NCD991278540_20101101_Weyerhaeuser Company_FRBCERCLA RA_Remedial Action Work Plan Revised-OCR

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dial Action o Reme W rk Plan
Domtar Paper ~o:!rt~~~~~;,;, North Carolina ou.4 Plymout , Welch Creek Area
2010 . d November Revise
I[)) ~ t ~ ~ 'W r~ ij
ITTJ DEC 2 1 2010 10
SUPERFUNO SECTION
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RMT
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• ENVIRONMENT • ENERGY• ENGINEERING
Remedial Action Work Plan
Domtar Paper Company, LLC
Welch Creek Area OU-4 Plymouth, Martin County, North Carolina
Revised November 2010
Michael B. Parker, P.E.
Robert W. Hanley, Ph.D.
Environmental Scientist
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
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Principal-In-Charge
e 2010 RMT, Inc.
All Rig/its Resuved
30 Patewood Drive, Suite 100 • Greenville, SC 29615-3535 • [phone] • [phone] FAX• www.rmtinc.com
CREATING BALANCE'"
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Table of Contents
1. Introduction ...................................................................................................................................... 1
1.1 Remedial Action Objectives ................................................................................................. 2
1.1.1 Remedial Action Objectives .................................................................................... 2
1.1.2 Remedial Goal Options ........................................................................................... 2
1.2 Scope of Remedial Action Work Plan ................................................................................ 3
2. Site Conditions ................................................................................................................................. 4
2.1 Current Site Conditions ........................................................................................................ 4
2.2 Welch Creek Manageable Properties Design Implications ............................................. 4
3. eMNR™ Cover and Monitoring Construction Tasks ................................................................. 7
3.1 eMNR'"" Design Components ............................................................................................. 7
3.2 eMNRTM Construction Monitoring Equipment Installation and Operation ................. 9
3.2.l Water Quality Sampling .......................................................................................... 9
3.2.2 Cover Placement Thickness .................................................................................. l O
3.2.3 Documentation of Overall Cover Integrity and Construction ......................... 10
3.3 Remedy Performance Standards ....................................................................................... 11
3.4 Site Restoration .................................................................................................................... 12
4. Additional Remedial Action Tasks ............................................................................................. 14
4.1 Mobility Monitoring-Midstream Reach ......................................................................... 14
4.1.1 Equipment Requirements ..................................................................................... 14
4.1.2 Summary of Sampling Program .......................................................................... 16
4.2 Performance Standard Monitoring ................................................................................... 17
4.3 Institutional Controls .......................................................................................................... 17
5. Description of Work Products and Deliverables ....................................................................... 22
5.1 Remedial Action Planning Documents ............................................................................ 22
5.1.l Remedial Action Work Plan ................................................................................. 22
5.1.2 Remedial Action Work Plan Attachments .......................................................... 22
5.2 Construction Documentation Reports ............................................................................. 23
5.2.1 Pre-final Construction Inspection Report ........................................................... 23
5.2.2 Interim and Final Remedial Action Reports ....................................................... 23
5.2.3 Performance Standard Verification/Operations and Maintenance Plan ........ 24
6. Project Schedule ............................................................................................................................. 25
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan i
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7. Project Management Plan ............................................................................................................. 27
7.1 Reporting Schedule ............................................................................................................. 27
7.2 Data Management ............................................................................................................... 27
7.3 Document Control ............................................................................................................... 27
7.4 Document Retention ........................................................................................................... 28
7.5 Description of Data Submittals/Reporting ...................................................................... 28
8. Community Relations ................................................................................................................... 30
List of Tables
Table 4-1
Table 4-2
List of Figures
Figure 2-1
Figure 3-1
Figure 4-1
Figure 6-1
List of Appendices
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Summary of Remedy Performance Monitoring ................................................ 18
Summary of Institutional Controls for Welch Creek Area ............................... 21
General Site Map ...................................................................................................... 5
Upstream Reach -eMNRTM Cover Area ............................................................... 8
Midstream Reach Plan View ................................................................................ 15
Remedial Action Construction Schedule ............................................................ 26
Cover Operations Plan
Project Delivery Strategy
Construction Management Plan
Construction Quality Assurance Project Plan
Construction Health and Safety Plan/ Contingency Plan
RMT North Caro/inn, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan ii
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Section 1
Introduction
The Welch Creek Area Operable Unit 4 (OU-4) is located at the Domtar Paper Company, LLC
(Domtar) site in Plymouth, Martin County, North Carolina. The Plymouth Mill Site (Site
No. NCD991278540) incorporates four operable units. Remedial actions for Operable Units 1
and 3 (the former Landfill No. 1 and former Chlorine Plant, respectively) have reached
construction completion and are being monitored. A remedy has also been selected for
Operable Unit 2, the Lower Roanoke River. The consent decree for the Remedial
Design/Remedial Action (RD/RA) for OU-4 between Domtar and United States Environmental
Protection Agency (USEPA) was filed in January 2009, [Civil Action No. 4:08-CV-179-D filed
1/07/09]. RD activities included supplemental data collection and baseline monitoring as well as
preparation of conceptual and final design reports. The Final Remedial Design Report for OU-4
was approved by the USEPA in July 2010. This Remedial Action Work Plan (RA Work Plan)
with associated attachments is also being completed under the requirements of the negotiated
Consent Decree (CD) and Statement of Work (SOW) for OU-4.
The remedial action selected in the Record of Decision (ROD) and defined in the final design
has five components: 1) enhanced Monitored Natural Recovery (eMNR™) of sediment
contaminated with dioxin above cleanup goals in the upstream reach of Welch Creek;
2) mobility monitoring for the less contaminated sediment in the midstream reach; 3) long-term
monitoring and maintenance of the eMNRTM sand cover; 4) long-term testing and monitoring of
sediment, surface water, and biota to document the performance of the remedy and compliance
with cleanup goals; and 5) institutional controls.
The components of this RA Work Plan specifically identified in the SOW and included in this
submittal include the following:
■ Description of RA tasks and work product deliverables in the RA Work Plan:
Schedule;
Project Management Plan; and
As requested by USEPA, a description of community relations support activities.
■ Series of appended summary plans in a handbook format that facilitate in-field use:
A. Cover Operations Plan
B. Project Delivery Strategy
C. Construction Management Plan (CMP)
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
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D. Construction Quality Assurance Plan (CQAP)
E. Construction Health and Safety Plan/Contingency Plan (CHSP/CP)
1.1 Remedial Action Objectives
As documented in the ROD for Welch Creek, the agreed-upon remedial action objectives
(RAOs) for Welch Creek include goals for the protection of human health and the environment
and for the management of migration potential as follows.
1.1.1 Remedial Action Objectives
Human Health Remedial Action Objectives
• Maintain acceptable levels of potential risk to site-specific human
receptors.
• Continue progress toward removal of remaining fish consumption
advisory in Welch Creek.
Ecological Remedial Action Objectives
•
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•
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Protect the health of local populations and communities of biota .
Reduce the dioxin concentrations in whole fish tissues over time, to the
extent practicable.
Achieve surface water concentrations at or below surface water standards,
to the extent practicable.
Limit biological uptake of constituents of concern (COCs) from the
sediment in areas with excess potential risk, to the extent practicable.
Minimize the adverse effects of remediation activities on the existing
aquatic environment and/or wetland habitat, to the extent practicable.
Management of Migration Potential
Minimize significant migration of COC-containing sediment in delineated areas
of concern, to the extent practicable.
1.1.2 Remedial Goal Options
Remedial goal options (RGOs) for the two final COCs, dioxin and mercury, were
addressed in the Welch Creek ROD. For Welch Creek OU-4, the term RGO was used to
identify a dioxin concentration (as l-TEQ) quantified in surficial sediment. The RGO
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
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1.2
was then used to define the areas targeted for remediation in Welch Creek. The selected
clean-up goal defined in the ROD was 1 ppb 1-TEQ (within the desired range of risk
protection) and consistent with existing USEPA guidance for residential use. The ROD
noted, "given the distribution of contaminants in sediment, achieving a clean-up goal of
1 ppb for dioxin TEQ will likely result in a surface area weighted average concentration
in the upstream reach approaching 0.41 ppb." In the ROD, the USEPA also addressed
considerations for a mercury RGO and determined that establishing a RGO for mercury
was not appropriate at this time due to the possibility of airborne deposition from other
sources.
Scope of Remedial Action Work Plan
The RA Work Plan provides a detailed plan of action for construction and implementation of
the response action remedy set forth in the ROD for achievement of the performance standards.
The performance standards for the Welch Creek OU-4 will be further described in the
Performance Standards Verification Plan (PSVP).
RMT North Carolina, Inc. ! Domtar Paper Company, LLC
Remedial Action Work Plan
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2.1 Current Site Conditions
Section 2
Site Conditions
Welch Creek is part of Subbasin 03-03-09 of the Roanoke River basin, which is an area with low
population density (45 people per acre) and a large portion of the landscape as wetlands or
forests (71.5 percent) or in cultivated crops (24.8 percent) (NC DENR DWQ, 2001 and 2006). In
terms of the study area, non-production Mill facilities (parking areas, green space, wastewater
settling ponds) border the creek along the west side (Figure 2-1) while the east bank has
wetland forest. There are a few residences located near the Highway 64 Bridge (the southern
limit of OU-4). The large expanse of dense vegetation, trees, and frequently flooded wetlands
limit access to the creek bank, and over the study area, Domtar owns and maintains security
fencing or access control for the property on the east side and most of the west side of the creek.
Welch Creek and its adjacent wetlands serve as the eastern boundary for the Domtar facility. A
total of six bridges span Welch Creek, including three railroad bridges and three bridges for
primarily mill-related automobile traffic. The low bridge clearances near the mouth restrict
boat access to upper reaches of the creek except for small watercraft. There is one small boat
ramp, accessible from the secured mill property, near Master Transect No. 5 (MT-5).
Bathymetric surveys of Welch Creek provide physical data on stream features needed to
evaluate the remedial alternatives. Data collected during the Remedial Investigation/Feasibility
Study (Rl/FS) confirmed variable side slopes along the upstream reach of Welch Creek.
Pre-design data collection activities described in the Conceptual Design Report further refined
the bathymetry in the upstream reach delineated for eMNR™ cover placement.
A survey of woody debris along the upstream reach of Welch Creek was done using side-scan
sonar. The survey identified an extensive amount of tree fall and other debris in the upstream
reach of Welch Creek. Woody debris was visible from the water surface and shore as well as
hidden beneath the water surface and contained within the sediments.
2.2 Welch Creek Manageable Properties Design Implications
As recommended in the USEPA Sediment Guidance (USEPA, 2005), the Conceptual Site Model
(CSM) for Welch Creek and adjacent wetlands continued to be revised throughout the Rl/FS
process. The updated CSM in the FS is focused on dioxin as a primary COC since on-going air
deposition sources of mercury cannot be controlled by a sediment remedy. This CSM
incorporated the applicable information from the facilitated meetings, the pilot studies;
RMT North Carolina, foe. I Domtar Paper Company, LLC
Remedial Action Work Pinn
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2,000 .0
FEEV
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11E010N EVALUATQI OF MTI.AND 11GN1ACNa (NC-CMWSi 1•.
DOMTAR (FORMERLY WEYERHAEUSER)
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK • OU◄
GENERAL SITE MAP
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supplemental data developed by independent entities and published literature. The revised
CSM reinforced the Welch Creek manageable properties defined by the site stakeholders. It is
these manageable properties that form the basis for the selected remedy and many components
of the RD presented in this report.
The p rimary manageable properties in the upstream and downstream reaches were identified
as surface concentrations and the bioavailability of COCs at these locations. To manage
ecological exposure, surface sediment was defined as the bioactive layer (agreed to be
5 centimeters in Welch Creek), and thus, concentrations in this layer were used to delineate
areas of Welch Creek that require cover placement. Bioavailability of dioxin in Welch Creek
depends upon clioxin's chemical characteristics (low water solubility and strong hydrophobic
nature), the total and black carbon content of the sediment, and the amount of physical mixing
of surficial sediment through bioturbation or even decomposition gas entrainment. The thin
layer eMNR™ cover selected as the remedial action for the upstream reach has been designed to
address both of these manageable properties.
The manageable properties for the midstream reach (MT-7 to GT-15) were velocity control and
sediment strength since this reach was identified by modeling to be most susceptible to
mobilization. This increased potentia l for scour is due to higher water velocities in a reduced
cross-section area present in this section of the creek. Actual movement of contaminants from
this reach was not assessed during the modeling. It is notable that the sediments in this area
had lower clioxin concentrations as well as higher density and larger particle size. The higher
shear strength is expected to offset, to some degree, the impact of higher velocity on sediment
stability. The lower contaminant concentrations further reduces potential for risk. Thus, the
selected remeclial action for this area was monitoring to further evaluate water depth and
secliment mobility to man age risk and then assess the results during the 5-year review as part of
an overall adaptive management process.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Pinn
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Section 3
eMNR™ Cover and
Monitoring Construction Tasks
3.1 eMNR™ Design Components
The ROD defined the general area requiring containment using the eMNR™ cover based upon
a clean-up criteria of 1 ug/kg dioxin (I-TEQ) in the bioactive zone of the sediment. Based on a
compilation of all investigation data to date including supplemental sampling during the
remedial design preparation, the area requiring containment was refined to extend bank to
bank from MT-3 immediately downstream of the railroad bridge (forming the upstream
boundary) to MT-6 (forming the downstream boundary). The containment area will not extend
into Little Mill Creek located near MT-5. Figure 3-1 identifies the area to be covered. The
containment area extends approximately 5,300 feet in length with an average width along this
length of approximately 125 feet bank to bank.
The cover system selected and designed for the upstream reach of Welch Creek was developed
to address the defined manageable properties (surficial sediment concentrations and
bioavailability of COCs), accommodate the physical characteristics of the sediments in this area
of the creek, and consider the bathymetry of the creek bottom. The overall cover system
configuration consists of placement of a minimum of two lifts of sand from the top of bank on
one side, across the entire bottom and near shore submerged side slopes to the top of bank on
the other side. The first lift will be no more than 1 to 2 inches (2 to 5 centimeters) thick to avoid
destabilizing the sediment substrate. The targeted thickness of the eMNR™ cover to be placed
over exposed sediment is specified in the ROD to be 5 to 10 centimeters.
The eMNR™ cover system will consist of layers of sand that are placed to uniformly load the
underlying sediments without destabilizing the deposits, resuspending surficial sediments or
mixing with the fine grained wastewater solid deposits. Two sand mixtures have been
specified with slightly different particle sizes of sand to accomplish these goals. The initial sand
layer will have slightly smaller grains and more angularity, while the next layer(s) will contain a
greater percentage of larger particle sizes and more rounded granules. The specific sand
requirements are presented in the cover placement plan. Care will be taken to limit the amount
of very fine particles by specification or washing on order to limit turbidity during cover
placement. The sand cover material was carefully selected to meet the following criteria:
■ Local availability;
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
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LEGEND
C::J Revised Delineation of Extent for eMNR Cover
-,v PROPERTY BORY.
TRANSECTS
/V GENERAL TRANSECT
/V MASTER TRANSECT
250 500
FEET
DOMTAR PAPER COMPANY, LLC
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK -OU-4
REMEDIAL ACTION WORKPLAN
UPSTREAM REACH -eMNR COVER AREA
JULY 010
RMT
PROJ.NO.:
FILE NO.:
FIGURE 3-1
30 PstsWOOd Drive, Suite 100
· Greenv/1/e, SC 29615
864.281.0030 phone
864.281.0288 rex
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■ Targeted grain sizes;
■ Limited angularity; and
■ Minimum release of turbidity when exposed to Welch Creek water.
Approximately 7,400 cubic yards of sand will be required to cover the targeted length of Welch
Creek.
3.2 eMNR™ Construction Monitoring Equipment Installation and Operation
The following subsections briefly describe the monitoring during construction. Further details
are included in the Cover Operations Plan (Appendix A) and CQAP (Appendix D) attached to
this document.
3.2.1 Water Quality Sampling
Turbidity data will be collected from upstream and downstream of the placement zone
being addressed at that time. At both upstream and downstream locations, turbidity
measurements will be collected at mid-depth and near-sediment intervals within the
water column. All downstream turbidity data (near GT-16) will be compared to a target
of 25 nephelometric turbidity units (ntus) or two times the upstream turbidity reading,
whichever is larger. Turbidity data will be considered confirmed if a turbidity plume
emanating from the excavation zone is visible or if three consecutive turbidity samples
averaged over 15-minute increments confirm the elevated turbidity above the target
levels. If turbidity monitoring data exceeds 50 ntus, notification will be made to the
USEPA Remedial Project Manager (RPM) and the Surface Water Protection Supervisor
of the North Carolina Department of Environment and Natural Resources (NC DENR)
Washington Regional Office.
Contingency measures anticipated to be implemented in response to confirmed elevated
turbidity are outlined in Section 10 of the Cover Operations Plan (Appendix A) and
Subsection 3.3 of the CQAP (Appendix D). Briefly stated, those measures include the
following mitigation actions to identify and eliminate the cause of elevated turbidity
observations:
Inspection of the area downstream of the excavation site and the turbidity curtains
and repair as needed.
Implementation of troubleshooting measures based on field conditions to reduce
turbidity (i.e., re-securing or re-positioning the silt curtain, modifying the placement
approach, etc.).
RMT North Cnrolinn, 111c. I Domtar Paper Company, LLC
Remedial Action Work Plan
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Finally, placement rates will be reduced or procedures modified (e.g., additional
sand screening) until the turbidity has returned to acceptable levels.
Water quality monitoring stations for use during sand cover placement activities will be
located upstream of MT-3, at the pipeline crossing and downstream near GT-16.
Equipment at these sampling locations will include the following:
6600EDS (or equivalent) Sonde unit configured to measure dissolved oxygen (DO),
conductivity, temperature, pH, and turbidity simultaneously;
Sontek Argonaut SL Current Meter to measure and record the water velocity and
flow direction (Pipeline Crossing and Near GT-16 Only); and
6712 or 3700 ISCO automatic sampler units configured to collect samples at mid
depth of the water column; samples will be tested for volatile suspended solids
(YSS), total suspended solids (TSS), dioxin and appropriate indicator elements
(manganese [Mn], magnesium [Mg], iron [Fe], calcium [Ca], barium [Ba], aluminum
[Al] and titanium [Ti]).
The comparison criteria for surface water analyzed during construction monitoring will
be the concentrations measured upstream and the range of background concentrations
established during the pre-construction sampling activities.
3.2.2 Cover Placement Thickness
After placement of the initial lift, a visual assessment utilizing an underwater camera
will be performed along with collecting cores at specified locations to verify placement
volume/speed are optimal.
3.2.3 Documentation of Overall Cover Integrity and Construction
The integrity of the eMNR™ cover placement will be documented on a daily basis using
several measurements:
volume measurements of cover material placed;
bathymetry of the covered area;
cover thickness as measured by 3 inch diameter core samples; and
visual assessment of cover integrity (consistency of coverage) as documented by
underwater cameras and sonar based bathymetry reading with a boat mounted
echo-sounder.
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3.3 Remedy Performance Standards
The performance standards for the remedial action at Welch Creek have been developed to
provide the means to ensure that the selected RA achieves the overall RAOs. The performance
standards are presented as either_construction impacts or long term remedy integrity evaluation
actions as related remedial action objectives. The construction monitoring activities and the
PSVP data collection activities will be focused cin collecting site-specific data needed to assess
the impacts of construction and the effectiveness of the remedy. Specific performance
standards are as follows.
Construction Performance Standards
Monitor turbidity in surface water on a real-time basis during remedy construction
to assess impact of cover placement and potential for resuspension of solids control
measures and adjust daily operations as necessary.
Monitor concentrations of dioxin in surface water on a weekly basis during remedy
construction to minimize adverse effects of remediation on existing aquatic habitat
to the extent practicable.
• The current North Carolina state water quality standard of 0.000005 ng/L
will be the comparison criteria for 2,3,7,8-tetrachlorodibenzo-p-dioxin
(TCDD) with consideration of the observed background concentrations of
2,3,7,8-TCDD in the event that observed upstream or background
concentrations are higher than water quality standard.
Limit extensive in-water activities during flooding events and then measure
mercury and possibly dioxin in wetland soils to delineate any expanded impacts of
remedy construction beyond existing areas of concern.
•
•
Cover placement activities will be limited during high-energy flood events
to minimize distribution of resuspended materials into adjacent wetlands.
To the extent in-stream activities are conducted during flood events and
high turbidity waters are carried into the adjacent wetlands, wetland soils
will be analyzed for mercury and/or dioxin. Sampling wetland soil for
mercury and/or dioxin will be based on observations of these compounds
at elevated level in flood stage surface water samples.
Place cover materials over existing debris to the extent practicable to limit adverse
impacts on the existing benthic habitat.
Long-term Remedy Performance -Human Health
Limit trespasser access to area and posting fish advisory notices, thus maintaining
acceptable levels of risk to site-specific human-health receptors.
RMT North Carolina, Inc. I Domtar Paper Compa11y, LLC
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3.4
Monitor concentrations of dioxin in fillet fish tissue to confirm stable to decreasing
concentrations that lead to the removal of remaining fish advisories and further
protect the local populations and communities of biota. Refine estimate on time
frame to remove fish advisories.
Long-term Remedy Performance -Ecological Health
Place and then maintain the integrity of the sediment cover to minimize
bioturbation of impacted wastewater solids, to reduce surface water dioxin
concentrations, to limit direct contact of organisms with impacted sediment and to
limit the biological uptake of COCs from sediment in areas with potential excess
risk to the extent practicable.
Monitor concentrations of dioxin in whole fish tissue to compare to local
background contributions and confirm stable to decreasing concentrations that
further protect the local populations and communities of biota.
Monitor concentrations of mercury in whole fish to compare to regional fish tissue
concentrations and confirm that mercury in fish is not a site-specific issue.
Conduct benthic community surveys to define the recovery time frame and confirm
that concentrations of dioxin in the benthic organisms are decreasing after cover
placement.
Measure dioxin concentrations is surface water after high velocity events to confirm
the cover is effective for controlling dioxin and that sediments located in the
midstream reach are stable during high velocity conditions.
Site Restoration
The proposed remedial action will affect approximately 60 linear feet of bank along Welch
Creek. The bank area will need to be cleared for creek access during the remedial action.
Staging and storage areas will be located away from the banks of the creek. The areas
anticipated to bed isturbed for creek access, and remedial action staging and storage constitute
less than one contiguous acre and are therefore not subject to sediment and erosion control
permitting requirements. Appropriate measures will be taken to protect water quality during
the bank clearing and remedial action and may include silt curtains installed around the area to
prevent erosion of soils along the bank or in the adjacent wetlands. The area will be maintained
during the remedial action implementation. Site measures will be maintained to prevent
erosion after the remedial action is completed and may include grass plantings or maintenance
of silt fences in the area.
Long-term site restoration of the bank areas will be performed upon completion of the remedial
action. Where necessary, the disturbed areas will be replanted with appropriate vegetation
RMT North Carolina, l11c. I Domtar Paper Company, LLC
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using established plants after completion of the 5-year review. Periodic planned inspections
will document the integrity of the cleared area during the first 5 years and annually after the
completion of the long-term bank restoration. Off-road vehicle use will be held to a minimum
in the cleared areas once in-water remedial action work is completed. Monitoring of the cleared
area will be conducted in conjunction with the annual inspections during the first 5 years upon
completion of the project. The inspections will document dominant plant species, hydrology,
and soils. Following inspections, if necessary, areas will be reseeded or replanted if the area has
not become established with suitable vegetation. Vegetation may be obtained from
commercially available seed stock or nurseries. During the growing season or during extreme
weather events, site inspections will be conducted by Domtar personnel, as necessary.
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Section 4
Additional Remedial Action Tasks
The remaining three components of the remedy do not involve major construction activities
with associated monitoring. Additional planning for implementing these remedy components
will be initiated during the remedial construction of the eMNRl'M cover. The final plans will
reflect information obtained during construction and construction monitoring. Thus, it is
anticipated that the mobility monitoring as well as the performance monitoring activities will
start after construction completion for the eMNRTM cover.
4.1 Mobility Monitoring -Midstream Reach
As identified in the FS, preliminary hydrologic modeling efforts indicated the midstream reach
(MT-7 to GT-15) has the greatest potential for erosion potential. The location of the midstream
reach is shown on Figure 4-1. The area with the potential for erosion is located primarily in
limited reach centered near MT-7 that has a small cross-sectional area due to a very shallow
bottom and constrained banks. The mid-stream reach monitoring program is designed to
evaluate actual contaminant mobility during baseflow and high velocity events. Specifically,
10 to 25 year recurrence interval events will be targeted since the United States Army Corps of
Engineers (USACE) concluded, based upon their hydrologic model, that the sediments in the
midstream reach were most susceptible to mobility during storm with 10-to 25-year frequency
recurrence intervals. Therefore, the initial mobility monitoring program will target events of
this magnitude during the first 5 years of monitoring. Samples will be collected up and
downstream of the midstream reach from automated sampling stations that can be activated
remotely. Additional details regarding the monitoring stations and other aspects of the
program will be·further described in the draft PSVP.
4.1.1 Equipment Requirements
Water quality monitoring stations to conduct mobility monitoring will be located at the
pipeline crossing and downstream near GT-16. Equipment at these sampling locations
will include the following:
6600EDS (or equivalent) Sande unit configured to measure DO, conductivity,
temperature, pH, and turbidity simultaneously;
Sontek Argonaut SL Current Meter to measure and record the water velocity and
flow direction;
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--~;-: '.;,p'.,.. , .. 1 .. ,~. ---0:\05174\05\51740502.Fig3_3.mxd 1/22/2010 12:30:29 -- --- ---- ---111 ZONE OF POTENTIAL SEDIMENT MOelLITY /V PROPERTY BORY. TRANSECTS - -250 ~EETe DOMTAR PAPER COMPANY, LLC MARTIN COUNTY, NORTH CAROLINA WELCH CREEK -OU-4 REMEDIAL ACTION WORKPLAN MIDSTREAM REACH PLAN VIEW t·-·· _·-· .. :1SCALE~NOTEO PROJ.NO.: 00825.0I.OOI FILE NO.: 517-t0502.Flg3_3 JULY 2010 RMT FIGURE 4-1 30 Patewoocl Drl\le, Su/le 100 Greenville, SC 29615 lUU.281.0030 phol'le 864.281.0288 fax
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6712 or 3700 ISCO automatic sampler units (or equivalent) configured to collect
samples at mid depth of the water column; samples will be tested for VSS, TSS,
dioxin and appropriate indicator elements (Mn, Mg, Fe, Ca, Ba, Al and Ti); and
meteorological station may also need to be installed, depending upon local
information that may be available, to evaluate the wind conditions and precipitation
events in order to target sampling specific events.
4.1.2 Summary of Sampling Program
The potential mobility of sediment in the midstream reach of Welch Creek is driven
largely by the receding river stages in the Roanoke River. A large receding event in the
Roanoke River can change elevations within Welch Creek by up to and over 2 feet in a
12-hour span. Receding river stages that result in an increase in stream velocity in
Welch Creek may occur from precipitation events, lunar tides, wind tides or a
combination of these events. Precipitation events that ultimately increase the stage level
in the Roanoke River to a level that results in increase stream velocities in Welch Creek
are relatively uncommon. Therefore, during the prior remedial investigation activities
water quality samples were collected during a period of base flow and various receding
stage events (up to -2 feet in elevation) to target the wind tide events that can cause a
dramatic increase in the Welch Creek flow velocity and correlate with potential mobility.
To monitor sediment mobility in the midstream reach surface water samples will be
collected a total of 2 to 3 times annually at the pipeline station and near GT-16. The
pipeline station is located upstream of the midstream reach near GT-11 and will be used
as the background/upstream location for the midstream reach. The sample events will
be selected depending upon the water stage observed in Welch Creek or the Roanoke
River. Baseline monitoring data from Welch Creek indicates that annually targeting a
base flow event and an event that causes a change in the receding stage of 1.5 to 2 feet
should be possible. In the event that a 1.5 to 2 foot stage event cannot be sampled, a
0.5 to 1 foot event will be targeted with the intent to sample a >2 foot event if the
opportunity is available later in the year (maximum of three annual samples). Sampling
events may be triggered remotely, by event based stage information or on-site
personnel. Once a receding stage of sufficient height has been identified, water
sampling will commence. An ISCO type sampler will be configured to collect water
samples every two hours over the event (recognizing for the response delay to begin
sampling). The collected water sample that correlates with the highest turbidity
observed during the event will be submitted for analysis. Water quality data will be
compared to the Welch Creek baseline monitoring data, the base flow stage event, as
well any other past sampling events that may be appropriate.
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4.2 Performance Standard Monitoring
As always in Superfund where some residuals remain on site, the performance monitoring
program forms the basis for on-going remedy evaluation and detailed remedy review at 5-year
intervals. In addition, the performance monitoring data provides additional input for refining
the SCM on sediment sites that are applying adaptive management tools. Table 4-1 identifies
multiple lines of evidence that illustrates how the performance monitoring data can be used to
assess potential corrective response actions and then integrated into a refined SCM to update
the next 5-year performance monitoring program. The PSVP and Performance Evaluation Plan
will establish flexible comparison criteria for each line of evidence to make certain that the
multiple lines of evidence are considered as a whole when evaluating the overall performance
of the remedy. Utilizing multiple lines of evidence is especially important during the initial
5-year review period, while the system recovers and reaches a new steady state condition.
4.3 Institutional Controls
Institutional controls are included as a component of the rerriedy for Welch Creek. The
objectives of institutional controls are to protect the integrity of the cover and to prevent or
reduce potential human consumption of contaminated fish. Institutional controls are non
engineered instruments that help to minimize and/or manage the potential for human exposure
to contaminated media and/or protect remedy integrity. Table 4-2 summarizes the institutional
controls included as components of the remedy.
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-- -- --- - -- - ---
Table 4-1
Summary of Remedy Performance Monitoring
COMPONENT OF REMEDY SUCCESS ANO PERFORMANCE
APPLICABLE REMEDIAL ACTION OBJECTIVE METRIC
UPSTREAM REACH
Integrity of Remedy Sediment -dioxin, total organic
• Limit biological uptake of COCs from the carbon (TOG), bulk density, and
sediment in areas with excess potential risk, to video assessment
the extent practicable.
• Achieve surface water concentrations at or
below surface water standards.
• Minimize adverse effects of remediation Surface Water" -dioxin, TSS, activities on the existing aquatic environment
and/or wetland habitat, to the extent practical. total volatile solids (TVS),
semi-permeable membrane • Maintain acceptable levels of potential risk to device (SPMD), TOG, and
site-specific human receptors. dissolved organic carbon (DOC)
and indicator elements (Mn, Mg,
Fe, Ca, Ba, Al and Ti).
Benthic Recovery Benthic Community Surveys
• Protect the health of local populations and
communities of biota.
• Minimize adverse effects of remediation
activities on the existing aquatic environment
and/or wetland habitat, to the extent practical.
Stable to Downward Trends in Fish Tissue Surface Water-DO,
Concentrations temperature, and specific
• Continue progress toward removal of remaining conductivity
fish consumption advisory in Welch Creek. Fish Tissue Analysis (dioxin and
mercury)
Benthic Tissue Analysis (dioxin)
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MONITORING PLAN
APPROACH
Physical inspection (video assessment and core
observations) of cover during implementation and
after to ensure proper cover thickness. A subset of
samples will be selected and analyzed for dioxins
from the top 5 cm of sediment. Assessment will
include an evaluation of areas with limited coverage
(e.g., steep, side slopes).
Evaluate dioxin trends in surface water of Welch
Creek after remedy implementation and system
equilibration.
Benthic community sampling will include community
surveys to document recovery after cover placement.
Benthic communities to be observed include thalweg,
side slopes, and debris and leaf packs in near shore
areas.
Water quality measurements will be used to identify
favorable surface water conditions for capturing and
sampling fish in Welch Creek.
Fish tissue sampling and analysis conducted.6· 8
Benthic tissue sampling for dioxin will be conducted
using Hester Dendy sampler and or other equipment
or collection methods.
-- - -
PRELIMINARY SAMPLING
FREQUENCY/TIME PERIOD '
Construction Monitoring -
During Implementation
Short-Term7 -
Annual Cover Inspection
Short-Term7 -
Annual Sampling Events
Construction and
Short-Term Monitoring -
(likely in Year 2)
Year 2, 3, and 5
Construction and
Short-Term -
Baseline Monitoring
Short-and Long-Term -
Annual Sampling Events
Short-Term -
Year 2,3, and 5
Revised November 2010
---- - - - - ----- - -
Table 4-1
Summary of Remedy Performance Monitoring
COMPONENT OF REMEDY SUCCESS AND PERFORMANCE
APPLICABLE REMEDIAL ACTION OBJECTIVE METRIC
MIDSTREAM REACH
No or Minimal Expansion of Dioxin Surface Water -mobility
Contaminated Sediments monitoring, dioxin, TSS, TVS, and
Minimize significant migration of COG containing indicator elements (Mn, Mg, Fe,
sediment in delineated areas of conc~rn, to the Ca, Ba, Al and Ti)
extent practical.
Sediment -AVS/SEM, grain size,
and TOG
Assess Impacts of Construction on Wetland Soil Wetland Soil -total mercury and
Mercury and Dioxin Concentrations dioxin 1-TEQ
Minimize significant migration of COC containing
sediment in delineated areas of concern, to the
extent practical.
Mercury Fish Tissue Concentrations Whole Fish -Total Mercury and
Minimize significant migration of COC containing dioxin 6· 8
sediment in delineated areas of concern, to the
extent practical.
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MONITORING PLAN
APPROACH
Surface water sampling will be utilized to determine if
dioxin impacted sediment mobilize and remain in the
water column during receding stage events
(e.g., wind tides) hat result in increased river
velocities.
These results will be utilized to evaluate the
bioavailability of metals, specifically mercury in
midstream reach sediments.
These results will be utilized to assess the impacts
from construction activities on wetland soil mercury
concentrations.
The applicable RAO is to minimize the adverse
effects of remediation activities on the existing
aquatic and/or wetland habitat to the extent
practicable. This objective will be met for the aquatic
environment through the water quality monitoring
since cover material placement has the potential to
adversely impact this media. In contrast, wetland
soils will only be impacted if there is dioxin in the
water column and a concurrent flooding event. Thus,
we propose to trigger post-construction wetland soil
monitoring for dioxin based upon a predetermined
formula which will be set out in the construction
monitoring document.
These results will be utilized to compare mercury
results with other regional sites to confirm
concentrations are similar within the region.
