and Shipping of Environmental and Waste Samples, SESDPROC-209, Most Recent Version USEPA Region 4 Environmental Investigations Standard Operating Procedures and Quality Assurance Manual (EISOPQAM), November 2001 USEPA Digital Camera Guidance for EPA Civil Inspections and Investigations, July 2006 COPY __________________________________________________________________________________ SESD Operating Procedure Page 6 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 2 Sample and Evidence Identification 2.1 Introduction Sample identification, chain-of-custody records, receipt for sample records and other field records will be legibly recorded with waterproof, non-erasable ink, unless otherwise specified. If errors are made in any of these documents, corrections will be made by crossing a single line through the error and entering the correct information. All corrections must be initialed and dated. If possible, all corrections should be made by the individual making the error. Following are definitions of terms used in this section: Field Investigator Any individual who performs or conducts field sampling, observation and/or measurement activities in support of field investigations Project Leader The individual with overall responsibility for conducting a specific field investigation in accordance with this procedure Field Sample Custodian Individual responsible for identifying the sample containers and maintaining custody of the samples and the Chain-of-Custody Record Sample Team Leader An individual designated by the project leader to be present during and responsible for all activities related to the collection of samples by a specific sampling team Sampler The individual responsible for the actual collection of a sample Transferee Any individual who receives custody of samples subsequent to release by the field sample custodian Laboratory Sample Custodian Individual responsible for accepting custody of samples from the field sample custodian or a transferee One individual may fulfill more than one of the roles described above. COPY __________________________________________________________________________________ SESD Operating Procedure Page 7 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 2.2 Sample and Evidence Identification Procedures 2.2.1 Sample Identification The method of sample identification used depends on the type of sample collected. Field measurement samples are those collected for specific field analysis or measurement where the data are recorded directly in bound field logbooks or on the Chain-of-Custody Record. Examples of field measurements and analyses include XRF, pH, temperature, dissolved oxygen and conductivity. Samples collected for laboratory analysis will be identified by using a stick-on label or a tag which is attached to the sample container. In some cases such as biological samples, the label or tag may have to be affixed to a bag containing the sample. If a sample tag is used, the sample should be placed in a bag, then the sample and the tag will be placed in a second bag. The following information will be included on the sample label or tag using waterproof, non-erasable ink: • Project number; • Field identification or sample station number; • Date and time of sample collection; • Designation of the sample as a grab or composite; • Whether the sample is preserved or unpreserved; • The general types of analyses to be performed. Other information such as readily detectable or identifiable odor, color, or known toxic properties may be added as deemed necessary by the project leader or sample custodian. 2.2.2 Photograph, Digital Still Image and Video Identification Photographs and Digital Still Images When photographs or digital images are taken for purposes of documenting and supporting a field investigation, a record of each exposure or image will be kept in a bound field logbook. The following information will be recorded in the logbook: • An accurate description of what the photograph or image shows, including orientation, if appropriate; COPY __________________________________________________________________________________ SESD Operating Procedure Page 8 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 • The date and time that the photograph or image was taken; • The name of the individual who took the photograph or digital image. When photographs are taken with a film camera, the film should be developed with the negatives supplied uncut, if possible. The identifying information that was recorded in the field logbook will be entered on the back of the prints. When digital images are obtained during a field investigation, an electronic copy of the unaltered investigation-related images will be placed in the official files. If deemed necessary due to project requirements, a printed copy of the original photographs may be placed in the official file. For enforcement cases, it is imperative that the individual who took the image be identified in the field logbook in the event their testimony is required. Video When a video recording is used as evidence in an enforcement case, the following information should be recorded in a bound field logbook: • The date and time that the video was recorded; • A brief description of the subject of the video; • The person recording the video. An audio record may also be included in the video tape with the above logistical information, as well as a narrated description of the video record. A label will be placed on the video media with the appropriate identifying information (i.e., project name, project number, date, location etc.). In the event testimony regarding a video recording is required for an enforcement case, one individual should be responsible for recording the video for each case. The original, unaltered recording will be placed in the official files. 