13020_Newman Machine_Risk_MGMT_Plan_06_30_2010

RISK MANAGEMENT PLAN

The Province at UNC Greensboro
Spring Garden Road at Fulton Street
Greensboro, Guilford County, North Carolina
North Carolina Brownfields Program Project No. 13020-09-41

Prepared for

UNIVERSITY RESIDENCES –GREENSBORO, LLC AND MULTICON DEVELOPMENT
COMPANY, LLC
495 South High Street, Suite 150
Columbus, Ohio 43215

Prepared by

TERRACON CONSULTANTS, INC.
Charlotte, North Carolina
Project No. 71097746

June 30, 2010

Terracon Consultants, Inc. 2020 Starita Road, Suite E Charlotte, NC 28206 [704] 509 1777 terracon.com
June 30, 2010

Mr. Dave Tyndall
Multicon Development Company, LLC
495 South High Street, Suite 150
Columbus, Ohio 43215

RE: Risk Management Plan
The Province at UNC Greensboro
Spring Garden Road at Fulton Street
Greensboro, Guilford County, North Carolina
Terracon Project No. 71107746

Dear Mr. Tyndall,

Terracon Consultants, Inc. (Terracon) presents this Risk Management Plan (RMP), on behalf of
Multicon Development Company, LLC, to address the management of environmentally impacted
soils and groundwater during the site redevelopment of the above listed property.

This RMP cannot be all inclusive nor anticipate every future condition involving workers or
construction for on-site activity involving soil/fills. Rather, the RMP acts as a risk management
advisory to persons and contractors involved with this property. The RMP attempts to instill a
sense of risk management to maintain the conditions and protection of public health and the
environment. The RMP and supporting information is based upon data obtained from prior field
activities and from other information discussed in this plan and as referenced. This report does
not reflect any existing site conditions which may occur between borings or across the site.
Actual soil conditions may vary. This report is prepared for the exclusive use of our client for the
specific application to the project discussed and has been prepared in accordance with
generally accepted environmental engineering practices. No warranties, either expressed or
implied, are intended or made.

In the event any changes in nature or location of site conditions as outlined in this report are
observed, the conclusions contained in this report cannot be considered valid unless the
changes are reviewed and the conclusions of this report are modified or verified in writing by the
Terracon.

Sincerely,
Terracon Consultants, Inc.

Stephen C. Brown Christopher L. Corbitt, PG
Project Geologist Environmental Services Manager
TABLE OF CONTENTS

1.0  INTRODUCTION .................................................................................................... 1 
1.1 Site Description ...................................................................................................... 1 
1.2 Planned Future Land Use ...................................................................................... 1 
1.3 Risk Management Plan Intent ................................................................................ 2 
2.0 SUMMARY OF PREVIOUS INVESTIGATIONS .................................................... 3 
3.0 SITE CONDITIONS AND ASSUMPTIONS ........................................................... 5 
4.0 CHEMICAL RISK ................................................................................................... 5 
4.1 Chemical Toxicity ................................................................................................... 6 
4.2 Exposure ................................................................................................................ 7 
4.3 Completing Exposure Pathways ............................................................................ 7 
5.0 REDUCING RISK WITH ENGINEERED CONTROLS .......................................... 8 
5.1 Engineered Barriers ............................................................................................... 8 
5.2 Soil Vapor Intrusion Barriers .................................................................................. 9 
6.0 REDUCING RISK WITH INSTITUTIONAL CONTROLS ....................................... 9 
6.1 Brownfields Agreement Land Use Restrictions ...................................................... 9 
7.0 REDUCING RISK OF EXPOSURE TO IMPACTED GROUNDWATER .............. 10 
8.0 REDUCING RISK OF DIRECT SOILS EXPOSURE DURING
SITE DEVELOPEMENT ...................................................................................... 10 
8.1 Air Monitoring Program ........................................................................................ 10 
9.0 REDUCING RISK OF DIRECT SOILS EXPOSURE DURING FUTURE SITE
MAINTENANCE AND UPKEEP ACTIVITES ................................................................. 11 
9.1 Construction or Installation of Buildings, Structures or Other Improvements ....... 11 
9.2 Replacement and Repair of Engineered Barriers ................................................ 12 
9.3 Utility Installations or Repairs ............................................................................... 13 
10.0 RISK MANAGEMENT PLAN ADMINISTRATION ............................................... 14 
10.1 Future Exposure Scenarios .................................................................................. 14 
10.2 Soil Management Plan ......................................................................................... 14 
11.0 POST CONSTRUCTION MONITORING AND MAINTENANCE ......................... 14 
FIGURES:

Figure 1: Site Redevelopment Plan
Figure 2: Environmental Impacts Map
Figure 2: Soil Management Areas Map

ATTACHMENTS:

A. Soil Management Plan
B. Soil Vapor Intrusion Barrier Specifications
C. Environmental Covenant Example and Public Notice Guidelines

COMMON ACRONYMS

AST ................ Aboveground storage tank
ASTM ............. American Society for Testing and Materials
AUL ................ Activity and use limitation
BGSL ............. Below ground surface level
BTEX .............. Benzene, toluene, ethylbenzene, and xylenes
CERCLA ........ Comprehensive Environmental Response, Compensation, and Liability Act
CFR ................ Code of Federal Regulations
COC………….Constituent of Concern
DRO………….Diesel range organics
EPA ................ United States Environmental Protection Agency
GRO………….Gasoline range organics
LUST .............. Leaking underground storage tank
MCL ............... Maximum contaminant level
MSDS ............. Material safety data sheet
NCDENR.……North Carolina Department of Environment and Natural Resources
NCDWM…… .. North Carolina Division of Waste Management
OSHA ............. Occupational Safety and Health Administration
PCB ................ Poly-chlorinated biphenyl
PAH ................ Polynuclear aromatic hydrocarbon
RCRA ............. Resource Conservation and Recovery Act
REC ............... Recognized environmental condition
SVOC………..Semi-volatile organic compound
TPH ................ Total petroleum hydrocarbons
UST ................ Underground storage tank
VOC ............... Volatile organic compound
VOV ............... Volatile organic vapor

Units of measure
sq ft or ft² ........ square feet
mg/kg ............. milligrams per kilogram
mg/l ................ milligrams per liter
ug/l ................. micrograms per liter
ppb ................. parts per billion
ppm………….. parts per million
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1.0 INTRODUCTION

Greensboro Residences-Greensboro, LLC (Greensboro Residences and Multicon
Development Company, LLC (Multicon) have requested Terracon Consultants, Inc (Terracon) to
prepare a Risk Management Plan (RMP) to address the management of environmentally
impacted soils and groundwater during site redevelopment of the property located along Spring
Garden Road at Fulton Street in Greensboro, Guilford County, North Carolina. This RMP was
developed to demonstrate that effective controls are being applied to protect human health and
the environment at the site build-out, to protect workers during site redevelopment work and to
ensure that the redeveloped property is safe for its intended uses. The engineered and
institutional controls described in this RMP will provide protection for future site occupants who will
reside in the newly constructed housing. A Soils Management Plan (SMP), including an
example Site Health and Safety Plan (SHSP), has been developed to provide guidance to
contractors during planned site improvements. The SMP describes measures being applied to
reduce worker’s exposure to impacted soils during construction and infrastructure installation and
maintenance activities. The SMP is included as Attachment A.

1.1 Site Description

The site is comprised of twenty-one parcels totaling approximately 10.515 acres. The primary
site address is 507 Jackson Street in Greensboro, Guilford County, North Carolina. The
Newman Machine property is developed with approximately 17 buildings. Some of the buildings
appeared to have additions constructed at different times. Newman Machine manufactures
woodworking equipment for the pulp and paper industry. The 507 Houston Street property is
developed with a metal building and is occupied by a company that buys and sells used
restaurant equipment. The New Age Builders property is developed with a commercial building
and a warehouse building.

1.2 Planned Future Land Use

University Residences plans to redevelop the property as a mulit-family apartment complex to
provide housing for students attending UNC Greensboro and Greensboro College.

The site will contain apartment buildings, a club house and swimming pool. The buildings will
be constructed with slab-on-grade, wood-framed construction, paved parking areas, green
spaces / landscaped areas and retention basins. Some earthwork operations will be conducted
to provide appropriate grade elevations for the complex.

Approximately thirty percent (30%) of the redeveloped site will be covered by permanent
structures. Approximately sixty percent (60%) of the redeveloped site will be covered
permanently by roadway paving and asphalt or concrete parking lots. Landscaping consisting
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of sod, grasses, and or shrubbery will cover the remainder. The planned development is
shown on the attached Site Development Plan (Figure 1).

1.3 Risk Management Plan Intent

This RMP applies only to areas of the site that have been impacted by contaminants of concern
(COCs). Petroleum contaminants have been identified in soils on certain portions of the site. In
addition, chlorinated compounds have been identified in groundwater below the site. Under the
North Carolina Brownfields Property Reuse Act of 1997, the North Carolina Brownfields
Program (NCBP) works with Prospective Developers (PDs) who did not cause or contribute to
site contamination to bring Brownfields properties back to safe and productive reuse. Under the
umbrella of the North Carolina Brownfields Program, the PD manages the contamination in a
manner that controls and minimizes exposure to contaminants and protects human health and
the environment. In addition to any necessary active remediation of contaminants, the
management of risk related to contaminants may include existing or proposed engineering or
institutional controls and the maintenance of those controls.

This RMP describes interim risk management measures to be implemented on the site in order
to comply with North Carolina Brownfields requirements. The Brownfields Agreement between
the PD and the North Carolina Department of Environmental and Natural Resources (NCDENR)
will be the enforceable document that contains the final risk management measures for the site.
These interim measures may include the installation of engineering barriers (clean soil / fill cap,
pavement, and buildings with soil vapor intrusion barriers and active or passive sub-slab
venting) and the implementation of institutional controls pursuant to Land Use Restrictions
(LURs) in the Brownfields Agreement for the property.

This RMP serves as an educational document to owners and workers involved with site build-
out of this property. It is intended to instill in the mind of the reader the important elements of
the management plan and to provide the public and contractors with knowledge of the on-site
conditions. The RMP provides an awareness of the conditions of the property identified during
previous investigations.

The RMP provides contractors involved in construction with information for use in executing
employer obligations for employee right-to-know and responsibilities for worker safety
supplemental to other programs of regulation. It also provides general guidelines for
minimization of potential exposures of occupants or workers to contaminated soils and
groundwater having potential health impacts.