-- - -
PRELIMINARY SAMPLING
FREQUENCY/TIME PERIOD
Short-Term -
One baseline and one to
two targeted flow events
annually (Years 1 to 5)
Short-Term-
Annual Monitoring
Short-Term-
Annual Monitoring
Short-Term -
Annual Monitoring
Revised November 2010
- -.. - ---- ----
Table 4-1
Summary of Remedy Performance Monitoring
1 Selected monitoring approach will be fully characterized (i.e., quantity, number, and frequency) in the PSVP.
2 Discussion of sampling options and final selection will be included in the PSVP.
3 Construction Monitoring -Indicates an approximately 2 year period including and following cover implementation.
4 Short-Term-Indicates an approximately 5-year period following cover implementation.
5 Long-Term -Includes a 6-to 10-year period following cover implementation.
- - - -- -
6 Fish tissue sampling will be conducted based on a prioritized program. Prior to sampling, calibrated automatic water quality measurements will be collected at one to two locations within the
creek, from March through April and, if necessary from September through October.
7 At the five year review time period it will be determined if further monitoring is necessary.
8 Fish Tissue Sampling Prioritized Sampling:
Priority 1: Tissue composite: one reference sample location between MT-1 and MT-2, as close to MT-1 as practicable based upon comparable habitat to downstream reaches, one sample
location within the remediation area prioritizing capture at (MT-3 to MT-6), then one sample downstream near MT-8 and one sampling within the midstream reach (MT-7 to GT-15).
One of each of the following three to five point sample composites will be collected per location:
Bottom feeder fillets for dioxin and mercury (pending the availability of catfish fillet comparison data).
Small game/large forage whole fish for dioxin and mercury.
Priority 2: Time permitting, sample efforts will be expanded to collect up to two additional composite samples (catfish fillets and whole body forage fish) one of each tissue type at the following
locations: upstream reach (MT-3 to MT-6) and midstream reach (MT-7 to GT-15). Analytical parameters will be dioxin and mercury as described for Priority 1 sampling.
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20
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--- - ---- - ---------
Table 4-2
Summary of Institutional Controls for Welch Creek Area
DESCRIPTION OF INSTITUTIONAL CONTROL
Limit the consumption of fish from Welch Creek by existing fish
consumption advisories. Fish consumption advisories will continue
until the State of North Carolina guidelines have been met.
Maintain the existing fencing which limits access to the Welch Creek
area.
Maintain signs in Welch Creek noting fish advisories and the
presence of the sand cover.
Place deed notice to inform future land owners of the Domtar
property regarding the remediation easement and land/water use
restrictions.
A Declaration of Perpetual Land Use Restrictions Document
(DPLURD)
A plat map identifying the area covered by the institutional control.
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LEAD AGENCY/ENFORCEMENT DOMTAR RESPONSIBILITY RESPONSIBILITY
North Carolina Department of Health Conduct annual fish tissue sampling and chemical analysis
and Human Services is responsible for to evaluate dioxin trends in Welch Creek
implementing/lifting fish advisories
USEPA/NC DENR will evaluate fence Domtar will maintain fencing around Welch Creek. Fence
integrity during five year review will be inspected periodically and necessary repairs made.
USEPA/NC DENR will approve the Domtar will develop and install the signs along Welch Creek
sign verbiage prior to implementation and repair/replace as necessary.
NC DENR /US EPA will confirm deed Domtar will file the deed notice with the North Carolina
notice has been filed during five year Register of Deeds consistent with the Consent Decree.
review
NC DENR Domtar will prepare a DPLURD document for submittal to
NC DENR.
NC DENR Domtar will prepare a plat map in conjunction with the
DPLURD document for submittal to NC DENR.
21
Revised November 2010
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5.1
Section 5
Description of Work Products and Deliverables
Remedial Action Planning Documents
5.1.1 Remedial Action Work Plan
This document provides a detailed plan of action for completing the RA activities. The
objective of this work plan is to provide for the safe and efficient completion of the RA.
The RA Work Plan includes a comprehensive description of the work to be performed
and the Final Construction schedule for completion of each major activity and
submission of each deliverable. The RA Work Plan also includes a project management
plan, including provision for status reports to the USEPA during and after construction
along with a description of the community relations support activities to be conducted
during the RA.
5.1.2 Remedial Action Work Plan Attachments
The following attachments are part of this Welch Creek OU-4 RA Work Plan package as
required by the CD.
■ Cover Operations Plan -This document provides a description of the areas
requiring eMNRTM cover, placement methods, sequencing and logistics for cover
placement. The Cover Operations Plan is included as Appendix A of this RA Work
Plan.
■ Project Delivery Strategy-This document provides a description of the strategy
for delivering the project and addresses the management approach, procurement
methods, contracting strategy, and phasing alternatives. In addition, this report
addresses issues associated with contractor and equipment availability. The project
delivery strategy is included as Appendix B of this RA Work Plan.
■ Construction Management Plan (CMP) -This plan describes the implementation
process for construction activities. Project management personnel and lines of
authority are defined in this plan. The CMP is included as Appendix C of this RA
Work Plan.
■ Construction Quality Assurance Plan (CQAP) -This purpose of this plan is to
ensure that the completed RA will meet or exceed design criteria, plans,
specifications and performance standards. The CQAP is included as Appendix D of
this RA Work Plan.
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5.2
■ Construction Health and Safety Plan/Contingency Plan (CHSP/CP) -This plan
consists of a health and safety risk analysis for the construction workers and
monitoring staff, a synopsis of the construction monitoring plan that would trigger
an action, a description of the identified equipment, and site control. Health and
safety personnel along with local emergency information are included in this plan.
The CHSP/CP is included as Appendix E of this RA Work Plan.
Construction Documentation Reports
5.2.1 Pre-final Construction Inspection Report
A Pre-final Construction Inspection Report will be submitted by Domtar to USEPA and
will outline the outstanding construction items, actions required to resolve the items,
completion date for the items, and an anticipated date for the Final Inspection. This
report will be prepared 'after the Pre-final inspection is performed by USEPA, Project
Coordinators, Supervising Contractor, Construction Contractor, Natural Resource
Trustees and other federal, state, and local agencies with a jurisdictional interest.
5.2.2 Interim and Final Remedial Action Reports
The Interim Remedial Action Report will be submitted to the USEPA following the
conclusion of the Final Construction Inspection. The Interim Remedial Action Report
will be generally consistent with USEPA guidance for preparing the report (Close Out
Procedures for National Priorities List Sites, USEPA, OSWER Directive 9320.2-09A-P) and
include the following sections:
Introduction, providing a brief history and description of the site;
Operable Unit Background;
Construction Activities;
Chronology of Events, including a projection of when clean-up levels for the
wetlands and groundwater will be achieved;
Performance Standards and Construction Quality Control;
Final Inspection and Certifications; and
Operation and Maintenance (O&M) Activities.
After USE!' A review of the Interim Remedial Action Report, Domtar will address any
comments and submit a revised report. The Interim Remedial Action report may be
amended to create the final Remedial Action report. The amendment would add
information on activities that occurred after the Interim Remedial Action Report was
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completed. The RA will be complete when the USEPA approves the Final Remedial
Action Report.
5.2.3 Performance Standard Verification/Operations and Maintenance Plan
This document will be:submitted 45 days after USEPA approval of the RA Work Plan.
The PSVP/Operations and Maintenance Plan (OMP) will address compliance with
performance standards and remedial action objectives noted in the ROD. The
PSVP/OMP will also address the performance of the sand cover including the degree of
intermixing with underlying contaminated material, settlement, and stability based on
normal water flows and higher flows/water levels associated with significant rainfall
events. The PSVP/OMP will also address mobility monitoring in the midstream reach.
The OMP will describe normal operation and maintenance, a description of tasks
required for cover system maintenance, a schedule showing the required frequency for
each O&M task and description of potential operating problems.
The performance standards verification component of the PSVP/OMP will include the
following information:
Direction for all fieldwork by defining in detail the sampling and data gathering
methods to be used;
Description of the quality assurance and quality control (QA/QC) protocols which
will be followed in demonstrating compliance with Performance Standards; and
QA/QC protocols that shall be used to achieve the desired DQOs.
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Section 6
Project Schedule
Dates for the completion of the RA are dictated by the CD. Production rates for marine
operations (e.g., monitoring equipment installation, site staging preparation, and eMNRTM cover.
placement) were provided by information obtained during the pilot studies and review of other
sediment capping projects. The targeted construction completion date may be extended due to
inclement weather or equipment related delays.
The NC DENR has a moratoriu,m on performing work within anadromous fish spawning areas
which typically runs from February 15th to October 31 st of any year. For this project, NC DENR
has agreed to allow in-water remediation work to be conducted between October 1st and
March 2"'· Upland constructio1;, equipment and material staging, and preparation for
monitoring are activities that are not impacted by the moratorium.
The schedule for completion of each required activity and submission required by the SOW is
presented in Figure 6-1. Based on the moratorium, and the desire to complete the remedial
construction in one continuous season, the start of construction is shown to begin on October 1,
2011.
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Figure 6-1
Remedial Action Construction Schedule
To be determined
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26
Revised November 2010
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7.1 Reporting Schedule'
Section 7
Project Management Plan
During RA construction, Domtar will submit monthly progress reports to USEPA by the
10th day of the following month in accordance with the requirements of the CD. This report will
describe the tasks initiated or completed during the reporting period.
Following the completion of the pre-final inspection, Domtar will submit a pre-final inspection
report. The report will be prepared by the RA project engineer and the resident construction
quality assurance (CQA) representative under the purview of the senior project oversight team.
Domtar will submit to the USEPA an interim remedial action report no later than 60 days after
the final construction inspection. The Interim Remedial Action Report will be prepared by the
RA project engineer under the purview of the senior project oversight team.
7.2 Data Management
Procedures for data management have been established to document and track project
analytical data, documents, and computer files as they are generated, reviewed, and finalized.
The analytical data generated by the laboratory in association with RA activities will be
managed in site-specific databases whose format is compatible with Microsoft"' Access software.
The data management coordinator will perform a QC check on the data and have sole
responsibility for maintenance and updates to the database. The database will be placed into
project-specific subdirectories on RMT North Carolina, Inc.'s (RMT's) computer network where
authorized personnel may access the data. It is not anticipated that chemical data will be
generated during the actual RA construction activities; however, chemical and physical
sediment and groundwater data will be collected as part of the performance monitoring plan.
Performance monitoring activitie_s will be initiated after completion of the landfill cover
construction.
7.3 Document Control
Data and documents originating in the field (e.g., chain-of-custody documents, overnight carrier
shipping records, field notes, and field-generated data) will be placed in a project file. The data
management coordinator will receive chemical data reports sent from an analytical laboratory.
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The data management coordinator will be responsible for storing the reports in a secure
location.
7.4 Document Retention
Until 10 years after receipt of USEPA's Certificate of Completion of the Work, Domtar will
preserve and retain records and documents that relate to liability under Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) with respect to the Welch
Creek Area OU-4 and the performance of activities required by the CD. Domtar will also
instruct its contractors and agents to preserve for the same period of time specified above
documents or records that relate in any manner to the performance of the activities required by
the CD. At the conclusion of the document retention period, Domtar will notify the USEPA
90 days prior to the destruction of any such records or documents. (Consent Decree,
Section XXV).
7.5 Description of Data Submittals/Reporting
Documents, including deliverables and progress reports, approvals and other correspondence
to be submitted in accordance with this RA Work Plan, will be sent by either certified mail or
overnight carrier, to the following addresses. All notices and submissions shall be considered
effective upon receipt, unless otherwise provided in the CD (Consent Decree, Section XXVI):
■ Documents to be submitted to the USEPA will be sent to:
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency, Region 4
North Site Management Branch, North Carolina Section
61 Forsyth Street, SW 11th Floor
Atlanta, Georgia 30303
■ Documents to be submitted to the State of North Carolina will be sent to:
Mr. Nile Testerman
State Project Coordinator
401 Oberlin Road, Suite 150
Raleigh, North Carolina 27605
■ Documents to be submitted to Domtar should be sent to:
Mr. Marcel Sylvestre
Project Coordinator
395 De Maisonneuve Blvd West
Montreal, QC H3A 1L6
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Remedial Action Work Plan 28
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■ Documents to be submitted to RMT should be sent to:
Mr. Michael B. Parker
Project Manager
RMT North Carolina, Inc.
30 Patewood Drive, Suite 300
Greenville, South Carolina 29615
These addresses may be changed by either Domtar or USEPA by written request of either party,
Major deliverables are listed in the Consent Decree, SOW, and Section 5 of this RA Work Plan.
Domtar will submit three copies of plans, reports, and other data required in this RA Work Plan
to USEPA, Domtar will submit one copy of such plans to the State (Consent Decree Section,
Section X.33). All project meetings will be jointly agreed upon and coordinated by USEPA,
Domtar and RMT. USEPA and Domtar representatives will coordinate supplemental project
team meetings as required.
RA1T North Carolina, Inc. I Domtar Paper c;ompm1y, LLC
Remedial Action Work Plan 29
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Section 8
Community Relations
A Community Relations Plan (CRP) was prepared for the site prior to initiation of the Rl/FS
activities. 1 The USEPA is responsible for developing and implementing community relations
activities. At the RD phase USEPA reviews the CRP and updates as needed, for the Welch
Creek Area. Domtar will provide assistance as requested by USEPA regarding the CRP plan
update and participation in public meetings.
1 Community Relations Plan, Weyerhaeuser Company, Plymouth, Martin County, North Carolina, USEPA Region 4,
October 1998
RMT North Carolina, Inc. I Domtar Paper.Company, LLC
Remedial Action Work Plan 30
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RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
/:\ WPGVL \PJTJ \00625\08\00J \R0062508001-00J .DOCX
Appendix A
Cover Operations Plan
Revised November 2010
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..... ·•
RMT
A
; ENVIRONMENT• ENERGY• ENGINEERING
Remedial Action Work Plan
Appendix A: Cover Operations Plan
Domtar Paper Company, LLC
Welch Creek Area OU-4 Plymouth, Martin County, North Carolina
Revised November 2010
RfvIT North Caroli11a, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix A: Cover Operations Plan
I:\ WPGVI. \ PJTl \ 00625\ 08\ 001 \ R0062508001.001A.DOCX
02010 RMT, lur.
All Rights Re$em-d
30 Patewood Drive, Suite 100 • Greenville, SC 29615•3535 • [phone] • [phone] FAX• www.rmtinc.com
CREATING BALANCE"'
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Table of Contents
Cover Operations Plan .............................................................................................................................. 1
1. Areas for Cover Placement ............................................................................................................. 1
2. Summary of Site Conditions .......................................................................................................... 1
3. Equipment and Placement Methods ............................................................................................. 2
4. Sequence of Placement .................................................................................................................... 3
5. Cover Material ................................................................................................................................. 3
6. Source of Cover Material ................................................................................................................ 4
7. Transport of Cover Material .......................................................................................................... 4
8. Access and Staging Area ................................................................................................................ 4
9. Scheduling and Time Constraints ................................................................................................. 5
10. Construction Monitoring ................................................................................................................ 6 I 10.1 Water Quality Sampling ....................................................................................................... 6
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10.2 Cover Placement TI1ickness ................................................................................................. 7
10.3 Documentation of Overall Cover Integrity and Construction ........................................ 7
List of Figures
Figure A-1
Figure A-2
Figure A-3
Figure A-4
Figure A-5
Upstream Reach -eMNR Cover Area .................................................................. 9
Cover Placement Sequence ................................................................................... 1 O
Slope Configuration ............................................................................................... 11
Staging Support Areas ........................................................................................... 14
Overview: Main Staging Area Detail .................................................................. 15
RMT North Caroli11a, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appc11dix A: Cover Operations Plan
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Cover Operations Plan
1. Areas for Cover Placement
Based on a compilation of all investigation data to date, the area requiring containment was
refined to extend bank to bank from MT-3 immediately downstream of the railroad bridge
(forming the upstream boundary) to MT-6 (forming the downstream boundary). The
containment area will not extend into Little Mill Creek located near MT-5. Figure A-1 identifies
the area to be covered. The containment area extends approximately 5,300 feet in length with
an average width along this length of approximately 125 feet bank to bank. The boundaries of
the cover placement area will be designated by flagging along the shoreline for use during
construction and future monitoring activities.
2. Summary of Site Conditions
A complete description of the site conditions can be found in the Remedial Design Report. A
summary of the site conditions which will impact construction activities include the following:
■ The wastewater solids accumulated in Welch Creek have limited strength and are very
compressible due to their low density, high water content, and high organic content. The
sediment deposits range in thickness from 1 to 6 feet deep, with 2 to 3 feet thick in the
majority of the area to be covered.
■ Extensive natural debris -the Welch Creek area targeted for covering has documented high
amounts of natural debris. This debris consists of fallen trees, branches, and submerged
root structures. The debris supports a diverse benthic community and will remain in place
wherever possible.
■ Flow reversals -both lunar and wind tides impact flow direction in Welch Creek. Wind
driven tides have a greater impact on flow patterns due to their greater magnitude
■ Variable submerged side slopes -the submerged banks along the targeted area for covering
have variable slopes from 0° to greater than 30°.
■ Shallow to moderate water depths -the water depths average 10.5 feet and vary from 3 to
15 feet throughout the creek.
■ Multiple low bridge crossings and tree canopy-access from the mouth of Welch Creek to
the area that requires cover is impeded by five bridge crossings. In addition, the wooded
wetlands have significant tree canopy that extends to over large areas of the surface water
in Welch Creek.
■ Surrounding wetlands -much of the Welch Creek length targeted for covering is
surrounded by wetlands.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix A: Cover Operations Plan
/:\ WPGVL \P/TI \00625\08\001 \R0062508001-001A,D0CX
1
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3. Equipment and Placement Methods
There are three main considerations when establishing the technical aspects of cover placement:
one involves the physical characteristics and strength of the underlying sediment material, the
second is the need for controlled, accurate placement, and the third is the location of the
sediment within the creek. The sediment physical characteristics control the placement
mechanism, the thickness of individual layers, and affect the desired rate of placement. The use
of equipment or placement rates which might result in the cover material displacing or mixing
with the contaminated sediment must be avoided or at least minimized to limit adverse impacts
on water quality and the possibility of localized cover failures. Consideration of the sediment
location includes proximity to the shore along with presence of debris or shallow water depths
that could obstruct or limit access for barge mounted equipment. All three factors will be
considered during review of contractors' construction estimates.
The total cover thickness of the sand is an average of 5 to 10 centimeters with a maximum
thickness of 10 centimeters. The sand cover material will be placed in two lifts as shown on
Figure A-2 and described as follows:
1. An initial lift will target a 2 to 5 centimeter thickness across the bottom of the creek which
are locations with a slope of less than 15°. This accounts for approximately 70 percent of
the area being covered. The cover thickness should be as uniform as possible (within
80 percent of an average t~ickness of 4 centimeters 11.5 inches]). In order to allow primary
consolidation and minimize the potential for differential settlement during the next lift
placement, a consolidation period of 24 to 48 hours prior to placement of the next lift is
being required.
2. The second lift will consist of 3 to 10 centimeters, again starting at the bottom of the creek
and moving toward the creek banks extending completely to the top of the banks.
3. The thickness of the final enhanced monitored natural recovery (eMNR™) cover should
range from 5 to 10 centimeters with a thicker cover along the bottom of the creek. The
eMNR™ cover thickness is not to exceed 10 centimeters in any location due to possibility of
disturbing the soft sediment deposits.
Global positioning system (GPS) monitoring of cover installation along the bottom of the creek
will be required to accurately place the sand along the desired pathway and monitor the desired
placement rates throughout the length of the upstream reach. Shallow water depths and debris
along the banks limit access to some types of equipment in certain areas. Different cover
placement procedures are expected to be necessary to meet the coverage requirements of 5 to
10 centimeters from top of bank to top of bank.
One of the measurable factors that will impact the cover thickness is the slope of the creek
bottom and near shore submerged banks within the eMNR™ cover area. The variability in
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix A: Cover Operations Plan
/;\ \'\'PGVl. \PJTJ \00625\08\001 \R0062S08001-001A.DOCX
2
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slope conditions was most noticeable in the near shore submerged banks. Figure A-3 identifies
the interpreted configuration ?f the creek slopes based on field measurements. The steeper side
slopes, in many cases, consist of root systems from the adjacent trees along the shoreline. These
areas of root cover have retained leaf fall debris present in protective layers over the sediment
base.
4. Sequence of Placement
The overall cover system configuration consists of placement of a minimum of two lifts of sand
from the top of bank on one side, across the entire bottom and near shore submerged side
slopes to the top of bank on the other side. The first lift will be no more than 1 to 2 inches (2 to
5 centimeters) thick to avoid destabilizing the sediment substrate.
Placement will begin at the upstream end of the upstream reach near MT-3 and move
downstream to MT-6. Based on the importance of debris for the overall health of the Welch
Creek system, the only debris planned for removal is that which is necessary to allow placement
of the cover material.
Debris from clearing and grubbing activities can be chipped for use as temporary vegetative
cover to support erosion control efforts in the project area. The root wads and any material not
chipped will be disposed of in the licensed on-site landfill.
5. Cover Material
Various cover materials were assessed during the pilot study work plan development and
reviewed as part of the remedial design. The eMNR™ cover system will consist of specified
particle sizes of sand containing minimal fine fractions, thus limiting turbidity during cover
placement. The material placed across the bottom of the creek bed will consist of washed and
screened natural sands or sands manufactured by crushing stones complying with the
requirements and tests of ASTM C33. A coarser grade of angular sand will be placed on the
steeper slopes. More angular sand will have a higher friction angle than sand with rounded
particles. Gradation requirements for the two sand types are shown on the following table:
SIEVE
SIZE FINE GRAINED -
FIRST LIFT
½" 100
3/8" 100
No. 4 95 to 100
No. 8 80 to 100
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix A: Cover Operations Pinn
/:\ WPGVL \P/TI \00625\ 08\001 \R0062508001-001A.DDCX
3
% PASSING
COARSER GRAINED -
SECOND LIFT AND SIDEWALLS
100
95 to 100
80 to 95
65 to 85
Revised November 2010
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1.
' % PASSING
SIEVE
SIZE FINE GRAINED -COARSER GRAINED -
FIRST LIFT SECOND LIFT AND SIDEWALLS
No. 16 50 to 85 50 to 75
No. 30 25 to 60 25 to 60
No. 50 10 to 30 10 to 30
No. 100 2 to 10 0 to 10
The sand shall have not more than 45 percent passing any sieve and retained on the next
consecutive sieve of those shown above.
6. Source of Cover Material
The sand cover material was carefully selected to meet the following criteria:
■ Local availability;
■ Targeted grain sizes;
■ Limited angularity; and
■ Minimum release of turbidity when exposed to Welch Creek water.
Sand that met these criteria has been identified at local quarries and will be further confirmed
for usage during the Remedial Action (RA) bidding process. Based on the placement methods
described above and an overall average thickness of 10 centimeters, approximately 2,600 cubic
yards of fine grained sand and 4,800 cubic yards of coarser grained sand will be required to
cover the entire area.
7. Transport of Cover Material
The material will be transported from the chosen quarry or quarries by truck to the staging
area(s). Methods to convey the material from the staging area to the placement barges will be
identified by the Contractor and approved by the Engineer.
8. Access and Staging Area
The main support zone area will require an equipment storage area and sand storage pad. The
secondary support zone will require a sand storage pad. A third sand storage pad may also be
constructed due to size limitations of the secondary storage pad. A single-lane haul road is
presently located at all three locations. The roads around the sludge pond have previously been
constructed to allow access to construction equipment. However, it is assumed that additional
reinforcement and a tum-around area will be constructed near the existing boat ramp. Further
RMT North Carolina, Inc. I Domtar Paper r:ompa11y, LLC
Remedial Action Work Plan
Appendix A: Cover Operations Plan
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details will be defined with Domtar Mill Engineering and Safety Staff prior to any construction
activities. Planned locations for the proposed staging and support areas are shown on
Figure A-4. The main staging/storage area detail is shown on Figure A-5.
The main support zone will include sufficient space to accommodate a truck turnaround area.
The secondary support zone adjacent to the sludge lagoons will also have a truck turnaround to
minimize the traffic around the lagoons. If necessary, a third sand staging area may be located
near the pipeline bridge.
The work platforms will be used to stage support equipment and to deliver the cover material.
The equipment and trailer storage area at the main support zone will require a gravel pad after
clearing and grubbing operations. The pad will be approximately 30 feet by 60 feet and the
sand storage pad will be approximately 50 feet by 100 feet (both within the main support area of
100 feet by 300 feet). The sand storage area near the existing boat ramp will be approximately
20 feet by 150 feet. The width in this area is limited by the existing haul road and sludge
lagoons.
All storage areas will be required to have silt fencing to minimize runoff of the sand material.
9. Scheduling and Time Constraints
Dates for the completion of the remedial action are dictated by the Consent Decree (CD).
Timely completion of agency reviews and approvals is required to meet the schedule for
full-scale remediation. Producti'on rates for marine operations (e.g., monitoring equipment
installation, site staging preparation, and eMNR™ cover placement) were provided by
information obtained during the pilot studies and review of other sediment capping projects.
The targeted construction completion date may be extended due to inclement weather or
equipment related delays.
The North Carolina Department of Environment and Natural Resources (NC DENR) has a
moratorium on performing work within anadromous fish spawning areas which typically runs
from February 1511' to October 31st of any year. For this project, NC DENR has agreed to allow
in-water remediation work to be, conducted between October 1st and March 2nd. Upland
construction, equipment and material staging, and preparation for monitoring are activities that
are not impacted by the moratorium.
RMT North Carolina, Inc. I Domtar Paper Compa11y, LLC
Remedial Action Work Pla11
Appendix A: Cover Operations Plan
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5
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10. Construction Monitoring
10.1 Water Quality Sampling
Turbidity data will be collected from upstream and downstream of the placement zone
being addressed at that time. At both upstream and downstream locations, turbidity
measurements will be collected at mid-depth and near-sediment intervals within the
water column. All downstream turbidity data will be compared to a target of
25 nephelometric turbidity units (ntus) or 2 times the upstream turbidity reading,
whichever is larger.
At a minimum, turbidity readings will be measured at these times:
prior to placement.of any equipment or materials in the work area;
following placement of equipment within the creek but prior to cover activities;
"continuously"(actually programmed at 3 to 5 minute intervals) during in water
construction with the data summarized in hourly averages; and
as needed based on in-field observations.
Visual inspections of the silt curtains will be conducted periodically during the cover
' placement activities. The inspections will assess the integrity of the silt curtains, looking
for proper anchoring, positioning, and alignment, and for physical damage such as rips
or tears. Results will be recorded in a field notebook and the curtain repaired as needed.
A contingency plan has been developed to address turbidity exceedances. The plan will
be implemented if the confirmed turbidity reading at the downstream monitoring
location is greater than 25 ntus or 2 times the upstream turbidity reading, whichever is
larger. Turbidity data will be considered confirmed if a turbidity plume emanating from
the excavation zone is visible.or if three consecutive turbidity samples averaged over
15-minute increments confirm the elevated turbidity above the target levels. The Surface
Water Protection Supervisor of the NC DENR Washington Regional Office will be
notified if turbidity monitoring data exceeds 50 ntus.
The Contingency Plan (CP) calls for the following mitigation actions to identify and
eliminate the cause of elevated turbidity observations:
Inspection of the area downstream of the excavation site and the turbidity curtains
and repair as needed.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix A: Cover Operations Pla11
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6
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Implementation of troubleshooting measures based on field conditions to reduce
turbidity (i.e., re-securing or re-positioning the silt curtain, modifying the placement
approach, etc.).
Finally, placement rates will be reduced or procedures modified (e.g., additional
sand screening) until the turbidity has returned to acceptable levels.
If unexpected turbidity exceedance continues to occur, or an equipment failure occurs,
additional turbidity and dioxin samples may be collected based on the severity of the
exceedance and on in-field professional judgment. Furthermore, additional inspections
may be conducted during unexpected or uncontrolled events.
10.2 Cover Placement Thickness
The lift thickness is controlled by the speed and volume of material discharged from the
feed conveyor and/or the rate of speed the placement barge travels. The optimal
discharge rate and placement speed will be adjusted as necessary.
After placement of the initial lift, a visual assessment utilizing an underwater camera
will be performed along with collecting cores at specified locations to verify placement
volume/speed are optimal. Further details on the sampling are located in the
Construction Quality Control Plan (CQAP). Based on the thickness and consistency
observations, placement rate will then be modified if necessary. Any areas with
deficiencies will be noted and recovered during the second lift placement.
10.3 Documentation of Overall Cover Integrity and Construction
After placement is completed, the integrity of the eMNR™ cover placement will be
documented using several measurements:
Volume measurements of cover material placed;
Bathymetry of the covered area;
Cover thickness; and
Visual assessment of cover integrity (consistency of coverage).
The bathymetry and thickness of the eMNR™ cover will be determined through the use
of an echosounder and physical core samples. 11,e echosounder will document
bathymetry and cover integrity by identifying changes in cover material throughout
creek bed. Thi_ckness will be verified through the use of lexan cores. Based on previous
sampling at the site, a vacuum core barrel system will be used to sample the cover
material. The lexan core will fully penetrate the cover into the underlying sediment.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix A: Cover Operations Plan
/:\ WPGVL \P/Tl \00625\08\001 \R0062508001-001A.DOCX
7
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Component integrity (consistency of coverage) will be documented through the use of
underwater camera equipment in association with the echosounder. Areas with limited
cover thickness or inconsistent coverage that could have an adverse impact on the
remedy success will be supplemented with additional cover material prior to removal of
construction equipment from the site.
RMT North Carolina, Inc. I Domtar Paper Comprmy, LLC
Remedial Action Work Plan
Appendix A: Cover Operations Plan
/:\ WPGVL \PJTI \00625\08\001 \R006250800M)()1A.D0CX
8
Revised November 2010
-----------
O:\05174\05151740501.Fig3_ 1.mxd 1/22/2010 12:13:30
-----
LEGEND
CJ Revised Delineation of Extent for eMNR Cover
/'V' PROPERTY BORY.
TRANSECTS
/V GENERAL TRANSECT
/V MASTER TRANSECT
500
FEET e
DOMTAR PAPER COMPANY, LLC
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK • OU-4
-
REMEDIAL ACTION WORKPLAN
UPSTREAM REACH • eMNR COVER AREA
-
PROJ. NO.: 00625.08.001
NW AS NOTED
JULV2010
RMT
FILE NO.: 00625.05.001. 1
FIGURE A-1
30 Patawood Drive, Suite 100
Gt11&nville, SC 29615
864.281.()030 phone
864.281.0288 lax
I I
I lve
2 -4cm SAND LAYER
CREEK BOTTOM
CREEK BOTTOM
0
FEATHER EDGE
OF LAYER (TYP.)
0
OF LA YER (TYP.)
THAL
INITIAL PLACEMENT -THALWEG
NOT TO SCALE
2nd LIFT
4 -8cm SAND LA YER
SECOND LIFT -CREEK BOTTOM
NOT TO SCALE
SIDESLOPE LA YER
WOODY DEBRIS
(LEFT IN PLACE)
NOTE:
ALLOW SAND LA YER AND UNDERLYING
SEDIMENT TO CONSOLIDATE 48 HOURS
PRIOR TO NEXT LIFT
WOODY DEBRIS
(LEFT IN PLACE)
NOTE:
SAND LA YER SHALL BE PLACED IN TWO
LIFTS IF NEEDED TO MINIMIZE DIFFERENTIAL
SETTLEMENT AND SLUDGE DISPLACEMENT
WOODY DEBRIS
(LEFT IN PLACE)
/
FEATHER EDGE
SIDESLOPE LA YER 5 -10cm COURSE SAND 5 -10cm COURSE
CREEK BOTTOM
0
SAND
8 -10cm TOT AL THICKNESS
THIRD LIFT -SIDESLOPES
NOT TO SCALE
NOTE:
DEBRIS LEFT IN PLACE
WILL ASSIST IN STABILIZING
SIDESLOPE LA YER
PROJECT:
SHEET TITLE:
DRAWN IY:
CHECKEO IY:
DOMTAR PAPER COMPANY, LLC
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK • OU-4
COVER PLACEMENT SEQUENCE
DMC SCALE: PROJ. NO. 00825.08.001
RKN AS NOTED FILE NO. cover,11n.dgn
APPROVED IY: RKN DATE PRINTED:
DATE: July 2010
RMT
FIGURE A-2
,o l'•l•wood Orf••• S~II• fOO
l'•t.wootl l'l•z• 011•
GrH11rlll•. SC 21115-JSJS
l'hoH: 114.211.00JO
Fu: 11,.211.0211
J\cOd\clvll\weyerhoueser\wetlonds\51010◄\coverplon.don
- ---8 --- ----.D:\05174\04\51740404.mxd --Side Slopes c:J <15 Degrees c:::J > 15 Degrees -1 11 ZONE OF POTENTIAL SE.DIMENT MOBILITY /V PROPERTY B.DRY. Transects ;v GENERALTRANSECT ;v MASTER TRANSECT -50 100 6 FEET V Notes: -■-II 1. Location of side slopes with angles <15 or > 15 degrees are approximate based upon field data collected in 2009. DOMTAR PAPER COMPANY, LLC MARTIN COUNTY, NORTH CAROLINA WELCH CREEK • OU-4 REMEDIAL ACTION WORKPLAN SLOPE ASSESSMENT -· BY: r ·-·--.. __ .. ..:BEAN15CAlE: PROJ.NO.: 00625.08.001 t,(111 AS NOTED JH JULY 2010 RMT FILE ,.01.001 ,Flo3J FIGURE A-3A 30 Patowood Drive, Suite 100 Groenvllte. SC 29615 864.281.0030 phone [phone] fax
- -- -
1!!1111 --- ----
Side Slopes
c:::J <15 Degrees
c::::::J > 15 Degrees
-
111 ZONE OF POTENTIAL
SEDIMENT MOBILITY
/V PROPERTY BORY.
Transects
/V GENERALTRANSECT
/V MASTER TRANSECT
-
0 50 100 0
FEET V
Notes:
-.. -
1. Location of side slopes with angles <15 or > 15
degrees are approximate based upon field data
collected in 2009.
DOMTAR PAPER COMPANY, LLC
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK • OU-4
REMEDIAL ACTION WORKPLAN
SLOPE ASSESSMENT
WEBERN SCALE:
lffl AS NOTED
JH
JULY 2010
RMT
PRo.J. NO.: 00625.08.001
FILE NO.: 00625.05.001. 3B
FIGUREA-3B
30 Patawood Drive, Suite 100
Greenville, SC 29615
864.281.0030 phone
864.281.0288 fa•
-- -------.. ... -D:10517 41041517 40404 .mxd .. -Side Slopes c:::::i <15 Degrees c:::=i > 15 Degrees -.. 111 ZONE OF POTENTIAL SEDIMENT MOBILITY /'v' PROPERTY BORY. Transects ~ GENERALTRANSECT ~ MASTER TRANSECT 50 100 0 FEET w Notes: -111!!!!]11 1. Location of side slopes with angles < 15 or > 15 degrees are approximate based upon field data collected in 2009. DOMTAR PAPER COMPANY, LLC MARTIN COUNTY, NORTH CAROLINA WELCH CREEK -OU-4 REMEDIAL ACTION WORKPLAN SLOPE ASSESSMENT -WEBERN !SCALE: IPROJ. NO.: 15.08.001 NW AS NOTED JH JULY 2010 RMT IFILENO.: 00625.05.001.Flg3C FIGUREA-3C 30 Patewood Drive, Suite 100 Greenville, SC 29615 864.281.0030 phone [phone] fax
---.. --.. .. ------
c::J Planned Staging Area
r:z::3 Potential Staging Area
c::J Revised Delineation of Extent for eMNR Cover
/'v PROPERTY BDRY.