2.2.3 Identification of Physical Evidence Physical evidence, other than samples, will be identified, when possible, by recording the necessary information on the evidence. When samples are collected from vessels or containers which can be moved (drums for example), the vessel or container should be marked with the field identification or sample station number for future identification. The vessel or container may be labeled with an indelible marker (e.g., paint stick or spray paint). The vessel or container need not be marked if it already has a unique marking; however, these markings will be COPY __________________________________________________________________________________ SESD Operating Procedure Page 9 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 recorded in the bound field logbooks. In addition, it is suggested that photographs of any physical evidence (markings, etc.) be taken and the necessary information recorded in the field logbook. Occasionally, it is necessary to obtain copies of recorder and/or instrument charts from facility owned analytical equipment, flow recorders, etc., during field investigations and inspections. A unique identifier will be recorded on the document with that information as well as the following recorded in the logbook: • Starting and ending time(s) and date(s) for the chart; • An instantaneous measurement of the media being measured by the recorder will be taken and entered at the appropriate location on the chart along with the date and time of the measurement; and • A description of the location being monitored and other information required to interpret the data such as type of flow device, chart units, factors, etc. The field investigator will indicate who the chart (or copy of the chart) was received from and enter the date and time, as well as the field investigator's initials. Documents such as technical reports, laboratory reports, etc., should be marked with the field investigator's signature, the date, the number of pages and from whom they were received. Documents that are claimed by a facility to be “confidential” and, therefore, potentially subject to the Confidential Business Information requirements, will be handled in accordance with SESD Operating Procedure for Control of Records (SESDPROC-002). COPY __________________________________________________________________________________ SESD Operating Procedure Page 10 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 3 Chain-of-Custody Procedures 3.1 Introduction Chain-of-custody procedures are comprised of the following elements: 1) maintaining custody of samples or other evidence, and 2) documentation of the chain-of-custody for evidence. To document chain-of-custody, an accurate record must be maintained to trace the possession of each sample, or other evidence, from the moment of collection to its introduction into evidence. 3.2 Sample Custody A sample or other physical evidence is in custody if: • It is in the actual possession of an investigator; • It is in the view of an investigator, after being in their physical possession; • It was in the physical possession of an investigator and then they secured it to prevent tampering; and/or • It is placed in a designated secure area. 3.3 Documentation of Chain-of-Custody The following are used to identify and demonstrate how sample integrity is maintained and custody is ensured. Sample Identification A stick-on sample label or a tag should be completed for each sample container using waterproof, non-erasable ink as specified in Section 2.2.1. Sample Seals If appropriate, samples should be sealed as soon as possible following collection using a custody seal with EPA identification. The sample custodian or project leader will write the date and their initials on the seal. The use of custody seals may be waived if field investigators keep the samples in their custody as defined in Section 3.2, from the time of collection until the samples are delivered to the laboratory analyzing the samples. Field Sample Custodian The field sample custodian is the person designated by the project leader to receive and manage custody of samples while in the field, including labeling and custody sealing. Chain-of-Custody Record COPY __________________________________________________________________________________ SESD Operating Procedure Page 11 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 The field Chain-Of-Custody record is used to document the custody of all samples or other physical evidence collected and maintained by investigators. All physical evidence or samples will be accompanied by a Chain-Of-Custody Record. This form may be generated by sample custody management software (Section 5) or it may be a pre-printed multi-sheet carbonless form for hand entry of required information. The Chain-Of-Custody Record documents transfer of custody of samples from the sample custodian to another person, to the laboratory or other organizational elements. The Chain-of-Custody Record will not be used to document the collection of split samples where there is a legal requirement to provide a receipt for samples (see Section 4, Receipt for Samples Form (CERCLA/RCRA/TSCA)). The Chain-Of-Custody Record also serves as a sample logging mechanism for the laboratory sample custodian. A separate Chain-of-Custody Record should be used for each final destination or laboratory used during the investigation. All information necessary to fully and completely document the sample collection and required analyses must be recorded in the appropriate spaces to complete the field Chain-Of-Custody Record. The