The RMP provides for a process of observation and recognition to allow identification of
conditions during construction that may differ significantly from those observed during testing
and sampling. The RMP provides a process for qualitatively and quantitatively identifying
whether the changed condition presents a potential hazard condition different from conditions
evaluated for compliance with Brownfields Program requirements. The RMP is not intended for
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direct, unmodified use by employers to protect workers. Rather, it is intended to provide general
considerations and procedures for modification and incorporation by employers into their
existing worker safety programs.

2.0 SUMMARY OF PREVIOUS INVESTIGATIONS

The following reports summarize investigation activities completed by Terracon and others that
were reviewed by Terracon. A summary of the conclusions are included in the following
paragraphs.

Phase I Environmental Site Assessment – September 24, 2009

Terracon completed a Phase I Environmental Site Assessment (ESA) for the site. A report of
our findings was issued as Terracon Project No. 71097746 on September 24, 2009. In the
Phase I ESA report, Terracon identified the following Recognized Environmental Conditions
(RECs):

On-Site
• the current and past use of USTs on the various site parcels
• a leaking AST on the Newman Machine parcel
• the use of petroleum lubricants and solvents and associated drums and drum storage
areas
• heavy staining adjacent to machinery on the Newman Machine property
• a hydraulically operated elevator system in the Newman Machine building
• the leaking hydraulic lift/ramp at the Newman Machine loading dock
• the historical use of cyanides for heat treating metal on the Newman Machine property
• staining adjacent to floor drains on the Newman Machine property
• uncontrolled fill reportedly containing scrap metal, used foundry sands and other “unknown”
materials
• the greater than 100-year historical use of the site for heavy industrial operations

Off-Site
• the historical use of the adjacent 625 Fulton Street property for manufacturing and a
reported metal plating operation
• the 25 to 30 year use of a nearby upgradient property as a dry cleaners located to the
southeast
• the use of an upgradient adjacent property to the southwest for metal plating and potential
chlorinated solvent use
• the presence of a UST on the upgradient, adjoining property to the east located at 508
Houston Street

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Limited Site Investigation – The Province at UNC Greensboro, October 6, 2009

Terracon conducted Limited Site Investigations (LSIs) at the former Newman Machine property
in response to RECs identified in our Phase I ESA study. Forty-five (45) Geoprobe borings
were advanced in areas of concern identified in the Phase I ESA report to collect soil and
groundwater samples. In addition, two permanent and two temporary Type II groundwater
monitoring wells were installed at selected locations to assess groundwater conditions
downgradient to areas of current/historical industrial use. The findings of the LSI included:

• A geophysical survey conducted in selected areas of the site did not identify the presence of
additional USTs or other buried environmental concerns. The survey was only applicable to
the areas surveyed and did not include the entire site.
• Low levels of petroleum constituents were detected in soils near the 10,000-gallon heating
oil UST and the approximate 550-gallon heating oil UST near the engineering building on
the Newman Machine property.
• Based the presence of petroleum constituents in soils and groundwater near the former
gasoline UST on the Newman Machine property and the former 1,000-gallon gasoline UST
on the New Age Builders property, additional assessment activities will be necessary to
achieve closure of these release incidents.
• The impacted areas appear to be limited to drum storage and machining operations at
various locations on the Newman Machine property.
• Chlorinated solvents were not identified in soils or groundwater on the site during this
assessment.
• Petroleum constituents and RCRA metals including arsenic, mercury, cadmium, chromium,
silver, lead and selenium were detected in fill materials near a retaining wall on the site.
Subsequent TCLP analyses indicate these detected metals are relatively immobile and are
not likely to leach into the underlying soils and groundwater.

Limited Site Assessments

Limited Site Assessments (LSAs) were conducted on the Newman Machine property and the
New Age Builders property to evaluate impacts at two former UST locations. The LSA is a
regulatory procedure used to close out release incidents associated with USTs. The results of
the LSA at the New Age Builders property did not indicate an impact to the property by the
former UST; however, carbon tetrachloride, a chlorinated solvent was detected a low levels in
the groundwater. The results of the LSA at Newman Machine indicated petroleum constituents
are present in the soil and groundwater at the location of the former UST. We also detected low
levels of chlorinated solvents in the groundwater at this location. Since solvents were not
detected in the soils at either LSA location (only in groundwater), the solvents are not
considered to be associated with the operations of the former USTs.

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Contaminant Impacts Summary

Contaminant impacts to the site are summarized on the attached Environmental Impacts Map
(Figure 2).

3.0 SITE CONDITIONS AND ASSUMPTIONS

The investigations indicate that limited areas of the property, beneath certain Newman Machine
buildings and an area of unsuitable fill materials on the Newman property are impacted due to
past industrial use of the site. Based on the analytical data collected during the various
investigations, the fill materials are generally impacted by various metals and / or polynuclear
aromatic hydrocarbons (PAHs). Groundwater at the site has also been identified as being
impacted by petroleum constituents and limited chlorinated solvent constituents.

Not all soils/fill materials located on the site are impacted by constituents of concern (COCs).
Furthermore, not all impacted soils / fill materials in the identified impacted areas are impacted
above the NCDENR regulatory limits.

4.0 CHEMICAL RISK

We tend to think of “chemicals” as man-made, as being solvents or fuels made by man.
Actually, chemical compounds make up everything physical in our lives. Most occur naturally,
with thousands of man-made chemical compounds merely being manufactured or combined
versions of natural chemical elements.

We are exposed to thousands of natural and man-made chemicals every day. They are in the
water we drink, the air we breathe and in the materials and equipment we use daily in our
personal and working lives. All of these chemicals could possibly cause us harm if they were
encountered in sufficient amounts, if sufficient exposure occurred and if enough material
entered the body to produce a negative effect.

Excessive or unacceptable public and personal chemical risk requires each of the following four
(4) elements to occur:
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1. A chemical must be of sufficient toxicity to cause harm
2. A sufficient amount of the chemical to be toxic
3. A sufficient amount of exposure to allow toxic effect to happen
4. A pathway by which the exposure can occur at a duration and frequency to cause harm

4.1 Chemical Toxicity

When the amount of material helps (as in the case of medicines, most of which are chemicals)
or does not harm the body, a condition of acceptable chemical risk may exist. When a chemical
exceeds the amount where it can begin to do harm immediately or over a long period, a
condition of unacceptable risk may exist. It is at this point of unacceptable risk that a chemical
may become harmful or toxic. A chemical becomes toxic when the amount of material which
enters the body begins to produce harm. If the harm is realized in a relatively short period – say
minutes, days or weeks – the material is said to have an acute toxicity. If harm is realized over a
relatively long period – say years, decades or a person’s lifetime – the material has a chronic
toxicity.

For example, a chemical used as a pain killer in medicine;

• In proper doses and short periods of exposure it has a beneficial medicinal effect.
• Used improperly in small doses over time, it has a negative chronic effect – addiction.
• Used improperly in large doses it has a negative acute effect – overdose, possibly death.

The North Carolina Department of Environment and Natural Resources (NCDENR) does not
perform its own studies to determine a chemical’s toxicity. The NCDENR relies on the same
chemistry and toxicity studies conducted by the United States Environmental Protection Agency,
more specifically the EPA Region 4 Preliminary Remediation Goals (PRGs).

SUFFICIENT
TOXICITY
SUFFICIENT
AMOUNT
COMPLETE
PATHWAY
RECEPTOR
RISK
SUFFICIENT
EXPOSURE
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The NCDENR determines a level of target risk that is acceptable. For chemicals in North
Carolina, the target risk for a chemical is one that produces cancer effects at less than one
additional cancer occurrence in one million, or 1-in-1,000,000 (1 x 10-6) and a hazard index of
1.0 for non-cancer endpoints. In comparison, workplace standards to protect workers from
chemical exposure are often calculated using 1-in-10,000 (1 x 10-4) risk levels.

A chemical risk endpoint is a way to define the degree of risk that an individual or a group of
individuals will sustain because of exposure to that specific chemical. The endpoints are
specific to a period of time of exposure and can be defined for a short period of time, for
example, for one year of exposure, or for a long period of time such as a lifetime risk. A
chemical risk endpoint is the underlying basis for a risk estimate.

4.2 Exposure

Exposure is the manner in which a chemical encounters a body. Exposure consists of three
basic parts:

1. The physical material or media that carries the chemical to the body. For this site, it was
determined to be soils / fill with chemical impacts above NCDENR standards.

2. The period of time or duration that the body occupies the site impacted by the chemical.
In general, this assumes 30 years residential occupancy of a site and 1 year for
construction worker occupancy.

3. The number of times that the contact and chemical delivery might occur during
occupancy is known as the frequency. In general, exposure frequency is assumed to
occur 350 days per year for residential occupants and 30 days per year for construction
workers. A day is considered 24 hours.

In comparing exposure to the NCDENR regulatory standards, it was assumed that a person is
theoretically exposed to the maximum amount of chemical measured in soils on the property.

4.3 Completing Exposure Pathways

An exposure pathway is the physical manner in which the chemical moves from its source to
enter the body. An exposure pathway for this site would be complete if the impacted soils are
actually available to a person or if there is a likelihood in the future that this condition could
occur. The general considerations in determining pathway completions for this site were;

• Soils with impact below 2 feet from the surface in typical green space areas are not
available for exposure to residential occupants through ingestion or direct contact.

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• Soils with impact below 3 feet from the surface in typical recreational areas are not
available for exposure to residential occupants through ingestion or direct contact.

• Soils with impact below 15 feet from the surface are not available for exposure to
residential occupants through inhalation of volatile chemical compounds.

• Soils beneath permanent buildings, pavements or other physical structures containing
an adequate soil vapor intrusion barrier are not available for exposure to residential
occupants through ingestion or inhalation.

• Soils at all depths with chemical impact could be available for exposure to construction
workers or maintenance workers disturbing soils in the course of construction or repairs,
although individual exposures will likely be less than the 30 days per year, 24 hours per
day.
5.0 REDUCING RISK WITH ENGINEERED CONTROLS

Although several environmental investigations have been performed at this site, we can only be
sure that our investigations were conducted in accordance with customary industry practice.
Hence, not only the identified impacted areas of the site, but other undiscovered areas of
contaminant impact, may be present.

5.1 Engineered Barriers

Some soils with elevated concentrations of metals and PAH contaminants will be disturbed
during site grading operations. The soils will be placed in one of four designated “Soil
Management Areas” on the site. The designated Soil Management Areas are shown on the
attached Soil Management Areas Map (Figure 3). The Soil Management Areas will be capped
by asphalt parking lots. The Areas are to be surveyed and the location memorialized in the
Brownfields Survey Plat to be recorded along with the Brownfields Agreement in the chain of
title for the property.