TRANSECTS
~ GENERAL TRANSECT
~ MASTER TRANSECT
0 250 soo
FEET 8
DOMTAR PAPER COMPANY, LLC
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK • OU-4
REMEDIAL ACTION WORKPLAN
STAGING SUPPORT AREAS
-
EJP SCALE:
':'"'":::"'.":'.:-:-::'.".'Y,----:7.:1 AS NOTED
PRQ.J. NO.: 00625.08.001
JULY2010
RMT
FILE NO.: 00625.05.001.
FIGUREA-4
30 Petewood Drive, Sulla 100
Greenville, SC 29616
864.281.0030 phone
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PROJECT: DOMTAR PAPER COMPANY, LLC
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK • OU-4
OVERVIEW:
MAIN STAGING AREA PLAN VIEW
DMC SCALE:
JH AS NOTED
APPROVED IY: JH DATE P'RINTED: .D .... A_TE_: ---J".""u".""ly"".:'20:::"'.1~0
RMT
PROJ. NO. 00625.08.001
FILE NO. 11nd1lockplle.•1•
FIGURE A-5
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RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
I:\ WPGVL \P/TJ 100625108\00J \R006250SOOJ-00l.D0CX
Appendix B
Project Delivery StratJ,gy
Revised November 2010
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...... ·•
AMT
A
• EIVIRONMENT. ENERGY. ENGINEERING
Remedial Action Work Plan I Appendix B: Project Delivery Strategy
I Domtar Paper Company, LLC
Welch Creek Operable Unit 04 Plymouth, Martin County, North Carolina
Revised November 2010
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix B: Project Delivery Strategy
©2010RMT,lnc.
All Rights Rrservrd
I:\ WPGVL \ PJT1 \00625\08\ 001 \ R0062508001-001 B.DOCX
30 Patewood Drive, Suite 100 j Greenville, SC 29615-3535 • [phone] • [phone] FAX• www.rmtinc.com
CREATING BALANCE"'
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Table of Contents '
1. Introduction ..................... \ ......................................................................................................... \ ...... 1
2.
3.
Management Approach: ~MNRTM Sand Cover ................................................................... ..\ ..... 2
. . I . I
2.1 Overview of Remedy Component ...................................................................................... 2
2.2 Procurement Methdds .............................. : .................................................................... ..\. .... 2
~:! ~I~:;~:;t:l~e~:::i:gl :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: ::::: ::::: ::\:::: !
2.5 Availability ConsidJrations ........................................................................................... ..\. ... 4
2.5.1 Contractor A1
1ailability ........................................................................................ \ ... 4
2.5.2 Equipment Availability ....................................................................................... !... 4
2.5.3 Materials Av!ilability .......................................................................................... .\... 5
Management Approach -Jobility Monitoring ....................................................................... \ .. 6
3.1 Overview of Remedy\Component .................................................. , ............................... + 6
3.2 Procurement Methods .......................................................................................................... 6
!:! ~l~:;;~;t:l~e~::::~:
1
1:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::
1
1: ~
3.5 Availability ConsiderJtions .............................................................................................. ..\ 7
3.5.1 Contractor Avtlilability .......................................................................................... .! 7
3.5.2 Equipment Av1ilability ........................................................................................... \7
3.5.3 Materials Avaiilability .............................................................................................. 7
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix 8: Project Delivery StrategiJ
/:\ WPG\/L \P]Tl \00625\08\001 \R006250S001-001B.DOCX 11122110 Revised November 2010
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Section 1
I ntrod u cti1p n
Welch Creek, Operable Unit #4 \(0U-4), is located at the Domtar Paper Company, LLC (DoJtar)
Plymouth Mill in Martin Count~, North Carolina. The Remedial Investigation/Feasibility SAidy
(Rl/FS) including a Baseline Ec~logical Risk Assessment (BERA), a series of facilitated meetihgs,
and several pilot studies were cbmpleted for the Welch Creek area (OU-4) under a negotiate8
Administrative Order on Conseht (CD) from 1998 to 2007. The remedial action selected in t~e
Record of Decision (ROD) has fi~e components: 1) enhanced monitored natural recovery
(eMNRT"') of sediment contami~ated with dioxin above cleanup goals in the upstream reach of
W~lch Creek; 2) mobility monitdring for the less contaminated sediment in the midstream
reach; 3) long-term monitoring ahd maintenance of the eMNR™ sand cover; 4) long-term
testing and monitoring of sedim~nt, surface water, and biota to document the performance of
the remedy and compliance wit~ cleanup goals; and 5) institutional controls. The negotiated
consent decree defines the work hctivities necessary to implement the selected remedy. The
eMNR™ sand cover and the mid\stream reach mobility monitoring are the two remedy
components that require in water\ remedial construction activities and thus are the main focus of
this project delivery strategy. There are no specific project delivery aspects of the other three
I
components of the selected remedial action (long-term monitoring and maintenance of the
eMNRT" cover, performance stan8ard verification monitoring, and institutional controls).
This project delivery strategy doclment addresses the management approach for implementing I the active construction components of the remedial action (RA), including procurement
methods and contractor and equiJment availability concerns. The project delivery strategy is I
required as part of the RA Work Plan document submittal.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Pfnn \
Appendix B: Project Delivery Strategy
I:\ WPGVI. \ PfT1 \()()625\08\001 \R00(,2508U0l-U0JB.DOCX 11122/10
1
Revised November 2010
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Section 2
Manageme'1t Approach: eMNR™ Sand coier
. I 2.1 Overview of Remedy Component
The general area requiring cont~inment using the eMNR™ sand cover identified in the ROD
was based upon a clean-up crit~ria of 1 ug/kg dioxin (1-TEQ) in the bioactive zone (top \
5 centimeters) of the sediment. Pre-design data was combined with previous investigation data
to refine the area requiring cont~inment. The final design established the eMNR™ sand coJer
area to extend bank to bank fro~ MT-3 immediately downstream of the railroad bridge \
(forming the upstream boundar~) to MT-6 (forming the downstream boundary). The resultant
containment area is approximatkly 5,300 feet in length with an average width along this len~th
of approximately 125 feet bank lo bank.
The overall cover system configLation consists of placement of a minimum of two lifts of sand
from the top of bank on one sidd, across the entire bottom and near shore submerged side \
slopes to the top of bank on the 6ther side. The first lift will be no more than 1 to 2 inches (2 to
5 centimeters) thick to avoid deslabilizing the sediment substrate. The final targeted thickne1s
of the eMNRTM cover to be placeh over exposed sediment is 5 to 10 centimeters. The actual
I thickness of the placed cover material will vary somewhat depending upon the physical
I characteristics of the cover material being placed, roughness and magnitude of debris extruding
from the sediment, the slope of tAe near shore submerged creek banks, and slope of the creek
bottom.
The implementation of the remedy for the Welch Creek area can be managed similar to open
water capping projects. Site conttol and health and saf~ty issues will need to be controlled ana
monitored during construction.
2.2 Procurement Methods
Qualified contractors and suppliers of sand cover material will be identified in coordination
with Domtar procurement proced1ures. A specific bid package will be developed for the
purposes of soliciting competitive\tenders (quotes) from qualified contractors for
implementation of the remedy. Included in the bid package will be the final design drawings, I specifications, the RA Work Plan, Cover Operations Plan, and Terms and Conditions by which
I the project will be implemented. Based upon review of the bids, one or more qualified
I contractors will be selected to implement the eMNR™ sand cover placement activities.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix B: Project Delivery 5/ralegtJ
I:\ WPGVL \PJTI \00625\08\00I \R006250SOOJ-OOJB.DOCX 11122/10
2
Revised November 2010
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2.3 Contracting Strategy!
Domtar will evaluate capabilities and qualifications of several contracting firms, prior to
I distributing the bid packages. Only those firms that meet Domtar's contracting requirements
will be considered to implemeAt the project. Pricing and capabilities/qualifications will be
I considered when choosing contractors to implement the RA.
2.4 Phasing Alternatives
Implementation of the RA willlbe completed in the following phases:
■ Site Staging and Material Storage
I ■ In Water eMNR™ Cover Sequenced placement
■ Site Restoration
The staging and material storage for this RA involves the following site construction activities:
■ Site surveying; I
■ Installation of temporary support facilities; ■ Implementation of a StorJ Water Pollution Prevention Plan (SWPPP); ■ Installation of erosion conJrol systems;
■ Clearing and grubbing;
■ Site grading and laydown area preparation;
I ■ Construction of onsite roads; and
■ Staging area security.
The in water eMNR™ Sand Cover Sequenced Placement will involve the following construction
activities:
Sequence placement by covering the bottom first to provide a buttress for the side slope cover
material. The sand cover mateiial will be broadcast spread to evenly load the cover materiJl
onto the soft sediments and reJuce the potential for contaminant resuspension. The cover iand
will be placed along the bottom of the stream (areas with slopes less than 15°) first and the~ the
placement will be sequenced w\th additional sand placed on the right and left submerged c~eek
banks.
The amount of sand placed in any given pass needs to be carefully controlled to limit adverse
uneven settlement and to redude the creation of a mudwave propagating through the very Joft
underlying sediments. The init\a1 lift will target a 2 to 5 centimeter thickness along the bott6m
RMT North Cnroli11n, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan I
Appendix B: Project DelivenJ StrnfegtJ
I:\ \VPGVl. \ P/TI \ 00625 \08\ OOI \ R0062508001-001B.DOCX 11122/10
3
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of the creek. In order to allow primary consolidation and minimize the potential for differential
settlement during the next lift placement, a consolidation period of 24 to 48 hours prior to \
placement of the next lift is beihg required. After this time, placement will move out from the
bottom areas toward the banks[ The second lift will consist of 5 to 10 centimeters, again sta~ting
at the bottom and moving towArd the creek banks. The second lift will be visually monitor~d at
the surface and using underwa\er cameras to assure that there is no differential settling I
occurring. If visual indications\(such as excessive gas bubbles, higher than typical turbidity, or
solids color change) identify the likelihood of some differential settlement, modifications to the
placement thickness or method will be taken to correct the situation.
Cover material will need to be placed across the entire width of the creek. The cover will be
"feathered" at the margins of tHe cover in order to mitigate the potential for sharp differential
settlement and sediment displa~ement at the edge of the fill. Shallow areas and debris alon~ the
banks limit access to some type~ of equipment in certain areas and alternative procedures Jill
likely be needed to meet the coJerage requirements. Global positioning system (CPS)
monitoring of placement will bJ required to accurately place the material along the desired
pathway and the desired thickn1esses throughout the length of the upstream reach.
Target placement of close to JO lentimeters of cover material along the bottom where benthic
facilitated bioturbation activitie~ are more pervasive.
I
Target placement of 5 to 10 centimeters of cover material along steeper side slopes where the
debris and leaf cover supports al predominantly epifaunal benthic community that has less
direct contact with sediment materials.
The site restoration will involve \the following construction activities: re-grade, re-seed, and
re-plant areas cleared for site la~down or access to minimize erosion and restore to the
pre-construction habitat to the extent practicable.
I 2.5 Availability Considerations
2.5.1 Contractor AvailJility
I Several qualified contractors are expected to be available to install the eMNRTM sand cap
per the approved constrJction schedule.
2.5.2 Equipment AvailJility
The necessary equipmenJ required to implement the RA is expected to be available.
Specialized equipment fo~ in water sand placement, including barges area is available.
RMT North Cnrolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix B: Project Delivery Stratch"Y
/:\ WPGVL \P/Tl \00625\08\001 \R006250800HIOI 8.DOCX 11122/10
4
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2.5.3 Materials Availability
Sand that meets the coJer requirements is readily available. The eMNR™ cover system
will consist of specifiedlparticle sizes of sand containing minimal fine fractions, thuJ
limiting turbidity during cover placement. The grain size and gradation for the covkr
material are detailed in ithe Specifications and the Cover Operations Plan.
The sand cover material was carefully selected to meet the following criteria:
Local availability;
Targeted grain sizes;
Limited angularity! and
Minimum release olf turbidity when exposed to Welch Creek water.
Sand that met these critLia has been identified at local quarries and will be further
confirmed for usage du~ing the RA Work Plan process. The sources will be selected
based on selection crite~ia, price, quantity, and material availability.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plfln
Appendix B: Project Delivery Strategi;
I:\ l\'PGVL \PfTI \00625\08\001 \R006250S001-001B.D0CX l l/22/10
5
Revised November 2010
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Section 3 I Managem~nt Approach -Mobility MonitoriJng
3.1 Overview of Remedy 1
1
component
As stated in the ROD and addressed in the final design, preliminary hydrologic modeling
efforts indicated the midstream reach (MT-7 to GT-15) has the greatest potential for erosion I potential. The area with the potential for erosion is located primarily in limited reach centered
near MT-7 that has a small crosl-sectional area due to a very shallow bottom and constrain~d
banks. Contaminant content whs not considered and no true flow volume calibration data is
available within Welch Creek d~e, in large part, to a lack of stream gauging stations within b,is
small watershed.
The mobility monitoring activities being designed for the midstream reach are focused on
collecting both base flow surfach water quality data and event based surface water quality data.
I I The hydrologic modeling completed by the United States Army Corps of Engineers (USACE)
for Welch Creek concluded that1 the sediments in the midstream reach were most susceptiblk to
mobility due to storm frequencibs of 10-to 25-year recurrence intervals. Therefore, the I
preliminary mobility monitorin~ program will target events within this window over the first
5 years of monitoring. Samples \will be collected up and downstream of the midstream reac~
from automated sampling stations that can be activated remotely.
3.2 Procurement Methodj
I Monitoring equipment and specialized installation equipment will be selected and then
procured by Dom tar's Supervisihg Contractor (currently RMT North Carolina, Inc. [RMT]) to
meet the requirements of the ap/,roved mobility monitoring design. Generally available
mounting equipment (brackets, tlamps bolts etc) will be purchased local hardware store(s).
Additional installation equipmeht may be obtained from the Plymouth Mill maintenance staff,
as needed.
3.3 Contracting Strategy
Domtar will evaluate capabilities and qualifications of several contracting firms, prior to
distributing the bid packages. oh1y those firms that meet Domtar's contracting requirements
will be considered to implement\the project. Pricing and capabilities/ qualifications will be
considered when choosing contractors to implement the RA.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appc11dix B: Project DelivenJ Strategy
/:\ WPGVL \P/TI \00625\08\001 \R0062508001·001B.DOCX 11112/IO
6
Revised November 2010
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3.4 Phasing Alternatives
Mobility monitoring sampling station installation will require the following activities:
I II . f h . I . . . 1. nsta at1on o t ree momtonng stations:
I Upstream of the eMNR™ cover area;
D f h I . . . . d ownstream o t e construction achv1t1es;, an
Downstream of the midstream reach.
2. At each location, specific sampling equipment components equipment are:
-One sonde unit (at 1ach of the three locations) equipped with probes to measure
I
dissolved oxygen (DO), turbidity, pH, conductivity, and temperature; and
Current profilers tol measure water velocity, water level and flow direction (to
determine tidal fluJes within Welch Creek).
Implementation of the mobilit) monitoring task of the RA will be completed in the following
phases:
1.
2.
3.5
Ordering and staging of monitoring equipment and installation components.
Installation of equipment i,( the three specified areas of Welch Creek.
Availability ConsiderJtions
I
3.5.1 Contractor Availability
The Supervising Contra~tor will be installing the monitoring equipment.
I 3.5.2 Equipment Availability
A small boat capable of /naneuvering in shallow water depths will be used in
conjunction with other a~proaches for installation of the mobility monitoring
equipment. Specific equ'ipment requirements are internal power sensor, a water quality
sonde unit, and a multi-tell Doppler current profiler. In addition, various mounting I
equipment including brcickets, anchors, and supports along with warning buoys will be
needed. The boat, mobii'ity monitoring equipment, and associated mounting system~
required to implement ti\e mobility monitoring activities are readily available.
I 3.5.3 Materials Availability
I Back-up batteries the only consumable materials required for the mobility monitoring.
Batteries are available fr6m a number of local sources.
RMT North Carolina, Inc. l Domtar Paper, Company, LLC
Remedial Action Work Pfn11
Appendix 8: Project Delivery StrntcgiJ 7
1:\ WPGVL \PJTI \00615\08\001 \R006250SOOHJOI B.DOCX 11122110 Revised November '2010
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Appendif C
Construction Management P!an
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Actio11 Work Plan
/: \ WPGVL \PJTI \ 00625 \08\001 \ R006250800J-00l .DOCX Revised November 2010
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.......
RMT
----J ~
; E VIRONMENT • ENERGY• ENGINEERING
RemJdial Action Work Plan II Appendix C: Construction Management Plan
(CMP)
Domtar Paper Company, LLC
II
Welch Creek Area OU-4 Plymouth, Martin County, North Carolina
Revised November 2010
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix C: CMP
/;\ WPGVL \PJTJ \00625\08\001 \R00G2508001-001C.DOCX
0 20IO RMT, Jnr.
All Rights Reseiiied
30 Patewood Drive, Suite 100 • Greenville, SC 29615-3535 • [phone] • [phone] FAX• www.rmlinc.com II c•1AT,NG SACANCS"
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Table of Contents
'
1.
2.
3.
lntroduction ..................... J.1. ....................................................................................................... .1. ..... 1
Construction Manageme~t Team .......................................................................................... ..1. ..... 2
2.1 Key Positions, ResJ~nsibility, and Authority ............................................................. l ..... 2
Construction Reporting .. 11 .................................................................... : ................................... I ..... 5
3.1 Daily Documentatib~ Reports ...................................................................................... J .... 5
3.2 Notifications to usk!PA and NC DENR ....................................................................... J ..... 6
II I
3.3 Progress Reports .................................................................................................................... 6
3.4 Administration andl !Approval of Changes in Construction .................................... ..\. .... 6
3.5 Pre-final lnspectionlkeport ........................................................................................... J .... 7
3.6 Interim Remedial Adtion Report .................................................................................. J ... 7
List of Figures
Figure C-1 Remedial Action Construction Management Team Organizational Chart ..... 4
List of Attachments
Attachment C-1 Daily Cost ani:l Schedule Report
RMT Norf11 Cnrolinn, Inc. I Domtar Paper Gompany, LLC
Remedial Actio11 Work Plan
Appendix C: CMP
I:\ WPGVL \ Pj'fl 100625108\0QJ \R006250SOOH)01CDOCX
1
Revised November 2010
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Section 1
lntroducti!on
This Construction ManagemeJI Plan (CMP) has been prepared as a part of the Domtar Papkr
Company, LLC (Domtar) Remci~ial Action (RA) Work Plan, in conformance to the requiren\ents II I of the Consent Decree and Statement of Work (SOW) for Welch Creek Operable Unit 4 (OUj-4).
The CMP provides a descriptio1A of how the construction activities will be implemented and
coordinated with United State/Environmental Protection Agency (USEPA). The CMP I
identifies key project manage~knt personnel and their lines of authority, describes the di/ties of
key construction ma~agement ~ersonnel and provides an organizational chart of the RA I
construction team. The CMP p~ovides a procedure for administration of construction changes
and USE!' A review of any cha~kes. The CMP also outlines formats for meetings and reports
that will be used for tracking a,~d communicating project progress. Detailed information is
provided in the following secti~ns.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix C: CM P
/:\ WPGVL \PJT1 \00625\08\001 \ R0062508001-001C.DOCX
1
Revised November 2010
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Section 2
Construction Management Te~m
The objective of this section is t~ provide a description of the roles and responsibilities of k~y
members of the RA constructio~ management team. The organizational chart shown in
Figure C-1 identifies the formai1 1authority and functional relationships between the team
members.
2.1 Key Positions, Responsibility, and Authority II Descriptions of key positions of, the RA construction management team are provided below:
■ RA Coordinator -Domtar
Assumes overall responsibility for RA activities on Welch Creek OU-4.
Serves as primary J~nagement contact with US EPA, North Carolina Departme'"t of II Environment, and Natural Resources (NC DENR), and other agencies.
Oversees preparatid~ and submittal of quarterly progress reports.
R "bl f I II. . d d" . RA ... espons, e or p anrnng, managing an coor mating activ1t1es.
■ RA Site Manager-Domtar\
Represents Domtar in planning, managing, and coordinating all RA construction II
activities conducted lby the RA construction management team.
Serves as site health knd safety representative (HSR) during RA construction in
accordance with the1
1
Construction Health and Safety Plan/Contingency Plan
(CHSP/CP). I .
Serves as Domtar's on-site management contact with USEPA and NC DENR
regulatory officials. I\
Oversees the implementation of cost controls, schedule controls and other site
controls on a daily b11sis.
Serves as liaison bet]een the RA contractor, on-site regulatory officials and Domtar.
Ensures that daily co1Astruction documentation reports are prepared. Maintains I
records and files on t~e site and assists in the preparation of monthly status reports
submitted to USEPA!\ \
Performs other respolsibilities as delegated by Domtar during the RA construction
activities.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Pinn
Appendix C: CMP
/:\ WPGVL \ PJT1 \00625\08\001 \R006250SOOJ-OOIC.DOCX
2
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■ RA Project Ma11ager -RMT
-Provides project co~tact between the supervising contractor, RMT, and Domtar.
Assists Domtar in Jksponding to USEPA, NC DENR, and other agencies.
I, ·ct . I! d . . h rov1 es semor proiect an construcl!on management overs1g t.
Responsible for assli~ting Domtar with the coordination of the RA construction II
activities conducted by the construction management team.
Assumes other resJbnsibility and authority as delegated by Domtar during the RA . . . '.I construction achv1hes.
■ RA Project E11gi11eer
Responsible for preparation of the pre-final construction inspection report.
Responsible for prdbaration and certification of the interim RA report.
Assists the construJiion management team during the RA construction phase to
provide interpretati6ns and clarifications of the RO documents. This includes
attendance at the ptb-bid and pre-construction conferences.
Serves as a liaison Jltween the RA site manager, the RA contractor and the design
team for resolution 1bf interferences and for clarification and interpretation of d~sign
documents. 11 I
Conducts periodic site visits to Welch Creek OU-4 to review the RA construction in
progress for compli~nce with the approved plans and specifications. Provides field
assessment of poteritial design problems or interferences. Personally observes Jach
of the major elemeri(s of construction including preparation of the subgrade,
deployment of the ibotextile, and placement of the soil cover. ■ Reside11t Co11stnictio11 Q11d\ity Assura11ce (CQA) Represe11tative
-Observes and docuilents construction and installation procedures.
Prepares daily sumilary and inspection reports and transmits these to the RA site
manager and the R1 project engineer. I
Ensures that all work activities comply with the Construction Quality Assurance II
Plan (CQAP). Notifies the RA site manager of any deficiencies.
I It is possible that one individual could perform the tasks of Project Manager, Project Engineer
and/or CQA representative. Thk CQA representative however must be independent of the
construction contractor.
RMT North Cnrolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan j
Appendix C: CMP
l:\ WPGVL \PfT1 \00625\ 08\001 \R006250800I-001C.IJOC
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I
H&S Manager
(To Be Assigned)
---... -
Figure C-1
Remedial Action Construction Management Team
Organizational Chart
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USEPA Region 4
Remedial Project Manager
Randy Bryant
'
RA Coordinator -Domtar Paper
Company
Marcel Sylvestre
RA Project Manager -RMT RA Site Manager & H&S
(Supervising Contractor) Coordinator •
-------I Domtar Paper Company
Mike Parker I
I Bill Morris
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I -----------------RA Project Engineer
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Resident CQA Representative I RA Contractor f-------.l
{To Be Assigned)
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Site Superintendent QA Officer
(To Be Assigned) (To Be Assigned)
RMT North Carolina, Inc. I D0111tar Paper Company, LLC
Remedial Action Work Plan
Appendix C: CMP 4
I:\ WPCVL \Pf11 \00625\0S\001 \R006250S001-00ICDOCX 11122110
-1111 --
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RA Subcontractor
(To Be Assigned)
Revised November 2010
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Section 3
Construction Reporti[ng
3.1 Daily Documentation Reports
During RA construction, the R1 contractor will prepare and submit a daily cost and schedule
report for each working day. 'Hie report will be submitted to the RA site manager within
1 working day after the compli~ion of the subject workday. A blank copy of this report is
included in Attachment C-1.
The resident CQA representative will also prepare a daily summary report for each day of
activity. This report will be suJ!tiitted to the RA project engineer and to the RA site man~ger.
The report will contain the follci{ving information:
■ Date, project name, locatio~, and name of the resident CQA representative; ■ Time work starts and end)!ach construction work day--this also includes duration and
reasons for work stoppageJ (i.e., weather delay, equipment shortage, unanticipated site
conditions, etc.); I
■ Documentation of weather !conditions; ■ Record of any visitors to thJ project site; ■ Description of RA contractl~'s work force, equipment used and materials delivered to the
job site; 11
■ Chronological description of work in progress, including materials used, locations, and
type of work performed; 11
■ Results or references of field testing and sampling;
■ Summary of meetings held l~nd attendees; ■ Discussion of problems/deflhiencies identified and corrective actions taken; and ■ Record of calibrations or stJhdardizations performed on field testing equipment.
D · d · ll . · kl ., f · . . ·11 b d urmg reme y construct1on achv1hes, a wee y e-rna1 summary o achv1hes w1 e prepare
and submitted to the USEPA Re~edial Project Manager (RPM). The weekly e-mail summar~
will transmit an overview of sitJ1progress and will, at a minimum, provide information on
■ volume of sand applied,
■ areal extent covered,
■ turbidity observations (including average, minimum, and maximum), and
II .
RMT North Carolina, I11c. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appe11dix C: CMP
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■ operational adjustments in response to turbidity, if any.
I 3.2 Notifications to USElA and NC DENR
As noted in Subsection 3.2 of ti\~ RA WP, if turbidity monitoring data during cover placement
activities exceeds 50 nephelom~tric turbidity units (ntus), notification will be made to the
11 USEPA RPM and the Surface Water Protection Supervisor of the NC DENR Washington
Regional Office.
3.3 Progress Reports
· During RA implementation, Domtar will submit a monthly report to the USEPA by the JO•h day
of the following month in acco~hance with the requirements of the Consent Decree (CD). This II I report will describe the tasks initiated or completed during the reporting period. The report
will include the following elem~nts:
S f RA .II . .. d . . . d ■ ummary o construction act1v1t1es unng reportmg peno ; ■ Description of project taskJland deliverables initiated or completed during the period; ■ Projection of project tasks J~d deliverables planned for the current period;
■ An update of the project scUedule and projection of work activities;
D . . f f II . . ... ■ escnption o per ormance,momtormg achv1hes; ■ Identification of work planll plan, or other deliverables completed and submitted during
the quarter; 11
■ Summary of sampling and testing data; and
■ Summary of any modificatillns to the RA Work Plan documents or the RA schedule that
II have been proposed or approved by the USEPA.
After RA implementation the re~orting will be reduced to quarterly per the requirements of the
CD.
3.4 Administration and Approval of Changes in Construction
During the course of performin~lthe RA construction work, the RA Work Plan, Construction
Management Plan (CMP), CQAP, CHSP/CP, and drawings and specifications may need to b~
updated or modified. Modificaii~ns to the RA documents would typically be to accommodlte
new information or changes in c~nditions at the Welch Creek OU-4.
The RA contractor will submit rlbuested engineering changes to these project documents
verbally and in writing by letter
1
/o the RA site manager. Domtar will also notify the US EPA ,in
writing of any substantial changJs or modifications to these project documents. The agency \.viii
I RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix C: CMP 6
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be given the opportunity to review and approve these changes or modifications. Domtar will
provide to the contractor verb~! and written approval or denial of each change request.
II 3.5 Pre-final Inspection Report
Following the completion of th~ pre-final inspection, Domtar will submit a pre-final inspection
report. The report will include! lhe following elements: ■ Punch list of outstanding o~ discrepant RA construction items, incomplete testing, and
d . d f' . . II emonstratlon e 1c1enc1es;
■ Actions required for the re~olution of each of the items identified in the punch list above;
■ Scheduled completion datlk for each of the punch list items; and
3.6
■ Scheduled date for final inklpection.
Interim Remedial Actlhn Report
II
Domtar will submit to the USE~A an Interim Remedial Action Report no later than 60 days
after the final construction insp~ction. The Interim Remedial Action Report will be preparea by 11
the RA project engineer under the purview of the senior project oversight team. As a · II
professional engineer registered in the State of North Carolina, the RA project engineer will
certify that the construction wo~k of the remedy has been constructed in accordance with Irie
approved RA documents.
The interim RA report will include the following elements:
■ Introduction;
■
■
Operable unit background;
Construction activities;
■ Chronology of events, incluaing projection of when clean-up levels for the wetlands ana
groundwater will be achiefd;
■
■
Performance standards and construction quality control;
F. 1. . d 'f' I . ma 1nspect10n an cert1 1cations;
■
■
Operation and maintenanckl(O&M) activities;
Notification of modificatioA~ to the original remedial design (RD) and RA Work Plans that
were made during the RA Jbnstruction, along with an explanation of why these changeb
were made; and
■ Record drawings.
RMT North Carol ilia, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix C: CMP
/: \ WPGVL \PfTI \00625\08\UOJ \R0062.'i08001-00IC.DOCX
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"' Attachment C-1
Daily Cost and Schedule Report
RMT North Caro/ilia, l11c. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix C: CMP
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RMT Daily Cost and Schedule Report
PROJECT NAME: DATE: WORK START TIME: WORK END TIME:
PROJECT NUMBER: WEATHER: DAY s M T w TH F
CLIENT NAME: TEMP. WIND: PRECIPITATION:
CONTRACTOR NAME: REPORT PREPARED BY: PROJECT MANAGER:
Status of Project in Relation to Schedule:
Contractor's Work Force (include subcontractors):
Equipment at Site (identify in use or idled):
Materials or Equipment Delivered:
Description of Work in Progress (chronological format including materials and equipment installed):
Notices to Contractor:
Requests from Contractor:
Testing Performed/Samples Collected:
Field Problems and Non-conforming Materials or Work:
RMT Nortlt Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix C: CMP
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Health and Safety Issues:
Exposure to Hazardous Materials:
PPE Utilized:
Results of Monitoring Tests:
Construction Safety Issues:
Additional Comments:
Daily Communications:
Name:
Subject/Comments:
Action (if necessary):
Name:
Subject/Comments:
Action (if necessary):
Name:
Subject/Comments:
Action (if necessary):
RMT North Carolina, file. I Domtar Paper Compa11y, LLC
Remedial Action Work Plan
Appendix C: CMP
I:\ WPGVL \ P{TI \ 00625\ 08\ 001 \ R0062508001-001 C. DOCX
Daily Cost and Schedule Report
Time:
Time:
(
Time:
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RMT
Name:
Subject/Comments:
Action (if necessary):
.
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Remedial Action Work Plan
Appendix C: CMP
I:\ WPGVL \P/Tl \00625\08\001 \R0062508001·001C.DOCX
Daily Cost and Schedule Report
Time:
Revised November 2010
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Appendix D
Construction Quality Assurance Project Plan
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
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..... ·•
RMT
A
•ENVIRONMENT• ENERGY• ENGINEERING
Remedial Action Work Plan
Appendix D: Construction Quality Assurance Plan
(CQAP)
Domtar Paper Company, LLC
Welch Creek Area OU-4 Plymouth, Martin County, North Carolina
Revised November 2010
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Phm
Appendix D: CQAP
!:\ WPG\/1. \P/TI \00625\08\001 \R0062508001--001 D.DOCX
©2010RMT,lur.
All Rights Reserved
30 Patewood Drive, Suite 100 • Greenville, SC 29615-3535 • [phone] • [phone] FAX• v.rww.rmtinc.com
CREATING BALANCE"'
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Table of Contents
1. Introduction ...................................................................................................................................... 1
1.1 Project Description ...................................................................... : ......................................... 1
1.2 Objectives ............................................................................................................................... 1
1.3 Construction Quality Assurance Plan Organization ........................................................ 2
1.4 Quality Assurance Definitions ............................................................................................ 3
2. Roles and Responsibilities .............................................................................................................. 4
2.1 Independent Quality Assurance Team .............................................................................. 4
2.1.1 Regulatory Agency .................................................................................................. 4
2.1.2 Domtar Remedial Action Coordinator. ................................................................. 4
2.1.3 Engineer of Record ................................................................................................... 5
2.1.4 Construction Manager ............................................................................................. 5
2.1.5 Remedial Action Contractor ................................................................................... 5
2.1.6 Resident Construction Quality Assurance Technician ....................................... 5
3. General Construction Inspection ................................................................................................... 8
3.1 Introduction ........................................................................................................................... 8
3.2 PreConstruction Requirements ........................................................................................... 8
3.2.1 Wetland Soil Sampling ............................................................................................ 8
3.2.2 Cover Sand Sampling .............................................................................................. 8
3.3 Construction Monitoring ..................................................................................................... 9
3.3.1 Monitoring activities and performance requirements ........................................ 9
3.3.2 Data review and response to non-compliance ................................................... 10
3.4 Inspection and Verification of Cover Placement ............................................................ 11
4. DoCL1mentation ............................................................................................................................... 18
4.1 Reporting .............................................................................................................................. 18
4.1.1 Daily Record Keeping ............................................................................................ 18
4.1.2 Daily Construction Report .................................................................................... 18
4.1.3 Inspection and Testing Report Forms ................................................................. 19
4.1.4 Control of Quality Records ................................................................................... 19
4.1.5 Monthly Progress Reports .................................................................................... 20
4.1.6 Quarterly Progress Reports .................................................................................. 20
4.2 Administration and Approval of Changes in Construction ......................................... 20
4.3 Pre-final Inspection Report ................................................................................................ 21
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP
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4.4 Interim Remedial Action Report ....................................................................................... 21
4.5 Problem/Deficiency Identification and Corrective Action ............................................ 22
4.6 Photographic and Video Documentation ........................................................................ 23
5. References ....................................................................................................................................... 24
List of Tables
Table D-1
List of Figures
Figure D-1
Figure D-2
Figure D-3
Figure D-4
Figure D-5
Figure D-6
List of Attachments
Summary of the Planned Calibration and Verification Activities ................... 12
Construction Quality Assurance Team Organization Chart ............................. 7
Transect Locations ................................................................................................. 13
Wetland Sampling Locations ................................................................................ 14
Segment A -Chemical and Cover Verification Samples .................................. 15
Segment B -Chemical and Cover Verification Samples .................................. 16
Segment C-Chemical and Cover Verification Samples .................................. 17
Attachment D-1 Soil Sampling Standard Operating Procedures
Attachment D-2 Daily Cost and Schedule Report
RMT North Caro/inn, Inc. I Domtar Paper Co111pany, LLC
Remedial Actio11 Work Plan
Appendix D: CQAP
/;\ WPGVL \PJTJ \00625\08\001 \R00625D8001-00JD.DOCX
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1.1 Project Description
Section 1
Introduction
Welch Creek, Operable Unit No. 4 (OU-4), is located at the Domtar Paper Company, LLC
(Domtar) Plymouth Mill in Martin County, North Carolina. The Remedial Investigation/
Feasibility Study (RI/FS) including a Baseline Ecological Risk Assessment (BERA), a series of
facilitated meetings and several pilot studies were completed for Welch Creek Area OU-4 under
a negotiated Administrative Order on Consent (CD) from 1998 to 2007. The remedial action
selected in the Record of Decision (ROD) and defined in the final design, has five components:
enhanced Monitored Natural Recovery (eMNR™) of sediment contaminated with dioxin above
cleanup goals in the upstream reach of Welch Creek; mobility monitoring for the less
contaminated sediment in the midstream reach; long-term monitoring and maintenance of the
eMNR™ sand cover; long-term testing and monitoring of sediment, surface water, and biota to
document the performance of the remedy and compliance with cleanup goals; and institutional
controls. This report presents the Construction Quality Assurance Plan (CQAP) for the
implementation of the active construction components of the Remedial Action (RA).