following requirements apply to Chain-Of-Custody records generated by either sample custody management software or by hand entry on pre-printed forms: • All sampling team leaders must sign in the designated signature block. • One sample should be entered on each line and not be split among multiple lines. • If multiple sampling teams are collecting samples, the sampling team leader's name should be clearly indicated for each sample. • The total number of sample containers for each sample must be listed in the appropriate column. Required analyses should be entered in the appropriate location on the Chain-of-Custody Record. • The field sample custodian, project leader or other designee, and subsequent transferee(s) should document the transfer of the samples listed on the Chain-of-Custody Record. Both the person relinquishing the samples and the person receiving them must sign the form. The date and time that this occurs should be documented in the proper space on the Chain-of-Custody Record. The exception to this requirement would be when packaged samples are shipped with a common carrier. Even though the common carrier accepts the samples for shipment, they do not sign the Chain-of-Custody Record as having received the samples. • The last person receiving the samples or evidence will be the laboratory sample custodian or their designee(s). COPY __________________________________________________________________________________ SESD Operating Procedure Page 12 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 The Chain-of-Custody Record is a uniquely identified document. Once the Record is completed, it becomes an accountable document and must be maintained in the project file. The suitability of any other form for chain-of-custody should be evaluated based upon its inclusion of all of the above information in a legible format. If chain-of-custody is required for documents received during investigations, the documents should be placed in large envelopes, and the contents should be noted on the envelope. The envelope will be sealed and an EPA custody seal placed on the envelope such that it cannot be opened without breaking the seal. A Chain-Of-Custody Record will be maintained for the envelope. Any time the EPA seal is broken, that fact will be noted on the Chain-Of-Custody Record and a new seal affixed, as previously described in this section. Physical evidence such as video tapes or other small items will be placed in an evidence bag or envelope and an EPA custody seal should be affixed so that they cannot be opened without breaking the seal. A Chain-Of-Custody Record will be maintained for these items. Any time the EPA seal is broken, that fact will be noted on the Chain-of-Custody Record and a new seal affixed. EPA custody seals can be used to maintain custody of other items when necessary by using similar procedures as those previously outlined in this section. Samples should not be accepted from other sources unless the sample collection procedures used are known to be acceptable, can be documented and the sample chain-of-custody can be established. If such samples are accepted, a standard sample label containing all relevant information and the Chain-Of-Custody Record will be completed for each set of samples. 3.4 Transfer of Custody with Shipment Transfer of custody is accomplished by the following: • Samples will be properly packaged for shipment in accordance with the procedures outlined in SESD Operating Procedure for Packing, Marking, Labeling and Shipping of Environmental and Waste Samples (SESDPROC-209). • All samples will be accompanied by the laboratory copy of the Chain-Of-Custody Record. If pre-printed forms are used, the white and pink sheets will be sent. If sample custody management software is used to generate the Chain-Of-Custody Record, the laboratory copy is identified with an “L” in the upper right corner. If multiple coolers are needed for shipment to a particular laboratory, the laboratory copy of the Chain-Of-Custody Record for the entire shipment is placed in a sealed plastic bag in one of the coolers. When shipping samples via common carrier, the "Relinquished By" box should be filled in; however, the "Received By" box should be left blank. The laboratory sample custodian is responsible for receiving custody of the samples and will fill in the "Received By" section of the Chain-of- COPY __________________________________________________________________________________ SESD Operating Procedure Page 13 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 Custody Record. One copy of the Record will be provided to and retained by the project leader. After samples have been received and accepted by the laboratory, a copy of the Chain-of-Custody Record, with ASB sample identification numbers, will be transmitted to the project leader. This copy will become a part of the project file. • If sent by mail, the package will be registered with return receipt requested. If sent by common carrier, an Air Bill should be used. The Air Bill number, shipment tracking number or registered mail serial number will be recorded in the remarks section of the Chain-Of-Custody Record. COPY __________________________________________________________________________________ SESD Operating Procedure Page 14 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 4 Receipt for Samples Form (CERCLA/RCRA/TSCA) 4.1 Introduction Section 3007 of the Resource Conservation and Recovery Act (RCRA) of 1976 and Section 104 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) of 1980 require that a "receipt" for all facility samples collected during inspections and investigations be given to the owner/operator of each facility before the field