As required by NCDENR, impacted soils not placed in a designated Soil Management Area will
be capped with a building, asphalt or concrete surface. In addition, any impacted soils detected
in green space or recreational areas will be moved to a designated Soil Management Area.

No excavation in the green or recreational areas will be allowed without permission from the
property owner or property manager.

In addition, every 500 cubic yards of soil/fill material to be used on the site as “clean” fill, must
be sampled and laboratory analyzed for RCRA metals, PAHs, and VOCs. Clean fill material is
defined as material containing concentrations of COCs at levels less than NCDENR regulatory
standards.
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5.2 Soil Vapor Intrusion Barriers

Volatile organic compounds (VOCs) have been identified in the groundwater and soils in certain
areas beneath the site. In addition, PAHs have been identified in soils below portions of the
site. Soil gas sampling with analytical testing will be conducted in areas on the site where
previous assessment work has identified soil and where groundwater contaminants and volatile
organics vapors (VOVs) could likely accumulate. If VOC concentrations above regulatory action
levels are identified in soils below areas planned for buildings, Soil Vapors Intrusion Barriers
(SVIBs) will be installed during construction to prevent VOCs or gases from collecting beneath
and in the on-site buildings. The SVIB acts as an engineered barrier that mitigates the potential
inhalation exposure pathway. Recommended SVIB construction specifications are included as
Attachment B.

6.0 REDUCING RISK WITH INSTITUTIONAL CONTROLS

To further reduce exposure risk, the institutional controls discussed below will apply to the entire
site. A Draft Brownfields Agreement was prepared and is included as Attachment C. Once
approved by the North Carolina Brownfields Program, the final Brownfields Agreement, Notice
of Brownfields Property and Brownfields Survey Plat will be recorded in the chain of title to the
property and the land use restrictions (LURs) established in the Brownfields Agreement will
apply to the site. These LURs may include:
• Groundwater shall not be used on the site as a potable or non-potable water source.
• Soils on the property shall not be disturbed in any manner inconsistent with the
approved Plan without the Owner obtaining prior approval of the NCDENR.

• Paved areas including sidewalks and parking lots shall not be disturbed in any manner
inconsistent with the approved Plan without the Owner obtaining prior approval of the
NCDENR.

• Soil vapor intrusion barriers beneath any building shall not be disturbed in any manner
inconsistent with the approved Plan without the Owner obtaining prior approval of the
NCDENR.

6.1 Brownfields Agreement Land Use Restrictions

To satisfy the Brownfields Program requirement that the property be safe for its intended uses
and support prudent property management, LURs have been included in the Brownfields
Agreement to serve as a risk management tool. The Brownfields Agreement has been or will be
recorded in the chain of title. The Brownfields Agreement and the Risk Management Plan
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(RMP) will notify future contractors, construction workers, utility companies and facility
maintenance workers of site conditions. The RMP will be kept on-file at the facility
maintenance/utilities center.

It is the responsibility of each contractor as an employer to integrate the information of the RMP
into their specific, individual programs for worker safety.

7.0 REDUCING RISK OF EXPOSURE TO IMPACTED GROUNDWATER

Groundwater below the site is impacted by VOC’s. The distance to groundwater from the
existing surface grade is approximately 25 feet. This distance and the engineered barriers /
institutional controls described in Sections 5.0 / 6.0 will mitigate the exposure pathway to
construction workers and future site occupants from impacted groundwater at its current
elevation. Groundwater shall not be used on the site as a potable or non-potable water source.

8.0 REDUCING RISK OF DIRECT SOILS EXPOSURE DURING
SITE DEVELOPEMENT

The greatest exposure risks for human health will occur during the site grading and construction
activities. A Soil Management Plan (SMP), including an example Site Health and Safety Plan
(SHSP), has been developed to provide guidance to contractors during planned site
improvements. The SMP describes recommended measures to be applied to reduce worker’s
exposure to impacted soils during construction and infrastructure installation and maintenance
activities. The SMP is included as Attachment A.

8.1 Air Monitoring Program

Air monitoring for particulate matter and volatile organic compounds will be performed in areas
of the site impacted by identified constituents of concern in order to monitor the potential risk to
on-site contractors, workers and third parties (e.g. visitors and surrounding community). The
purpose of the air monitoring program is to:

1. Monitor and detect airborne COCs;
2. Assess the required level of personal protection for site workers based on air monitoring
results;
3. Implement engineering controls (ECs) as needed to protect workers and the local
community; and
4. Document the airborne concentration of COCs during site development activities.

The on-site environmental manager or equivalent qualified environmental professional will
perform air monitoring for COCs in upwind locations, the immediate work zone, and downwind
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of the work zone. This monitoring will allow for the timely initiation of ECs and
upgrades/downgrades in levels of personal protective equipment for site workers.

The following field equipment will be used for the air monitoring during site development
activities and will address VOCs and particulates:

• Photoionization detector (PID) or flame ionization detector (FID)
• Particulate / aerosol monitoring instrument (i.e. Miniram)

Air monitoring instruments will be calibrated, at a minimum, at the beginning of each workday
the equipment is to be used. A calibration log will be maintained depicting date and time of
calibration and procedures followed.

No visible emissions criteria will be established during excavation of impacted soils. If
excessive visible dust emissions are observed during excavating or loading operations, work will
be curtailed until the excavation area is lightly sprayed with potable water. Slow movement of
equipment and low bucket dump heights will be used to reduce the potential for off-site
migration of contaminated dusts.

Monitoring for particulates will be used in the absence of real-time screening technologies for
inorganic COCs (i.e. metals) identified at the site. Since the COCs are known to exist in the
soils / fill at the site, and since inorganic COCs are nonvolatile, any airborne concentrations of
COCs are expected to be associated with airborne dust. Particulate screening will take place
prior to the start of work activities and then hourly thereafter until the work is completed or the
workday ends.

9.0 REDUCING RISK OF DIRECT SOILS EXPOSURE DURING FUTURE SITE
MAINTENANCE AND UPKEEP ACTIVITES

If any construction and / or maintenance activities have potential to penetrate the engineered
barriers, this RMP and the attached Soil Management Plan (SMP) must be followed.

9.1 Construction or Installation of Buildings, Structures or Other Improvements

Contractors installing buildings, structures or other improvements on the property must follow
the requirements of this RMP, while complying with the conditions specified below:

A) The contractor performing the work shall be provided with a copy of this RMP. The
contractor shall prepare a site health and safety plan, appropriate for the work being
performed. The contractor’s health and safety plan shall be compliant with this RMP.

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B) Materials used in the pavement or foundation shall not contain hazardous substances.
Site soils which are excavated shall be separated and segregated to the extent
practicable so that they may be backfilled or disposed upon completion of the work.
Excavated soils shall be segregated and stored on the site until completion of the work
and shall be, at a minimum, placed onto plastic sheeting and covered, or placed into a
watertight container such as a covered roll-off box.

C) Upon completion of the work, previously excavated soils may be backfilled provided that
the backfilled soils maintain the compaction characteristics of the surrounding
subsurface soils. The soils, as well as any additional clean soil or granular fill material
necessary to backfill to grade, shall be backfilled in such a manner as to maintain the
original depth of the soils or granular materials layer. All such excavated soils shall be
segregated and stored on the site until completion of the work. The backfill area shall be
restored in a manner consistent with the original capping condition (i.e., asphalt or
concrete surface, buildings and SVIB).

D) A report shall be prepared describing the work preformed; identifying the person(s)
performing the work and the date of the work, and confirming that the RMP was followed
in completion of the work. A copy of the report shall be kept on file by the owner and the
property manager, if any, and at the property.

9.2 Replacement and Repair of Engineered Barriers

If it becomes necessary or desirable to replace or repair the engineered barriers including
asphalt, concrete, or building foundations, the repair or replacement shall be undertaken in the
following manner:

A) The contractor performing the work shall be provided with a copy of this RMP. The
contractor shall prepare a site health and safety plan, appropriate for the work being
performed. The contractor’s health and safety plan shall be compliant with this RMP.

B) Soils which are excavated from beneath the engineered barriers shall be separated and
segregated to the extent practicable so that they may be replaced upon completion of
the work. Excavated soils shall be segregated and stored on the site until completion of
the work, and shall be, at a minimum, placed onto plastic sheeting and covered, or
placed into a watertight container such as a covered roll-off box.

C) Upon completion of the work, previously excavated soils may be backfilled provided that
the backfilled soils maintain the compaction characteristics of the surrounding
subsurface soils. The soils, as well as any additional clean soil or granular fill material
necessary to backfill to grade, shall be backfilled in such a manner as to maintain the
original depth of the soils or granular materials layer. The backfill area shall be restored
in a manner consistent with the original capping condition (i.e., asphalt or concrete
The Province at UNC Greensboro – Risk Management Plan
Terracon No. 71097746
June 30, 2010

13
surface, buildings and SVIBs). Any previously excavated soils or excavated granular
material that has been co-mingled, mixed, or in contact with other site soils shall be
segregated and stored on the site until completion of the work.

D) A report shall be prepared describing the work preformed; identifying the person(s)
performing the work and the date of the work, and confirming that the RMP was followed
in completion of the work. A copy of the report shall be kept on file by the owner and the
property manager, if any, and at the property.

9.3 Utility Installations or Repairs

Utility repairs or installation of new or replacement utilities shall not be conducted until after the
utility and any contractor(s) for the utility have acknowledged receipt of a copy of this RMP.
Otherwise, the utility repairs or installation(s) shall be conducted in conformance with the
standards set forth below:

A) The contractor performing the work shall be provided with a copy of this RMP. The
contractor shall prepare a health and safety plan, appropriate for the work being
performed. The contractor’s health and safety plan shall include a copy of this RMP.

B) Soils which are excavated from beneath the engineered barriers shall be separated and
segregated to the extent practicable so that they may be replaced upon completion of
the work. Excavated soils shall be segregated and stored on the site until completion of
the work, and shall be, at a minimum, placed onto plastic sheeting and covered, or
placed into a watertight container such as a covered roll-off box.

C) Upon completion of the work, previously excavated soils may be backfilled provided that
the backfilled soils maintain the compaction characteristics of the surrounding
subsurface soils. The soils, as well as any additional clean soil or granular fill material
necessary to backfill to grade, shall be backfilled in such a manner as to maintain the
original depth of the soils or granular materials layer. The backfill area shall be restored
in a manner consistent with the original capping condition (i.e. asphalt or concrete
surface, buildings and SVIP). Any previously excavated soils or excavated granular
material that has been co-mingled, mixed, or has come in contact with other site soils
shall be segregated and stored on the site until completion of the work.