This CQAP is a "working" document, which will be updated as necessary to reflect changes in
specific contractors, materials used, installation practices, or monitoring requirements.
1.2 Objectives
Dom tar's approach to management of the quality of the RA implementation includes a
combination of quality control by the contractor and quality assurance (QA) by the
Construction Manager. The CQAP details the systems and controls that Dom.tar has put in
place so that the quality of the project will meet the requirements specified in the Remedial
Design (RD). Domtar provides definition and overall management of the quality approach to
be followed by its contractors and consultants. The quality of the RA implementation will be
ensured through an integrated system of quality assurance performed by the Construction
Manager and quality control (QC) provided by the contractors. Domtar's Construction
Manager is responsible for the day-to-day coordination of QA/QC measures in the field.
This CQAP has been developed in accordance with Task Ill of the Statement of Work (SOW).
Contractors are responsible for constructing the work in accordance with the plans and
specifications. Each contractor is also responsible for controlling the quality of its work to meet
contract plans, specifications, and related requirements. The contractor's QC is the systematic
RMT Nort/J Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP
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implementation of a program of inspections, tests, and production controls to attain the
required standards of quality and to preclude problems resulting from noncompliance. Each
contractor will establish an independent QC program and write a Contractor Quality Control
Plan (CQCP). The CQCP must provide for tests and inspections pursuant to various technical
specifications. 1t will define procedures to ensure that activities affecting quality are properly
documented and accomplished in accordance with contract documents; written instructions;
and industry standards, codes and procedures. Furthermore, the CQCP will define methods for
ensuring that activities affecting quality will be accomplished under controlled conditions.
Independently of the contractors, the construction manager (CM) will provide QA through
daily monitoring and scheduled inspections to verily the effectiveness of the contractor's QC
program and assure that the quality and contract requirements are met by the contractors. TI1e
CM assures that the contractor's QC is working effectively and that the resultant construction
complies with the quality requirements established by the contract. The objectives of this CQAP
are to:
■ Describe the quality program and organization to be implemented so that the project is
constructed in accordance with the contract requirements and industry standards;
■ Describe guidelines for inspection and documentation of construction activities;
■ Provide reasonable assurance that the completed work will meet or exceed the
requirements of the construction drawings and specifications; and
■ Describe how any unexpected changes or conditions that could affect the construction
quality will be detected, documented, and addressed during construction.
1.3 Construction Quality Assurance Plan Organization
This CQAP is organized into four sections.
1. Introduction
Describes the project setting, and the CQAP quality program overview.
2. Roles and Responsibilities
Identification of responsibilities and authorities of all organizations and key
personnel involved in the design and construction of the site remediation.
3. General Construction Inspection
Description of inspection activities, observation and tests to be conducted,
schedules, and scope.
RMT North Carolina, Tnc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appelldix D: CQAP
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Construction quality assurance (CQA) objectives, specific quality control
requirements, and performance standards to be followed during implementation of
remedial actions.
Sampling strategies to include sampling types, locations, size, frequency of testing,
acceptance and rejection criteria, and plans for implementing corrective measures.
4. Documentation
Procedures for scheduling and managing submittals, including those of
subcontractors.
1.4
Documentation of inspections and sampling events.
Proposed inspection and sampling report submittal schedule.
Quality Assurance Definitions
In the context of this RA, the CQA and construction quality control (CQC) are defined as
follows:
■ CQA refers to measures taken by either RMT North Carolina, Inc. (RMT) or Domtar to
determine if the RA contractor is in compliance with the design plans and specifications.
■ CQC refers to measures taken by the RA contractor to determine their own compliance
with the requirements for materials and workmanship as stated in the contract drawings
and specifications.
References to Standards
The CQAP includes references to testing and installation procedures of the following:
American Society for Testing and Materials (ASTM)
Code of Federal Regulations (CFR)
Occupational Safety and Health Act (OSHA)
United States Environmental Protection Agency (USEPA)
North Carolina Department of Environment and Natural Resources (NC DENR)
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Actio11 Work Pinn
Appendix 0: CQAP
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2.1
Section 2
Roles and Responsibilities
Independent Quality Assurance Team
The principal parties involved in the CQA activities during implementation of the RA for the
Welch Creek Area include USEPA, NC DENR, Domtar, senior project oversight team, RA site
manager, resident CQA representative, and the RA contractor. The CQAP includes the
involvement of an Independent Quality Assurance Team (IQAT) that will implement the QC
measures for all aspects of work specified in the RA Work Plan. This will be accomplished by
conducting CQA inspections, as needed, that will be coordinated by the resident CQA
representative. The resident CQA representative will report to the site manager, who will be
responsible for communicating to the Domtar RA coordinator. Domtar's RA coordinator will
be responsible for communicating with USEPA and NC DENR. Refer to Figure D-1 for the
IQATorganization chart. The IQATwill be comprised of qualified individuals with strong
professional backgrounds and reputations for ethical conduct, previous work experiences in
implementing CQA activities, and a demonstrated ability to perform the required CQA
activities.
These individuals will have a strong background in the varying engineering disciplines
necessary to facilitate the design and CQA activities. The IQAT members will be independent
of the RA contractor.
2.1.1 Regulatory Agency
USEPA and NC DENR will review the RA pre-final construction inspection report and
CQAP. USEPA and NC DENR will also review the Interim RA Report. Final approval
of all documents is the responsibility of the USEPA.
2.1.2 Domtar Remedial Action Coordinator
The RA coordinator is Domtar' s primary management contact with US EPA and
NC DENR. This responsibility includes the submission of the CQA documentation
demonstrating that the remediation has been completed in accordance with the design
criteria, plans, and specifications; and that the performance standards were achieved.
Domtar is responsible for coordinating the implementation of the RA activities of the
Welch Creek Area and has the authority to accept or reject modifications to design plans,
specifications, and CQA reports. Domtar' s RA coordinator has the authority to select
and dismiss parties charged with design, remediation activities, and CQA.
RMT North Cnroli11a, lllc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appc11dix D: CQAP
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2.1.3 Engineer of Record
The Engineer of Record is an independent, duly qualified, licensed design professional,
retained directly by Domtar to provide design and engineering services in connection
with the project. RMT is the Engineer of Record for the Welch Creek RO. RMT will
provide submittal review and resolution of design issues as they arise during
construction.
2.1.4 Construction Manager
The CM is retained by Domtar to provide professional construction management and
related services in connection with the project. The CM is responsible for
implementation of this CQAP. The CM will manage construction contractors on behalf
of Domtar and serve as the primary point of contact with the contractors for all
communications to and from the contractors. The CM will provide QA and monitor the
day-by-day CCC activities performed by construction contractors to verify compliance
with the contract plans and specifications. The CM will also manage, coordinate, and
administer all QC/QA activities and requirements, including those of subcontractors to
the CM. Additionally; the CM may be assigned management of any third party QA
inspection and testing firms retained by Domtar.
2.1.5 Remedial Action Contractor
The RA contractor is responsible for the CQC to ensure that the construction activities
are performed using the procedures and equipment necessary to produce final results in
conformance with the contract documents. The RA contractor is also responsible for the
quality of the materials and the installation of materials in conformance with the
contract documents. The RA contractor is responsible to submit a project-specific CQCP
to the site manager and resident CQA representative for review and file prior to the
initiation of construction activities. The RA contractor is to prepare all required CQA
submittals for the resident CQA representative's review.
2.1.6 Resident Construction Quality Assurance Technician
The resident CQA representative is responsible for observing and documenting the
construction activities related to the CQAP. In general, the responsibilities and
authorities of the resident CQA representative are as follows:
Complete understanding of the design plans and specifications in relation to all
aspects of the CQAP.
Review of construction schedules, participation in construction meetings,
observation of field activities, and performance of CQA activities.
RMT North Carolina, Inc. I Domtar Paper Compn11y, LLC
Remedial Action Work Plan
Appendix D: CQAP
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Communicating with the RA site manager, Domtar RA coordinator, USEPA,
NC DENR, senior project oversight team, contractors, and other involved parties
during construction activities.
Performing independent on-site observation of the work in progress to assess
compliance with the CQAP, permit documents, design plans, and specifications.
Recognizing and reporting deviations from the CQAP, permit documents, design
plans, and specifications to the RA site manager.
Securing and maintaining documents which approve changes to the CQAP, design
plans, and specifications.
Verifying that CQA testing equipment meets testing and calibration requirements,
and that tests are conducted according to standardized procedures defined in the
CQAP.
Recording, maintaining, reviewing, and forwarding monitoring data.
Identifying CQA tested work that should be accepted, rejected, or further evaluated.
Verifying that corrective measures are implemented.
Documenting and reporting CQA activities to the RA site manager, Domtar RA
coordinator, USEPA, and NC DENR on a weekly basis.
Maintaining a set of "as-built" record drawings during construction.
RMT North Carolina, Inc. I Domtar Paper Compa11y, LLC
Remedial Action Work Plan
Appendix D: CQAP
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Figure D-1
Construction Quality Assurance Team
Organizational Chart
Domtar Paper Co. LLC
Operations Manager
----------------RA Site Manager & H&S
Engineer of Record >--RMT I
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Construction Manager I ! Independent Testing lab ~ I
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Resident CQA Representative ----------------·
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H&S Manager Site Superintendent
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP
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7
Coordinator•
Domtar
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RA Contractor
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QA Officer RA Subcontractor
Revised November 2010
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3.1 Introduction
Section 3
General Construction Inspection
The construction inspection activities for placement of the eMNR™ sand cover in the upstream
reach of Welch Creek have been divided into three separate sections. The first set of activities
will be completed prior to construction activities. The second group of actions is associated
with monitoring surface water quality during cover placement and defining specific actions to
minimize adverse impacts on the water quality at specific downstream monitoring stations in
Welch Creek due to placement of the cover material. The third component of the construction
inspections is focused on confirming the cover material placement thickness and consistency
daily to ensure that the eMNR™ cover is uniformly placed in two lifts of 2 to 5 centimeters
initially and a final targeted cover thickness of 5 to 10 centimeters across the width of the creek.
To help define sample locations before, during and after construction, a series of reference
transects have been identified throughout the placement area and are shown on Figure 0-2.
The specific inspection procedures will be performed by the Engineer of Record on behalf of
Domtar. Reporting of the results will be conducted daily on specific forms that will be
developed in conjunction with Domtar and after final selection of the construction contractor.
3.2 PreConstruction Requirements
3.2.1 Wetland Soil Sampling
During the baseline monitoring activities, a field reconnaissance was conducted to
identify potential wetland soil monitoring locations. The station locations were
recorded via global posi_tioning system (GPS). Five wetland soil monitoring locations
were identified as indicated on Figure 0-3. One wetland soil sample will be collected
from each of the five monitoring locations during Part 2 baseline sampling and post
construction sampling to assess impacts of construction activities on wetland soil
concentrations in the midstream reach. Soils will be analyzed for total mercury and
dioxin. Procedures for wetland soil sampling are identified in the Standard Operating
Procedure (Attachment 0-1).
3.2.2 Cover Sand Sampling
As previously discussed in the Cover Operations Plan, the sand will consist of specified
particle sizes of sand containing minimal fine fractions. Pre approval sampling of the
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Actio11 Work Pinn
Appendix D: CQAP
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3.3
sand material will consist of gradation performed in accordance with ASTM
D6913-04(2009) Standard Test Methods for Particle-Size Distribution (Gradation) of Soils
Using Sieve Analysis. Chemical analysis will consist of dioxin, mercury, total organic
carbon (TOC), and specific metals (manganese [Mn], magnesium [Mg], iron [Fe],
calcium [Ca], barium [Ba], aluminum [Al], and titanium [Ti]). After material approval,
additional chemical analysis will only be performed if the location of imported material
changes from the approved location, or if there is a visual indication that the material
has changed. Gradation sampling will be performed once for every 500 cubic yards of
material.
Construction Monitoring
3.3.1 Monitoring activities and performance requirements
Monitoring activities are designed to evaluate the impacts from the placement activities
(i.e., sand) and from resuspension (i.e., wastewater solids). As described previously, the
design of the placement activities has been developed to limit potential resuspension of
the sediment. An additional safeguard is to implement a resuspension monitoring
program that provides real time water quality data for use in assessing a need for
operational changes that minimize any unintended secondary effects.
If the turbidity from the downstream station exceeds either 25 nephelometric turbidity
units (ntus) or twice the measured turbidity at the upstream sampling location
(whichever is greater), a series of contingency responses will be implemented to
minimize possible adverse impacts. The turbidity data will also be supplemented by
weekly dioxin analyses and visual inspections of the water barriers associated with the
residuals isolation area.
The use of turbidity as the real time water quality indicator parameter is based upon the
following rationale:
Turbidity measurements are rapid, easy to instrument, reliable and commonly used
to monitor suspended solids during in water activities.
Turbidity has been shown to be well correlated to total suspended solids (TSS).
Furthermore, based upon their physical/chemical characteristics, specifically very
low water solubility and hydrophobic nature, dioxin will remain associated with
solid particles which are measured both as TSS and turbidity. As such, turbidity
combined with indicator element analysis of surface water provides a good
surrogate for identifying suspended wastewater solids.
RMT North Carolina, Inc. \ Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP 9
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3.3.2 Data review and response to non-compliance
A contingency plan has been developed to address turbidity exceedances. The plan will
be implemented if the confirmed turbidity reading at the downstream monitoring
location is the greater of 25 ntus or two times the upstream turbidity reading. Turbidity
data will be considered confirmed if a turbidity plume emanating from the excavation
zone is visible or if three consecutive turbidity samples averaged over 15-minute
increments confirm the elevated turbidity above the target levels. The Surface Water
Protection Supervisor of the NC DENR Washington Regional Office and USEPA will be
notified if turbidity monitoring data exceeds 50 ntus.
The Contingency Plan (CP) calls for the following mitigation actions to identify and
eliminate the cause of elevated turbidity observations:
Inspection of the area downstream of the excavation site and the turbidity curtains
and repair as needed.
Implementation of troubleshooting measures based on field conditions to reduce
turbidity (i.e., re-securing or re-positioning the silt curtain, modifying the placement
approach, etc.).
Finally, placement rates will be reduced or procedures modified (e.g., additional
sand screening) until the turbidity has returned to acceptable levels and/or to
reduce future levels.
If an unexpected turbidity exceedance is observed, or an equipment failure occurs,
additional turbidity and dioxin samples may be collected based on the severity of the
exceedance and on in-field professional judgment. Furthermore, additional inspections
may be conducted during unexpected or uncontrolled events.
Surface water samples will be collected on a weekly basis during cover placement
activities to support the turbidity monitoring information. The surface water sample
will be analyzed for dioxin, TSS, total volatile solids (TVS), TOC and indicator elements
(Mn, Mg, Fe, Ca, Ba, Al, and Ti). Whenever possible, sampling will be conducted on the
same day of the week and correlated with turbidity samples. Samples will be co-located
with the turbidity monitoring locations upstream and downstream of the placement
area. Additional samples will be collected as needed based upon in-field observations.
The comparison criteria for surface water analyzed during construction monitoring will
be the concentrations measured upstream and the range of background concentrations
established during the pre-construction sampling activities.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP
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Water samples will be collected in accordance with the procedures outlined in the Field
Sampling Plan (FSP; RMT, 2009) for the site. Analysis will be performed in accordance
with the site-specific Quality Assurance Project Plan (QAPP; RMT, 2009).
As a component of preparing the Performance Standards Verificati~m Plan (PSVP) for
the RA, analytical methods and detection limits will be reviewed to confirm they remain
appropriate for the media and contaminants of concern. Updates to the existing site
FSP/QAPP, as needed, will be included in an addendum to the RA PSVP.
3.4 Inspection and Verification of Cover Placement
The adequacy and quality of sand cover placement activities will be evaluated on a daily basis
by a multiple lines of evidence approach that include measurement of the mass of cover
material placed over specific areas, visual and photographic assessments, remote sensing scans
and core sample measurements. The effectiveness and relationships between these inspection
activities will be evaluated during an initial calibration period during the first 5 to 8 days of
cover material placement. Verification activities will be refined and modified, if needed, based
upon the calibration activities.
A summary of the planned calibration and verification activities is presented in Table D-1.
Maps illustrating the transect locations and approximate visual assessment locations are
included as Figures D-4 to D 6.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Aclio11 Work Pinn
Appendix D: CQAP
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Revised November 2010
- --- -.. .l!!!!I!! l!!!!I l!!!5
Table D-1
Summary of the Planned Calibration and Verification Activities
LINE OF SPECIFIC OBSERVATION(S)/ TESTING SUMMARY FOR INITIAL SAND LAYER AND FINAL SAND LAYER
EVIDENCE MEASUREMENTS REQUIRED
Mass per unit area -to Mass of sand placed in area
establish a simple quality (M lbs)
control measure that allows
correlation of placement rate Area covered (A) tt2
to cover thickness
Use core samples to assess
accuracy
Sand placement coverage Confirm consistent aerial
coverage based upon visual or
photographic observations at
specific locations.
Sand placement thickness Core samples to top of sediment
Remote sensing device (echo-
sounder or comparable
equipment) that can measure
the thickness of the sand cover
Chemical concentration in Chemical concentrations in
bioactive layer bioactive layer:
Dioxin I-TEQ
TOC
Total solids
RMT North Carolina, Inc. I Domtar Paper Compm1y, LLC
Remedial Action Work Plan
Appendix D: CQAP
I:\ WPG\'l. \Pfll \00625\08\001 \R0062508001-001D.DOCX
CALIBRATION VERIFICATION
Record mass of sand placed over a specified length Daily -Record mass of placed sand.
to correlate to placement rate.
Calculate specific area in 50 to 100 feet lengths Daily -Calculate area covered (length and
(estimate creek width from field verified aerial estimated corresponding creek width).
photos).
Use underwater camera to evaluate coverage in 50 to Daily use of underwater camera to document
100 feet lengths for the first 2 to 3 days of sand coverage for the specific areas.
placement. Modify placement plan for final sand layer to even
Identify areas that will require additional coverage the coverage to the targeted 5 to 10 cm.
during placement of final sand layer.
Adjust placement approaches to improve aerial
coverage.
Advance core samples along transects and in Collect from 5 to 7 core samples to top of sediment
quadrants within the coverage area to assess ability to confirm cap thickness in area. Creek area
of the placement method to measure the thickness of defined by daily length of cover placement
the cover. achieved by estimated creek width for segment of
Number of cores to range from 10 to 15. interest. Daily cover placement is targeted to
address creek segments of 100 feet or greater.
Use remote sounding device and real time electronic Use remote sounding device and real time
reports to map the cover thickness across the areas electronic reports to map the cover thickness
where both the initial and final sand cover layers were across the areas where both the initial and final
placed on a spec~c day. sand cover layers were placed on a specific day.
Correlate to core sample thickness. Correlate to core sample thickness.
Subsample the top five centimeters (bioactive layer Subsample the top 5 cm (bioactive layer thickness)
thickness) for the three core samples collected along for the three core samples collected along the
the verification transects. verification transects.
Note: no additional samples required for calibration.
12
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r;;;;
--- - ----- - -
SHEET TITLE:
-- -
~ Supplemental Transects
~ Existing Transects
/V PROPERTY BORY.
TRANSECTS
-
l=i eMNR Placement Sections (Approx.)
Notes:
I. EXlent ol eMNATM areas are clf)pn)xlmate
and may change depending upon field cood!llons.
0 100 200
FEET
DOMTAR PAPER COMPANY, LLC
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK · OU-4
REMEDIAL ACTION WORKPLAN
TRANSECT LOCATIONS
8
-
DRAWN BY: PAPEZ J SCALE: PAOJ. NO.: 00625.08
CHECKED BY: NW AS NOTED
APPROVED BY: JH
DATE: AUGUST2010
RMT
FILE NO.: 00625.05.001.RA. 1
FIGURE D-2
30~1'1WOOdt::lrlve,Sl.rt9 100
~.SC2llefS
8&4.2111.00JOphot,t
854.2111.0288 fH
-111!11
-----------------------------------------------------,---------------------- ---1!!!!!111 ---
Wetland Sampling Location
SEDIMENT TYPES
111 ZONE OF POTENTIAL
SEDIMENT MOBILITY
/V PROPERTY BORY.
TRANSECTS
0 250
DOMTAR PAPER COMPANY, LLC
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK · OU-4
REMEDIAL ACTION WORKPLAN
WETLAND SAM PLING LOCATIONS
WEBERN SCALE: PROJ.NO.:
-
00625.0B
NW AS NOTED FILE NO.: 00625.05.001.AA.F 3.m~d
JH
AUGUST2010
AMT
FIGURE D-3
30 Pa/awood Dnve, Sult, 100
Gt9wMle, SC 29615
8(W.28l.0030~
&W.28l.0288 ru
-.. --- ------- ---
• CHEMICAL VERIFICATION SAMPLES
• COVER THICKNESS SAMPLE
VERIFICATION TRANSECTS
~ SUPPLEMENTAL TRANSECTS
~ EXISTING TRANSECTS
eMNR PLACEMENT SECTIONS SIDE SLOPES (APPROX.)
c::::J <15 DEGREES
c::::J >15 DEGREES
ORIGINAL TRANSECTS
/V GENERAL TRANSECT
/V MASTER TRANSECT
100 ~
Fm ~
Notes:
1. Location of side slopes with angles <1 5 or > 15
degrees are approximate based upon field data
collected in 2009.
2. Sample locations are approximate and will be
located in the field using GPS coordinates.
3. Final field sample locations will be selected
appropriately represent bottom conditions (i.e. side
slopes).
DOMTAR PAPER COMPANY, LLC
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK • OU-4
REMEDIAL ACTION WORKPLAN
SEGMENT A· CHEMICAL AND COVER VERIFICATION SAMPLES
WEBERN SCALE:
AS NOTED
JH
AUGUST2010
RMT
PROJ. NO.: 00625.08
FILE 2501. I.Fl 3
FIGURE 0-4
30P•tewood0rlve, Sult• 100 -.scm,6
864,281,00JO phone
8114.281.0288 lax
- --.. -- ----- -
D:10517 4104\517 40404 .mxd
---.. -
• CHEMICAL VERIFICATION SAMPLES
• COVER THICKNESS SAMPLE
VERIFICATION TRANSECTS
~ SUPPLEMENTAL TRANSECTS
~ EXISTING TRANSECTS
eMNR PLACEMENT SECTIONS SIDE SLOPES (APPROX.)
c::J <15 DEGREES
c::::::J > 15 DEGREES
ORIGINAL TRANSECTS
,v GENERAL TRANSECT
,v MASTER TRANSECT
100 ~
FEET ~
Notes:
1. Location of side slopes with angles <15 or > 15
degrees are approximate based upon field data
collected in 2009.
2. Sample locations are approximate and will be
located in the field using GPS coordinates.
3. Final field sample locations will be selected
appropriately represent bottom conditions (i.e. side
slopes).
DOMTAR PAPER COMPANY, LLC
MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK · OU-4
REMEDIAL ACTION WORKPLAN
-
SEGMENT B • CHEMICAL AND COVER VERIFICATION SAMPLES
WEBERN SCALE:
NW AS NOTED
JH
AUGUST 2010
AMT
PROJ. NO.: 00625.08
FILE NO.: 00625.01.001. A
FIGURE D-5
31) ,,.,._ Orlw, Su/It ,oo
Gtw«>YIIM.SCml15
844.281.003/JphoM
864,281.0288 , ..
- --al - ---- - -0:\05174\0C\51740404.mxd ------- -• CHEMICAL VERIFICATION SAMPLES • COVER THICKNESS SAMPLE VERIFICATION TRANSECTS ~ SUPPLEMENTAL TRANSECTS ~ EXISTING TRANSECTS eMNR PLACEMENT SECTIONS SIDE SLOPES (APPROX.) c:, <15 DEGREES c:::::J >15 DEGREES ORIGINAL TRANSECTS ~ GENERALTRANSECT ~ MASTER TRANSECT 50 100 ~ FEET ~ Notes: 1. Location of side slopes with angles <15 or > 15 degrees are approximate based upon field data collected in 2009. 2. Sample locations are approximate and will be located in the field using GPS coordinates. 3. Final field sample locations will be selected appropriately represent bottom conditions (i.e. side slopes). DOMTAR PAPER COMPANY, LLC MARTIN COUNTY, NORTH CAROLINA WELCH CREEK -OU-4 REMEDIAL ACTION WORKPLAN SEGMENT C -CHEMICAL AND COVER VERIFICATION SAMPLES 'EBERN !SCALE: NW AS NOTED JH ,UGUST 20101 AMT IPROJ.NO.: 00625.08 FILE NO.: 00625.01.001.Ag3A FIGURE D-6 30PeulwoodDtM, Sull• ,oo G-.scm,s 864.281.0030 pJlotlo 85◄,281.0288 lax
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Section 4
Documentation
This section describes general documentation procedures to be implemented including use of
forms, identification and resolution of problems or deficiencies, and photographic
documentation. A preconstruction conference will be conducted in accordance with the
Construction Health and Safety Plan/Contingency Plan (CHSP/CP).
4.1 Reporting
4.1.1 Daily Record Keeping
Project documents will be managed through a combination of a secure document filing
and storage system and a computerized document tracking system. Sufficient records
shall be prepared and maintained as work is performed to furnish documentary
evidence of the quality of construction and laboratory analysis and of activities affecting
quality. ,Each contractor QC technician shall maintain a daily log of all inspections
performed for both contractor and subcontractor operations on a form acceptable to the_
CM. The Daily Inspection and Daily Test reports shall be signed by the responsible QC
technician and the QCM. The CM shall be provided at least one copy of each daily
inspection and test report on the work day following the day of record.
4.1.2 Daily Construction Report
The resident CQA representative will also prepare a daily summary report for each day
of activity. The report will include a summary of the contractor's daily construction
activities. Supporting inspection data sheets will be attached to the daily report where
needed. Example forms are provided in Attachment D-2.
At a minimum, the daily construction report will include the following information:
Date, project name, location, and other identification
Description of weather conditions, including temperature, cloud cover, and
precipitation
Reports on any meetings held and their results
Record of visitors to site
Locations of construction underway during that day
Equipment and personnel working in each activity, including subcontractors
RMT North Carolinn, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP 18
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Descriptions of work being inspected
Decisions made regarding approval of units of material or of work, and corrective
actions to be taken
De~cription of problems or delays and resolution
Communications with contractor staff
Construction activities completed and/or in progress
Progress photos, where applicable
Signature of the report preparer
The daily construction reports will be routed on a daily basis to the project QC/QA files
and will be maintained as part of the permanent project record. These reports are
reviewed by the CM and also distributed to Domtar.
4.1.3 Inspection and Testing Report Forms
Report forms will be completed for inspections and tests conducted. The forms vary
depending on inspection or test type. Representative forms for several types of
inspection and testing reports are included in Attachment D-2. These forms include:
Description or title of the inspection activity
Location of the inspection activity or location from which the sample was obtained
Recorded observation or test data
Results of the inspection activity
Personnel involved in the inspection activity
Signature of the inspector
4.1.4 Control of Quality Records
The CQAO verifies QA record accuracy and maintains copies of all quality-related
documentation. This includes, but may not be limited to:
Daily construction QA logs and records;
lnsp~ction checklists and reports;
Surveillance reports;
Non'.conformance reports;
Material receiving reports; and
Monitoring and test data.
RMT North Carolina, Inc. I Domtar Paper Compa11y, LLC
Remedial Action Work Plan
Appendix D: CQAP 19
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4.2
These ;ecords will be stored in files maintained in the project document control files. All
original documents pertaining to project information will be maintained in the project
file located at the project office in Plymouth, North Carolina. The CM and Site Manager
have primary responsibility for the centralized document control files for the project and
construction documentation. Pursuant to the contract specifications, the contractor
provides an electronic or paper copy (suitable for scanning) of QC documentation
associated with the work to document control within three business days of the
generation of such documents; and one electronic copy of all required submittals to
CM's document manager. All contractors shall maintain a fire-resistant file cabinet at the
construction site. The file shall contain all inspection reports, test records, contract
documents, project, and daily field reports. All records shall be available for inspection
and audit, at any time, by the CM and Domtar.
4.1.5 Monthly Progress Reports
During RA construction, Domtar will submit a monthly report to USEPA by the 10th day
of the following month in accordance with the requirements of the Consent Decree. This
report will describe the tasks initiated or completed during the reporting period.
Additional details regarding the monthly progress reports are provided in the CMP.
4.1.6 Quarterly Progress Reports
In compliance with the CD, Domtar currently submits one copy of a written quarterly
progress report by the 15th day of the following quarter when construction activities are
not active. The quarterly reports will be superseded by the monthly report during RA
activities and will resume once RA construction activities are complete.
Administration and Approval of Changes in Construction
During the course of performing the RA construction work, the RA Work Plan, Construction
Management Plan (CMP), CQAP, CHSP/CP, and drawings and specifications may need to be
updated or modified. Modifications to the RA documents would typically be to accommodate
new information or changes in conditions in Welch Creek. The process for approval of the
engineering changes will depend upon the significance of the requested modification. If the
proposed change is substantially different than the approved RD concepts and approach, the
USEPA will be notified first by telephone and then, as necessary in writing to review and
approve the suggested changes. However, prior to that notification, any engineering changes
will be approved through the sequence of events summarized below:
1. The RA contractor will submit requested engineering changes to these project documents
verbally and_ in writing by letter to the RA site manager.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP 20
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2. The RA site manager will review the proposed changes. If the RA site manager determines
that change is warranted, the proposed change will be signed and forwarded to the RA
project engineer for coordination and approval or disapproval.
' 3. Domtar or their representative will provide to the contractor verbal and written approval of
each change request. This engineering approval process is not expected to take more than
5 working days, and will be expedited as necessary in support of the RA construction
schedule '
4. Domtar will notify USEPA and NC DENR in writing of any substantial changes or
modifications to these project documents. The agency will be given the opportunity to
review and approve or disapprove these changes or modifications.
The RA contractor will also submit to the RA site manager shop drawings for any pre-fabricated
components, certificates of conformance for g·eosynthetic materials, test reports and as-built
drawings. Approved changes, substitutions and modifications to these project documents will
be incorporated into the record or "as-built" drawings that are submitted to USEPA with the
Final Construction Report.
4.3 Pre-final Inspection Report
Following the completion of the pre-final inspection,Domtar will submit a Pre-Final Inspection
Report. The report will include the following elements:
■ Punch list of outstanding or discrepant RA construction items, incomplete testing and
demonstration deficiencies.
■ Actions required for the resolution of each of the items identified in the punch list above.
■ Scheduled completion dates for each of the punch list items.
■ The scheduled date for final inspection.
4.4 Interim Remedial Action Report
Domtar will submit to USEP A an Interim RA Report no later than 60 days after the final
construction inspection. The Interim RA Report will be prepared by the RA project engineer
under the purview of the senior project oversight team. As a professional engineer registered in
the State of North Carolina, the RA project engineer will certify that the construction work of
the remedy has·been constructed in accordance with the approved RA documents.
The Interim RA Report will include the following elements:
■ Introduction
■ Operable unit background
RMT Nortlz Caroli11n, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
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■ Construction activities
■ Chronology of events, including projection of when clean-up levels for the wetlands and
groundwater will be achieved
■ Performance standards and CQA
a Final inspection and certifications
■ Operation and maintenance (O&M) activities
4.5 Problem/Deficiency Identification and Corrective Action
Problem or deficiency identification and corrective action will be documented in the daily
summary report when an activity is observed that does not meet the requirements set forth in
this plan and in the construction specifications. The summary report should clearly reference
other reports, photographs, or forms that contain data or observations leading to the
determination of a problem or deficiency. Problem/deficiency identification and corrective
action documentation may include the following information:
■ A description of the problem or deficiency, including reference to supplemental data or
observations responsible for determining the problem or deficiency.
■ Location o'f the problem or deficiency, including how and when the problem or deficiency
was discovered. In addition, an estimate of how long the problem or deficiency has
existed.
■ An opinion as to the probable cause of the problem or deficiency.
■ A recommended corrective action for resolving the problem or deficiency. If the corrective
action has already been implemented, then the observations and documentation to show
that the problem or deficiency has been resolved. If the problem or deficiency has not been
resolved by the end of the day upon which it was discovered, then the report will clearly
state that it is an unresolved problem or deficiency. Subsequent daily reports shall indicate
the status of problems or deficiencies until resolved.
If the problem or deficiency has not been resolved, the resident CQA representative and the
preparer will discuss the necessary corrective actions. The resident CQA representative will
work with the owner and construction contractor to implement actions as necessary to resolve
the problem or deficiency. A description of such problems or deficiencies and corrective actions
implemented shall be provided in the construction documentation report.
The resident CQA representative, working with the RA site manager and RA contractor, will
determine if the problem or deficiency is an indication of a situation that might require changes
to the plans and specifications and/or the CQAP. Revisions to the plans or specifications or the
CQAP must be approved by the RA project engineer and Domtar after consultation with
RMT North Carolina; Inc. I Domtar Paper Company, LLC
Remedial Action Work Pln11
Appendix D: CQAP ·
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USEPA. Documentation of the Department's concurrence and/or conditions regarding
proposed changes shall be incorporated into the construction documentation report.
4.6 Photographic and Video Documentation
Photographs and video footage will be taken to document observations, problems, deficiencies,
corrective actions, and work in progress. Photographs will be in digital format and will be filed
in chronological order in a permanent protective file by the resident CQA representative.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedinf Action Work Plan
Appendix D: CQAP . 23
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Section 5
References
RMT Nor.th Carolina, Inc. 2009. Remedial Design Field Sampling and Analysis Plan (FSP),
Welch Creek Operable Unit 4 (OU-4), Domtar Paper Company, LLC (Domtar) Facility,
Martin County, North Carolina. June 2009.