investigator departs the premises. The Toxic Substances Control Act (TSCA) contains similar provisions. The laws do not require that homeowners or other off-site property owners be given this form. 4.2 Receipt for Samples Form If necessary, a Receipt for Samples form, using either the pre-printed form or one generated by sample custody management software, is to be used to satisfy the receipt for samples provisions of RCRA, CERCLA and TSCA. The form also documents that split samples were offered and either "Received" or "Declined" by the owner/operator of the facility or site being investigated (if a sample is split with a facility, state regulatory agency or other party representative, the recipient should be provided (if enough sample is available) with an equal weight or volume of sample). All information must be supplied in the indicated spaces to complete the Receipt for Samples form. • The sampler(s) must sign the form in the indicated location • Each sample collected from the facility or site must be documented in the sample record portion of the form. The sample station number, date and time of sample collection, composite or grab sample designation, whether or not split samples were collected (yes or no should be entered under the split sample column), a brief description of each sampling location and the total number of sample containers for each sample must be entered. • The bottom of the form is used to document the site operator's acceptance or rejection of split samples. The project leader must sign and complete the information in the "Split Samples Transferred By" section (date and time must be entered). If split samples were not collected, the project leader should initial and place a single line through "Split Samples Transferred By" in this section. The operator of the site must indicate whether split samples were received or declined and sign the form. The operator must give their title, telephone number and the date and time they signed the form. If the operator refuses to sign the form, the sampler(s) should note this fact in the operator's signature block and initial this entry. COPY __________________________________________________________________________________ SESD Operating Procedure Page 15 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 The Receipt for Samples form is an accountable document after it is completed. A copy of the form is to be given to the facility or site owner/operator. The original form must be maintained in the project files. COPY __________________________________________________________________________________ SESD Operating Procedure Page 16 of 16 SESDPROC-005-R2 Sample and Evidence Management Sample and Evidence Management(005)_AF.R2 Effective Date: January 29, 2013 5 Sample Custody Management Software The container labels and the Chain-of-Custody record should be generated using a sample custody management software to streamline the documentation required by SESD and/or the Contract Laboratory Program (CLP) for sample identification and chain-of-custody. When possible, the sample custody management software should be used during all field investigations. Once the appropriate information is entered into the computer, the software will generate stick-on labels for the sample containers and will generate sample receipt forms and chain-of-custody records for the appropriate laboratory. The advantages to this system include faster processing of samples and increased accuracy. Accuracy is increased because the information is entered only once, and consequently, consistent for the bottle labels, sample receipt forms and chain-of-custody records. . COPY Appendix I USEPA SESD Procedure for Packing, Marking, Labeling, and Shipping of Environmental and Waste Samples (SESDPROC-209-R3) COPY ______________________________________________________________________________________ SESD Operating Procedure Page 2 of 8 SESDPROC-209-R3 Packing, Marking, Labeling and Shipping of Environmental and Waste Samples (209)_AF.R3 Effective Date: February 4, 2015 Revision History The top row of this table shows the most recent changes to this controlled document. For previous revision history information, archived versions of this document are maintained by the SESD Document Control Coordinator on the SESD local area network (LAN). History Effective Date SESDPROC-209-R3, Packing, Marking, Labeling and Shipping of Environmental and Waste Samples, replaces SESDPROC-209-R2. Cover Page: Changes made to reflect reorganization of SESD from two field branches to one: John Deatrick listed as the Chief, Field Services Branch. The FQM was changed from Liza Montalvo to Hunter Johnson. Revision History: Changes were made to reflect the current practice of only including the most recent changes in the revision history. February 4, 2015 SESDPROC-209-R2, Packing, Marking, Labeling and Shipping of Environmental and Waste Samples, replaces SESDPROC-209-R1. April 20, 2011 SESDPROC-209-R1, Packing, Marking, Labeling and Shipping of Environmental and Waste Samples, replaces SESDPROC-209-R0. November 1, 2007 SESDPROC-209-R0, Packing, Marking, Labeling and Shipping of Environmental and Waste Samples, Original Issue February 05, 2007 COPY ______________________________________________________________________________________ SESD Operating Procedure Page 3 of 8 SESDPROC-209-R3 Packing, Marking, Labeling and Shipping of Environmental and Waste Samples (209)_AF.R3 Effective Date: February 4, 2015 TABLE OF CONTENTS 1 General Information ................................................................................................. 4 1.1 Purpose............................................................................................................... 