D) A report shall be prepared describing the work performed, identifying the person(s)
performing the work and the date of the work, and confirming that the RMP was followed
in completion of the work. A copy of the report shall be kept on file by the owner and the
property manager, if any, and at the property.

The Province at UNC Greensboro – Risk Management Plan
Terracon No. 71097746
June 30, 2010

14
10.0 RISK MANAGEMENT PLAN ADMINISTRATION

10.1 Future Exposure Scenarios

Under the plan to redevelop the site into an apartment complex for residential use, plausible
future exposure scenarios include construction workers and residents. While additional
scenarios (e.g. property management worker, visitors, and utility workers) are possible, their
exposures are expected to be less than those for construction workers and student residents.
Thus, the construction worker and student resident scenarios are the primary concern for all
potential future uses of the property.

10.2 Soil Management Plan

The health and safety of on-site personnel is a vital element of the work to be completed under
this plan. This concern is addressed by a series of operating practices to which field personnel
are held accountable as prescribed in the Soil Management Plan (SMP). The SMP includes
health and safety and related regulatory requirements during intrusive work for site
redevelopment, as well as future intrusive activities such as building additions and utility repairs.
Procedures for protecting the health and safety of third parties (e.g., residents, visitors, or the
surrounding community) are also provided in the SMP.

The SMP will identify and outline potential hazards that may be encountered, along with
procedures to be followed to limit human exposure to potentially harmful constituents. The SMP
will include information pertaining to exposure levels with respect to the constituents anticipated,
personal protective equipment, decontamination procedures, site contacts, and emergency
response measures.

Contractors requested to provide bids or proposals for services related to activities associated
with this plan must demonstrate qualifications by providing health and safety policies and
procedures, including medical surveillance and required training programs for proposed on-site
workers. Site personnel will be required to read, sign, and be familiar with this RMP prior to
entering the project work zone.

11.0 POST CONSTRUCTION MONITORING AND MAINTENANCE

The purpose of post construction monitoring is to verify the ongoing integrity of all engineered
barriers (i.e. building foundations, asphalt/concrete surfaces and soil vapor barriers) and to
properly manage potentially contaminated materials encountered during maintenance activities.
Maintaining the integrity of the engineered barriers will provide continued protection of human
health and the environment by minimizing potential exposure to the on-site soils.

The Province at UNC Greensboro – Risk Management Plan
Terracon No. 71097746
June 30, 2010

15
Annual site inspections will be made by the owner, or the owner’s environmental manager or
equivalent qualified environmental professional, to verify the integrity of all engineered barriers
(i.e. building foundations, asphalt/concrete surfaces and soil vapor barriers). If impairment of
any of these engineered barriers is observed, repairs should be expedited following the
procedures of this RMP.

A report shall be prepared following each annual inspection. This will document conditions as
well as any corrective measures performed in response to defects identified. In the event that
defects are identified, the report should include identifying the person(s) performing the work
and the date of the work, and confirming that the RMP and the SMP were followed in
completion of the work. A copy of the report shall be kept on file by the owner and the property
manager, if any, and at the property.

Figure 1: Site Redevelopment Plan

Figure 2: Environmental Impacts Map
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LEGEND
APPROXIMATE BORING LOCATION
ELEVATOR OR HYDRAULIC LIFT LOCATION
GEOPHYSICAL SURVEY AREA
THIS DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION PURPOSES
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PUGH METAL
FINISHING
B-7
B-8 B-8A
B-35
B-37
B-36
B-34
B-38 B-1
B-2
B-21
B-15
B-46
B-48
BG-2
B-3
B-4
B-47
BG-1
B-5B-6
EXISTING
TANK
SUSPECT FORMER 2,000
GALLON GASOLINE UST
UNKNOWN LOCATION
HEATING
OIL UST
B-14B-12B-10
B-9 B-11 B-13
B-16
B-33
B-45B-32
B-29
B-28
B-31
B-30
B-44
B-20
B-27B-26
B-25
B-24
B-23
B-22
B-17B-18
B-19 B-42
B-43
B-40
B-41
B-39
FORMER DRY
CLEANERS
FORMER
BUILDING
MW-2
MW-1
APPROXIMATE RETAINING WALL/FILL AREA
LSA: FORMER GASOLINE UST,
SEEKING REGULATORY CLOSURE
GB-11
GB-12
GB-10
GB-9
DRO
GROUNDWATER
methyl tert butyl ether
24.6 ppm (10)
7 ppb
oil & grease 122 ppm
toluene 0.0066 ppm
GROUNDWATER
toluene 1 ppb
sample depth 6'-7.5'
sample depth 1'-2.5'
BACKGROUND SAMPLE
BACKGROUND SAMPLE
LSA: FORMER GASOLINE UST,
SEEKING REGULATORY CLOSURE
WASTE OIL/SPENT
SOLVENT ASTs
TPH/DRO 14.6 ppb (10)
TPH/DRO
GROUNDWATER
cyanide
30.6 ppb (10)
14 ppb
GRO 36 ppm (10)
benzo(a)anthracene
benzo(a)pyrene
benzo(a)fluoranthene
benzo(a)fluoranthene
chrysene
fluorathene
phenanthrene
pyrene
0.599 ppm (0.022)
0.66 ppm (0.022)
0.82 ppm (0.22)
0.504 ppm
0.655 ppm
1.21 ppm
1.42 ppm
1.98 ppm
arsenic
barium
cadmium
chromium
lead
zinc
mercury
1,1-dichloroethane
1,1,1-trichloroethane
benzo(a)anthracene
benzo(a)pyrene
benzo(a)fluoranthene
benzo(g,h,i)perylene
benzo(k)fluoranthene
chrysene
dibenzo(a,h)anthracene
fluorathene
indeno(1,2,3-cd)pyrene
pyrene
1.1 ppm
65.3 ppm
0.93 ppm
25.2 ppm
22.3 ppm
101 ppm
0.14 ppm
0.0061 ppm
0.005 ppm
0.666 ppm (0.022)
1.18 ppm (0.022)
1.19 ppm (0.22)
2.36 ppm
0.543 ppm
0.828 ppm
0.397 ppm (0.022)
0.653
1.28 ppm (0.22)
1.66 ppm
arsenic
barium
cadmium
chromium
lead
zinc
mercury
2.4 ppm
109 ppm
1.0 ppm
11.7 ppm
29.0 ppm
50.4 ppm
0.021 ppm
oil & grease
naphthalene
125 ppm
0.0091 ppm
oil & grease
acetone
7620 ppm
1.85 ppm
oil & grease
n-butylbenzene
p-isopropyltoluene
naphthalene
1,2,4-trimethylbenzene
225 ppm
0.0044 ppm
0.0052
0.0043
0.009
oil & grease 865 ppm
GROUNDWATER
acetone
arsenic
barium
cadmium
chromium
lead
zinc
mercury
25.8 ppb
0.76 ppm
107 ppm
0.25 ppm
13.6 ppm
11.0 ppm
38.3 ppm
0.032 ppm
oil & grease
arsenic
barium
cadmium
chromium
lead
selenium
silver
zinc
mercury
209 ppm
255 ppm (4.4)
39.7 ppm
115 ppm (7.4)
262 ppm (44)
5070 ppm (400)
14.2 ppm
1.8 ppm
108 ppm
0.011 ppm
arsenic
barium
cadmium
chromium
lead
selenium
silver
zinc
mercury
ND (4.4)
32.0 ppm (N/A)
1.2 ppm (7.4)
17.8 ppm (44)
5.3 ppm (400)
ND (78)
ND (78)
10.8 ppm (4,600)
0.033 ppm (4.6)
benzene
n-butylbenzene
sec-butylbenzene
ethylbenzene
isopropylbenzene
p-isopropylbenzene
naphthalene
n-propylbenzene
toluene
1,2,4-trimethylbenzene
1,3,5,-trimethylbenzene
xylenes (total)
m&p - xylene
o - xylene
2-methylnaphthalene
naphthalene
TPH/GRO
Sample Depth
0.984 ppm
2.89 ppm
0.408 ppm
18.4 ppm
1.09 ppm
0.859 ppm
34.5 ppm
5.76 ppm
1.24 ppm
65.2 ppm
16.5 ppm
81.1 ppm
66.2 ppm
15 ppm
0.669 ppm
2.67 ppm
18.9 ppm
18' - 20'
TPH/GRO
GROUNDWATER
acetone
benzene
ethlbenzene
methylene chloride
naphthalene
styrene
toluene
m&p - xylene
o - xylene
1-methylnaphthalene
2-methylnaphthalene
naphthalene
cyanide
Sample Depth
18.9 ppm (10)
1130 ppb (700)
1840 ppb (1)
3170 ppb (550)
55 ppb (4.6)
1300 ppb (21)
89.5 ppb
3760 ppb (1000)
7130 ppb (530)
2900 ppb (530)
27.9 ppb
53.6 ppb (14)
487 ppb (21)
0.014 ppb
6' - 8'
oil & grease 366 ppm
oil & grease
arsenic
barium
cadmium
chromium
lead
selenium
zinc
mercury
cyanide
147 ppm
3.7 ppm
78.6 ppm
3.1 ppm
19.8 ppm
26.3 ppm
1.0 ppm
51.9 ppm
0.021 ppm
0.34 ppm
9071 O&G
arsenic
barium
cadmium
chromium
lead
zinc
mercury
90.0 ppm
1.6 ppm
5.8 ppm
0.34 ppm
3.8 ppm
2.6 ppm
6.0 ppm
0.017 ppm
oil & grease
arsenic
barium
cadmium
chromium
lead
selenium
zinc
mercury
294 ppm
1.5 ppm
77.7 ppm
0.98 ppm
24.2 ppm
33.1 ppm
0.93 ppm
68.7 ppm
0.049 ppm
arsenic
barium
cadmium
chromium
lead
selenium
silver
zinc
mercury
0.79 (4.4)
36.5 ppm (N/A)
1.7 ppm (7.4)
30.4 ppm (44)
5.0 ppm (400)
ND (78)
ND (78)
20.7 ppm (4,600)
0.039 ppm (4.6)
arsenic
barium
cadmium
chromium
lead
mercury
4 ppm
25.1 ppm
2.9 ppm
66.4 ppm (44)
30.9 ppm
0.021 ppm
arsenic
barium
chromium
lead
mercury
2.2 ppm
27.9 ppm
140 ppm (44)
28.1 ppm
0.067 ppm
sample depth 8.5'-10'
arsenic
barium
chromium
lead
mercury
1.1 ppm
3.2 ppm
2.8 ppm
3.3 ppm
0.017 ppm
arsenic
barium
cadmium
chromium
lead
selenium
silver
zinc
mercury
190 ppm (4.4)
59.1 ppm
50.1 ppm (7.4)
75.7 ppm (44)
3850 ppm (400)
8.4 ppm
2.0 ppm
112 ppm
0.019 ppm
arsenic
barium
cadmium
chromium
lead
selenium
12.6 ppm (4.4)
127 ppm
5 ppm
18.3 ppm
321 ppm
1.6 ppm
arsenic
barium
cadmium
chromium
lead
9 ppm (4.4)
8.8 ppm
1.5 ppm
11.4 ppm
23.6 ppm
arsenic
barium
cadmium
chromium
lead
mercury
4.3 ppm
160 ppm
2.1 ppm
24.8 ppm
29.9 ppm
0.041 ppm
sample depth 18.5'-20'
ELEVATED METAL CONCENTRATIONS,
WASTE FOUNDARY SANDS
ELEVATED METAL CONCENTRATIONS,
WASTE FOUNDARY SANDS
GROUNDWATER
MW-3
MW-4
GROUNDWATER
barium
chromium
toluene
169 ppb
6.7 ppb
1.2 ppb
GROUNDWATER
barium
chromium
acetone
diisopropyl ether
methyl-tert butyl ether
208 ppb
8.5 ppb
25.3 ppb
3.8 ppb
3.5 ppb
GROUNDWATER
acetone
benzene
chloroform
1,2-dichloroethane
cis 1,2-dichloroethene
diisopropyl ether
ethylbenzene
methyl-tert butyl ether
naphthalene
tetrachloroe
thenetoluene
m&p-xylenes
o-xylenes
lead
43.3 ppb
83.1 ppb (1)
1.8 ppb
7.2 ppb (0.38)
1.2 ppb
9.4 ppb
156 ppb
10 ppb
13 ppb (6)
2 ppb (0.7)
125 ppb
272 ppb
129 ppb
24.2 ppb (15)
GROUNDWATER
carbon tetrachloride
methyl-tert butyl ether
lead
83.1 ppb (0.3)
1.6 ppb
5.5 ppb