RMT North Carolina, Inc. 2009. Remedial Design Q11nlity Assurance Project Plan (QAPP),
Welch Creek Operable Unit 4 (OU-4), Domtar Paper Company, LLC (Domtar) Facility,
Martin County, North Carolina. June 2009.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Pla11
Appendix D: CQAP 24
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Attachment D-1
Soil Sampling Standard Operating Procedures
'
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP '
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Standard Operating Procedure
Surficial/Wetland Soil Sampling
This standard'operating procedure (SOP) is applicable to the collection of representative soil
and/or wetland soil samples. The methodology is generic in nature and may be modified in
whole or part to meet the handling and analytical requirements of the contaminants of concern,
as well as the ~onstraints presented by site conditions and equipment limitations. Modifications
of sampling methodologies will be documented in the appropriate field logbook and discussed
in reports summarizing field activities and analytical results. For the purposes of this
procedure, soils are those mineral and organic materials not submerged in water for an
extended period of time sufficient to support aquatic life.
Equipment/Apparatus
Equipment ne~ded for collection of soil samples may include:
■ Maps/plot plan
' ■ Safety equipment
■ CPS
■ Tape meas_ure
■ Survey stakes, flags,
■ Digital camera
■ Stainless steel, plastic, or other appropriate composition bucket
■ 4-oz., 8-oz.; and one-quart wide mouth jars w/Teflon® lined lids
■ Ziploc plastic bags
■ Logbook
■ Sample jar labels
■ Chain-of-Custody records, field data sheets
■ Cooler(s)
■ Ice
■ Decontamination supplies/equipment
■ Spade or shovel
■ Spatula
■ Scoop
■ Trowel
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Pinn
Appendix D: CQAP
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Decontamination Procedures
Decontamination Prior to Sampling
Proper decontamination of sampling equipment is essential to minimize the possibility
of cross-contamination of samples. Nondedicated equipment used for sampling various
environmental media (soil, groundwater, surface water, etc.) will be cleaned before its
initial use in the field and again before use at each subsequent sampling site.
All no~dedicated sampling equipment will be new, or will be decontaminated prior to
its initial use on-site. Decontamination procedures will include the following steps:
1. Wash the equipment in a nonphosphate detergent.
2. Rinse with potable tap water.
3. Rinse with deionized (DI) or distilled organic-free water.
To the ~xtent practicable, single-use sampling equipment and materials will be used for
the collection of all environmental samples. The materials used will be new and clean,
and will be placed in plastic for transport to the site. Once used, this equipment will be
placed in plastic bags and managed as investigation-derived waste material.
In-Field Sampling Decontamination Procedures
As described above, this sampling protocol describes multiple methods for soil/wetland
soil sample collection. The decontamination procedures described below will be relied
upon in the field as appropriate for equipment decontamination.
' Nondedicated equipment that is to be used at additional locations at the site will be
field-decontaminated between sampling locations. Details regarding the
decontamination of field equipment are included in the section below.
The field decontamination of sampling equipment will take place at the sampling
location,-All decontamination water will be contained in 5-gallon buckets and
transported to the designated decontamination area for collection.
The field equipment blanks will be collected in accordance with USEPA sampling
methodology.
Rlvf.T North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP ·
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Sample Collection
Sampling Surface Soil/ Wetland Soil with a Trowel or Scoop
The sampling method is accomplished by scooping the soil sample along the top
6 inches of the surface with a stainless steel scoop. Accurate, representative samples can
be collected with this procedure depending on the care and precision demonstrated by
the sample team member. Once collected, the sample is placed in a glass or stainless still
bowl and homogenized.
A stainless steel scoop or lab spoon will suffice in most applications. Follow these
procedures to collect soil samples with a stainless steel scoop:
Using a precleaned stainless steel scoop, remove the desired thickness of soil from the
sampli~g area.
Transfer the sample into an appropriate sample or homogenization container.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plm1
Appendix D: CQAP .
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Attachment D-2
Daily Cost and Schedule Report
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP
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I RMT Daily Cost and Schedule Report
PROJECT NAME: DATE: WORK START TIME: WORK END TIME:
PROJECT NUMBER: WEATHER: DAY s M T w TH F
CLIENT NAME: TEMP. WIND: . PRECIPITATION:
. CONTRACTOR NAME: REPORT PREPARED BY: PROJECT MANAGER:
Status of Project in Relation to Schedule:
Contractor's Work Force (include subcontractors):
,
Equipment at Site (identify in use or idled):
Materials or Equipment Delivered:
Description of Work in Progress (chronological format including materials and equipment installed):
Notices to Contractor:
Requests from Contractor:
Testing Performed/Samples Collected:
Field Problems and Non-conforming Materials or Work:
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Remedinl Action Work Plan
Appendix D: CQAP
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RMT
Health and Safety Issues:
Exposure to Hazardous Materials:
PPE Utilized:
Results of. Monitoring Tests:
Construction Safety Issues:
Additional Comments:
Daily Communications:
Name:
Subject/Comments:
Action (if necessary):
Name:
Subject/Comments:
Action (if necessary):
Name:
Subject/Comments:
Action (if necessary):
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix D: CQAP
I:\ WPGVL \ P{TI \ 00625 \08\ OOI \ R006250SOOJ-00l D. DOCX
Daily Cost and Schedule Report
Time:
Time:
Time:
Revised November 2010
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Name:
Subject/Comments:
Action (if necessary):
RMT North C11roli11a, Inc. I Domtar Paper Comp1111y, LLC
Remedial Action Work Plan
Appendix D: CQAP
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Daily Cost and Schedule Report
Time:
Revised November 2010
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Appendix E
Construction Health and Safety Plan/
Contingency Plan
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
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........
RMT
~
•ENVIRONMENT• ENERGY• ENGINEERING
Remedial Action Work Plan
Appendix E: Construction Health and
Safety Plan/Contingency Plan (CHSP/CP)
Domtar Paper Company, LLC
Welch Creek Area OU-4 Plymouth, Martin County, North Carolina
Revised November 2010
RlvlT North Carolina, lllc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP
/:\ WPGVL \PJTJ \00625\08\001 \R0062508001-001£.DOCX
© 2010 RMT, foe.
A/I Rights Reserved
30 Patewood Drive, Suite 100 • Greenville, SC 29615-3535 • [phone] • [phone] FAX• www.rmtinc.com
CREATING BALANCE"'
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Table of Contents
Preface ......................................................................................................................................................... iii
1. Introduction ...................................................................................................................................... 1
1.1 Background ............................................................................................................................ 1
1.2 Welch Creek Area Setting .................................................................................................... 1
1.3 Purpose ................................................................................................................................... 1
1.4 Scope ....................................................................................................................................... 2
1.5 Applicability .......................................................................................................................... 3
1.6 Responsibilities ...................................................................................................................... 3
1.7 Plan Components .................................................................................................................. 4
2. Health and Safety Training and Medical Surveillance ............................................................... 6
2.1 Health and Safety Training .................................................................................................. 6
2.2 Medical Surveillance ............................................................................................................. 7
3. Hazard Evaluation ........................................................................................................................... 8
3.1 Welch Creek Area Chemical Hazards ................................................................................ 8
3.2 Physical Hazards ................................................................................................................. 10
3.2.1 Equipment ............................................................................................................... 10
3.2.2 Traffic ....................................................................................................................... 11
3.2.3 Utilities ..................................................................................................................... 11
3.2.4 Overhead Hazards ................................................................................................. 11
3.2.5 Field Equipment ..................................................................................................... 11
3.2.6 Snakes, Ticks, Other Biting Insects ...................................................................... 11
3.2.7 Vegetation ............................................................................................................... 12
3.2.8 Confined Spaces ..................................................................................................... 12
3.2.9 On-Water Activities ............................................................................................... 12
3.2.10 Evening and Night Work ...................................................................................... 12
3.2.11 Material Storage and Handling ............................................................................ 13
3.2.12 Noise ........................................................................................................................ 13
3.2.13 Temperature Extremes .......................................................................................... 13
3.2.14 Severe Weather ....................................................................................................... 15
3.3 Task-Specific Hazard Table ............................................................................................... 15
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Remedial Action Work Plan
Appendix E: CHSPICP i
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4. Site Control Measures ................................................................................................................... 17
4.1 Site Access ............................... : ............................................................................................ 17
4.2 Other Site PersonnelNisitors ............................................................................................. 17
4.3 Personnel Decontamination Procedures .......................................................................... 18
5. Personal Protective Equipment ................................................................................................... 20
5.1 Levels of Protection ............................................................................................................. 20
5.2 Changes in Levels of Protection ........................................................................................ 21
5.3 Buddy System ...................................................................................................................... 21
5.4 Work Limitations ................................................................................................................ 21
6. Contingency Plan ........................................................................................................................... 22
6.1 Emergency Contacts ........................................................................................................... 22
6.2 Emergency Procedures ....................................................................................................... 23
6.3 Medical Emergency ............................................................................................................ 23
6.4 Emergency Equipment ....................................................................................................... 23
6.5 Emergency Route ................................................................................................................ 24
7. Record Keeping .............................................................................................................................. 25
7.1 Training Attendance ........................................................................................................... 25
7.2 Respirator Fit Test ............................................................................................................... 25
7.3 Medical Certification .......................................................................................................... 25
List of Tables
Table E-1
Table E-2
List of Figures
Figure E-1
List of Attachments
Attachment E-1
Attachment E-2
Attachment E-3
Constituents of Potential Concern and Exposure Limits at Welch Creek ........ 9
Emergency Contacts .............................................................................................. 22
Site Location Map ..................................................................................................... 5
Domtar Contractor Safety, Environmental, and Security Documents
Spill Contingency Plan
Hospital Emergency Route Map
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP ii
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Preface
This Construction Health and Safety Plan/Contingency Plan (CHSP/CP) is part of the Remedial
Action (RA) documentation for the Domtar Paper Company, LLC (Domtar) Plymouth, Martin
County, North Carolina, facility, developed in response to United States Environmental
Protection Agency (USEPA) Consent Order Docket No. 98-10-C issued by the USEPA on
March 24, 1998. It has been prepared for use by RMT North Carolina, Inc. (RMT) employees to
meet the requirements of Occupational Health and Safety Administration (OSHA) Standards
under 29 CFR 1910 and 1926 and related guidance. This document will be provided to all RMT
employees and subcontractors on site and its contents will be considered the minimum health
and safety requirements for performing work associated with the sampling or construction
activities being conducted as part of the RA.
RMT North Caroli11a, Inc. I Domtar Paper Company, LLC
Remedial Action Work Pla11
Appendix E: C/-ISPICP iii
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1.1 Background
Section 1
Introduction
The Domtar Plymouth Mill is an active wood and paper products manufacturing facility located
on State Road 1565 in Martin County, North Carolina (Figure E-1). Domtar has been the
owner/operator of this facility since 2007, when the company purchased the facility from
Weyerhaeuser Company (Weyerhaeuser). Prior to Weyerhaeuser, the facility was owned and
operated by Kieckhefer-Eddy Company. The Kieckhefer-Eddy Company, which began
operations at the facility in 1937, also manufactured pulp and container-board products.
Several potable water production wells are maintained on the site and process and sanitary
wastewater is discharged to a National Pollutant Discharge Elimination System
(NPDES)-permitted wastewater treatment plant. Solid waste is recycled or disposed of at
appropriately permitted landfill sites either on or off the site.
The facility is located about 1.5 miles west of the town of Plymouth. The nearest residence to
the facility is about 1 mile to the south. The facility is generally bounded on the north by the
Roanoke River, on the east by woodlands, on the south by woodlands and agricultural fields,
and on the west by wooded wetlands and Highland Prong of Warren Neck Creek. Cypress,
black gum, sweet gum, and wax· myrtle are the predominant trees generally c,,bserved in the
wetland and flood plain areas.
1.2 Welch Creek Area Setting
The Welch Creek Area is defined to extend approximately 4.5 miles from the Highway 64
bridge overpass to the confluence with the Roanoke River. The adjacent wetlands are
occasionally submerged depending upon seasonal and weather conditions. Water levels in
Welch Creek and the Roanoke River are primarily controlled by the discharge from the
upstream Kerr Lake dam and wind tides. Over the study area, Domtar owns the land on all of
the east side and most of the west side of Welch Creek.
1.3 Purpose
This site-specific CHSP/CP has been developed to provide guidelines and procedures intended
to protect the health and safety of RMT personnel performing site work associated with
sampling or construction. These site activities are generally defined by the RA Work Plan and
are described in detail in the final design. The CHSP/CP will be reviewed with RMT field
personnel before construction are begun. Subcontractors will be required to develop and
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Pla11
Appendix E: CHSPICP
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implement their own CHSP/CP applicable to their work on the site in accordance with OSHA
requirements, Domtar contractor requirements, and this CHSP/CP.
Specific questions regarding the HSP should be addressed to the RMT Health and Safety
Coordinator (HSC). A copy of the CHSP/CP will be available for review by site personnel and
authorized visitors on request from the site RMT Health and Safety Representative (HSR). A
copy of this CHSP/CP will be provided to contractor/subcontractor personnel for their
information and review prior to beginning site work. The Domtar Plymouth Mill Safety,
Environmental, Security, and Checklists for consultants and contractors have been included as
Attachment E-1 to this CHSP/CP. A Spill Contingency Plan has been included as Attachment E-
2 to outline procedures that would be followed in the event of an accidental spill or release. The
CHSP/CP will be reviewed if site conditions change by the HSR and updated as necessary. The
CHSP/CP will also be updated to reflect new or additional site information when this
information becomes available. All on-site RMT personnel will be required to acknowledge the
changes to the CHSP/CP by re-signing the on-site sign-in sheet.
1.4 Scope
The CHSP/CP is aimed specifically at protecting RMT site workers from reasonably foreseeable
health and safety hazards arising from the materials found in the Welch Creek Area at the
Domtar Plymouth facility. The procedures presented have been identified based on the
analytical results from sediment, wetland soil, and surface water. This CHSP/CP meets the
requirements of the Administrative Order by Consent (CD), US EPA Docket No. 98-10-C.
The CHSP/CP has been developed in conformance with the Domtar/Martin County Safety,
Environmental, Security and Checklists (see Attachment E-1), various additional Domtar
requirements and the following requirements and guidance:
■ OSHA Standards, 29 CFR 1910 and 1926, including 29 CFR 1910.120
■ National Institute for Occupational Safety and Health (NIOSH)/OSHA/United States Coast
Guard (USCG)/USEPA, Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities, October 1985
■ USEPA, Standard Operating Safety Guides, June 1992
The CHSP/CP has been developed from technical information available as of July 2010 and is
subject to revision as new data and information about the site and site activities become
available. The plan shall cover employees performing site fieldwork associated with the
Remedial Design (RD). These activities include, but are not limited to, the following:
■ Site clearing;
RMT North Carolina, Inc. l Domtar Paper Company, LLC
Remedial Action Work Pla11
Appendix £: CHSP/CP
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2
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■ On-water activities (e.g., sampling and monitoring); and
■ Other construction activities, using backhoes and/or trackhoes.
1.5 Applicability
The CHSP/CP applies to RMT personnel who participate in RD field activities. It contains the
minimum requirements necessary to protect on-site personnel from physical, chemical, and
other hazards particular to the Welch Creek Area that have been identified as of the date of this
CHSP/CP. More stringent practices than those outlined in this CHSP/CP may be used, but this
CHSP/CP specifies the minimum practices to which personnel must adhere. RMT personnel are
also required to comply with the Domtar/Martin County Safety, Environmental, Security, and
Checklists for consultants and contractors while performing work related to this project.
1.6 Responsibilities
The specific duties of those RMT personnel who are responsible for the CHSP/CP are as follows:
■ Project Manager (PM) -Provides an overview of site facilities, equipment, and personnel so
that site activities can be conducted in a safe and efficient manner.
■ HSC-Develops CHSP/CP in conjunction with PM and Site HSR; reviews plan periodically
and revises plan when new information becomes available; offers technical support to site
HSR on health and safety issues; and audits work activities for adherence to CHSP/CP.
■ Site HSR -Implements the CHSP/CP; advises field team on aspects of on-site health and
safety; selects and reviews protective clothing and equipment with input from HSC;
monitors the field team members for signs of heat or cold stress; monitors on-site hazards
and conditions; knows emergency procedures, evacuation routes, and emergency
telephone numbers; and notifies public emergency officials when necessary. The HSR has
the authority to stop work, at any time, if necessary.
■ On-site Coordinator (OSC) -The On-site Coordinator will be responsible for coordinating
the field activities. The OSCwill ensure that field quality assurance/quality control
(QA/QC) procedures are followed, including communicating applicable QC procedures to
field staff and reviewing field reports to ensure compliance. The OSC will also be
responsible for conducting field audits and for initiating corrective action on problems
encountered in the field.
■ Other Site Personnel -Responsible for adhering to the provisions of the site CHSP/CP and
all OSHA requirements specified in the CHSP/CP.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
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Appendix E: CHSP/CP
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1.7 Plan Components
The CHSP/CP contains information addressing the following areas:
■ Health and safety training requirements;
■ Medical surveillance requirements;
■ Chemical and physical hazard evaluations and control measures;
■ Air monitoring parameters and equipment;
■ Delineation of work zones;
■ Decontamination procedures;
■ Personal protective equipment (PPE) and levels of protection;
■ Work limitations;
■ contingency planning; and
■ Maintenance or records.
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Appendix£: CHSPICP
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2,000 _6
FEEV
I. WE1\NII lYl'l Do\TA l'llOII NOIITN CMCU1A COASTAi.
11E010N EVM.UATION OF wrn.NC> SIONFICNa (NC, -~,--
IXlMT AR (FORMERLY WEYERHAEUSER)
MARTIN COUNTY, NORTH CAROLINA WELCH CREEK· OU_.
SITE LOCATION MAP
...,..,
AS NOTED .... ..,
DRAFT FIGURE E·1
,o~a.....~,oo
~SCffllSI~
,e,,21r,cmr>p1tot,e
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Section 2
Health and Safety Training
and Medical Surveillance
In order to meet OSHA requirements, all field personnel will participate in health and safety
training and the required medical surveillance program.
2.1 Health and Safety Training
Prior to beginning field activities, personnel conducting or observing on-site activities will be
certified in the following health and safety training sessions:
■ Site-Specific CHSP/CP Review -During this session, this CHSP/CP will be reviewed, and
any special procedures will be outlined.
■ Health and Safety for Hazardous Waste Site Activities (OSHA 40-Hour hazardous waste
operations [HAZWOPER]) -This one-time 40-hour training session includes the following
elements: regulations, industrial hygiene, toxicology, respiratory protection, physical
hazards, noise, temperature extremes, PPE, medical surveillance, air monitoring
equipment, site control and decontamination, standard operating procedures (SOPs), and
confined space entry.
■ 8-hour Health and Safety Refresher Training (OSHA 8-Hour HAZWOPER Refresher) -
This training is required annually after the initial 40-hour training. It serves to review the
key aspects of the 40-hour training.
■ Mobile Equipment-Prior to operating mobile equipment including, but not limited to,
cranes and track hoes, operators must have received prior certification training on the
equipment they will be operating.
As appropriate, training will also be provided to additional field personnel so that backup
personnel can be assigned to perform RA activities at the site as the need arises. Documentation
of attendance in training sessions shall be maintained by the RMT human resources department
and the HSC. In addition, copies of this documentation will be maintained on the site by the
HSR. The training requirements in OSHA Standard 29 CFR 1910.120 are to be followed, at a
minimum, by all personnel that enter the site.
Domtar staff will provide a site-specific safety orientation for consultants and contractors that
will review Domtar safety and environmental requirements and procedures prior to the start of
the project field activities. A visitor safety orientation training card will be issued to all
consultants and contractors after mandatory orientation.
RMT North Caroli11a, Inc. I Domtar Paper Compa11y, LLC
Remedial Action Work Plan
Appendix E: CHSl'!CP
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2.2 Medical Surveillance
RMT field personnel assigned to the site will be placed in a medical surveillance program prior
to performing their first field assignment. Medical surveillance requirements contained in
OSHA Standards 29 CFR 1910.134 and 29 CFR 1910.120 will be followed, at a minimum, for
RMT personnel who meet the requirements of the rule and actively perform extensive field
sampling activities at the site. This surveillance will include an initial and annual medical
examination.
The basic protocol for the medical examination includes the following:
■ Health history ■ Urinalysis
■ Vital signs and physical examination screen ■ Blood chemistry screen
■ Pulmonary function test ■ Vision test
■ Hematology survey ■ Hearing test
Field personnel assigned to conduct these investigations will have passed the required medical
examination as determined by the occupational health physician before entering the project site.
T~e medical records of personnel are managed through an outside health resources
management company, which follows all applicable state and federal regulations. Personnel
would be contacted directly by the management company regarding medical screening results.
RMT Nortl, Caroli11n, Inc. I Domtar Paper Company, LLC
Remedial Actio11 Work Plan
Appendix £: CHSPICP
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7
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Section 3
. Hazard Evaluation
This section describes the possible hazards associated with each source area based upon
information that is available. The hazard evaluation has been prepared to meet the
requirements of OSHA Standard 1910.120 and as such includes information regarding chemical
hazards, physical hazards, and any other relevant site hazards.
Information regarding potential health effects associated with the site-related constituents is
based upon maximum estimates of constituent concentrations and exposure parameters
designed to err on the side of overestimating the potential occupationally related risks
associated with the Welch Creek Area at the Domtar Plymouth facility.
3.1 Welch Creek Area Chemical Hazards
The chemical constituents in the Welch Creek source area have been identified as follows:
2,3,7,8-tetrach I orod ibenzo-p-di oxin/2,3, 7,8-tetrachl orod ibenzo-fu ran (2,3, 7,8-TCD D /TCD F),
mercury, chromium, copper, nickel, and zinc. Table E-1 summarizes the media, maximum
known concentration, and associated Threshold Limit Values (TL Vs) (as Time-Weighted
Average [TWA]), Permissible Exposure Limits (PELs) (as both TWA and ceiling), and
Immediately Dangerous to Life or Health (IDLH) concentrations, where applicable.
The primary exposure routes for the chemicals shown in Table E-1 are as follows:
■ Inhalation of vapors and affected particulate matter;
■ Skin contact with affected soil, sediment, water; or investigative derived materials (IDW);
and
■ Accidental ingestion from contact with affected material.
Mercury may cause skin and eye irritation upon contact and is also absorbed into the body
system upon contact. Potential health effects associated with chronic overexposure (through
inhalation, skin absorption; and ingestion) may include the following:
■ Coughing
■ Irritability
■ Skin Rashes
■ Memory Loss
■ Chest Pain
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Remedial Action Work Plan
Appendix E: CHSPICP
/: \ WPGVl. \ PJTI \ 00625 \ 08 \ 001 \ R006250800I-001 £.DOCX
■ Insomnia
■ Indecision
■ Fatigue
■ Weakness
■ Stomach Upset
8
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■
■
Pneumonitis
Tremors
■ Weight Loss
2,3,7,8 TCDD/TCDF may produce health effects upon inhalation, skin absorption, or ingestion
(Agency for Toxic Substances and Disease Registry [ATSDRl). Health effects associated with
overexposure potentially include:
■ Anorexia;
■ Liver damage;
■ Chloracne;
■ Wasting syndrome (ATSDR);
■ Gastric ulcers; and
■ Vascular lesions.
Some of the dioxin isomers are also classified as carcinogens and teratogens (International
Agency for Research on Cancer [!ARC]).
At this time, safe exposure levels for 2,3,7,8 TCDD/TCDF have not been established as noted in
Table E-1. However, all measured concentrations of this COC in sediment is below the 5 to
20 ppb clean-up levels in soil for an industrial or commercial setting defined in the Office and
Solid Water and Emergency Response (OSWER) Directive entitled Approach for Addressing
Dioxin in Soil at RCRA and CERCLA Sites -OSWER Directive No. 9200.4-26, USEPA 1998). In
the approved risk assessment incorporated into the Remedial Investigation (RI) Report, the
highest potential excess risk calculated was for aquatic scientists and recreational fishermen and
the result was within USEPA's acceptable range of 1 x 104 to 1 x lQ-6_ However, to further
protect the team members involved in performing work on Welch Creek, additional precautions
are outlined in this HSP.
Table E-1
Constituents of Potential Concern and Exposure Limits at Welch Creek
SAMPLE OBSERVED
CHEMICAL CONCENTRATION MATRIX RANGES
Native Sediment ND to 59 ng/kg
2,3,7,8-TCDD('l Wastewater Solids 3.0 to 3,400 ng/kg
Surface Water ND to 0.63 ng/L
Native Sediment ND to 400 ng/kg
2,3,7,8-TCDF('l Wastewater Solids 12.0 to 22,500 ng/kg
Surface Water ND to 3.56 ng/L
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Remedial Action Work Plan
Appendix E: CHSPICP 9
/:\ WPGVL \ PfTI \00625\08\001 \R006l!i08001-()01 F,,DOCX
2001 TL\J®l1l PEL11l IDLH11l
N.E. N.E. N.E.
N.E. N.E. N.E.
Revised November 2010
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Table E-1
Constituents of Potential Concern and Exposure Limits at Welch Creek
OBSERVED SAMPLE CHEMICAL MATRIX CONCENTRATION 2001 TLlf"'1 PEL(1l IDLH11l
RANGES
Native Sediment ND to 0.19 mg/kg 0.025 mg/m3 0.1 mg/m3
Mercury Wastewater Solids 0.66 to 12.9 mg/kg to TWA to ceiling 10 mg/m3
Surface Water ND to 0.00083 mg/L
Native Sediment 3.1 to 56 mg/kg 0.5 mg/m3 1.0 mg/m3
Chromium Wastewater Solids 35.6 to 2,740 mg/kg to TWA to TWA 250 mg/m3
Copper
Nickel
Zinc
,,,
'"
'"
None
mg/m3
ppm
ng/kg
3.2
Surface Water ND to 0.060 mg/L
Native Sediment 0.71 to31.2mg/kg 1.0 mg/m3 1.0 mg/m3
Wastewater Solids 5.4 to 95.1 mg/kg to TWA to TWA 100 mg/m3
Surface Water ND
Native Sediment ND to 22.6 mg/kg 1.0 mg/m3 1.0 mg/m3
Wastewater Solids 4.0 to 63.8 mg/kg to TWA to TWA 10 mg/m3
Surface Water ND
Native Sediment 2.9 to 125 mg/kg 10.0 mg/m3 15.0 mg/m3
Wastewater Solids 35.3 to 399 mg/kg to TWA to TWA 500 mg/m3
Surface Water ND
These values are inhalation exposure limits for sediment, solids, and water sources.
At this time, safe exposure levels have not been established and a standard method for sampling and analysis of airborne
dioxin and furan isomers has not been developed. Some of the dioxin isomers are also classified as carcinogens and
teratogens (IARC).
RTE ls the allowed limit to particulate matter exposure (i.e., mini•ram reading) for each of the metals. The calculation of the
RTE takes into account the maximum concentration of metals in the soil (maximum constituent of concern [COC] concentration).
No exposure limit established
milligrams per cubic meter
parts per million
nanogram/ki1ogram
Physical Hazards
3.2.1 Equipment
Equipment, such as heavy construction equipment, chainsaws, trucks, track hoes, and
backhoes, will be used on the site. The person controlling the equipment is responsible
for maintaining the equipment in good working order and operating it safely. Moving
equipment must have audible backup alarms in working condition. RMT personnel will
not work near equipment or conditions they judge to be unsafe because of deterioration,
missing parts, obvious defects, or improper operation. If it is necessary to operate
equipment in areas with steep embankments or unstable ground, the subcontractor will
make provisions for the safety of RMT personnel in the area. RMT staff will:
maintain proper distance from equipment, and in the line-of-sight of the operator;
and
RMT Nor/II Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP 10
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understand and review hand-signals, and wear an orange safety vest, if necessary.
3.2.2 Traffic
Portions of the Welch Creek Area will be a contractor lay down and storage area with
frequent vehicular traffic. Warning tape and safety vests will be used as necessary to
provide visibility and control within the work area.
3.2.3 Utilities
Although there are no known utilities present near the boat ramp area of Welch Creek,
equipment may be mobilized to the site near utilities, so care will be taken to identify
areas with both overhead and underground utilities that could be damaged by site
activities. Therefore, overhead or underground utilities, such as electric, gas, telephone,
water, sewer, or drainage, in the project storage and access areas will be located by
Domtar representatives before the start of operations that require subsurface work or the
moving and setup of heavy equipment by the contractor. Information regarding the
location of utilities will be kept at the field site for reference.
3.2.4 Overhead Hazards
Pay attention to overhead equipment, piping, falling trees, and structures. A hard hat
must be worn at all times when overhead hazards are present on site.
3.2.5 Field Equipment
If field equipment is heavy or awkward to carry, work teams or carts will be used to
help move it around the site.
3.2.6 Snakes, Ticks, Other Biting Insects
Welch Creek is bordered on both sides by wetlands and contains thick vegetation. Due
to these site features, snakes may be encountered at the work site. For protection against
snakebites, personnel will be provided with snake boots or snake leggings, as
appropriate.
Ticks may also be encountered at the site during warm weather. An appropriate tick
repellent will be available on the site and clothing will be worn to limit exposed skin. As
appropriate, workers should check for ticks at the end of each day. Additionally, flies are
abundant in the area so a broad based insect repellent with DEET will also be available
on the site.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP 11
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Site workers with know!"\ allergies to insect bites should carry their own medication. It is
also a good idea to inform fellow workers of the allergy, in case of emergencies.
3.2.7 Vegetation
Welch Creek is bordered on both sides by wetlands and contains thick vegetation.
Vegetation, such as poison ivy, poison oak, and poison sumac, which can cause severe
skin irritation, may be present. For protection against contact with these plants, clothing
that limits skin exposure will be worn, and contact with the vegetation will be avoided.
3.2.8 Confined Spaces
It is not anticipated that confined space entry will be required for the RD activities. If
confined space entry is required, the HSC will prepare a written entry plan and permit.
Personnel shall not enter confined spaces without proper training and equipment.
Oxygen deficiency, explosive atmospheres, and elevated concentrations of hazardous
airborne contaminants m~y be encountered in confined spaces.
3.2.9 On-Water Activities
On water activities include a bathymetry survey, sediment sampling, surveying, and
visual observations. Each watercraft must be equipped with one USCG-approved
personal flotation device (PFD) for each occupant, and one USCG-approved throwable
device. A PFD will be worn whenever personnel are onboard a watercraft or working
above bodies of water where a drowning hazard exists. All watercraft should be
equipped with adequate safety equipment to meet USCG requirements and any hazards
that may be encountered 'during normal operations. With respect to capping activities,
travel cables and silt curtains will be properly marked, and will display appropriate
lights at night and when visibility is restricted. The on-water activity items were
adapted from the Bureau.of Remediations Section 28 safety and health standards for
watercraft and dredging.!
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Communication between'land and on-water equipment will be conducted using hand
held walkie-talkies, cell p11ones, or a two way radio and will be maintained during field
activities that require specific task work but not for intermittent boat transport (i.e.,
shuttling passengers between the barge and land are not covered by this requirement).
3.2.10 Evening and Night Work
Work may be required during the evening and night hours. This work shall be limited
by the availability and the quality of artificial lighting. Care should also be taken to
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Appendix £: CHSPICP 12
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avoid slip, trip, and fall.hazards that are not as easy to identify during low light
conditions.
3.2.11 Material Storage and Handling
The following procedures shall be followed when handling and storing materials:
Move containers and heavy material only with the proper equipment.
Secure them to prevent dropping, falling, or loss of control during transport.
Stay clear of materi~l handling operations, especially near slopes.
Do not stand down the slope from equipment, supplies, or materials being moved
above on the slope, or being deployed on the slope.
Avoid working near, or do not stand adjacent to materials stacked up, such as pipes,
geosynthetic rolls, etc., or in the deployment area since stored material may be a
falling or a crush hazard.
3.2.12 Noise
' Hearing protection must be worn by personnel when they are exposed to noise levels
above 84 decibels (dBA). A "rule of thumb" to follow is for personnel to wear hearing
protection if they must rnise their voice to be heard at arm's length.
3.2.13 Temperature Extremes
'
The site activities are expected to occur from summ'er 2010 through winter 2011. The
time frame of the project will potentially expose site personnel to both heat stress and
cold stress. However, heat stress problems are more prominent in North Carolina.
Heat Stress
The USEPA Standard Operating Safety Guides (1992) recommend that a heat
stress monitoring program be implemented when employees are wearing
impervious clothing and ambient temperatures are 70°F or above. The
frequency of monitoring should increase as temperatures increase, and
employees should be monitored after each 2-hour work period when ambient
temperatures exceed 85°F. The following paragraph describes the monitoring
program recommended by the USEPA that will be used by personnel when
ambient temperah.1res exceed 70°F.
Heart rate (HR) should be measured at the radial pulse for 30 seconds as early
as possible in the ~esting period. The HR at the beginning of the rest period
RMT North Carolina, Inc. I Domtar Paper COmpany, LLC
Remedial Action Work Plan ·
Appendix E: CHSPICP 13
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should not exce~d 110 beats per minute. If the HR is higher, the next work
period should be shortened by 33 percent while the length of the rest period
stays the same. If the pulse rate is 110 beats per minute at the beginning of the
next rest period,, the following work cycle should be shortened by another
33 percent. '
All personnel must be instructed on the symptoms of the main heat-related
disorders and how to recognize these disorders. These disorders and their
symptoms are outlined below:
Heat Rash: Decreased ability to tolerate heat, chafing clothes, raised red
vesicles on affected areas.
Heat Cra111ps: Muscle spasms and pain in the extremities and abdomen.
Heat Ex'1a11s\ion: Shallow breathing; pale, cool, moist, clammy skin; profuse
sweating; dizziness and lassitude; and fainting. Medical attention is
warranted.
Heat Stroke: IRed, hot, dry skin; no perspiration; nausea; dizziness and
confusion; strong rapid pulse; coma. This condition is life-threatening, and
immediate medical assistance 11111st be obtained.
Because it may not always be feasible to follow the work/rest regimen outlined
above, site personnel should take a break every 2 hours, at a minimum, and
drink adequate amounts of nonalcoholic fluids. An average of 1 quart of liquid
per hour is recommended.
Cold Stress
Site personnel will be instructed on the signs and symptoms of cold stress and
on the methods qf preventing cold-related disorders. In general, the two major
cold-related disorders are frostbite and hypothermia. The general symptoms
are outlined below.
Frostbite -Sudden blanching of the skin, progressing to skin with a waxy or
white appearance that is firm to the touch, while the tissue beneath the skin
is resilient.
Hypothermia -Hypothermia may be of greatest concern in the winter
months should personnel become wet from falling into water. The
symptoms of systemic hypothermia are usually exhibited in the following
stages:
• Shivering;
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Appendix E: CHSP/CP 14
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• Apathy, listlessness, drowsiness, and (sometimes) rapid cooling of the
body to less than 95'F;
• Unconsciousness, glassy stare, slow pulse, and slow respiratory rate;
and
• Freezing of the extremities .
Each person will watch for personal signs of frostbite and hypothermia as well
as signs in team members. If temperatures drop below 20'F, as measured by
the wind chill index, thermal clothing shall be required.