4 1.2 Scope/Application ............................................................................................. 4 1.3 Documentation/Verification ............................................................................. 4 1.4 References .......................................................................................................... 5 1.5 General Precautions.......................................................................................... 5 1.5.1 Safety .......................................................................................................... 5 2 Shipment of Dangerous Goods ................................................................................ 6 3 Shipment of Environmental Samples ...................................................................... 7 COPY ______________________________________________________________________________________ SESD Operating Procedure Page 4 of 8 SESDPROC-209-R3 Packing, Marking, Labeling and Shipping of Environmental and Waste Samples (209)_AF.R3 Effective Date: February 4, 2015 1 General Information 1.1 Purpose Regulations for packing, marking, labeling, and shipping of dangerous goods by air transport are promulgated by Department of Transportation under 49 CFR, Subchapter C, Hazardous Materials Regulations, and the International Air Transport Authority (IATA), which is equivalent to United Nations International Civil Aviation Organization (UN/ICAO). Transportation of hazardous materials (dangerous goods) by EPA personnel is covered by EPA Order 1000. This document describes general and specific procedures, methods and considerations to be used and observed by SESD field investigators when packing, marking, labeling and shipping environmental and waste samples to ensure that all shipments are in compliance with the above regulations and guidance. 1.2 Scope/Application The procedures contained in this document are to be used by field personnel when packing, marking, labeling, and shipping environmental samples and dangerous goods by air transport. Samples collected during field investigations or in response to a hazardous materials incident must be classified prior to shipment, as either environmental or hazardous materials (dangerous goods) samples. In general, environmental samples include drinking water, most groundwater and ambient surface water, soil, sediment, treated municipal and industrial wastewater effluent, biological specimens, or any samples not expected to be contaminated with high levels of hazardous materials. Samples collected from process wastewater streams, drums, bulk storage tanks, soil, sediment, or water samples from areas suspected of being highly contaminated may require shipment as dangerous goods. Government employees transporting samples or hazardous materials (i.e., preservatives or waste samples) in government vehicles are not subject to the requirements of this section in accordance with 49 CFR 171.1(d)(5). EPA contractors, however, are not covered by this exemption and may not transport these materials without full compliance with 49 CFR. Mention of trade names or commercial products in this operating procedure does not constitute endorsement or recommendation for use. 1.3 Documentation/Verification This procedure was prepared by persons deemed technically competent by SESD management, based on their knowledge, skills and abilities and have been tested in practice and reviewed in print by a subject matter expert. The official copy of this procedure resides on the SESD local area network (LAN). The Document Control Coordinator (DCC) is responsible for ensuring the most recent version of the procedure is placed on the LAN and for maintaining records of review conducted prior to its issuance. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 5 of 8 SESDPROC-209-R3 Packing, Marking, Labeling and Shipping of Environmental and Waste Samples (209)_AF.R3 Effective Date: February 4, 2015 1.4 References International Air Transport Authority (IATA). Dangerous Goods Regulations, Most Recent Version. Title 40 Code of Federal Regulations (CFR), Pt. 136.3, Identification of Test Procedures, July 1, 2001. See Table II, Footnote 3. Title 49 CFR, Pt. 171.1(d)(5), Applicability of Hazardous Materials Regulations (HMR) to Persons and Functions. United States Department of Transportation (US DOT). 2003. Letter from Edward T. Mazzullo, Director, Office of Hazardous Materials Standards, to Henry L. Longest II, Acting Assistant Administrator, USEPA, Ref No. 02-0093, February 13, 2003. US Environmental Protection Agency (US EPA) Order 1000.18, February 16, 1979. US EPA. 1981. "Final Regulation Package for Compliance with DOT Regulations in the Shipment of Environmental Laboratory Samples," Memo from David Weitzman, Work Group Chairman, Office of Occupational Health and Safety (PM-273), April 13, 1981. US EPA. 2001. Environmental Investigations Standard Operating Procedures and Quality Assurance Manual. Region 4 Science and Ecosystem Support Division (SESD), Athens, GA. US EPA. Analytical Support Branch Laboratory Operations and Quality Assurance Manual. Region 4 SESD, Athens, GA, Most Recent Version. US EPA. Safety, Health and Environmental Management Program Procedures and Policy Manual. Region 4 SESD, Athens, GA, Most Recent Version. 1.5 General Precautions 1.5.1 Safety Proper safety precautions must be observed when packing, marking, labeling, and shipping environmental or waste samples. Refer to the SESD Safety, Health and Environmental Management Program (SHEMP) Procedures and Policy Manual and any pertinent site-specific Health and Safety Plans (HASPs) for guidelines on safety precautions. These guidelines, however, should only be used to complement the judgment of an experienced professional. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 6 of 8 SESDPROC-209-R3 Packing, Marking, Labeling and Shipping of Environmental and Waste Samples (209)_AF.R3 Effective Date: February 4, 2015 2 Shipment of Dangerous Goods The project leader is responsible for determining if samples collected during a specific field investigation meet the definitions for dangerous goods. If a sample is collected of a material that is listed in the Dangerous Goods List, Section 4.2, IATA, then that sample must be identified, packaged, marked, labeled, and shipped according to the instructions given for that material. If the composition of the collected sample(s) is unknown, and the project leader knows or suspects that it is a regulated material (dangerous goods), the sample may not be offered for air transport. If the composition and properties of the waste sample or highly contaminated soil, sediment, or water sample are unknown, or only partially known, the sample may not be offered for air transport. In addition, the shipment of pre-preserved sample containers or bottles of preservatives (e.g., NaOH pellets, HCL, etc.) which are designated as dangerous goods by IATA is regulated. Shipment of nitric acid is strictly regulated. Consult the IATA Dangerous Goods Regulations for guidance. Dangerous goods must not be offered for air transport by any personnel except SESD’s dangerous goods shipment designee or other personnel trained and certified by IATA in dangerous goods shipment. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 7 of 8 SESDPROC-209-R3 Packing, Marking, Labeling and Shipping of Environmental and Waste Samples (209)_AF.R3 Effective Date: February 4, 2015 3 Shipment of Environmental Samples Guidance for the shipment of environmental laboratory samples by personnel is provided in a memorandum dated March 6, 1981, subject "Final National Guidance Package for Compliance with Department of Transportation Regulations in the Shipment of Laboratory Samples". By this memorandum, the shipment of the following unpreserved samples is not regulated:  Drinking water  Treated effluent  Biological specimens  Sediment  Water treatment plant sludge  POTW sludge In addition, the shipment of the following preserved samples is not regulated, provided the amount of preservative used does not exceed the amounts found in 40 CFR 136.3 or the USEPA Region 4 Analytical Support Branch Laboratory Operations and Quality Assurance Manual (ASBLOQAM), Most Recent Version. This provision is also discussed in correspondence between DOT and EPA (Department of Transportation, Letter from Edward T. Mazzullo, Director, Office of Hazardous Materials Standards, to Henry L. Longest II, Acting Assistant Administrator, USEPA, Ref No.: 02-0093, February 13, 2003). It is the shippers' (individual signing the air waybill) responsibility to ensure that proper amounts of preservative are used:  Drinking water  Ambient water  Treated effluent  Biological specimens  Sediment  Wastewater treatment plant sludge  Water treatment plant sludge Samples determined by the project leader to be in these categories are to be shipped using the following protocol, developed jointly between USEPA, OSHA, and DOT. This procedure is documented in the "Final National Guidance Package for Compliance with Department of Transportation Regulations in the Shipment of Environmental Laboratory Samples." Untreated wastewater and sludge from Publicly Owned Treatment Works (POTWs) are considered to be "diagnostic specimens" (not environmental laboratory samples). However, because they are not considered to be etiologic agents (infectious) they are not restricted and may be shipped using the procedures outlined below. COPY ______________________________________________________________________________________ SESD Operating Procedure Page 8 of 8 SESDPROC-209-R3 Packing, Marking, Labeling and Shipping of Environmental and Waste Samples (209)_AF.R3 Effective Date: February 4, 2015 Environmental samples should be packed prior to shipment by air using the following procedures: 1. Allow sufficient headspace (ullage) in all bottles (except VOA containers with a septum seal) to compensate for any pressure and temperature changes (approximately 10 percent of the volume of the container). 2. Ensure that the lids on all bottles are tight (will not leak). 3. Place bottles in separate and appropriately sized polyethylene bags and seal the bags. If available, the use of Whirl-Pak bags is preferable, if unavailable seal regular bags with tape (plastic electrical tape). 4. Select a sturdy cooler in good repair. Secure and tape the drain plug with fiber or duct tape inside and outside. Line the cooler with a large heavy duty plastic bag. 5. Place cushioning/absorbent material in the bottom of the cooler and then place the containers in the cooler with sufficient space to allow for the addition of cushioning between the containers. 6. Put "blue ice" (or ice that has been "double bagged" in heavy duty polyethylene bags and properly sealed) on top of and/or between the containers. Fill all remaining space between the containers with absorbent material. 7. Securely fasten the top of the large garbage bag with tape (preferably plastic electrical tape). 8. Place the Chain-of-Custody Record or the CLP Traffic Report Form (if applicable) into a plastic bag, and tape the bag to the inner side of the cooler lid. 9. Close the cooler and securely tape (preferably with fiber tape) the top of the cooler shut. Chain-of-custody seals should be affixed to the top and sides of the cooler within the securing tape so that the cooler cannot be opened without breaking the seal. COPY