Figure 2: Soil Management Areas Map
OWNER / DEVELOPER:
EDWARDS COMMUNITIES DEVELOPMENT COMPANY
495 S. HIGH STREET, STE. 150
COLUMBUS, OH 43215
PHONE: [phone]
CONTACT: STEVE SIMONETTI
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BLDG #14
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BLDG #13
BLDG #8 BLDG #9
BLDG #3
BLDG #1
BLDG #3
COMMUNITY
CENTER
SOIL ZONE #6
SOIL ZONE #5
Notes
· Site personnel will be required to read, sign, and be familiar with the Brownfields Risk
Management Plan (RMP) for the site prior to entering the project work zone.
· Contaminant impacts to the site are summarized in the RMP. The RMP applies only to areas
of the site that have been impacted by contaminants of concern (COCs).
· During the initial site grading activities, all soils below the site buildings must be assumed to
be impacted by COCs and workers should use appropriate safety apparel.
· Minimize unnecessary disturbance of soils / fill materials from their original depths and areas.
· There is a possibility that materials of unknown type could be present between sample
locations. The worker and contractor must be able to recognize when conditions change.
· The health and safety of on-site personnel is a vital element of the work to be completed
under this plan. This concern is addressed by a series of operating practices to which field
personnel are held accountable as prescribed in the Soil Management Plan (SMP).
· Contractors requested to provide bids or proposals for services related to activities
associated with this plan must demonstrate qualifications by providing health and safety
policies and procedures, including medical surveillance and required training programs for
proposed on-site workers.
· Some soils with elevated concentrations of metals and PAH contaminants will be disturbed
during site grading operations. The soils will be placed in one of four designated "Soil
Management Areas" on the site.
· Utility contractors installing subsurface utilities shall be provided with a copy of the RMP. The
contractor shall prepare a health and safety plan, appropriate for the work being performed.
The contractor's health and safety plan shall include a copy of the RMP.
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SOIL ZONE #2
SOIL ZONE #3
LEGEND
SOIL ZONE #4
SOIL ZONE

ATTACHMENT A

Soil Management Plan

SOIL MANAGEMENT PLAN

The Province at UNC Greensboro
Spring Garden Road at Fulton Street
Greensboro, Guilford County, North Carolina
North Carolina Brownfields Program Project No. 13020-09-41

Prepared for

UNIVERSITY RESIDENCES-GREENSBORO, LLC AND MULTICON DEVELOPMENT
COMPANY, LLC
495 South High Street, Suite 150
Columbus, Ohio 43215

Prepared by

TERRACON CONSULTANTS, INC.
Charlotte, North Carolina
Project No. 71097746

June 30, 2010

TABLE OF CONTENTS
1.0 INTRODUCTION .................................................................................................... 1 
2.0 SOIL MANAGEMENT PLAN INTENT ................................................................... 1 
3.0 SITE CONDITIONS AND ASSUMPTIONS ........................................................... 2 
4.0 SITE HEALTH AND SAFETY ................................................................................ 2 
5.0 SOIL MANAGEMENT OPERATIONS ................................................................... 2 
5.1 Routine Control ...................................................................................................... 3 
5.2 Dust Control ........................................................................................................... 3 
5.3 Water Management ................................................................................................ 4 
5.4 Underground Excavation and Trenching ................................................................ 4 
5.5 Discovery or Changed Conditions .......................................................................... 6 
5.6 Constant Observation ............................................................................................ 6 
5.7 Isolate Suspect Soils .............................................................................................. 7 
5.8 Preliminary Screening Identification ....................................................................... 7 
6.0 MEASUREMENT OF CHANGED CONDITION ..................................................... 7 
6.1 Increased Isolation from Exposure ......................................................................... 8 
6.2 Laboratory Testing ................................................................................................. 9 
6.3 Comparison ............................................................................................................ 9 
7.0 DISPOSITION OF EXCESS SOIL / FILL SPOILS ................................................ 9 
8.0 SPECIAL DISPOSAL REQUIREMENTS .............................................................. 9 
8.1 On-Site Disposition .............................................................................................. 10 
8.2 Off-Site Removal .................................................................................................. 10 
9.0 SUMMARY ........................................................................................................... 11 

APPENDICES:

A. Contaminant Summaries: Agency for Toxic Substance and Disease Registry (ATSDR) Summaries
- Arsenic
- Cadmium
- Chromium
- Lead
- Polynuclear Aromatic Hydrocarbons (PAHs)
- Volatile Organic Compounds
B. Field Screening Technology Techniques for Organics in Soils
C. Suggested Sampling Methods For Suspect Soils
D. Example Health & Safety Plan For Contractor Modification

SOIL MANAGEMENT PLAN
Terracon No. 71097746
June 30, 2010

1
1.0 INTRODUCTION

University Resicences-Greensboro, LLC (University Residences) and Multicon Development
Company, LLC (Multicon) have requested Terracon, Inc. (Terracon) to prepare a Soil
Management Plan (SMP) to address the management of environmentally impacted soils during
the site redevelopment of the property located along Spring Garden Road at Fulton Street in
Greensboro, Guilford County, North Carolina (the “site”).

Conditions will be protective of human health and the environment provided the following occur:

• The future land use is made safe for residential use.
• The approved engineered and institutional controls are incorporated in the site
redevelopment and maintained for the duration of the site development.
• Groundwater shall not be used as a potable or non-potable source of water.
• After the site is improved, soils with potentially harmful constituents remain in place and
disturbances are minimized.
• Workers are informed of site soil conditions relating to construction or maintenance
activities.

This Soil Management Plan serves to inform workers and owners as to the health and safety
conditions of concern. This plan provides the following information specific to soil conditions
observed on this site:

• Requirements of the North Carolina Brownfields Program for management of site
constituents of concern (COCs) to make the site safe for its intended use and how they
relate to minimizing potential worker exposure to COCs.,
• General summary of conditions of contaminant impairment and COCs,
• Generic discussions of public health issues relative to each COC,
• Hazard recognition procedures in working with soils / fill materials at the site,
• Hazard response procedures, if needed, in working with soils / fill materials at the site,
• Suggested procedures, regarding the excavation and storage of soils suspected to contain
COCs,
• Educational packet for the owner and contractors for conducting briefings.

2.0 SOIL MANAGEMENT PLAN INTENT

Residual COCs exist in soils, fill and groundwater on certain portions of the site. The greatest
potential exposure risks for human health will occur during the site grading and construction
activities. This SMP, including the example Site Health and Safety Plan (SHSP), has been
developed to provide guidance to contractors during the planned site improvements. The SMP
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recommends measures to be applied to reduce worker’s exposure to impacted soils during
construction, infrastructure installation and maintenance activities. It also recommends
procedures to minimize impact and maintain the engineered barriers in order to comply with the
Risk Management Plan and reduce exposure to the residential occupants after site build-out.

3.0 SITE CONDITIONS AND ASSUMPTIONS

The investigations indicate that limited areas of the property, beneath certain Newman Machine
buildings and an area of unsuitable fill materials on the Newman property are impacted with
COCs due to past industrial use of the site. Based on the analytical data collected during the
various investigations, the fill materials are generally impacted by various metals and / or
polynuclear aromatic hydrocarbons (PAHs). Groundwater at the site has also been identified as
being impacted by petroleum constituents and limited chlorinated solvent constituents.

In fact, not all soils / fill materials located on the site are impacted by chemicals of concern
(COCs). Furthermore, not all impacted soils / fill materials in the identified impacted areas are
impacted above the NCDENR regulatory limits.

4.0 SITE HEALTH AND SAFETY

The health and safety of on-site personnel is a vital element of the work to be completed under
this RMP. Compliance with applicable federal, state and local regulations will be mandatory
during the site redevelopment project, including applicable Occupational Safety and Health
Administration (OSHA) standards under 29 CFR 1910.120. Prior to the initiation of site
activities, all contractors must develop a Site Health and Safety Plan, compliant with 29
CFR 1910.120, to address chemical and physical hazards at the site and provide criteria
intended to protect worker safety and restrict site access to only essential personnel.

Contractors requested to provide bids or proposals for services related to activities associated
with this SMP, must demonstrate qualifications by providing health and safety policies and
procedures, including medical surveillance and required training programs for proposed on-site
workers. An example of Site Heath and Safety Plan for contractor modification is provided in
Appendix D.
5.0 SOIL MANAGEMENT OPERATIONS

The SMP recognizes that initial and future construction must necessarily disturb soils on this
site. The SMP recognizes that unplanned or yet unknown maintenance might expose workers
to soils. The SMP tries to manage future site conditions to remain as close as possible to
conditions as they were at the time of evaluation. The site investigations performed on the site
were extensive, but our testing and analysis program conducted under customary industry
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practice did not test all areas of the property. There is always a possibility that unknown
conditions could occur between testing locations.