3.2.14 Severe Weather
Work may be suspended if dangerous weather conditions (lightning, tornadoes,
hurricanes, high winds, heavy rain, freezing rain, etc.) occur. Be aware of changing
weather conditions and b~ prepared to take shelter as necessary. Potential shelters will
be identified prior to beginning work.
3.3 Task-Specific Hazard ~able
TASK POTENTIAL HAZARD
Preparing the Site
Install silt fence Working over/near water
Remove trees and shrubs Laceration from sharp tools
Slip/trip/fall
Vehicle arid pedestrian
interface
Operate earthmoving Vehicle and pedestrian
equipment to strip topsoil, interface
grade exposed sub-base,
place and compact
crushed stone
Construct the working Vehicle and pedestrian
platform interface
Contact underground
utilities
Working on Barge Working over/near water
Slip/trip/fail -water on
barge
RMT North Carolina, Inc. I Domtar Paper <:;ompany, LLC
Remedial Action Work Pla11
Appendix E: CHSPICP
/:\ WPGVL \PJTI \00625\08\001 \R0062508001-001 E.DOCX
SAFETY CONTROLS
Wear USCG-approved life jacket or buoyant work vest
while working near water,
Ring buoys with at least 90 feet of line, and at least one
lifesaving skiff will be available.
Level D PPE including cut resistant gloves
Awareness training and safety shoes
Awareness training, high-visibility vests
Awareness training, maintain safe distance from
machinery, high visibility vests
High-visibility vests, maintain safe distance from
machinery
Excavation permit
Wear USCG-approved life jacket or buoyant work vest or
ring buoys with at least 90 feet of line and at least one
lifesaving skiff will be available.
Maintain dry floor as much as practical
15
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TASK POTENTIAL HAZARD
Barge M9vement
Install turbidity curtain Working Over/near water
and cables,
'
Construction work Public access to
construction site
Cover Construction
Deliver cap materials Vehicle a'nd pedestrian
interface 1
Engulfment from
unexpected collapse of
stored materials.
Use crane to transfer Crane failure (too much
cover materials from land load) !
to spreader on barge and Crush hazard (contact deposit in river. person with crane/load)
Operate spreader to Entanglement with moving
apply capping material parts of spreader
Struck by airborne material
Visual inspection, Working over/near water
documentation, and water
and sediment sampling
Water quality monitoring Working over/near water
.
Site Restoration
'
Detach the turbidity Working (?ver/near water
curtain and transfer to ' hoppers for disposal I
Contact sediments
Remove silt fences, Final EntanglerTlent with moving
site grading and seeding parts of spreader
Struck by:airborne material
' RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP
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SAFETY CONTROLS
Barges are extremely heavy and while moving possess a
significant quantity of momentum and may be difficult to
stop. Be especially weary of potential pinch points.
Wear USCG-approved life jacket or buoyant work vest or
ring buoys with at least 90 feet of line and at least one
lifesaving skiff will be available.
Perimeter fence with gated access
Control pedestrian access by loading area, high-visibility
vests, awareness training
Store cover material in a manner to prevent accidental
collapse.
Crane operator certification
Limited access zone
Machine guarding, employee training
Spreader operators training, safety glasses, high-visibility
vests, hard hat, maintain safe distance from spreader
USCG-approved life jacket or buoyant work vest, ring
buoys with at least 90 feet of line, and at least one
lifesaving skiff will be available
USCG-approved life jacket or buoyant work vest, ring
buoys with at least 90 feet of line, and at least one
lifesaving skiff will be available
USCG-approved life jacket or buoyant work vest, ring
buoys with at least 90 feet of line, and at least one
lifesaving skiff will be available
Level D PPE including chemical resistant gloves
Machine guarding, employee training
Spreader operators training, safety glasses, high-visibility
vests, hard hat, maintain safe distance from spreader
16
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Section 4
Site Control Measures
Site control minimizes the transfor of contaminants from and within the project site and
provides a clear understanding of the basic layout of the RA sampling work area. Specific
zones will be established prior to any construction activities within the work area to limit
exposure and possible spread of contaminants.
4.1 Site Access
Access to the Domtar Plymouth facility is controlled by Domtar employees. All contractors
I
entering the site will be required to follow Domtar contractor safety/orientation requirements
(see Attachment E-1).
Welch Creek is a fishing location for the public; therefore, public access is available from both
upstream and downstream of the construction and long-term monitoring areas. During cover
placement activities, signs will be posted at the confluence of Welch Creek and the Lower
Roanoke River and upstream of Highway 64 crossing to notifying boaters of the presence of silt
curtains and in-water construction activities. Post construction, buoys will be placed near
unattended monitoring stations if equipment impairs navigational access.
Contractor's transporting and using chemicals at the Domtar Plymouth facility must complete a
Chemical/Product Request Form and Product Analysis Worksheet. Copies of these forms are
included in Attachment E-1.
4.2 Other Site PersonnelNisitors
Other site personnel or visitors refers to government employees, Domtar representatives not
directly involved with the project, nonessential contractor personnel, news media representatives,
and any other person not actively involved in the RA activities that enter the exclusion zone.
Other site personnel entering the facility to observe or participate in the sampling or construction
activities must report directly to the HSR upon reaching the support zone near the boat ramp. All
visitors will first be required to complete Domtar's mill safety orientation. Then visitors must sign
in with the HSR and obtain a visitors checklist of procedures to be followed while on site.
Signature constitutes a waiver for entry into the work area, if authorized by the HSR.
Other site personnel must review'the Visitors Health and Safety Checklist and obtain an
orientation by the HSR or designee. They will also have the opportunity to review this RMT
CHSP/CP prior to entry into the work area. However, visitors are responsible for providing
RMT North Carolina, Inc. I Domtar Paper Company, LLC
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Appendix E: CHSP/CP
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their own CHSP/CP and protective equipment and must accept responsibility for their personal
health and safety while on the site as indicated on the waiver. Entry authorization to visitors by
the HSR does not constitute acceptance on the part of the HSR, RMT, or Domtar of
responsibility for visitor CHSP/GP adequacy or visitor safety.
If a fire, explosion, or toxic gas/vapor release occurs while visitors are present on the site, the
visitors will immediately evacuate the area, using the main facility access road. The HSR will
initiate the evacuation plan as outlined in Subsection 6.2.
4.3 Personnel Decontamination Procedures
Whenever field personnel or equipment leave the sampling area, they must follow prescribed
decontamination procedures.
Field Personnel
Personal protective levels required are presented in Section 5. Levels C and D
decontamination procedures will be as follows: ' .
Remove gross soil and sediment from boots and gloves with brush and water if
needed.
' Remove protective outer garments, and place them in disposable plastic bags at the I perimeter of the exclusion zones (see Subsection 4.1.1 for definition of exclusion
zones) before leaving the exclusion zone each time.
Remove outer gloves first, if used. Remove protective coveralls by rolling them
inside out from the upper torso to the feet.
If exposed to wastewater solids, brush, wash or rinse impervious safety boots as
appropriate before removing them when leaving the contamination reduction zone.
After removal, place b?ots in a plastic bag for transport to the next exclusion zone.
For Level C work, first:remove the respirator and then the spent cartridges or
canisters to clean the face piece. Change the cartridges after each work shift.
Remove inner gloves if used.
Wash and dry your hands before leaving the contamination reduction zone, and
place used paper towels in the disposal bag.
'
The plastic bags containing the protective equipment waste materials will be disposed of
as specified in Domtar's Contractor Safety, Environmental, Security, and Checklists
contract requirements (see Attachment E-1). A solid waste monitoring program data
collection record must be c~mpleted for all waste materials. A copy of this form is
included in Attachment E-1'.
RMT North Carolina, Inc. I Domtar Paper Co/npnny, LLC
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Appendix E: CHSP/CP 18
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Clean outer garments will be kept accessible to field personnel in the work trailer in the
support zone. Water, soap, and paper towels will also be kept in the trailer for both
regular clean-up and emergency use.
RMT North Carolilin, l11c. I Domtar Paper Company, LLC
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Appendix E: CHSP/CP
/: \ \VPGVI. \ P/TI \ 00625 \ 08\001 \ R006250800l-OOI E.DOCX
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Section 5
Personal Protective Equipment
Protective clothing must be worn whenever the potential exists for employees to come in
contact with or to be exposed to affected material, Worker PPE for intrusive activities will begin
at modified Level D protection based on the most current information available on potential
health and safety hazards at the site. Other means of protection include using the buddy
system and employing work limitations,
5.1 Levels of Protection
Domtar requires that steel toed work boots be worn at the site and that a hard hat, safety
glasses, and hearing protection be used as appropriate. This equipment is available at check-in
to the facility. Additional personal protective equipment specified below will be worn at Welch
Creek. Two levels of protection are specified in this CHSP/CP. A modified Level D will be the
standard level of protection applied throughout the pilot study. Levels of protection higher
than C (i.e., B or A) are not anticipated to be needed at this site. If conditions exist where
Level C protection is not adequate, all work will stop and conditions and personal protection
will be reevaluated.
Personnel performing intrusive activities or sediment sampling at Welch Creek can begin in
modified Level D, Intrusive activities are defined as sampling, excavating, or otherwise
disturbing sediment materials, Modified Level D protection will consist of the following:
■ Steel-toed, impervious work boots (already required at the facility);
■ Hard hat if overhead hazards are present;
■ Hearing protection (if required as described in Subsection 3.2.7 );
■ Eye protection with permanently mounted side shields if splash hazards exist; and
■ Disposable nitrile or Silvershield gloves, if handling chemicals or sediment materials,
In addition, persons that are expected to collect or directly handle samples or otherwise come in
direct contact with contaminants will wear Tyvek® suits or impervious apron and sleeves (when
the potential for skin or clothing contact with contaminants exists).
Gloves and Tyvek® suits must be changed upon leaving an exclusion zone, and whenever there
is visible contamination, such as dirt smudges, on the protective gear to minimize the potential
for mercury, dioxin, or furan permeation through the material to the skin.
RMT Nortft Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP 20
/: \ WPGVL \ P/TI \ 00625 \08\ 001 \ R006250SOOl-00l £.DOCX Revised November 2010
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5.2 Changes in Levels of Protection
The site HSR may authorize a change in the level of protection based on an evaluation of actual
field conditions after consulting with the HSC. Upgrades in protection will be at the HSR's
discretion, while downgrades must be approved by the HSC. If changes in the level of
protection are warranted due to site conditions/hazards, the site HSR will inform field
personnel and the RMT PM of the required changes. The RMT PM will then notify the Domtar
PM. Notifications will be made after the area has been appropriately secured.
5.3 Buddy System
The buddy system will be used at all times in the exclusion zone. "Buddies" will maintain line
of sight contact or radio contact with each other whenever they are in an exclusion zone.
Buddies can be any two site personnel regardless of company affiliation. Two-way radio
systems, walkie-talkies, or ce11 phones will be used when line of sight is not possible.
5.4 Work Limitations
The following work limitations will apply to all field personnel working on the site:
■ No smoking will be allowed in the exclusion or contamination reduction zones or
additional on-site locations identified by Domtar.
■ No eating, drinking, or chewing gum or tobacco will be allowed in the exclusion or
contamination reduction zones.
■ Seat belts are required to be used in all moving vehicles.
■ All personnel and equipment leaving the sampling areas must be properly decontaminated
prior to leaving the site. Personnel decontamination procedures are described in this
document and equipment decontamination are described in the Field Sampling and
Analysis Plan (FSAP).
■ When possible, on-site work will be limited to daylight hours. If work must be done at
night, illumination levels will conform to OSHA Construction Standard 29 CFR 1926.56 and
OSHA 29 CFR 1910.120.
■ Work will be suspended if weather conditions are:
Significantly windy, causing excessive waves that make working over or near
water dangerous, or
If lightning and other storm conditions threaten worker safety.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP 21
/: \ ¾'PGVl. \ P/TI \ 00625 \OS\ 001 \ R006250800I-001E,D0CX Revised November 2010
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Section 6
Contingency Plan
This contingency plan provides the emergency information needed should there be a sudden
life or health-threatening situation where work activities are being conducted. The provisions
of the contingency plan are to be implemented immediately in the event of a fire, explosion, or
accident, which could threaten human health or the environment.
6.1 Emergency Contacts
Emergency contacts and telephone numbers for use in emergency situations occurring during
field activities are detailed in Table E-2.
Table E-2
Emergency Contacts
EMERGENCY CONTACT
Domtar Emergency Assistance (from a Domtar phone)
Domtar Contacts
Dianne Hardison
Bill Morris
Environmental Person on-call (24 hours, 7 days/week)
Roanoke Medical (8:00 a.m. to 5:00 p.m.)
Washington County Hospital
OSC -Bill Morris
Site HSR -Mike Parker or designee
HSC -Jennifer Meek
RMT PM -Mike Parker
RMT Senior Management Contact -Karen Saucier
USEPA Remedial Project Manager (RPM) -Randy Bryant
North Carolina Department of Environment and Natural Resources
(NC DENR) -Nile Testerman
NC DENR Division of Water Quality -Washington Regional Office -
Al Hodge
Washington County Hospital
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP 22
/:\ WPGVL \ P{TI \00625\08\0QI \R0062508001-0()JE.DOCX
TELEPHONE NUMBERS
8, 911
252-793-8269
252-793-8494
800-979-7738
252-793-4500
252-793-4135
800-256-4135
252-793-8494
864-608-2569 (mobile)
864-234-9490 (office)
864-414-7674 (mobile)
864-234-9462 (office)
864-608-2569 (mobile)
864-234-9307 (office)
864-787-6638 (mobile)
404-562-8794
919-508-8482
252-946-6481
252-793-4135
Revised November 2010
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6.2 Emergency Procedures
If an emergency situation develops at the site, the discoverer will notify the HSR who will
perform the following:
■ Evacuate visitors and non-essential site personnel from the site.
■ Notify any other affected personnel at the site.
■ Call 8, 911 from a Domtar telephone and give the operator the location and nature of the
emergency. The operator will notify the proper emergency services (fire, ambulance,
police, etc.) for assistance. Answer all operator questions and let the operator hang up first.
■ Determine and initiate (if necessary), in conjunction with emergency personnel, evacuation
of residents in the surrounding community.
■ Contact the HSC to inform him/her of the incident as soon as possible.
■ Contact the Domtar PM and RMT PM to inform them of the incident as soon as possible.
■ Prepare a written summary report of the incident for the RMT HSC and the Domtar PM as
soon as possible, but no later than 24 hours after the incident. A copy of the report' format
required to be submitted to Domtar is included in Attachment E-1.
If the HSR is not available, the person discovering the emergency situation will initiate the
above actions.
6.3 Medical Emergency
The Domtar facility has a medical facility staffed by health care professionals from 8:00 a.m.
to 5:00 p.m. If a first aid or medical emergency occurs, the person should be taken to the
Domtar medical facility first. The health care professional will provide first responder care and
will determine wl,1ether the emergency requires further care in a hospital. The nearest full
service hospital is Washington County Hospital located at 958 US Hwy 64 East Plymouth,
North Carolina 27962.
If a medical or first-aid emergency occurs when the facility is not staffed, contact the on-site
emergency medical technician (EMT) by dialing 8, 911 from a Domtar telephone .. An on-site
EMT is on call 24 hours a day.
6.4 Emergency Equipment
Emergency equipment that will be available on the site with field personnel will include the
following:
■ First-aid kits/bloodborne pathogen kits;
■ Ring buoys with at least 90 feet of line;
RMT North Carolina, Inc. I Domtar Plrer Company, LLC
Remedial Action Work Pinn ·
Appendix E: CHSP!CP 23
/;\ WPGVL \P/Tl \00625\08\001 \R0062508001-00I £.DOCX Revised November 2010
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■ At least one motorized boat with ring buoy;
■ Disposable eyewash flush bottles; and
■ ABC type 3 to 5-pound fire extinguisher.
6.5 Emergency Route
Attachment E-3 contains a map of ambulance pickup stations at the Domtar facility and a map
of evacuation routes for the facility.
RMT North Carolina, l11c. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP
/:\ WPGVL \PJT1 \00625\08\001 \R0062508001-001 f..DOCX
24
Revised November 2010
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Section 7
Record Keeping
This section discusses the records that will be maintained as part of this CHSP/CP.
7.1 Training Attendance
A copy of each employee's certificate verifying the completion of the 40-hour Health and Safety.
Training for Hazardous Waste Sites is maintained in the employee's personnel file. Each
employee retains the original certificate issued. A copy of the training records will be
maintained on the site by the HSR.
Site-specific CHSP/CP review is documented on a sign-in sheet. The sign-in sheet is kept in a
safety project file to be maintained by the HSR or in the pilot study field log.
7.2 Respirator Fit Test
Copies of respirator fit testing forms containing the employee's name, protocol used, respirator
tested, and fit test results are distributed as follows:
■ One copy to the employee;
■ The signed original filed in the personnel file; and
■ A copy of the fit test record will be maintained on the site by the HSC and checked by the
HSR if the respiratory protection level changes to Level C.
7.3 Medical Certification
Personnel must receive periodic physical exams to determine their ability to wear a respirator
and perform required job functions. The medical records of personnel are managed through an
outside health resources management company, which follows all applicable state and federal
regulations. Personnel would be contacted directly by the management company regarding
medical screening results. The health resource management company will provide a
certification of medical fitness for the tasks described and any work restrictions or limitations
the employee may have.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP 25
/:\ WPGVJ. \PJTl \00625\08\001 \ R0062fi0800J.<)01L.DOCX Revi~ed November 2010
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Attachment E-1
Domtar Contractor Safety,
Environmental, and Security Documents
RMT Nort/J Caroli11a, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP A-1
I:\ WPG\'L \ PJTI \ 00625\08\001 \ RD062508001-001 E. DOCX Revised Novemher 2010
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GENERAL
ATTACHMENT A
SAFETY, ENVIRONMENTAL, SECURITY & CHECKLISTS
Safety Orientation, Contractor, Consultant, Factory Representatives
(Including Controlled Substance Certification); Vehicle Pass and Employee Name
This Attachment is to be reviewed and will be completed in full with all signatures properly affixed, and a
copy maintained on file by the Domtar Representative.
1.0 CONSTRUCTION -GENERAL SAFETY REQUIREMENTS
I. I The Standard for Safety is no unsafe conditions or practices, no accidents large or small, no "near
misses." There is no acceptable level of accidents or unsafe conditions. Safety can never be
compromised for production. These requirements are a part of the Construction Safety
Requirements to assure a minimal standard of performance in preventing accidents at this mill.
They apply to Contractors, Sub-contractors, and Suppliers. THE CONTRACTOR WILL:
1.1.1 Provide a copy of the Contractor's written safety and drug testing program for the Owners
review. It will be kept on file in the Domtar Representative/Project Manager's Office.
1.1.2 Provide a list for the Domtar Representative/Project Manager, and the Environmental
Department prior to the start of work of"!!!.!" chemicals (with accompanying Material
Safety Data Sheets) the Contractor anticipates bringing onto the mill site. Domtar will
provide a list of hazardous chemicals (with MSDS's if requested) for the areas in which the
Contractor will be working.
I .1.3 Demonstrate a pro-active attitude toward the protection of Contractor's employees.
1.1 .4 Inform the Domtar Representative/Project Manager of all accidents and investigate each
one. Copies of the investigation report will be forwarded to the Domtar
Representative/Project Manager for information and review. Reporting procedures are as
follows:
1.1 .4.1 Notify the responsible Domtar Project Manager "daily" of any safety incidents,
(i.e .. First Aids, Lost Time Incidents, and Total Recordables and should be
reported on the attached Sample Fann: Exhibit 4 -INCIDENT
INVESTIGATION REPORT).
1.1.4.2 A summary of data to allow calculation of incident ratios should be sent to
Engineering "weekly" (each Thursday by approximately 4:00 P.M.). The data
should include work-hours worked (Hourly and Supervision for the period Friday
-Thursday), First Aid Visits, Lost Time Incidents, and Total Recordables. "Year
To Date" should be included to keep up with accurate data. The weekly data to
be reported on the attached sample form: Exhibit 5 -CONTRACTORS
WEEKLY SAFETY PERFORMANCE.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-2
/: \ WPGVL \ P/Tl \ 00625 \ 08 \001 \ R0062508001-001 [.DOCX Revised November 2010
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l. l .5 Hold Tool Box Safety meetings (weekly minimum) with all employees. Written minutes of
each meeting shall be submitted to the Domtar Representative/Project Manager to serve as
verification of compliance and Contractor's intent to promote and enforce safe work
practices.
l. l .6 Provide all necessary safety equipment, education, training, and devices necessary to safely
perform work, and demand use of such equipment from Contractor's employees:
1.1.7
l. 1.8
1.1.6. l
1.1.6.2
1.1.6.3
1.1.6.4
Utilize a written, job-specific hazard review or other safety planning tool for
daily assignments or activities of employees. Maintain the documentation for
review by the Domtar Representative.
Policy establishes the maximum hours to be worked by an employee in a 24-
hour workday at the Plymouth Mill Operations and applies to all company and
contractor employees on site. It is the intent of this policy that employees do not
work beyond 16 hours in any 24-hour period.
Contractors with non-English speaking employees shall have a bilingual
supervisor/translator in direct visual and verbal contact with employees at all
times.
Contractors working with or around energized electrical equipment shall comply
with the latest version ofNFPA ?OE, Standard for Electrical Safety in the
Workplace, especially related to the following items:
a. Wearing of appropriate PPE for the task
b. Approach Boundaries to Live Parts
c. Energized Electrical Work Penni!
Have an emergency response plan well known by all Contractor's employees.
Comply with OSHA safety standards as they apply to the construction industry. A copy of
these standards and the Contractor's safety rules and procedures must be kept at the plant
site for Contractor's employees to refer to. The Owner will be allowed to participate in all
OSHA inspections of the Contractor's on-site operation. As a Minimum, the following
rules are to be adhered to as part of the Contractor's safety rules and procedures.
1.1.8.1
1.1.8.2
1.1.8.3
l. l.8.4
' 1.1.8.5
Industrial safety glasses shall be worn at all times throughout the mill.
Safety footwear shall be worn at all times throughout the mill.
Hard hats shall be worn at all times throughout the mill.
Trousers and shirts with sleeves shall be worn at all times throughout the mill.
Shorts and/or tank tops are not permitted.
Machinery processes and equipment will be tagged and locked-out and "start"
circuit-tested prior to maintenance or repair activities commencing on that
machinery, process, or equipment.
RMT North Carolina, Inc, I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP A-3
/:\ WPGVL \PJTJ \00625\08\001 \R0062508001-001E.DOCX Revised November 2010
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1.2
1.1.8.6
1.1.8.7
1.1.8.8
1.1.8.9
1.1.8.5.1 The Contractor will provide each of his employees with individual
locks to secure all equipment they are working on. Individual locks
must be affixed to group lockout devices.
Procedures shall be developed and followed for the protection of employees
during confined space entry. The procedure will include atmospheric
testing/evaluation and emergency response. Domtar will not provide air
monitoring services.
Portable fire-fighting equipment shall be made available at all areas of welding,
torch work, or flammable and combustible liquid storage. Hot Work Permit
must be used for any welding, cutting or burning.
Approved safety cans, complete with spring closing lid and screen, shall be used
for temporary storage of flammable liquids.
Manlifts shall not be utilized by Contractor or his employees.
1.1.8.I0 Mill traffic speed limit of 10 MPH shall be adhered to at all times.
1.1.8.11 Exposed live electrical parts are not permitted at any time. This includes
temporary electrical work.
1.1.8.12 Digging Penn its are required for all penetrations l 2" or more below ground
level. Permits are to be requested through the Domtar Representative/Project
Manager.
1.1.8.13 All overhead work will have the area below roped off with appropriate hazard
warnings.
1.1.8.14 Chlorine respirators are to be required for employees working in Chlorination
Areas.
1.1.8.15 Rings, bracelets and dangling jewelry are not permitted in operating areas of the
mill. Watches shall have break-away bands.
1.1.8. l 6 Seat belts shall be used by all occupants while in licensed or non-licensed
motorized vehicles on the mill site.
ALCOHOL AND/OR CONTROLLED SUBSTANCE
The use of alcohol and/or controlled substances is not to be consumed, sold, given, or brought onto
the mill site. Employees under the influence will not be allowed on the mill site. Also, the
Contractor will provide documentation to Domtar that each of his employees who will be working
on the site, has been prescreened by a certified lab of the Contractor's choice and is free of illegal
drugs.
RMT North Carolina, Inc. I Domtar Paper Campany, LLC
Remedial Action Work Plan
Appe11dix E: CHSPICP A-4
/:\ WPGVI. \P[TJ \00625\08\00J \R0062508001--00l £.DOCX Revised November 2010
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1.3
1.4
1.5
DOMTAR WILL:
1.3.1 Provide safety orientation for Contractor prior to beginning work (see orientation checklist).
1.3.2 Audit Contractor's work habits to ensure employees' safety and health.
1.3.3 Act as safety and health resource, as needed.
MEDICAL CENTER -MEDICAL CARE FOR CONTRACTORS
I .4.1 Medical care for employees of independent Contractors with on-the-job injuries or illnesses
will be available at the Domtar Plant Site Medical Center unless otherwise specified.
Contractors and their employees will retain the option of seeking medical care elsewhere in
the community if they prefer.
FIRST AID TREATMENT
1.5.1 Treatment will include treatment for minor cuts, scrapes, bruises, and foreign bodies in the
eye as well as treatment for minor gas inhalations. Treatment may be instituted at the
Medical Center or in more complicated cases the patient may be referred to the local
hospital or the office ofa physician of their choice. The Contractor shall provide insurance
carrier's information to the hospital or doctor.
1.5.2 No charge will be made to independent Contractors for services by the Domtar Medical
Center.
2.0 PROCEDURE FOR EMERGENCY ASSISTANCE
2.1
2.2
The procedure for reporting a need for emergency assistance will be as follows:
2.1.1 Decisions as to whether a nurse, roving guard, or ambulance is needed will be made by the
injured party and/or supervisor.
2.1.2 First aid cases -Nurse is on duty 8:00 AM to 5:00 PM, Monday through Friday.
2.1.3 !fit is determined that the ambulance is needed, call (8911) and give the guard answering
the phone the location and nature of the injury. Example:
"Send an ambulance to pickup point #8. A person just fell off a ladder."
2.1.4 Be sure someone is at the designated pickup point to meet the ambulance and guide it to the
injured party.
Process Safety Management Guidelines
2.2.1 Contractors who work on or adjacent to covered process areas are required to fully comply
with OSHA Regulation 1910.119. Sections (h)( I) and (h)(3) of 1910.119 detail the
responsibilities of contractor employers to safely perform work in these areas.
RMT North Carolina, I11c. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP A-5
/: \ WPGVL \ P/TI \ 00625 \08 \001 \ RO/J6250800l-001 E.DOCX Revised November 2010
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2.2.1.1 Contract employers shall:
2.2.1.2 Assure each contract employee is trained in the work practices necessary to
safely perform his/her job.
2.2.1.3 Assure each contract employee is instructed in the known potential fire,
explosion, or toxic release hazards related to his/her job and to the applicable
provisions of the emergency action plan.
2.2.1.4 Provide documentation that each contract employee has received and understood
the training required by this paragraph. The contract employer shall provide
Domtar with a record, which contains the identity of the contract employee, the
date of training, and a copy of the means used to verify that the employee
understood the training. The contract employer may use the attached sample
forms (Exhibit I -Training Documentation and Exhibit 2-Contractor Safety
Information Verification), or an equal, to comply with this section.
2.2.1.5 Assure that each contract employee follows the safety rules of the facility
including safe work practices required by paragraph (!)(4) of OSHA Regulation
1910.119.
2.2.1.6 Advise Domtar of any unique hazards presented by the contract employer's work,
or of any hazards found by the contract employer's work.
2.2.2 Domtar will:
2.2.2.1 lnfonn contract employers of known hazards related to the contractor's work and
the process and of the applicable provisions of the emergency response plan (SEE
CONTRACTOR SAFETY ORIENTATION CHECKLIST).
2.2.2.2 lnfonn contract employers of the procedures that control the entrance, presence,
and exit of contract employers and employees in covered process areas.
2.2.2.3 Periodically evaluate the contract employer's perfonnance in fulfilling their
obligations as specified in (h)(3) of OSHA Regulation 1910.1 19 (Exhibit 3-
Contractor's Programs Compliance Audit-page I and bottom portion of page 3
for pre-work audit). The evaluations will then occur at least every four weeks of
continuous service by the contract employer (Exhibit 3 -pages I to 3).
3.0 -5.0 PLYMOUTH CONTRACTOR ORIENTATION ENVIRONMENTAL
AS REVISED BY DON WYNNE FEBRUARY 2009
Although the title is contractor orientation, this training is intended and applies to all contractors,
suppliers, service technicians, vendors and anyone who is not a Domtar Paper Company Plymouth mill
employee who performs work on the plant site. It is the responsibility of the general contractor to ensure
all subcontractors are trained and comply with these expectations. It is the responsibility of the Domtar
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-6
I:\ WPGVL \ P/T1 \ 00625 \08 \ 00 l \ R0062508001-00l E. DOCX Revised November 2010
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representative who orders and/or directs the activities to ensure that "contractors" comply with these
expectations.
Domtar Company has gained a very good reputation in the area of environmental performance over the
years. We take this reputation and our responsibility to protect the environment and the communities in
which we do business very seriously. Many of our company policies are more stringent than the federal
and state regulations by which we are regulated to protect our reputation and communities. Domtar
Company has a vision (or goal) of becoming the best forest products company in the world. We cannot
achieve this vision without excellence in environmental performance.
As with safety, contractors, suppliers and vendors who perform work, visit or make deliveries on the plant
site are expected to adhere to the same environmental policies and expectations as our employees. Those
individuals who fail to conform to our expectations will not be allowed to continue providing services to
the facility.
Contractor representatives who attend the safety and environmental orientation sessions are required to
provide this training to each of their crews that will be working at the Plymouth mill. Each contractor
employee should sign an attendance sheet stating that he or she has received this training. The original
signed contractor attendance sheet(s) should be given to the Plymouth mill contact who should forward
the signed attendance sheets to the Environmental Department.
ISO 14001 -Environmental Management System (EMS)
Environmental Policy
Domtar has an environmental policy, which can be found on the back of this handout.
Some main points about the environmental policy:
• As with safety, everyone at the mill is responsible for environmental management, including
contractors and suppliers.
• Full compliance with laws and regulations is basic.
• We are committed to continual improvement.
Our EMS is how we execute our Policy:
• Contractor and supplier personnel must conform to the environmental policy and EMS
requirements.
Significant Environmental Aspects
Some elements of our work activities can have a significant impact on the environment. These are
called "significant environmental aspects."
We have identified these significant aspects in all areas of the mill and have established
"operational controls" that relate to them.
Your mill contact person will notify you of any significant aspects that apply to your activities at
the mill. Contractor and supplier employees are responsible for knowing these significant
environmental aspects.
Operational Controls
"Operational controls" are in the form of standard operating procedures (SOPs).
Again, wherever we may have significant impact on the environment (i.e., for each significant
environmental aspect) we have put one or more SOPs in place.
~T North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appe11dix E: CHSPICP A-7
/:\ WPGVL \PJTI \00625\08\001 \R0062508001-001E.DOCX Revised November 2010
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We expect everyone who enters our mill and whose activities are associated with significant
aspects to know and conform to the relevant procedures and requirements.
Emergency Response
Be aware of potential environmental emergency situations in mill areas where you are active.
Be aware of emergency response plans for these areas and your role in them.
Examples of information you need to know:
• Emergency phone number-8911
• Whom to notify -Your supervisor or mill contact
• Where to go -Evacuation area for emergencies
Checking and Corrective Action
The mill will monitor its environmental performance to ensure regulatory compliance and
continual improvement.
We expect everyone who enters our mill site to:
• Report environmental incidents to your supervisor or mill contact.
• Cooperate with our environmental audits and assessments.
Chemical Management
Chemical Approval -No product, chemical or chemical compound is to be brought on to the plant site
without first obtaining proper approval. This includes vendor samples, trials, and even a single aerosol
can or tube of something you may need. To obtain proper approval, a MSDS (material safety data sheet)
for the product you propose to use must be submitted to the Domtar representative with whom you are
working. A MSDS is required for all liquids. gasses. powders and solids that could emit or generate
fumes. vapors or dust in the course of being used. The Domtar representative will forward the MSDS and
completed chemical approval process forms to the Environmental Department (Delores McCray) for
routing to the appropriate people in the review process and possible approval. Only after a chemical has
been approved and a purchase order issued will the product be allowed onto the plant site. For tracking
and control purposes a "zero value" requisition must be written and purchase order issued before free
samples or trial materials can be sent to or left on the plant site. The approval process takes time. Every
chemical must be evaluated for safety, air emission, wastewater, hazardous waste and other regulatory
implications. It involves not only the evaluation of the chemical(s) itself, but the potential employee
exposures, quantity to be stored and used, how it is to be used, how and where it is to be stored, and
possible waste streams and disposal of them, among other things. If you or your Domtar representative
do not agree with the decision of the Environmental Depanment (Chemical Approval Team) the Domtar
representative can take your position up with the Technical/Quality Assurance Manager or the Manager
responsible for the area in which the material will be used. Be sure the manager reviews the chemical
review team's comments in conjunction with your comments so they fully understand the risks and
benefits involved with their decision. At this time, only a member of the mill Management Team can
override a disapproval decision or approve chemicals in an emergency. Domtar also requires that all
MSDSs must be no more than 5 years old.
Liquid chemicals, chemical compounds, or products having a pH of 2 or less, or, 12.5 or greater are rarely
approved due to the potential that they will generate or become a hazardous waste. Solids that will
generate a liquid waste with these pH ranges are also rarely approved. Products in aerosol cans are rarely
approved due to the solvents or propellants they contain and the additional handling requirements for
RMT North Carolina, 111c. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP A-8
/:\ WPCV/, I /'/Tl \00625\08\001 \R00625/!8001-001E.DOCX Revised November 2010
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proper disposal. Liquids with a flash point of less than 140 'F (60 'C) are seldom approved. In addition,
products, including oils and grease, which contain a total of I% by weight or I 0% by volume or more of a
solvent(s) listed on the US EPA 's "F" List of chemicals regulated as listed solvents are rarely approved
because !!!!.Y waste is automatically considered hazardous.