The SMP also provides workers with precautionary measures to recognize and address
potential new discoveries of COCs on the site, including the following:

• Minimize unnecessary disturbance of soils / fill materials from their original depths and
areas.
• If soils / fill materials are disturbed, return them as close as possible to their original
depths and areas.
• When moving impacted soils / fill materials, minimize dust and use standard industry
safety precautions.
• If a new area of impacted soils is discovered, understand how to isolate and evaluate the
conditions.
• If a new area of impacted soils is discovered, understand how to contain and seek
assistance.
• If impacted soils / fill materials must be removed from the site, use special procedures
for disposal.

The SMP contains general discussions and examples of industry standards, technologies or
methods available to contractors or owners. These discussions or references do not represent
any endorsement, certification or testimonial as to accuracy or quality by University Residences,
Multicon Development Company, Terracon, or the NCDENR.

5.1 Routine Control

Areas identified as impacted with COCs above NCDENR regulatory limits must be capped by
buildings, asphalt-paved parking and driveway areas or other impervious pavements. In the
event COCs are identified in areas designated as green space and/or recreational areas, the
contaminated soils should be excavated and moved to one of the designated Soil Management
Areas.

5.2 Dust Control

Dust generation is to be avoided at all times. If soils are dry and the potential for soils to migrate
through air is increased, standard construction procedures for dust control should be used. This
usually takes the form of a light application of water periodically to moisten soils. In case of
visible dust and before dust controls are in place, workers should make use of disposable dust
masks as a precautionary measure.

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5.3 Water Management

Excavation areas and property boundaries shall be graded, bermed, or provided with an
equivalent barrier where necessary to help prevent storm water from entering the excavation
and storm water run-off from leaving the site boundaries. Storm water that collects in
excavation areas will be diverted and pumped into temporary on-site holding tanks or left in the
excavation until proven to not be impacted by COCs. The storm water must be sampled and
analyzed to determine if it has been impacted by COCs above appropriate regulatory levels. If
the water is not impacted by COCs above regulatory levels, it will be used either as dust
suppression during further excavation/grading activities or may be discharged to on-site storm
water management basins.

If an analysis of the water indicates that it contains significant concentrations of COCs above
regulatory action levels, the on-site environmental manager or equivalent qualified
environmental professional will contact the client to discuss the potential treatment (i.e.
solidification, filtration, etc.) and / or disposal options.

5.4 Underground Excavation and Trenching

During the initial site grading activities, all soils below the on-site buildings must be assumed to
be impacted by COCs and workers should use appropriate safety apparel, referred to as
Modified Level D Safety. Areas of the site where soils impacted by COCs are encountered will
be capped by a building foundation, asphalt, or concrete surface or the impacted soils will be
excavated and placed in a designated Soil Management Area.

The SMP recognizes that after initial grading and installation of the approved engineered
barriers, these soils will at times need to be disturbed for the construction of utilities or other
structures. The general rule will be to remove and stockpile soils so that a “last out, first in”
process occurs. The soils/fill materials are the last returned to the excavation during backfill and
will be capped by an impervious structure or pavement.

Concerns and methods for environmental handling of soils do not preclude nor modify any of
the Occupational Safety and Health Administration (OSHA) requirements for worker safety
incumbent upon contractors for regular site safety and trenching/excavation activities. OSHA
requirements will dictate adjustment of the soil management methods where necessary.

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The SMP recognizes that soils “bulk” or expand in volume when disturbed during excavation.
The contractor will compact these materials into place according to the compaction
requirements of construction design. If no specifications for compacted fill exist, the contractor
will tamp the materials in place using the mechanical excavator or equivalent. Utilities or
structures will replace volumes of soils in these zones, resulting in excess soils as excavation
spoils. If these excess soils are impacted, they will be placed in a designated Soils
Management Area.

Petroleum contaminated soils excavated from the former on-site gasoline UST location will be
removed to a North Carolina-approved disposal facility.

Upper 2 Feet Green
Space, 3 Feet
Recreational Space
Original Grade
At Evaluation
Below 2 Feet Green
Space, 3 Feet
Recreational Space
First Soil Out,
Last Back In Spoil

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5.5 Discovery or Changed Conditions

There is a possibility that materials of unknown type could be present between sample
locations. The worker and contractor must be able to recognize when conditions change. Field
staff must be able to identify if a new discovery of changed chemical conditions has occurred,
and if so, if it is significant. If there is a question of the significance of a new discovery or
changed condition, the on-site environmental manager or equivalent qualified environmental
professional should make the determination.

5.6 Constant Observation

The worker or contractor should be alert during earthwork activities for 3 indicators which will
trigger the possible identification of a new COC condition not addressed by previous
investigations and evaluations.

1) During soil disturbance, the worker or contractor should observe soils for unique color
changes that are unlike surrounding soils / fill and unlike conditions of the original
assessment. The soils / fills identified during the previous investigations and testing are
varied in color and composition, ranging from browns through grays and dark grays to
almost black. In observing soils, some may be more saturated than others depending on
recent rainfall. Moist soils tend to appear darker. The worker or contractor should observe
closely dark, moist soils for evidence of saturation by other than water. No free oils or other
chemicals were observed during the site investigation. Oddly colored soils or those
saturated by free oil or other material is indicative of a changed condition.

2) Secondly, soils observed during prior site investigations had no chemical or solvent odors
associated with COC impacts measured in the laboratory, with the exception of the
impacted areas identified on Figure 2. Soils may often have a “musty” or “rotting” odor if
found mixed with vegetation or dark organic soils. Strong fuel, solvent or chemical odors in
soils found outside of the impacted areas identified on Figure 2 are indicative of a changed
condition.

3) Thirdly, soils / fill observed during exploration did not contain whole or crushed drums,
underground storage tanks, or other metal, plastic or glass bulk containers mixed into the fill.
However, fill soils were historically placed in this area from former manufacturing activities
and routinely contain fragments of metal, concrete, brick, tile and glass. Varying amounts of
sand and gravel mixed with soils were common. The worker and contractor should be alert
to man-made containers or remnants of containers of any material. The presence of whole
or crushed drums or containers in excess of 1 gallon in the soils / fill in combination with
odor or unique color changes may be indicative of a changed condition.

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If a changed condition is triggered by any of the above 3 observations, soils / fill and whole or
crushed drums or containers in excess of 1 gallon should be isolated.

5.7 Isolate Suspect Soils

The suspect soils should be isolated as soon as possible from contact and disturbance by rain
and wind until screening identification can be made. Construction flagging tape attached to
stakes can be used to prevent accidental movement of the soils by earthwork operations. When
possible, cover the soils with plastic sheeting and weight the covering with planks, sandbags, or
equivalent.

5.8 Preliminary Screening Identification

The soils should be screened for volatile and semi-volatile organic compounds. All screening
procedures must be conducted if conditions indicate a possible new discovery. The screening
will be provided by the on-site environmental manager or equivalent qualified environmental
professional. The owner or contractor may alternatively go directly to laboratory measurement
for identification purposes.

Screening tests can be conducted on the site and will produce preliminary results in a short
period. The field test does not produce a precise measurement of the amount of contaminant
found in the soils / fill, but indicates that contaminants are likely present and warrants further
caution and actual measurement. Specific field screening techniques are provided in Appendix
B.
6.0 MEASUREMENT OF CHANGED CONDITION

When preliminary screening indicates a changed condition may be present, it is necessary to
make more detailed measurements of COCs to determine if contaminants present in the soil
actually pose an excess risk. This requires testing in the laboratory. Laboratory testing requires
time. The amount of time varies depending on the type of test. In general, the testing for
metals is a matter of a few days. Hydrocarbon testing can take on the order of 5 to 7 business
days unless special arrangements are made with the laboratory for more expensive “RUSH”
results.

The impacted soils / fill should be further isolated from worker and public exposure. Special
handling and care must be taken in sampling and transporting soils for the laboratory tests to be
accurate. The workers in physical contact with soil/fill should have training consistent with 29
OSHA 1910.120.

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6.1 Increased Isolation from Exposure

During the period of laboratory testing, the impacted soil / fills should be further isolated from
public exposure and to prevent weather and construction activity from distributing these
potentially contaminated materials to other portions of the site. This can be done in a number of
ways, usually depending on the quantity of suspect soils / fills. For small volumes, the soil can
be placed temporarily in steel open-top drums with bolt-on lids. After sealing, the drum should
be clearly labeled “SOILS PENDING LABORATORY TESTING – DO NOT DISTURB, [Insert
Location], SAMPLE NO. [Insert #], [Insert Date], [Insert Name of Sampler and Phone Number]”.
The drums should be placed in an on-site area protected from general traffic.

For larger volumes, it can be effective to place the soils / fills into commercial roll-off dumpsters
which have been previously washed and cleaned of residues or soils / fills can be stockpiled on
plastic sheeting. The containers will not be of free-draining bottom construction and stockpiles
shall be graded, bermed, or provided with an equivalent barrier where necessary to help prevent
water run-off. The tops of the containers or stockpiles will then be covered with multiple plastic
sheeting and secured against wind and rain. The commercial containers or stockpiles should
be placarded on both sides with information similar to the above. In addition, each container /
stockpile should be clearly marked on every side with a highly visible sign as
“ENVIRONMENTAL CONTAINMENT - DO NOT USE FOR WASTE DISPOSAL OF ANY KIND”.

6.2 Sampling

Soils / materials will be collected by the on-site environmental manager or equivalent qualified
environmental professional and in laboratory-approved containers of sufficient volume to
conduct the requisite tests. The containers will be prepared to laboratory instructions consistent
Plastic Sheeting Secured Against Wind and Rain
Pre-Cleaned, Bulk Steel Waste Container or Stockpile
ENVIRONMENTAL
CONTAINMENT
DO NOT USE FOR
WASTE DISPOSAL OF
ANY KIND
Sampling Label As Above
SOILS PENDING
LABORATORY TESTING
DO NOT DISTURB
Location: A-1 Sample No.: 6B January 28, 2003
TERRACON, Inc.
704-509-1777
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with the necessary tests. Laboratory testing for chemical compound groups can be expensive.
A minimum of one sample for every 200 cubic yards of soil will be collected. Suggested
methods for collecting samples are attached in Appendix C.

6.2 Laboratory Testing

Suspect soils / materials will be tested for 3 groups of compounds; metals, PAHs and VOCs.
Acceptable detection limits for measurement will be set to the contaminant’s respective
NCDENR regulatory action level.

6.3 Comparison

Analytical results will be compared to the NCDENR regulatory action levels and a report will be
generated describing the changed conditions. Soils / fill may be returned to their respective
locations of depth under the appropriate engineered barrier as necessary to comply with the
Risk Management Plan. If soils are not able to be returned to their original location, then the
impacted soils should be placed in a soil management area, or removed off the site for disposal
at a North Carolina-approved disposal facility. Please see Section 8.0 Special Disposal
Requirements.
7.0 DISPOSITION OF EXCESS SOIL / FILL SPOILS

This SMP recognizes excess soils will be removed from the site. Only clean soils will be
removed from the site. In the event impacted soils must be removed from the site, the will be
transported to a North Carolina-approved disposal facility.

The worker or contractor must exercise care in placing impacted soils in a designated Soil
Management Area. Care must also be exercised in documenting and recording the location and
elevations of the soils placed in the designated Soil Management Areas. This is very important
in properly handling soils at this site.

8.0 SPECIAL DISPOSAL REQUIREMENTS

The prior site investigations indicate that limited areas of the property, beneath certain Newman
Machine buildings and an area of unsuitable fill materials on the Newman property are impacted
due to past industrial use of the site. Based on the analytical data collected during the various
investigations, the fill materials are generally impacted by various metals and/or polycyclic
aromatic hydrocarbons (PAHs). Groundwater at the site has also been identified as being
impacted by petroleum constituents and limited chlorinated solvent constituents.

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In fact, not all soils/fill materials located on the site are impacted by chemicals of concern
(COCs). Furthermore, not all impacted soils / fill materials in the identified impacted areas are
impacted above NCDENR regulatory limits.

8.1 On-Site Disposition

Excess soil / fill generated, isolated or contained as excavation spoils from the site will require
testing consistent with that described in Section 6.0 Measurement of Changed Condition. If the
laboratory testing indicates those chemicals are actually less than NCDENR regulatory action
level, the material is considered “clean” soil under the Risk Management Plan. Theses
materials may be redistributed on the site as with any other “clean” soil / fill material.

If laboratory testing of the excess soils / fill indicates chemicals above their respective NCDENR
regulatory action levels, the soil / fill may be placed in a Soil Management Area or in any area
which contains or will contain the approved Engineered Barrier(s), per the Risk Management
Plan. These Engineered Barriers include areas capped with a building, asphalt or concrete
surface.

In addition, if the owner chooses to assume that excess soils/fill are impacted by chemicals
above NCDENR regulatory action levels rather rely on laboratory analytical data, these soils/fill
may be placed in a Soil Management Area or in any area which contains or will contain the
approved Engineered Barrier(s), per the Risk Management Plan. These Engineered Barriers
include areas capped with a building, asphalt or concrete surface.

8.2 Off-Site Removal

Soils/fill materials which are to be removed from this site will require special evaluation and
documentation in addition to that previously discussed. The contractor should isolate, and
preferably contain these soils/fill materials for testing as done for suspect soils of new discovery.
Additional sampling and laboratory analysis is required to determine if the excess soils/fill
materials are hazardous or non-hazardous as defined by RCRA regulations. One sample per
every 500 cubic yards of soils/fill materials will be collected for analysis of semi-volatile organic
compounds (SVOCs), VOCs, and RCRA metals using the Toxicity Characteristic Leaching
Procedure (TCLP) to determine if the soils/fill materials are hazardous or non-hazardous waste.

Appropriate steps should be taken to minimize access to the stockpile area by non-essential
personnel. The stockpiles will be placed on the site at a minimum distance of 100 feet from
nearby residences and no closer than 50 feet to surface water drains, where practicable.
Additional protective measures may be necessary depending upon site conditions.

The top cover shall be installed to prevent soil from becoming exposed to wind or water and in a
manner which is designed to divert water away from the stockpile. The top cover shall be
placed to ensure that it will remain secured as long as the soil remains in the stockpile. The top
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cover shall be of one piece construction or be seamed in accordance with manufacturer’s
requirements and lapped over the bottom liner to prevent water runoff from reaching the
stockpiled material. The top cover will be inspected daily with repairs to the cover made
immediately if necessary.

Soils determined to be a hazardous waste, as indicated by TCLP analytical results, must be
transported off the site for disposal or treatment in accordance with applicable regulations.
Having knowledge of hazardous waste on the site triggers several federal requirements for
worker training, handling of the materials, reporting to state and federal agencies, and disposal.
Excavated soils that are to be transported off the site for disposal shall be loaded from the
stockpile into dump trucks for transportation to the disposal facility. All truck beds will be in
good condition with no leaks or damages. All trucks will be covered by a tarp prior to exit from
the project site. Soils identified as hazardous waste will be disposed at a landfill permitted for
hazardous waste disposal, referred to as a Subtitle C solid waste facility.

Soils/fill materials identified as non-hazardous by TCLP analytical results that will not be
managed on site, may be disposed at a local sanitary landfill permitted for waste disposal,
known as a Subtitle D solid waste facility. The landfill may require additional laboratory testing
prior to accepting the soils/fill materials for disposal to demonstrate the material is not a
hazardous waste.
9.0 SUMMARY

The worker or contractor involved with soils / fill on this site should recognize that COC impacts
have occurred to some soils. The maximum concentrations of COCs detected during prior site
investigations have been found not to pose excess risk to the public, occupants or workers on
the site, providing the materials are managed and maintained in accordance with this SMP. In
summary,

• Do not disturb soils unless necessary. Restore soils as close as possible to original
conditions when they must be disturbed.
• Incorporate the concepts of this Soil Management Plan in planning earthwork activity.
• Employ the concepts of this Soil Management Plan in conducting earthwork activity.
• Practice sound horizontal and vertical control with documentation consistent with this
Plan in conducting earthwork activity.
• Incorporate safety practices in the requisite contractor program to protect employees
and prudently avoid contact with soils and dust whenever possible.