Chemicals Regulated as Listed Solvents (EPA "F" List)
Waste Chemical Common Synonym
FOOi (T) tetrachloroethylene perchloroethylene
perchlorethylene
ethylene tetrachloride
ethene, tetrachloro-
ethene, I, 1,2,2-tetrachloro-
trichloroethylene trichloroethene
trichloran
ethylene trichloride
ethene, trichloro-
methylene chloride dichloromethane
methane, dichloro-
methylene dichloride
narkotil
I, I, I-trichloroethane methyl chlorofonn
ethane, I, 1, 1-trichloro-
chlorothene
carbon tetrachloride tetrachloromethane
methane, tetrachloro-
perchloromethane
tetrafonn
chlorinated fluorocarbons
F002 (T) tetrachloroethylene perchloroethylene
perchlorethylene
ethylene tetrachloride
ethene, tetrachloro-
ethene, 1, 1,2,2-tetrachloro-
trichloroethylene trichloroethene
trichloran
ethylene trichloride
ethene, trichloro-
methylene chloride dichloromethane
methane, dichloro-
methy Jene dichloride
narkotil
I, I, I-trichloroethane methyl chloroform
ethane, I, I, 1-trichloro-chlorothene
chlorobenzene phenyl chloride
phenol chloride
RMT North Caroli11a, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-9
/: \ WPGVL \l'/TJ \0(1625\0S\O()J \R006250800HJ01 I:.DOCX
CAS#
127-!8-4
79-01-6
75-09-2
71-55-6
56-23-5
CFC's, Freon vanous
127-18-4
79-01-6
75-09-2
71-55-6
I 08-90-7
Revised Novcm/Jcr 2010
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monochlorobenzene
chlorobenzol
benzene,chloro-
ortho-dichlorobenzene 1,2-dichlorobenzene 95-50-1
benzene, 1,2-dichloro-
trichlorofluoromethane CFC 11 75-69-4
trichloromonofluoromethane
methane, trichlorofluoro-
fluorotrichloromethane
FCI I
I, 1,2-trichloroethane ethane trichloride
ethane, I, 1,2-trichloro-
vinyl trichloride
refrigerant 113 CFC 113, Freon 113
chlorinated fluorocarbon
1, 1,2-trichlorotri fluoroethane
I, 1,2-trichloro-1,2,2-trifluoroethane
FC I 13
F003 (I) xylene dimethyl benzene
dimethylbenzene
xylene (mixed)
xylenes
xylenes (isomers & mixture)
xylenes (o-,m-,p-isomers)
xylene (NOS)
acetone 2-propanone
methyl ketone
dimethylfonnaldehyde
acetone oils
cyclohexanone
ethyl acetate
ethyl benzene
ethyl benzene
ethyl ether
ether
diertyl ether
methly isobutyl ketone
isopropylacetone
hexane
n-butyl alcohol
n-butanol
butanols
butyl alcohols
methylolpropane
propyl carbinol
methanol
methanol alcohol
ketohexamethylene
acetic acid, ethyl ester
phenylethane
I, I '-oxybisethane
4-methyl-2-pentanone
1-butanol
methyl alcohol
monohydroxymethane
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-10
I:\ WPGVL \ P/TI \ 00625 \ 08\001 \ R006250800HJ01 f.. DOCX
79-00-5
76-13-1
1330-20-7
67-64-1
I 08-94-1
141-78-6
100-41-4
60-29-7
108-10-1
71-36-3
67-56-1
Revised November 2010
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wood alcohol
F004 (T) nitrobenzene
oil of mirbane
essence of mirbane
benzene, nitro-
nitrobenzol 98-95-3
cresols/cresylic acid methyl phenols 1319-77-3
hydroxytoluene
cresols (isomers & mixture)
FOOS (l,T) toluene methyl benzene 108-88-3
phenylmethane
benzene, methyl-
2-ethoxycthanol glycol monethyl ether 110-80-5
ethanol, 2-ethoxy-
ethylene glycol monoethyl ether
EGEE
cellosolve
methyl ethyl ketone
methyl acetone
MEK
2-butadiene 78-93-3
ethy I methy I ketone
carbon disulfide dithiocarbonic anhydride 75-15-0
carbon sulfide
carbon bisulfide
pyridine
benzene
coal naphtha
cyclohexatriene
phenyl hydride
2-nitropropane
isonitropropane
propane, 2-nitro-
azabenzene
benzol
dimethyl nitromethane
isobutanol isobutyl alcohol
1-propanol, 2-methyl-
110-86-1
71-43-2
79-46-9
78-83-1
From How to Recognize a Hazardous Waste (even if it's wearing dark glasses) by Gary Crouth 9•h edition
and some synonyms from the J.J. Keller Chemical Regulatory Cross reference April 1997
Container Labeling -All containers must be labeled with a proper and completely filled out NFPA
label. This includes bulk tanks, drums, barrels, buckets, bags and portable containers. Oil and chemical
bulk tanks (>55 gal.) must also have the appropriate DOT label with the proper hazard symbol and UN
number. Any chemical used as a pesticide (biocide, for biological control) must have an EPA pesticide
registration number on the label. Manual labeling stations should be established at appropriate locations
to .insure compliance. Labels can also be printed automatically in the Environmental Department (see
Deloris McCray) by utilizing our computerized MSDS system and label printer.
RMT North Carolhia, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-11
/:\ WPGVL I rrn \00625\08\001 \R00625D8001-001£DOCX Revised November 2010
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Chemical Storage -All chemicals will be properly stored while on the Plymouth plant site. Bulk oil,
fuel and chemical tanks will have secondary containment. Acidic and caustic solutions will be kept in
separate storage cabinets specifically designed for their storage, away from oils and grease. Oils and
other flammable chemicals will be stored in FM approved fireproof cabinets. In all cases, oil and
chemicals will be stored in such a way that stormwater will not come in contact with the containers and
any leak or spill will not come in contact with soil, water systems or surface waters. No chemicals are to
be stored within 50 feet ofa potable water well.
Management of Refrigerant-Related Work -Contractors shall be responsible and accountable for
compliance with the EPA Clean Air Act (CAA) Section 608, 40 CFR Part 82 and any state and local
codes for all refrigerant-related work. Contractor shall ensure that all contractor employees are made
aware of the content of these practices prior to beginning work on refrigerant containing equipment. All
technicians that work on refrigerant containing equipment or appliances must be properly certified.
Technician certifications must be provided to your Domtar representative and forwarded to the
Environmental Department. Service records for any work on refrigerant containing equipment or
appliances must be provided to your Domtar representative and forwarded to the Environmental
Department. Records (type of each refrigerant and quantities used) must be maintained and forwarded to
the Environmental Department. Contact your Domtar representative or the Environmental Department for
proper disposal procedures of equipment or appliances that contain refrigerants. Any appliance or
equipment that contains refrigerant which is taken out-of-service for disposal must have the refrigerant
removed by a certified refrigerant technician prior to disposal. The appliance should also be tagged using
the mill's disposal tag. Contact the Environmental Department for further instructions when removing
from service any appliance or equipment that contains refrigerant.
Halon Fire-Suppression Equipment Section 608 of the Clean Air Act Amendments prohibits the
intentional release of halon during the repair, testing, and disposal of equipment containing halons.
Contractors inspecting, servicing, or disposing of the halon-containing fire suppression equipment at the
Plymouth Mill must comply with the requirements of 40 CFR 82 Subpart H. As part of this requirement,
contractors must provide emissions reduction training to their technicians employed to work with the
halon fire suppression equipment at the Plymouth Mill. Contractors must also provide service records to
the Environmental Department for work performed on equipment containing halon.
Waste Disposal -Under no circumstances are chemical and solvent wastes to be mixed with used oil,
water or solid waste. The Environmental Department (Chemical Approval Team) must give approval for
any chemical wastes you intend to generate. Prior to the generation of the waste, you must contact the
Environmental Department and establish an approved collection procedure, storage area and disposal
plan. Regulations require Domtar to be responsible for the proper disposal of !l1! wastes generated on the
plant site.
Oils -Used oil must be kept separate from other wastes. In additiofi·crank case oil must be kept separate
from other oil and fuel wastes.
Waste or mixed waste fuels -must be kept separate and tested prior to disposal. You must see the
Environmental Department for instructions on how to handle these wastes.
Aerosol cans -Regulations require aerosol cans to be totally emptied of liquid and depressurized prior to
disposal. Because the sun can re-pressurize an aerosol can and the remaining liquid usually contains a
solvent, the cans must never be disposed of with other trash. Aerosol cans must be collected in a
RMT North Caroli11a, lnc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP!CP A-12
/:\ WPGVL \P/T1 \00625\08\001 \R0062508001-001 £.DOCX Revised November 2010
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dedicated container marked "Aerosol Cans Only" and then taken by Domtar's Facility Services crew to
the can popper and punctured. At the can popping station the liquid is collected and disposed of as
hazardous waste and the cans are collected for recycling.
Vacuum Trucks must have prior approval from the Environmental Department before collecting any
material for disposal. With the approval you will be given specific instructions for proper disposal of the
material to be collected. Each time the material to be disposed of changes in any way (consistency,
viscosity, color, texture or material type) the Environmental Department must be notified again to receive
additional approval and instructions for the proper disposal of this new material. All domestic waste
(porta potties, toilet sumps, septic tanks, etc.) must be pumped and disposed of only by an approved
contractor (contract issued annually) or the Facilities Services Crew.
Other garbage should be placed in the yellow trash dumpsters for disposal in the on site landfill with the
exception of items to be recycled which are outlined later in this document. If you will be generating
large amounts of garbage you may be asked to haul the waste directly to the onsite landfill. If you haul
materials to the landfill, proper tracking must be done as detailed earlier in this document.
Universal Waste -Universal wastes consists of used fluorescent light lamps, used batteries, and mercury
containing equipment (switches, thermostats, them10meters, mercury vapor lamps, etc.). Universal waste
must be placed in properly labeled containers and the containers must be kept closed. Containers for
fluorescent lamps must be marked with the words "Universal Waste Lamps" and the accumulation start
date must also be marked on the container. Containers for used batteries must be marked with the words
"Universal Waste Batteries" and the accumulation start date must also be marked on the container.
Releases of universal waste must be cleaned up and handled appropriately. Broken universal waste
fluorescent lamps must be contained and stored in a properly marked container. Call the Facility Services
team for assistance and to transport universal waste containers to the Hazardous waste building for
shipment to a recycling facility.
Waste Tracking -All waste hauled to the on site landfill area must be documented for tracking and
reporting purposes by weighing in and out at the Landfill Scales which utilizes an automated scale
system. If the scales are down tracking is handled by having each driver complete a ;iolid Waste
Monitoring frogram (SWAMP) Data Collection Record for each load hauled. The SWAMP records are
yellow 8.5" x 6.5" cards titled "Contractor Operations" and are available from your Domtar
Representative or the Environmental Department. The completed cards arc to be checked by the
supervisor or foreman, and your Domtar Representative for accuracy and completeness. The completed
and verified cards are to be sent to Delores McCray in the Environmental Department on a weekly basis
or at the end of the job if the job is finished in less than a week.
Waste Disposal in Onsite Landfill -The Domtar landfill may only accept "standard industrial waste"
(includes construction debris: concrete, asphalt, gravel, etc.). The landfill may not accept liquid waste,
hazardous waste, house-hold waste from employees' homes, radioactive waste, aluminum cans, or tires.
Waste loads need to be covered when transporting the waste to the landfill, as necessay, to prevent
blowing of the waste. Contractors need to notify the Environmental Department with questions,
comments, or concerns related to the mill's landfill.
Recycling Solid Waste -Because it is the right thing to do and due to the cost of constructing a new lined
landfill the following items should be collected separately for recycling:
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP A-13
l: \ WPGVL \ P/TI \ 00625 \ 08 \ 001 \ R0062508001-001 £. DOCX Revised November 2010
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Wood and wood waste materials are to be collected and placed in the brown hoppers labeled 'WOOD
Only" or taken to the temporary storage site near the landfill to be ground as boiler fuel. Only treated
(creasote, CCA or salt), heavily painted and furniture waste wood materials should be sent to the landfill.
!fa brown wood collection hopper is not located with the other waste hoppers in the area you are working
place the wood in a pile next to the other hoppers for collection by our Facilities Services Crew. If you
are generating a large volume of wood waste you should haul it 10 the storage area.
Melttl is to be collected in our green hoppers labeled "METAL ONLY" or transported to the scrap metal
pick up site at the contractor lay down area.
Lead acid batteries (auto type) should be given lo the supplier of the new battery for recycling. If this is
not possible they must be collected and sent off site for recycling. See a member of the Environmental
Department for details on storage and disposal. The Facility Services team will transport them to the
Hazardous waste building for shipment to recycling.
A/11111i1111111 cam are to be collected in marked receptacles throughout the facility for recycling. You may
collect and recycle your own cans but we require they be collected and recycled.
Tires should be sent to a recycler. The on site landfill will not accept tires for disposal.
Co11slr11ctio11 debris (asphalt, concrete, gravel, etc.) can currently be hauled to the on site landfill. This
material may also be suitable as inert fill for a construction project if it is uncontaminated and contains no
metal. Check with your Domtar representative or the environmental department for disposal instructions.
For help with the proper storage, transportation and disposal of these items contact a member of the
Facility Services Crew or Environmental Department. Phone numbers are listed at the end of this
document.
Other Issues
Open Burning of waste, debris and other fuels is not permitted on the site without proper approval from
the Environmental Department and obtaining a pem1it for open burning from the county. Open burning is
the burning of any material in a drum, pile or container not already included in our State issued Air
Permit. We rarely allow open burning.
Equipment Leaks -Under no circumstances is a piece of equipment to be brought onto the plant site
with known oil or fuel leaks. If equipment is found to have or develops a leak it must be shut down
immediately and repaired before it is used again. All spilled material must be cleaned up and the spill
reported to your mill representative. Your mill representative will report the spill to the Environmental
Department for proper regulatory tracking and reporting as well as clean up and disposal instructions.
Equipment Maintenance -All equipment maintenance and repairs will be perfonned only on a paved
area with drainage to a mill sewer. This is to protect spills from contaminating groundwater, surface
water or the soil and to allow proper clean up of spilled materials. All drained or spilled material must be
collected for proper disposal. Never drain or wash spilled materials into a sewer or onto the ground.
Equipment Washing -All equipment washing will be perfonncd on a paved area where the wash water
will drain to or be collected in our waste water treatment system. Check with a member of the
'
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appe11dix £: CHSP/CP A-14
I:\ WPGVL \ l'JTI \00625\08\DOI \R0062508001-001E.DOCX Revised November 2010
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Environmental Department to be sure that the area you select does not drain to a storm water collection
system or discharge point.
Asbestos -No asbestos containing materials are to be utilized applied or otherwise installed at the plant
site. We have gone to great lengths to identify, map and label all materials containing asbestos fibers on
the site. An ongoing maintenance program manages all materials containing friable and non-friable
asbestos. We are not asbestos free! The asbestos containing materials are not to be cut, drilled,
hammered or otherwise disturbed in a manner such that fibers or dust will be generated. If work must be
done which would or could disturb any asbestos containing materials, a qualified asbestos removal firm or
maintenance man will be called to safely remove and properly dispose of the asbestos containing material
before your work proceeds. It is the responsibility of your Domtar Representative to include the cost of
proper asbestos removal and disposal in the job or project schedule, scope and budget. Only a Domtar
approved asbestos removal company or properly trained and qualified Domtar employee may repair or
remove asbestos containing materials on the site. For your protection, before beginning work verify that
your Domtar Representative has addressed all potential asbestos related issues. Wynne Shaw coordinates
all asbestos work on our site and should be contacted for more information on our asbestos program and
procedures.
Lead -Regulations for the use, removal and disposal of materials contammg lead are getting more
restrictive to protect people and the environment. Materials containing lead are not to be used in any
potable water system. Paints containing lead are not to be applied on our site or applied to products and
equipment being purchased by Domtar. Paint removal must now be handled similar to asbestos. If paint
or painted material is to be removed or otherwise disturbed, in a manner that fumes, dust or other forms of
paint waste will be generated, it must be tested for lead content. If the paint is found to contain leachable
quantities of lead above regulated levels it must be properly removed, by a Domtar approved contractor,
prior to you perfonning the main task. Waste materials containing 0.5 ppm lead, by the TCLP test, or
more cannot be landfilled on site. Waste materials containing concentrations of 5.0 ppm-mg/I or greater,
by the TCLP test, or I 00 mg/kg, on a total mass basis, or more must be handled as a hazardous waste.
OSHA 's health based standard is 1910.1025 and is to be complied with when dealing with materials
containing lead. It is the responsibility of your Domtar Representative to include the cost of proper paint
removal and disposal in the job or project schedule, scope and budget. For your protection, before
beginning any work please verify that your Domtar Representative has addressed all potential lead paint
related issues. Contact Wynne Shaw for more information on our lead paint program and procedures.
Tanks -Before relocating, installing or removing a tank or changing the contents of a tank to a new
product you must notify or ensure your mill contact has notified the Environmental Department and
Wynne Shaw. Any vessel that could hold more than 55 gallons is considered a tank. There are inspection
records for the tank and spill containment issues, which must be revised. Tank installations and content
changes for existing tanks require a review to see if an air permit is required or a permit revision. Other
permits and regulatory requirements must also be reviewed for compliance with any proposed changes.
Spills and Leaks -All spills and leaks of oil or chemicals must be stopped and contained as soon as
safely possible. Absorbent materials are available in various locations on site for oil and chemical spill
clean up. Polypropylene oil absorbent pads and booms are available for oil spill clean up and
containment. Polypropylene will absorb oil but not water. All spills must be reported by calling 891 I,
your mill contact and/or the Environmental Department as soon as possible for proper reporting and to
obtain instructions for the proper storage and disposal of the waste material. Assistance can be obtained
by calling 891 I, contacting your mill representative, the facility maintenance crew, the main security
R!vlT North Carolina, I11c. l Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-15
I:\ WPGVL \ P/Tl \00625\08\()01 \R0062508001-001E.DOCX Revised November 2010
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guard house or the Environmental Department (at the numbers listed below). The members of the
Environmental Department are scheduled to work first shift, Monday through Friday, and each carries a
cell phone for faster spill response. One member of the Technical Project & Environmental Department
is always on call 24 hrs a day and can be reached in emergency situations by cell phone. In addition,
plant operations and maintenance personnel will respond to lend assistance ifrequired.
Potable water systems shall not be worked on without prior approval from the Environmental
Department. Even in emergency situations you are not to work on a potable water system unless you
know and follow proper material selection and disinfecting procedures. We do not allow any cross
connections between our potable water systems and any process water system. Back flow prevention
devices and hose connections between our potable water system and any process are prohibited. The only
legal way for potable water to be utilized in any process is if an air gap is established between the potable
water distribution system and the process utilizing the water. A proper air gap is where the potable water
must fall through the air before entering the process. The point a which the water leaves the potable water
system must be at a sufficient height above the process so that the process water will never come in
contact with the potable water system (tank overflows and splashing count as contact) to be an approved
air gap. All uses of potable water must be approved by the Environmental Department (monitors and
reports regulator compliance), the Power Department (monitors volumes consumed and provides system
maintenance) and Engineering (keeps the system drawings and documentation updated). See your mill
contact for information on our Cross-Connection Policy, disinfecting procedures and assistance in
material selection, as well as proper approval and documentation.
Wells and holes -At no time is a well to be installed for any reason without prior approval from the
Environmental and Engineering Departments. All wells require permitting or registering with the State of./
North Carolina prior to installation. The volume of water used must be tracked and submitted to the state
monthly. Before digging or drilling any hole deeper than I 2" an excavation permit must be obtained.
Your Domtar Representative will issue the necessary excavation pennits and will coordinate a review of
the proposed location by the Maintenance, Environmental and Engineering Departments who must
inspect and give their approval to the location and disposal of any removed debris. Verifying the location
of underground utilities and compatibility with other planned work is required. Due to the age of the site
and changes in the regulations the Environmental Department must also approve the proposed location
and disposal of removed debris.
Material Safety Data Sheets for every product you bring onto, store, use or come in contact with on the
plant site shall be neatly maintained and stored in your area so that your employees have access to them.
Material Safety Data Sheets arc required for all liquids, gasses, powders and solid materials that could
emit or release a vapor, "rume or dust while being used or worked. To obtain MSDS's for chemicals we
have on site see Delores McCray (8113) in the Environmental Department. As a reminder, all products
must be approved, by utilizing Domtar's chemical approval process, before they are brought on site. As
you eliminate chemicals from use on the plant site Deloris McCray is to be notified so that the MSDS and
chemical inventory tracking systems can be updated.
Radiation Information Notice
This company is licensed to use radioactive material devices in plant instrumentation.
These radioactive sources are installed in lead-filled assemblies that contain the radioactive material and
direct gamma radiation only into the material being measured. Each source housing has a shutter that can
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-16
I:\ WPGVL \P/1'1 \00625\08\001 \ R0062!i0S001·001£.DOCX Revised November 2010
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be locked closed in the event it is necessary to work in a monitored vessel. Adequate protection is
provided by adhering to established lock-out/tag-out procedures.
The radiation produced by the sources is gamma radiation, a form of energy. There is no radon gas or
other radioactive by-product produced in the decay of the sources. Material exposed to the radiation
does not become radioactive.
A number of personnel have been trained in radiation safety. Every effort is made to use these devices in
a safe, conscientious manner and to keep personnel exposures As Low As Reasonable Achievable
(ALARA). If there are questions about the application of these devices, our license, regulations,
procedures, or if anything unusual is observed, the following personnel should be contacted in the order
listed:
Personnel Position Mill Extension Cell Phone Numbers
Mark Radiation Safety Officer 8914 217-3913
Shennard
John Grav Environmental 8870 809-3173
Selected Provisions and Practices from the Radiation Protection Program
All radioactive material, sources, and associated activities are the responsibility of the Radiation Safety
Officer (RSO). No sources shall be brought onto the site except with the approval of the RSO.
All activities involving the use of radioactive materials on-site must be approved in advance by the
RSO. This includes, but is not limited to:
installation, relocation, removal, or repairs to nuclear gauges
contractors providing radiographic inspection services (e.g. x-ray inspections of piping welds)
contractors providing soil compaction measurements using portable nuclear gauges
machine clothing suppliers using portable nuclear gauges (e.g. drainage profilers)
In the event that a source is involved in fire, explosion or other incident, appropriate emergency measures
will be taken to limit employee exposure and to render the source safe (Refer to Plant Emergency
Procedures for Incidents Involving Radiation.).
Lock-out procedures will be established and followed any time personnel may be present in the path of a
radiation beam. Area Maintenance Superintendents are responsible for adequate equipment records,
vessel entry procedures, safety procedures, and lock-out procedures.
In the absence of the RSO, matters relating to Radiation Safety shall be addressed to qualified designees.
RMT Norflt Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-17
I:\ WPGVL \ P/Tl \ 00625 \ OB \001 \R006250800HIOl £.DOCX Revised November 2010
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Storm Water Pollution Prevention
I. Storm water can flow off of the plant site into the nearby swamps, creeks or river through:
sheet flow ( over ground, unorganized, can be wide spread)
point discharge (channeled, passage way which can be natural or man made)
2. The majority of all stom1 water that falls on facility (including Wood Products) is collected and routed
to the wastewater treatment system (exception is Power/Recovery parking area). The only stonn water
discharging through other outfalls is from the outlying (surrounding) properties.
3. The only substances allowed (legally authorized) to discharge through a stonn water outfall other than
rain, include:
uncontaminated ground water,
foundation drains,
air-conditioner condensate without added chemicals,
springs,
discharges of uncontaminated potable water,
waterline and fire hydrant flushings,
water from footing drains,
flows from riparian habitats and wetlands, and
discharges resulting from fire-fighting or fire fighting training.
4. The most important Best Management Practices to always carry out include:
Good housekeeping, don't leave stuff lying around, especially drums,
Store all chemicals and fuels properly, in containment, away from storm drains, use drip pans, and
Conduct maintenance under shelter as much as possible.
5. The most important Preventative Maintenance Activities to always implement include:
Repair leaks from vehicles, machines, tanks, piping, etc, ASAP, use drip pans,
Keep storm water collection devices in good working order, cleaned out, empty, and
Inspect and maintain berms, rip rap, ditches, dams, curbs.
6. The most important Spill Prevention, Response and Clean Up Procedures to carry out include:
Call your mill representative, the Environmental Department or 8911 in the event of any spill or
unauthorized discharge to a storm water outfall,
Maintain a facility-wide, up-to-date, Comprehensive Emergency Management Plan,
Provide and maintain containment around potential spill sources and divert spills from stonn
water outfalls,
Keep spill and cleanup materials in stock and available, and
Maintain a trained spill response team onsite.
7. Storm water outfalls at greatest risk of pollution include:
Outfalls surrounding contractor laydown areas which drain into the nearby wetlands and swamps,
External coal pile area ditch discharge into nearby swamp,
Wood recycle storage area (on haul road to landfill) which drain into nearby creek,
Norfolk Southern Rail Yard, east end of mill, which drains into nearby swamp and eventually into
Welch Creek, and
Outfalls surrounds #3 landfill.
West Contractor Lav Down Arca Restrictions
No penetration or any other alteration of the surface of this area will be permitted. This surface serves as
a new cover system for an old landfill that was recently remediated to meet the requirements of US EPA.
Rlv1T North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appe11rlix E: CHSP/CP A-18
/:\ WPGVL \P/TJ \00625\08\ 001 \R0062508001-001[,D0CX Revised November 2010
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Cluster Rule Best Management Practices (BMP)
The BMP's are Cluster Rule requirements for the Pulp and Paper Industry that are intended to prevent
and/or contain leaks and spills of black liquor, soap and turpentine and to control intentional diversions of
these materials. The intent is to prevent these materials from getting into the wastewater treatment system
in amounts that could jeopardize its performance. There are ten basis BMP requirements that are as
follows:
I. Return spill or diverted black liquor, soap and turpentine to process.
2. Establish program for regular visual inspections of applicable equipment.
3. Operation of a continuous monitoring system needed to detect and control leaks, spills and
intentional diversions.
4. Initial and annual employee training.
5. Spill reporting to regulatory agency.
6. Process to review planned facility changes for spill and leak prevention during construction.
7. Secondary containment for turpentine bulk storage tanks.
8. Annual tank integrity testing for black liquor bulk storage tanks when coupled with diversion and
containment structures.
9. Curb, dike and isolate soap and turpentine processing areas from wastewater system.
I 0. Mill must conduct influent wastewater monitoring to detect leaks and spills.
Contractors visiting or working at the Plymouth site are expected to understand and comply with the
mill's BMP Plan and practices. Contractors working in areas that have black liquor, soap or turpentine
will be required to receive additional BMP and annual refresher training related to the specific area.
Please contact your mill representative or the environmental department for additional BMP training.
Contacts
Environmental Department:
PHONE CELL/PAGER
PAGER
John Gray 8870 809-3173 Oil and fuel containment, Emergency Response,
Wastewater Treatment Dredging and Dewatering Operations
Environmental Manager Diane Hardison
Alan Barnes
8611
8638
217-7820
661-3681 Wastewater Treatment System, Sewers, Groundwater,
Drinking Water, Lab
Johnnie Brown 8331 809-3614 Wastewater System Sampling and Analysis
Deloris McCray 8 I I 3 MSDS 's & chemical approval process, Landfill Scales
Don Wynne 8984 945-0830 Air em1ss10ns and reporting, Cluster Rule Best
Management Practices, and Refrigerant Management
Bill Morris 8494 217-7482 Universal, Solid and Hazardous Wastes, Landfill
Tamika Boone 7490 799-1249 General Air, Wastewater,
Water, Storm water
Other:
Mark Sheppard 8914 217-3913 Radiation Safety Officer
Wynne Shaw 8912 24 426 Asbestos, lead & ASME tank inspection programs
Security Guard 8202 24 339 Fire, EMT's & HazMat -Emergency Response
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-19
Drinking
I;\ WPGVL \P/TI \00625\08 \LJ01 \R0062508001·00ll:.DOCX Revised November 2010
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Emergency Response 891 I Fire, EMT's, HazMat, & Environmental Response
Kelvin Outlaw 8848 24 656 Safety Manager -Emergency Response
Mike Nihoa 8560 217-3748 Facility Services Superintendent
Harry White 7144 809-9 I 21 Facility Services Supervisor
Env. Person on Call See weekly Call Duty List Emergency assistance -night & weekend
IF IN DOUBT, ASK! IF IN DOUBT, ASK!
6.0 CONTRACTOR SAFETY ORIENTATION CHECKLIST
6.1 GENERAL SAFETY
6.1.1 Review Contractor's safety program.
6.1.2 Discuss construction safety requirements per safety manual.
Provide copy.
6.1.3 Discuss Domtar Medical Center availability and location
-8235.
6.1.4 Emergency Medical Response
I 6.1 .4.1 Review mill ambulance pick-up points and provide copy.
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6.1.4.2 Emergency number -8911.
6.1.5 Emergency -Fire Department
6.1.5.1 Emergency number -8911
6.1.6 Obtain and evaluate MSDS's provided by contractor as appropriate.
6.1.6.1 Inform Contractor of the availability of Domtar MSDS's
on the Dolphin system.
6.1.7. Discuss all hazards found in work area to include:
6.1. 7.1 Chemicals
6.1. 7.2 Asbestos
6.1.7.3 Noise
6.1.7.4 High Heat
6.1.7.5 Automatic Machinery
6.1.7.6 Vehicular Traffic
6.1.8 Discuss vessel labeling system used in mill
(Refer to Hazard Communications Program).
6.1.9 Discuss any appropriate protective measures for hazardous
substances in the area.
(Example: escape respirator for Chlorine Gas).
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix£: CHSPICP A-20
/:\ WPGVL \P/TI \00625\08\001 \R0062508001-00IE.DOCX Revised November 2010
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6.2
7.0
6.1.10 Discuss Emergency Response Plan for the area(s):
6.1.10.1 Alarms in the area
6.1.10.2
6.1.10.3
ENVIRONMENTAL
Evacuation routes out of the area
Assembly areas
6.2.1 Discuss handling procedures for waste chemicals that are part of the
Contractor's contract.
6.2.1.1 Contact: Environmental Group (8611)
6.2.2 Discuss chemical spill procedures
6.2.2.1 Contact: Environmental Group -days: (8611)
Environmental Call Duty on nights and weekends
(sec weekly call duty list)
CONSTRUCTION SECURITY PROCEDURE & REGULATIONS:
7.1 The following items are prohibited and are grounds for immediate removal from the premises:
-Alcohol, drugs or fiream1s will not be allowed on Domtar property.
Cameras of any kind without expressed written consent from Domtar Management.
Harassment
Unsafe vehicle operations/ speeding.
Fighting on Domtar property.
Smoking in prohibited areas.
Failure to use proper sanitary facilities.
Misuse of manlifts.
Failure to observe Owner's regulations.
7.2 Access I Vehicles
A. All Contractor personnel are required to enter and leave the mill premises through the
designated construction road personnel gate only. Only the driver of the vehicle may accompany
the vehicle through the gate.
B. All Contractor employees are required to park outside of the West Contractors gate in designated
parking lot.
C. All Contractor vehicles shall enter and leave the mill through the designated West Contractors
Gate only. Each shall be issued a mill pass by the STOC receptionist. Domtar owner's
representative for said contractor must be contacted and approve all permits.
D. Vehicles will be required to have Contractor's logo or name on both sides of vehicle.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix£: CHSP/CP A-21
I:\ IVPGVL \ PJT1 \00625 \OS\ 001 \R0061508001-001 £.DOCX Revised November 2010
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8.0
7.3
7.4
7.5
7.6
7.7
E. Vehicles containing tools or materials must have an egress pass before leaving the mill. Egress
passes can be obtained from the owner's representative.
F. All vehicles, tool boxes and lunch boxes will be checked on entry and exit to the mill.
G. Pipe, steel, wood or other materials that extend two (2) feet or more from the rear of the truck or
other vehicle must be red flagged.
Nonna I hours of operation: Monday -Friday 6:00 am -6:00 pm. Domtar contractor representative
must contact Security for contractor admittance after hours.
In any event of security infractions or assistance needed, Security may be contacted by calling Main
Gate at 8202 or 8203 from any mill phone. Outside line use 793 prefix.
All deliveries for Contractor jobs will go to the West Contractors gate and be met there by
Contractor.
Contractor's hiring of labor not permitted at West Contractors gate.
Contractor is not to block railroad tracks without prior approval from Domtar I Project Manager. A
blue light must be flashing at the location of the blocked track.
CONTRACTOR CHECKLIST
8.1
8.2
8.3
8.4
This checklist will be completed in full with all signatures properly affixed.
The following personnel will review and fill out the checklist:
Phone
Office Home Radio
8.2.1 Contractor's Supt.: _____________________ _
8.2.2 Signature:. _______________________ _
8.2.3 Domtar's Representative/Project Manager: ________ _
8.2.4 Signature:. _______________________ _
8.2.5 Domtar's Operating Supt.:. ________________ _
8.2.6 Signature.: _______________________ _
Project Title:. ______________________ _
Date of Work: ____ _ thru _____ Work Area: ______ _
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-22
/:\ WPGVL \PJTT \00625\08\001 \R0062508001-00IE.DDCX Revised November 2010
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8.5
8.6
8.7
8.8
8.9
Contractor1s Name:
8.5.1 Home Office Address:
8.5.2 Home Office Phone No.:
8.5.3 Home Office Project Contact:
8.5.4 Emergency Contact & Phone No.:
8.5.5 Contractor's Mill Phone No.:
8.5.6 Contractor's On-Site Supervisors:
EMERGENCY PHONE NOS:
FIRE -891 I ' FIRST AID -8911
AMBULANCE -891 I (SEE MAP FOR PICK UP STATIONS.)
REPORT ACCIDENTS TO: ____________ _
DOMTAR COMPANY REPRESENTATIVE/PROJECT MANAGER
NAME PHONE RADIO
Representative/Project Manager
SAFETY:
8.8.1 Refer to 1.0 "Construction General Safety Requirements".
8.8.2 Any potential safety hazards to Domtar's employees:
8.8.3 Special safety equipment required: _________________ _
PROCESS CONTAMINATION
8.9.1 Frequency of inspection of production process for possible contamination:
(per shift, day, or weekly) ___________________ _
8.9.2 List points of possible contamination: (open conveyors, vessels or other devices). __ _
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Pinn
Appendix E: CHSP/CP A-23
/:\ WPGVL \PJTI \00625\08\001 \R006250SOOJ-OOlE.DOCX Revised November 2010
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8.9.3 Special Equipment to be used on job:
Contractor supplied:
8.10 CLEAN-UP REQUIREMENTS:
8.10.1 Clean-Up will be ______________ responsibility.
8.10.2 List what will be cleaned up:
8.10.3 Frequency of clean-up: ________________ _
8.10.4 Method of clean-up: --------------~~--
8.11 ALCOHOL AND/OR CONTROLLED SUBSTANCE CERTIFICATION
8.11.1 The following signature is affixed by authorized Contractor Representative for
documentation of compliance with article 1.2:
__________________ (signature).
8.12 MILL SITE "VEHICLE PASS" POLICY:
8.12.1 Vehicle passes issued will be to individual vehicles and will be assigned to the specific
person responsible for that vehicle.
8.12.2 Vehicle passes must accompany all vehicles in the plant, but must be returned upon job
completion at exit interview to insure full payment of final project invoice.
8.12.3 Contractor's Name:
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-24
1: \ WPGVL \ P/TI \ 00625 \ OS \001 \R0062508001-001 E.DOCX Revised November 2010
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Type of Vehicle Vehicle Pass No
RMT Nortfl Carolina, Inc. I Domtar Paper Compa11y, LLC
Remedial Action Work Pinn
Appendix£: CHSP!CP A-25
I;\ WPGVI. \ P/Tl \ 00625 \ 08 \ 001 \ R0062508001-001 £.DOCX
Dates
Pass Is Valid
Dates
Pass Is Returned
Revised November 2010
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8.13 CONTRACTOR EMPLOYEE'S NAME
(or computer printout of same)
8.13.1 This sheet is required to be completed by the end of the first day.
Brass No.
8.13.2 The Contractor is responsible to keep this list updated prior to the arrival of a new employee and to
remove names as required.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-26
/:\ Wl'CVI. \l'fTI \00625\ 08 \VVl \R0062508001·001 [.DOCX Revised November 2010
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Contractor Inspection Checklist
Contractor Name: ___________ _ Date: ______ _
Site Inspected: ____________ _ Time: ______ _
Completed By: __________ _
Item Yes/No orN/A Notes
1. Supervisor on job site?
2. All employees wearing proper PPE?
3. Proper permits on job site?
(Hot Work, Excavation, Confined Space etc.)
4. Hole watch/fire watch on duty, alert and knowledgeable? ____ _
5. Equipment properly locked out/tagged out?
6. Electrical connections/cords in good condition?
7. Barricade areas properly marked off?
8. Scaffolding properly installed/labeled?
9. Ladders properly used?
I 0. Tools used properly and in good condition?
11. Mobile equipment operated safely?
12. Labels affixed to chemical containers?
13. Good Housekeeping (lfno, cite specific problem)
14. Safe behaviors/ work practices observed?
15. Substandard acts/conditions corrected?
Other items / comments:
Discussed with Contractor Supervisor: ________________________ _
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-27
I:\ WPCVI. IP/Tl \00625\ OS\001 \H.006250800/·001£.DOCX
(Name)
Revised November 2010
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PROCESS SAFETY MANAGEMENT
TRAINING DOCUMENTATION
Exhibit I
The following employees has received and understood the training required to safely perfonn their jobs.
Each employee has been instructed in the known potential fire, explosion, or toxic release hazards related
to his/her job and the emergency action plan. The Contractor Safety lnfonnation Verification fonn was
used to verifv the emnlovee's understanding of the safety information.
Em11lovee Name ID Number EmJlloyee Name ID Number
Contractor ________________ _ Date. _________ _
Contract Supervisor __________________________ _
RlvlT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix£: CHSP/CP A-28
/:\ Wl'GVL \l'}Tl \00625\VS\0()1 \R0062.'iOS001-0m £.DOCX Revised November 2010
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True False
T F
T F
T F
T F
T F
T F
T F
T F
T F
T F
PROCESS SAFETY MANAGEMENT
CONTRACTOR SAFETY INFORMATION VERIFICATION
Circle "T" if the statement is TRUE, circle "F" if the statement is FALSE.
I. Written hazard communication programs are developed for each specific workplace.
2. Cracked wooden handles on personal tools may be repaired with duct tape.
3. A Material Safety Data Sheet gives specific information regarding the physical and
chemical properties of the substance.
4. Under no circumstances can trade secret information ever be revealed.
5. Employees must be provided with specific infonnation and training regarding the
potentially hazardous substances used in their work areas.
6. Material Safety Data Sheets identify precautions necessary for the safe use, handling,
and storage of potentially hazardous substances.
7. Warning labels used on containers of potentially hazardous substances must always give
recommendations for appropriate protective devices.
8. The emergency phone number for first aid is 8911.
9. A body harness is not required unless the employee is exposed to a fall of at least 1 O feet
or greater.
10. Employers must develop a list of all the hazardous chemicals used in a specific
workplace.
VERIFICATION RESULTS
Questions answered correctly ______ Percent of total, _____ _
(Note: A score of80 or above is required.)
I hereby state that I have received and understood the safety information related to my job.
Signature. _________________ Date ______________ _
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CI' A-29
l:\ WPGVL \PJT1 \00625\08\00J \R006250800l-001£.D0CX Revised November 2010
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Multiple Choice: Circle the correct answer to the following questions.
I. Which of the below listed items is not considered to be personal protective equipment?
a. Hard hat.
b. Safety toe shoe/boots.
c. Pocket knife.
d. Eye/ear protection.
2. Noise protection is required when:
a. Posted.
b. While working with or around high-noise level producing machines.
c. While using a grinder.
d. All of the above.
3. Respiratory protection is to be used by employees for protection against:
a. Dusts, fumes.
b. Vapors, gases.
c. Mists, oxygen deficiency.
d. All of the above.
4. Good housekeeping is the responsibility of:
a. The labor crew.
b. The foreman.
c. Everyone.
d. The helpers.
5. A fire watch:
a. Will remain in their work area for at least 30 minutes after hot work has stopped.
b. Is required to know the types of fire extinguishers for different types of fires.
c. Will not leave their assigned area without relief.
d. All of the above.
6. Chlorine Dioxide:
a. Is a yellow-green to orange gas or a liquid with a sharp odor similar to Clorox.
b. Is dangerous if not handled correctly.
c. Will cause eye irritation.
d. All of the above.
7. Chlorine Dioxide is produced or used in the process at the following locations:
a. #6 Bleach Plant.
b. #7 Bleach Plant.
c. North Chem Prep.
d. All of the above.
8. Material Safety Data Sheets can be found:
a. In the control rooms of the operating areas.
b. At Domtar's Safety Department
c. In the MMS Computer
d. All of the above.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Acti011 Work Pla11
Appendix E: CHSPICP A-30
/:\ WPGVl. \P{Tl \00625\08\001 \R006250SOOl--OOIE.DOCX Revised November 2010
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9.
IO
II.
12.
13.
14.
15.
Smoking will be allowed:
a. In designated areas only.
b. Areas where hot work permits have been issued.
c. In the port-a-john.
d. Both a. and b.
Cutting, welding, and burning does not require:
a. Hot work pennit.
b. Fire retardant clothing.
c. Long sleeves covering arms.
d. A hard hat.
Prior to entering a confined space:
a. The area is to be checked ( atmospheric testing) by a competent person.
b. Adequate ventilation will be provided.
c. Proper lighting installed and a competent person assigned as a hole watch.
d. All of the above.
Prior to operating any valve, switch, or perfonning work on a piece of equipment you should:
a. Check with your supervisor.
b. Lock, tag-out, and push the start button for the items you are to work on.
c. Check to _see that wiring leads have been disconnected.
d. Have your supervisor tag-out the equipment
When fueling equipment, you should not:
a. Shut down the equipment.
b. Set the brake.
c. Leave the switch on so you can tell when the equipment is full.
d. Use only proper containers to handle fuel.
Emergency phone number charts are posted throughout the mill and on all telephones. In the event
of an emergency you should.
a. Check the emergency phone numbers for adequate assistance, dial the number, state your name
and the nature of your call and your location.
b. If able, give a brief survey of the situation. Wait-be sure you have given all important
information. Do not hang up until the person you called does so first.
c. Do not panic, leave, or move the injured person more than necessary until professional help
arrives.
d. All of the above
Which is not true of chlorine?
a. ls used to purify water.
b. Liquid chlorine is as safe to handle as Clorox.
c. ls used at the Demineralizer and the Filter Plant.
d. Inhalation of high concentrations of chlorine gas may cause death.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix£: CHSP/CP A-31
1: \ WPGVL \ P/Tl \ 00625 \08\ 001 \ R006250800I •001 £. DOCX Revised November 2010
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16. Hydrogen Peroxide is used at:
a. #6 Bleach Plant
b. #7 Bleach Plant
c. Both a. and b.
d. Neither a. orb.
17. Hydrogen Peroxide:
a. May cause fire if it comes in contact with clothing or combustibles.
b. Causes skin and eye irritation when in contact.
c. Requires protective clothing when there is potential contact with skin or eyes.
18.
19.
20.
d. Alloftheabove.
All injuries shall be:
a. Reported to your supervisor immediately.
b. Reported to the project first aid office immediately.
c. Both a. and b.
Excavation and trenches:
a.
b.
C.
Requires an excavation pennit.
Do not have to be barricaded.
Both a. and b.
In the event of an emergency evacuation:
a. Do not cross between equipment units, use walkways and roadways when possible.
b. Go cross wind of any chemical release.
c. Assemble at your pre-determined assembly point for head count. Do not leave until an all
clear has been given.
d. All of the above.
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-32
/: \ WPGVL \ PJTI \ 00625\08\001 \ R0062508001-00l E.DOCX Revised November 2010
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Answers to True-False Questions
I. T 6. T
2. F 7. T
3. T 8. T
4. F 9. F
5. T 10. T
Answers to Multiple Choice Questions
I. C 11. d
2. d 12. b
3. d 13. C
4. C 14. d
5. d 15. b
6. d 16. C
7. d 17. d
8. d 18. C
9. d 19. a
10. b 20. d
RMT North Carolina, foe I Domtar Paper Company, LLC
Remedinl Action Work Plmi
Appclldix E: CHSP/CP A-33
/: \ WPGVL \ P/Tl \ 00625 \ OS \001 \ RD062508001-001 £. DOCX Revised November 2010
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PROCESS SAFETY MANAGEMENT
CONTRACTOR'S PROGRAMS COMPLIANCE AUDIT
Mark the "Yes" or "No" to each of the following PSM audit guideline questions.
A.
Yes
Yes
Yes
Yes
Yes
Yes
B.
Yes
Yes
Records Review
No 1. Are all contractor employees trained in the work practices necessary
Comments:
No 2.
Comments:
No 3.
Comments:
No 4.
Comments:
No 5.
CommentS:
to perfonn their jobs safely?
Is each contract employee instructed in the known potential fire,
explosion, or toxic release hazards related to his/her job and the
processes and applicable provisions of the emergency action plan?
Is there documentation that each contract employee has received and
understands the required training.
Do the contract employee training records contain the following:
The identity of the employee?
The date of training?
The means used to verify that the training was understood?
Are there means to assure that contract employees follow the safety
rules of the facility, including safe work practices?
(Review evidence of enforcement by the contractor.)
No 6. Is the employer advised of any unique hazards presented by the
contract employer's work or any hazards found by the contract
employer's work?
Comments:
On-site Conditions
No 1. Based on a representative sample of observations of contractor employees,
has the employer1s program to control their entrance, presence, and exit
been implemented?
Comments:
No 2.
Comments:
Based on a representative sample of observations of contractor employees,
do they follow the safety rules (lockout/tagout, confined space entry, hot
work pcnnits, etc.) of the facility?
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Ap11cndix E: CHSPICP A-34
Exhibit 3
f:\ WPGVL \P/TT \00625\08\001 \R006250SOOHJOT E.DOCX Revised November 2010
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C. Interviews
Yes
Yes
Yes
Yes
Yes
Yes
No I. Based on interviews with contractor employers, have they been informed of the
known fire, explosion, or toxic release hazards related to their work and the
processes in which they are involved?
Comments:
No 2.
Comments:
No 3.
Comments:
No 4.
Comments:
No 5.
Comments:
No 6.
Based on interviews with contractor employees, have they been informed of the
applicable provisions of the emergency action plan?
Based on interviews with contractor employers and employees, have work practices
to control their entrance, presence, and exit of covered process areas been
implemented?
Based on interviews with a representative number of contractor employees, are they
being instructed in the known potential fire, explosion, or toxic release hazards
related to their work and the processes in which they are involved?
Based on interviews with a representative number of contractor
employees, have they been instructed in the applicable provisions of
the emergency action plan?
(Ask them to explain the plan and evacuation procedures.)
Based on interviews with a representative number of contractor
employees, has the contract employer assured that they follow the
safety rules of the facility?
(Ask how safe work practices, entry restrictions for the facility, and
use ofrequired PPE are enforced.)
Comments:. ________________________ _
Type of audit:
___ a) Initial -completed before work begins (page I only).
__ b) Periodical (pages I to 3).
Domtar representative performing the audit, ________________ _
Contractor being audited, _______________________ _
Contractor representative. ________ Date of audit, _____________ _
Total number of "Yes" answers. ____ Overall rating(% of total questions), __ _
This record is to be kept on file for 6 months after completion of contract work.
Note: Use additional sheets to make comments if needed.
RMT North Carolina, l11c. I Domtar Paper Company, LLC
Remedial Action Work Plfln
AppcHdix E: CHSP/CP A-35
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Exhibit 4
This is an online form available from the Plymouth's Intranet home page.
Plymouth Facility Safety Incident Investigation Report Form
Name of Person Reporting Department Incident No. (To be
Incident assigned by Ken
Laton)
(Select Department from "Drop Down"
listing)
Primary Type of Incident Severity Level
(Select Incident Type from (Select Severity Level from "Drop Down" listing)
"Droo Down" listi1rn)
Exact Location of Incident Date/ Time of Incident Date Reported Date of
AM
PM
Facility Condition
(Select Facility Condition from "Drop Down" listing)
Sequence of Events (describe what happened before, during and after the incident)
Primary Type Of' Contact
(Select Contact Type from "Drop Down" listing)
Cause(s) of Incident (indicate all substandard behaviors and substandard condition,)
Basic or Root Causes (factor.,)
Recommendations {actions short term, intermediate, By When
and long term)
Approvals
Investigation Leader's Signature
Safety Committee Representative's Signature
Approved By Next Level Manager (for a level I & 2 incident,
must be hiio levels above team leader)
RMT North Cnroli11n, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix£: CHSP!CP A-36
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Compl.
Date
Date
Date
Date
Investigation
By Whom
Revised November 2010
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Plymouth Facility Safety Incident Investigation Report Form
(continued)
This Page To Be Completed For All Injuries Or Illnesses:
1 f lnjury/lllness, Enter Person's Name OSHA Recordability of
lnjury/lllness
(Select OSHA
Rec?rdability from "Drop
Down" listing)
EHS Job/Task I Time On Task (Hours) Years Experience
Hours Years
Lost Days Restricted Days Lost/Restricted Time Lost/Restricted Time
Start Date End Date
Part of Body Affected
Agency of Injury/Illness
When finished, click the Send Form button to submit the fonn to the appropriate ~ :·~_11dtir~~,
people .
(Kelvin Outlaw, Ken Laton, and Shirley Davenport)
RlvlT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP A-37
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Page 2 of2
Revised November 2010
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Exhibit 5
CONTRACTOR SAFETY PERFORMANCE
Note: Report Due Not Later Than 4:00 PM Thursday Of The Current Work Week.
DATE. _______ _ REPORTING
COMPANY NAME WEEK# _____ _
DOMTAR
CALENDAR WEEK
Person Reporting ___________________ _
(Signature of Responsible Manager or Contractor)
Current Week Year-To-Date
* FIRST AIDS
...........................
* RECORDABLE
INCIDENTS .......
* LOST TIME INCIDENTS
............
* TOTAL WORK HOURS
............
*Attach copy of investigative report or other pertinent data; SEND ORIGINAL TO
SAFETY DEPT.
DETAILS
WORK PROJECT DOMTAR PROJECT/ WORK
HOURS NUMBER PROJECT LOCATION
PER PROJECT MANAGER
TOTAL WORK HOURS FOR CURRENT WEEK
If Safety Orientation Compliance Met (Check)
RMT North Caroli11n, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSP/CP
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A-38
Revised November 2010
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COMMENTS
(Do not write below this line)
Return to: ------"D"o"m'-'-"ta.,r...,S"a"'l,""e"-ty'-"D"e"p"'a"-rt"-m"e""n"'t'---------
Address: PO Box 747, Plymouth, N.C. 27962
Email: [e-mail]
(3/01)-(Rev. 7)
RMT North Carolina, Inc. I Domtar Paper Company, LLC
Remedial Actim1 Work Pinn
Fax [phone]
Appendix E: CHSP/CP A-39
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RMT North Caroli11a, Inc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CI-ISP/CP
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Attachment E-2
Spill Contingency Plan
Revised November 2010
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..... ·•
RMT
~
•ENVIRONMENT• ENERGY• ENGINEERING
Spill Contingency Plan
Welch Creek Area OU-4
Plymouth, Martin County, North Carolina
RMT North Caroli11n, Inc. I Domtar Corporation
Final
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July 2010
© 2010 RMT, Ille.
All Rig/its Re~en,ed
150 N. Patrick Boulevard, Suite 180 • Brookfield, WI 53045-5854 • [phone] • [phone] FAX• www.rmtinc.com
CREATING BALANCE'"
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Table of Contents
1. Introduction ...................................................................................................................................... 1
1.1 Purpose and Scope ................................................................................................................ 1
1.2 Resources at Risk ................................................................................................................... 1
1.3 Risk Assessment .................................................................................................................... 2
1.4 Response Strategy ................................................................................................................. 2
2. Spill Discovery and Response ........................................................................................................ 3
2.1 Distribution of Responsibilities ........................................................................................... 3
2.2 Response Activities ............................................................................................................... 4
2.2.1 Discharge Discovery and Source Control. ............................................................ 4
2.2.2 Assessment and Notifications ................................................................................ 5
2.2.3 Control and Recovery .............................................................................................. 5
2.2.4 Disposal of Recovered Product and Contaminated Response Material .......... 6
2.2.5 Termination ............................................................................................................... 6
2.3 Discharge Notification .......................................................................................................... 7
3. Response Resources and Preparedness Activities ...................................................................... 8
3.1 Equipment, Supplies, Services, and Manpower ............................................................... 8
3.2 Access to Receiving Waterbody .......................................................................................... 9
3.3 Communications and Control ............................................................................................. 9
3.4 Updating Procedures ............................................................................................................ 9
3.5 Reporting Requirements .................................................................................................... 10
List of Appendices
Appendix A Emergency Contacts
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1.1 Purpose and Scope
Section 1
Introduction
This Spill Contingency Plan is prepared in accordance with 40 CFR 112.7(d) to address areas of
the operations that may potentially cause a release where secondary containment is
impracticable or prevent a release from an undocumented source during excavation activities.
The purpose of this Spill Contingency Plan ("Contingency Plan") is to define procedures and
tactics for responding to discharges of oil into navigable waters or adjoining shorelines of the
United States, originating more specifically from land based sources in association with the
Welch Creek remedial activities. The Contingency Plan is implemented whenever a discharge
of oil has reached, or threatens, navigable waters or adjoining shorelines.
The objective of procedures described in this Contingency Plan is to protect the public,
RMT North Carolina, Inc. (RMT) personnel and subcontractors, and other responders during oil
discharges. In addition, the Contingency Plan is intended to minimize damage to the
environment, natural resources, and the Domtar Mill property from a discharge of oil. This
Contingency Plan addresses areas of the facility that have inadequate secondary containment
and where impacts may result from a discharge in these areas. Contractor equipment rentals
implement a detailed and stringent maintenance program to prevent leaks. Areas where a
potential release could occur include hydraulic or gasoline leaks associated with heavy
equipment working within the equipment staging area, near, or on the adjacent waterways.
This Contingency Plan follows the content and organization of 40 CFR Part 109 and describes
the distribution of responsibilities and basic procedures for responding to an oil discharge and
performing cleanup operations.
1.2 Resources at Risk
The Welch Creek area (OU-4) is located on the eastern portion of the Domtar site. The entire
manufacturing facility is located in a low-lying area near the confluence of Welch Creek and the
Roanoke River. The drainage basin for Welch Creek is comprised of flat, low-lying terrain
typical of the Tidewater Region within the Coastal Plain Physiographic Province of North
Carolina with 5 to 15 feet of relief. Welch Creek is a slow-moving, blackwater stream, similar to
other creeks and tributaries that drain the swamp and upland areas adjacent to the lower
reaches of the Roanoke River. The confluence of the creek with the Roanoke River is located
approximately 7 miles up-river from the Albemarle Sound. In the area defined as OU-4 (4.5
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miles from the Highway 64 Bridge crossing to the confluence with the Roanoke River), the
Welch Creek averages approximately 120 feet in width, has an average maximum depth of
about 10.5 feet, and is bordered by wetlands approximately 1,000 feet in width.
Welch Creek is not used in the immediately area as a public drinking water supply, but is does
flow into the Lower Roanoke River where a number of cities depend on it for drinking water.
In the immediate vicinity and downstream from the Domtar facility the waterway does provide
habitat for a number of aquatic species and mammals and are used by local residents for
fishing.
No residences are located in the immediate vicinity of the facility. RMT will coordinate with the
Plymouth fire and/or police departments and with nearby residential neighbors to provide the
appropriate warnings in the unlikely event of a discharge that could affect public health and
safety.
1.3 Risk Assessment
A discharge of hydraulic fluid or other small quantity fluid from the construction equipment
would be at the greatest risk of potentially reaching Welch Creek. Due to the vicinity of the
construction equipment and Welch Creek, depending upon the specific action, this release
would be immediate and partially contained within the silt curtain and on land using
appropriate spill countermeasures.
1.4 Response Strategy
RMT personnel are equipped and trained to respond to certain "minor discharges" confined
within the facility. Minor discharges can generally be described as those where the quantity of
product discharged is small, discharged material can be easily stopped and controlled, the
discharge is localized, and the product is not likely to seep into groundwater or reach surface
water or adjoining shorelines. Procedures for responding to these minor discharges are covered
below.
This Contingency Plan addresses all discharge incidents, including those that affect navigable
waters or during which the oil cannot be safely controlled by facility personnel and confined
within the boundaries of the facility. Response to such incidents may necessitate the assistance
of outside contractors or other responders to prevent imminent impact to navigable waters.
RMT North Caroli11a, Inc. I Domtar Corporation
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Section 2
Spill Discovery and Response
2.1 Distribution of Responsibilities
RMT has the primary responsibility for providing the initial response to oil discharge incidents
originating during its construction operations. To accomplish this, RMT has designated the
Project Manager, Jim Hutchens, as the qualified oil discharge Response Coordinator (RC) in the
event of an oil discharge.
The RC has the authority to commit the necessary services and equipment to respond to the
discharge and to request assistance from Plymouth fire and/or police departments, contractors,
or other responders, as appropriate.
The RC will direct notifications and initial response actions in accordance with training and
capabilities. In the event of a fire or emergency situation that threatens the health and safety of
those present at the site, the RC will direct evacuations and contact the fire and police
departments.
In the event of an emergency involving outside response agencies, the RC's primary
responsibility is to provide information regarding the characteristics of the materials and
equipment involved and to provide access to RMT resources as requested. The RC shall also
take necessary measures to control the flow of people, emergency equipment, and supplies and
obtain the support of the Plymouth police department as needed to maintain control of the site.
These controls may be necessary to minimize injuries and confusion.
Finally, the RC serves as the coordinator for radio communications by acquiring all essential
information and ensuring dear communication of information to emergency response
personnel. The RC has access to reference material at the field office either as printed material
or on computer files that can further assist the response activities.
Whenever circumstances permit, the RC transmits assessments and recommendations to RMT
Senior Management for direction. Senior Management is contacted in the following order:
1) Client Service Manager; 2) Client Project Manager.
In the event that the RC is not available, the responsibility and authority for initiating a
response to a discharge rests with the most senior RMT employee (e.g., Construction
Superintendent) on site at the time the discharge is discovered.
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2.2 Response Activities
In the event of a discharge, the first priority is to stop the product flow and to shut off all
ignition sources, followed by the containment, control, and mitigation of the discharge. This
Contingency Plan breaks actions to be performed to respond to an oil discharge into different
phases, described in greater detail in the checklists below.
2.2.1 Discharge Discovery and Source Control
Minor Discharge - A minor discharge (i.e., small volume leak from construction
equipment) will be discovered by RMT construction personnel or by contractor
personnel during scheduled inspection activities and observation of proper equipment
operation.
Major Discharge -Due to limited quantities of chemicals on site, a major discharge is
unlikely. In the event of a more severe or sudden discharge, all construction operations
will stop immediately and the discharge will be addressed immediately and appropriate
regulatory contacts will be notified according to Appendix A.
Notifications to the National Response Center, North Carolina authorities, and
Plymouth Emergency Committee must occur immediately upon discovery of reportable
discharges.
Completed Actions
Immediately report the discharge to the RC, providing the following information:
• exact location;
• material involved;
• quantity involved;
• topographic and environmental conditions;
• circumstances that may hinder response; and
• injuries, if any .
Turn off all sources of ignition.
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2.2.2 Assessment and Notifications
Completed Actions
Investigate the discharge to assess the actual or potential threat to human health or the
environment:
• location of the discharge relative to receiving water bodies;
• quantity of spilled material;
• ambient conditions (temperature, rain);
• other contributing factors such as fire or explosion hazards; and
• sensitive receptors do\-vnstream .
Request outside assistance from local emergency responders, as needed.
Evaluate the need to evacuate facility and evacuate employees, as needed.
Notify the fire/police departments to assess whether community evacuation is needed.
Notify immediately:
• USEPA Onsite Coordinator and NCDENR;
• National Response Center;
• Response contractor(s); and
• State authorities .
Depending upon spill location, communicate with neighboring property owners
regarding the discharge and actions taken to mitigate the damage.
If the oil reaches (or threatens to reach) Welch Creek, notify the local fire/police
departments to limit access to the River by local residents until the oil has been
contained and recovered. Also contact the Domtar On-site Contact. Additionally,
notify downstream water users of the spill and of actions that will be taken to protect
these downstream receotors.
2.2.3 Control and Recovery
The RC directs the initial control of the spill by RMT and other contractor personnel. The
actions taken will depend on whether the spill has reached water or is still on land. All
effort will be made to prevent the spill from reaching water.
If the oil has not vet reached water:
Completed Actions
Deploy sand bags and absorbent socks downgradient from the spill, or erect temporary
barriers such as trenches or mounds to prevent the spill from flowing towards Welch
Creek.
Implement land based response actions (countermeasure) such as digging temporary
containment pits, ponds, or curbs to prevent the flow into the river.
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Completed Actions
Deploy absorbent sock and sorbent material along the shoreline to prevent oil from
entering waters.
If the oil has reached water
Completed Actions
Contact cleanup contractor(s).
Deploy floating booms immediately downstream from the release point.
Control oil flow on the ground by placing absorbent socks and other sorbent material
or physical barriers (e.g., "kitty litter," sandbags, earthen berm, trenches) across the
spill path.
Deploy protective booming measures for downstream receptors that may be impacted
by the spill.
2.2.4 Disposal of Recovered Product and Contaminated Response Material
The RC ensures that all contaminated materials classified as hazardous waste are
disposed of in accordance with all applicable solid and hazardous waste regulations.
Completed Actions
Place any recovered product that can be recycled into the a 55-gallon drum to be
separated and recycled.
Dispose of recovered product not suitable for on-site recycling with the rest of the
waste collected during the response efforts.
Collect all debris in property labeled waste containers (impervious bags, drums, or
buckets).
Dispose of contaminated material in accordance with all applicable solid and
haznrdous waste regulations using a licensed waste hauler and disposal facility, after
appropriately characterizing the material for collection and disposal.
Dispose of all contaminated response material within 2 weeks of the discharge.
2.2.5 Termination
The RC ensures that cleanup has been completed and that the contaminated area has
been treated or mitigated according to the applicable regulations and state/federal
cleanup action levels. The RC collaborates with the local, state and federal authorities
regarding the assessment of damages.
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Completed Actions
Ensure that all repairs to the defective equipment have been completed.
Review circumstances that led to the discharge and take all necessary precautions to
prevent a recurrence.
Evaluate the effectiveness of the response activities and make adjustments as
necessary to response procedures and personnel training.
Carry out personnel and contractor debriefings as necessary to emphasize prevention
measures or to communicate changes in operations or response procedures.
Submit any required follow-up reports to the c1uthorities. In the case where the
discharge (as defined in 40 CFR 112.1 (b)) was greater than 1,000 gallons or was the
second discharge (as defined in 40 CFR 112.1 (b)) of 42 gallons or more within any
12-month period, the RC is responsible for submitting the required information within
60 days to the USEPA Regional Administrator following the required procedures.
Within 30 days of the discharge, the RC will convene an incident critique including all
appropriate persons that responded to the spill. The goal of the incident critique is to
discuss lessons learned, the efficacy of the Contingency Plan and its implementation,
and coordination of the plan/RC and other state and local plans. Within 60 days of the
critique, the Contingency Plan will be updated (as needed) to incorporate the results,
findings, and suggestions developed during the critique.
2.3 Discharge Notification
Instructions and phone numbers for reporting a discharge to the National Response Center and
other federal, state, and local authorities are provided in Appendix A to this Contingency Plan.
Any discharge to water must be reported immediately to the National Response Center.
If the discharge qualifies under 40 CFR Part 112, the RC is responsible for ensuring that all
pertinent information is provided to the USEPA Regional Administrator.
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Section 3
Response Resources and
Preparedness Activities
3.1 Equipment, Supplies, Services, and Manpower
Spill kits are provided in a storage shed at the construction site that is accessible by RMT
personnel (location to be shown on addendum figure after placement of on-site storage areas).
Response equipment and material present at the site include:
■ (2) empty SS-gallons drums to hold contaminated material;
■ (1) SO-foot absorbent sock;
■ (2) 10-foot sections of hard skirted deployment boom;
■ (2) SO-foot floating booms;
■ (200 pounds) "Oil-dry" loose absorbent material;
■ (4 boxes) 2 foot x 3 foot absorbent pads;
■ (3 boxes) Nitrile gloves;
■ (3 boxes) Neoprene gloves;
■ (6 pairs) vinyl/PVC pull-on overboots;
■ (1) non-sparking shovel; and
■ (1) broom.
This material is sufficient to respond to most minor discharges occurring at the construction site
and to initially contain a major discharge while waiting for additional material or support from
outside contractors. The inventory is verified on a monthly basis during the scheduled facility
inspection by designated personnel and is replenished as needed.
All RMT employees upon entering the site are instructed to the location of spill response
equipment and staging areas, and response strategies, and with the SPCC and Contingency
Plans for these activities. All have received training in the deployment of response material and
handling of hazardous waste (HAZWOPER) and have attended the required refresher courses.
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3.2 Access to Receiving Water Body
Welch Creek would be the first water body affected in the event of a discharge. From there, the
spill would continue downstream into Lower Roanoke River then the Albemarle Sound and
eventually the Atlantic Ocean. The response strategy consists of: 1) deploying booms and other
response equipment at various points/bridge crossings downstream from the plume to prevent
its migration; and 2) deploying booms as a protective measure for an irrigation water intake and
other downstream sensitive receptors.
3.3 Communications and Control
A central coordination center will be set up at the field office in the event of a significant
discharge. The field office is equipped with a variety of fixed and mobile communication
equipment (telephone, fax, cell phones, two-way radios, computers) to ensure continuous
communication with RMT management, responders, authorities, and other interested parties.
Communications equipment includes:
Cell phones -Each field vehicle and the RC are provided with a cell phone. The RC
and/or his alternate (Site Supervisor when the Field Operations Manager is not "on
call") can be reached by cell phone 7 days a week, 24 hours a day.
Additional equipment -Additional communications equipment will be obtained from
the RMT, field office in Plymouth in the event that more communications equipment is
necessary.
The RC is responsible for communicating the status of the response operations and for sharing
relevant information with involved parties, including local, state, and federal authorities.
ln the event that local response agencies, Plymouth authorities, or a federal On Site Coordinator
(OSC) assumes Incident Command, the RC will function as the facility representative in the
Unified Command structure.
3.4 Updating Procedures
Following a response to a discharge, the RC will evaluate the actions taken and identify
procedural areas where improvements are needed. The RC will conduct a briefing with field
personnel, contractors, and local emergency responders to discuss lessons learned and will
integrate the outcome of the discussion in subsequent health and safety briefings and employee
training seminars. As necessary, the RC will amend this Contingency Plan to reflect changes
made to the facility equipment and procedures.
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3.5 Reporting Requirements
In the event that reporting is required, the person reporting the discharge must provide the
following information:
■ name, location, organization, and telephone number;
■ name and address of the owner/operator;
■ date and time of the incident;
■ location of the incident;
■ source and cause of discharge;
■ types of material(s) discharged;
■ total quantity of materials discharged;
■ quantity discharged in harmful quantity (to navigable waters or adjoining shorelines);
■ danger or threat posed by the release or discharge;
■ description of all affected media (e.g., water, soil);
■ number and types of injuries (if any) and damaged caused;
■ weather conditions;
■ actions used to stop, remove, and mitigate effects of the discharge;
■ whether an evacuation is needed;
■ name of individuals and/or organizations contacted; and
■ any other information that may help emergency personnel respond to the incident.
Whenever the facility discharges more than 1,000 gallons of oil in a single event, or discharges
more than 42 gallons of oil in each of two discharge incidents within a 12-month period, the
Manager of Field Operations must provide the following information to the USEPA's Regional
Administrator within 60 days:
■ name of the facility;
■ name of the owner or operator;
■ location of the facility;
■ maximum storage or handling capacity and normal daily throughput;
■ corrective actions and countermeasures taken, including a description of equipment repairs
and replacements;
■ description of facility, including maps, flow diagrams, and topographical maps;
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■ cause of the discharge(s) to navigable waters, including a failure analysis of the system and
subsystems in which the failure occurred;
■ additional preventive measures taken or contemplated to minimize possibility of
recurrence; and
■ other pertinent information requested by the regional administrator.
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NAME
Michael B. Parker
Robert W. Hanley
Karen C. Saucier
Bill Morris
NAME
Appendix A
Emergency Contacts
RMT NORTH CAROLINA, INC. AND DOMTAR OPERATIONS TEAM
TITLE TELEPHONE ADDRESS
RMT North Carolina, Inc. [phone] (office) 30 Patewood Drive, Suite 100
Response Coordinator [phone] (cell) Greenville, SC 29615
RMT North Carolina, Inc. [phone] (office) 30 Patewood Drive, Suite 100
Field Services [phone] (cell) Greenville, SC 29615
RMT North Carolina, Inc. [phone] (office) 30 Patewood Drive, Suite 100
Client Service Manager [phone] (cell) Greenville, SC 29615
Domtar Paper Company, [phone] (office)
LLC
LOCAL EMERGENCY RESPONDERS
TELEPHONE ADDRESS
Fire/Police Department 911 132 E. Water Street
[phone] Plymouth, NC 27962
Washington County Hospital [phone] 958 U.S. 64
Plymouth, NC 27962
OTHER EMERGENCY RESPONSE CONTACTS
NAME TELEPHONE
National Response Center [phone]
North Carolina
State Emergency Operations Center [phone]
RMT North Carolina, Inc. I Domtar Corporation
/: \ WPMLW\ PfT\ 00-05 J 7 4 \OS\ R0005 I 740S-SCP _REV.DOCX
ADDRESS
NATIONAL RESPONSE CENTER
c/o United States Coast Guard (CG-3RPF-2) -
Room 2111-B
2100 2nd Street, SW
Washington, DC 20593-0001
North Carolina Emergency Response
Commission/EPCRA
4714 Mail Service Center
Raleigh, North Carolina 27699-4714
Final July 2010, Revised November 2010
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Attachment E-3
Hospital Emergency Route Map
RMT North Carolina, lllc. I Domtar Paper Company, LLC
Remedial Action Work Plan
Appendix E: CHSPICP
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Washington County Hospital
958 US Hwy 64 East
Plymouth, NC 27962
[phone]
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