APPENDIX A

Contaminant Summaries: Agency for Toxic Substance and Disease Registry
(ATSDR) Summaries
Tetrachloroethylene (PERC): Public Health Statement
Public Health Statement for Tetrachloroethylene
September 1997
CAS# 127-18-4
This Public Health Statement is the summary chapter from the Toxicological
Profile for tetrachloroethylene (/ToxProfiles/TP.asp?id=265&tid=48) . It is one in a
series of Public Health Statements about hazardous substances and their health
effects. A shorter version, the ToxFAQs™ (/toxfaqs/TF.asp?id=264&tid=48) , is also
available. This information is important because this substance may harm you.
The effects of exposure to any hazardous substance depend on the dose, the
duration, how you are exposed, personal traits and habits, and whether other
chemicals are present. For more information, call the ATSDR Information Center
at 1-888-422-8737.
This public health statement tells you about tetrachloroethylene and the effects of exposure.
The Environmental Protection Agency (EPA) identifies the most serious hazardous waste sites
in the nation. These sites make up the National Priorities List (NPL) and are the sites targeted
for long-term federal cleanup. Tetrachloroethylene has been found in at least 771 of the 1,430
current or former NPL sites. However, it's unknown how many NPL sites have been evaluated
for this substance. As more sites are evaluated, the sites with tetrachloroethylene may increase.
This is important because exposure to this substance may harm you and because these sites
may be sources of exposure.
When a substance is released from a large area, such as an industrial plant, or from a
container, such as a drum or bottle, it enters the environment. This release does not always
lead to exposure. You are exposed to a substance only when you come in contact with it. You
may be exposed by breathing, eating, or drinking the substance or by skin contact.
If you are exposed to tetrachloroethylene, many factors determine whether you'll be harmed.
These factors include the dose (how much), the duration (how long), and how you come in
contact with it. You must also consider the other chemicals you're exposed to and your age, sex,
diet, family traits, lifestyle, and state of health.
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1.1 What is tetrachloroethylene?
Tetrachloroethylene is a synthetic chemical that is widely used for dry cleaning of fabrics and
for metal-degreasing operations. It is also used as a starting material (building block) for
making other chemicals and is used in some consumer products. Other names for
tetrachloroethylene include perchloroethylene, PCE, perc, tetrachloroethene, perclene, and
perchlor. It is a nonflammable liquid at room temperature. It evaporates easily into the air and
has a sharp, sweet odor. Most people can smell tetrachloroethylene when it is present in the air
at a level of 1 part in 1 million parts of air (ppm) or more. In an experiment, some people could
smell tetrachloroethylene in water at a level of 0.3 ppm.
Page 1 of 6ATSDR - Public Health Statement: Tetrachloroethylene (PERC)
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1.2 What happens to tetrachloroethylene when it enters the environment?
Tetrachloroethylene enters the environment mostly by evaporating into the air during use. It
can also get into water supplies and the soil during disposal of sewage sludge and factory waste
and when leaking from underground storage tanks. Tetrachloroethylene may also get into the
air, soil, or water by leaking or evaporating from storage and waste sites. It can stay in the air
for several months before it is broken down into other chemicals or is brought back down to
the soil and water by rain.
Much of the tetrachloroethylene that gets into water and soil will evaporate into the air.
However, because tetrachloroethylene can travel through soils quite easily, it can get into
underground drinking water supplies. If it gets into underground water, it may stay there for
many months without being broken down. If conditions are right, bacteria will break down
some of it and some of the chemicals formed may also be harmful. Under some conditions,
tetrachloroethylene may stick to the soil and stay there. It does not seem to build up in animals
that live in water, such as fish, clams, and oysters. We do not know if it builds up in plants
grown on land.
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1.3 How might I be exposed to tetrachloroethylene?
People can be exposed to tetrachloroethylene from environmental and occupational sources
and from consumer products. Common environmental levels of tetrachloroethylene (called
background levels) are several thousand times lower than levels found in some workplaces.
Background levels are found in the air we breathe, in the water we drink, and in the food we
eat. The chemical is found most frequently in air and, less often, in water. Tetrachloroethylene
gets into air by evaporation from industrial or dry cleaning operations. It is also released from
areas where chemical wastes containing it are stored. It is frequently found in water. For
example, tetrachloroethylene was found in 38% of 9,232 surface water sampling sites
throughout the United States. There is no similar information on how often the chemical is
found in air samples, but we know it is widespread. We do not know how often it is found in
soil, but in one study, it was found in 5% of 359 sediment samples.
In general, tetrachloroethylene levels in air are higher in cities or industrial areas where it is in
use more than in more rural or remote areas. You can smell it at levels of 1 ppm in air.
However, the background level of tetrachloroethylene in air is usually less than 1 part in 1
billion parts of air (ppb). The air close to dry cleaning shops and chemical waste sites has levels
of tetrachloroethylene higher than background levels. These levels are usually less than 1 ppm,
the level at which you can smell it. Water, both above and below ground, may contain
tetrachloroethylene. Levels in water are also usually less than 1 ppb. Levels in contaminated
water near disposal sites are higher than levels in water far away from those sites. Water
polluted with this chemical may have levels greater than 1 ppm. In soil, background levels are
probably 100–1,000 times lower than 1 ppm.
You can also be exposed to tetrachloroethylene by using certain consumer products. Products
that may contain it include water repellents, silicone lubricants, fabric finishers, spot removers,
adhesives, and wood cleaners. Although uncommon, small amounts of tetrachloroethylene
have been found in food, especially food prepared near a dry cleaning shop. When you bring
clothes home from the dry cleaners, the clothes may release small amounts of
tetrachloroethylene into the air. The full significance to human health of these exposures to
Page 2 of 6ATSDR - Public Health Statement: Tetrachloroethylene (PERC)
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small amounts of tetrachloroethylene is unknown, but to date, they appear to be relatively
harmless. Tetrachloroethylene can also be found in the breast milk of mothers who have been
exposed to the chemical.
The people with the greatest chance of exposure to tetrachloroethylene are those who work
with it. According to estimates from a survey conducted by the National Institute for
Occupational Safety and Health (NIOSH), more than 650,000 U.S. workers may be exposed.
For the general population, the estimated amount that a person might breathe per day ranges
from 0.08 to 0.2 milligrams. The estimated amount that most people might drink in water
ranges from 0.0001 to 0.002 milligrams per day. These are very small amounts.
back to top (#)
1.4 How can tetrachloroethylene enter and leave my body?
Tetrachloroethylene can enter your body when you breathe air containing it. How much enters
your body in this way depends on how much of the chemical is in the air, how fast and deeply
you are breathing, and how long you are exposed to it. Tetrachloroethylene may also enter your
body when you drink water or eat food containing the chemical. How much enters your body in
this way depends on how much of the chemical you drink or eat. These two exposure routes are
the most likely ways people will take in tetrachloroethylene. These are also the most likely ways
that people living near areas polluted with the chemical, such as hazardous waste sites, might
be exposed to it. If tetrachloroethylene is trapped against your skin, a small amount of it can
pass through into your body. Very little tetrachloroethylene in the air can pass through your
skin into your body.
Most tetrachloroethylene leaves your body from your lungs when you breathe out. This is true
whether you take in the chemical by breathing, drinking, eating, or touching it. A small amount
of the tetrachloroethylene is changed by your body (especially your liver) into other chemicals
that are removed from your body in urine. Most of the changed tetrachloroethylene leaves your
body in a few days. Some of it that you take in is found in your blood and other tissues,
especially body fat. Part of the tetrachloroethylene that is stored in fat may stay in your body
for several days or weeks before it is eliminated.
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1.5 How can tetrachloroethylene affect my health?
To protect the public from the harmful effects of toxic chemicals and to find ways to treat
people who have been harmed, scientists use many tests.
One way to see if a chemical will hurt people is to learn how the chemical is absorbed, used,
and released by the body; for some chemicals, animal testing may be necessary. Animal testing
may also be used to identify health effects such as cancer or birth defects. Without laboratory
animals, scientists would lose a basic method to get information needed to make wise decisions
to protect public health. Scientists have the responsibility to treat research animals with care
and compassion. Laws today protect the welfare of research animals, and scientists must
comply with strict animal care guidelines.
Tetrachloroethylene has been used safely as a general anesthetic agent, so at high
concentrations, it is known to produce loss of consciousness. When concentrations in air are
high—particularly in closed, poorly ventilated areas—single exposures can cause dizziness,
headache, sleepiness, confusion, nausea, difficulty in speaking and walking, unconsciousness,
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and death. Irritation may result from repeated or extended skin contact with the chemical. As
you might expect, these symptoms occur almost entirely in work (or hobby) environments
when individuals have been accidentally exposed to high concentrations or have intentionally
abused tetrachloroethylene to get a "high." In industry, most workers are exposed to levels
lower than those causing dizziness, sleepiness, and other nervous system effects. The health
effects of breathing in air or drinking water with low levels of tetrachloroethylene are not
definitely known. However, at levels found in the ambient air or drinking water, risk of adverse
health effects is minimal. The effects of exposing babies to tetrachloroethylene through breast
milk are unknown. Results from some studies suggest that women who work in dry cleaning
industries where exposures to tetrachloroethylene can be quite high may have more menstrual
problems and spontaneous abortions than women who are not exposed. However, it is not
known for sure if tetrachloroethylene was responsible for these problems because other
possible causes were not considered.
Results of animal studies, conducted with amounts much higher than those that most people
are exposed to, show that tetrachloroethylene can cause liver and kidney damage and liver and
kidney cancers even though the relevance to people is unclear. Although it has not been shown
to cause cancer in people, the U.S. Department of Health and Human Services has determined
that tetrachloroethylene may reasonably be anticipated to be a human carcinogen. The
International Agency for Research on Cancer (IARC) has determined that tetrachloroethylene
is probably carcinogenic to humans. Exposure to very high levels of tetrachloroethylene can be
toxic to the unborn pups of pregnant rats and mice. Changes in behavior were observed in the
offspring of rats that breathed high levels of the chemical while they were pregnant. Rats that
were given oral doses of tetrachloroethylene when they were very young, when their brains
were still developing, were hyperactive when they became adults. How tetrachloroethylene
may affect the developing brain in human babies is not known.
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1.6 Is there a medical test to determine whether I have been exposed to
tetrachloroethylene?
One way of testing for tetrachloroethylene exposure is to measure the amount of the chemical
in the breath, much the same way breath alcohol measurements are used to determine the
amount of alcohol in the blood. This test has been used to measure levels of the chemical in
people living in areas where the air is contaminated with tetrachloroethylene or those exposed
to the chemical through their work. Because it is stored in the body's fat and is slowly released
into the bloodstream, it can be detected in the breath for weeks following a heavy exposure.
Tetrachloroethylene can be detected in the blood. Also, breakdown products of the chemical
can be detected in the blood and urine of people exposed to tetrachloroethylene.
Trichloroacetic acid (TCA), a breakdown product of tetrachloroethylene can be detected for
several days after exposure. These tests are relatively simple to perform. The breath, blood, or
urine must be collected in special containers and then sent to a laboratory for testing. Because
exposure to other chemicals can produce the same breakdown products in the urine and blood,
the tests for breakdown products cannot determine if you have been exposed only to
tetrachloroethylene.
back to top (#)
1.7 What recommendations has the federal government made to protect human
health?
Page 4 of 6ATSDR - Public Health Statement: Tetrachloroethylene (PERC)
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The federal government develops regulations and recommendations to protect public health.
Regulations can be enforced by law. Federal agencies that develop regulations for toxic
substances include the EPA, the Occupational Safety and Health Administration (OSHA), and
the Food and Drug Administration (FDA). Recommendations provide valuable guidelines to
protect public health but cannot be enforced by law. Federal organizations that develop
recommendations for toxic substances include the Agency for Toxic Substances and Disease
Registry (ATSDR) and NIOSH.
Regulations and recommendations can be expressed in not-to-exceed levels in air, water, soil,
or food that are usually based on levels that affect animals; then they are adjusted to help
protect people. Sometimes these not-to-exceed levels differ among federal organizations
because of different exposure times (an 8-hour workday or a 24-hour day), the use of different
animal studies, or other factors.
Recommendations and regulations are also periodically updated as more information becomes
available. For the most current information, check with the federal agency or organization that
provides it. Some regulations and recommendations for tetrachloroethylene include the
following:
The EPA maximum contaminant level for the amount of tetrachloroethylene that can be in
drinking water is 0.005 milligrams tetrachloroethylene per liter of water (mg/L) (0.005 ppm).
EPA has established regulations and procedures for dealing with tetrachloroethylene, which it
considers a hazardous waste. Many regulations govern its disposal. If amounts greater than
100 pounds are released to the environment, the National Response Center of the federal
government must be told immediately.
OSHA limits the amount of tetrachloroethylene that can be present in workroom air. This
amount is limited to 100 ppm for an 8-hour workday over a 40-hour workweek. NIOSH
recommends that tetrachloroethylene be handled as a chemical that might potentially cause
cancer and states that levels of the chemical in workplace air should be as low as possible.
back to top (#)
1.8 Where can I get more information?
If you have any more questions or concerns, please contact your community or
state health or environmental quality department or:
Agency for Toxic Substances and Disease Registry
Division of Toxicology
1600 Clifton Road NE, Mailstop F-32
Atlanta, GA 30333
Information line and technical assistance:
Phone: [phone]
FAX: [phone]
ATSDR can also tell you the location of occupational and environmental health clinics. These
clinics specialize in recognizing, evaluating, and treating illnesses resulting from exposure to
hazardous substances.
To order toxicological profiles, contact:
Page 5 of 6ATSDR - Public Health Statement: Tetrachloroethylene (PERC)
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Agency for Toxic Substances and Disease Registry, 4770 Buford Hwy NE,
Atlanta, GA 30341
Contact CDC: 800-232-4636 / TTY: 888-232-6348
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Phone: [phone] or 703-605-6000
back to top (#)
References
Agency for Toxic Substances and Disease Registry (ATSDR). 1997. Toxicological profile for
tetrachloroethylene (/ToxProfiles/TP.asp?id=265&tid=48) . Atlanta, GA: U.S. Department of
Health and Human Services, Public Health Service.
back to top (#)
Page last reviewed: March 1, 2010•
Page last updated: March 1, 2010•
Content source: Agency for Toxic Substance and Disease Registry (http://www.atsdr.cdc.gov/) •
Page 6 of 6ATSDR - Public Health Statement: Tetrachloroethylene (PERC)
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PUBLIC HEALTH STATEMENT
Carbon Tetrachloride
CAS#: 56-23-5
Division of Toxicology August 2005
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
This Public Health Statement is the summary
chapter from the Toxicological Profile for Carbon
Tetrachloride. It is one in a series of Public Health
Statements about hazardous substances and their
health effects. A shorter version, the ToxFAQs™,
is also available. This information is important
because this substance may harm you. The effects
of exposure to any hazardous substance depend on
the dose, the duration, how you are exposed,
personal traits and habits, and whether other
chemicals are present. For more information, call
the ATSDR Information Center at 1-888-422-8737.
_____________________________________

This public health statement tells you about carbon
tetrachloride and the effects of exposure to it.

The Environmental Protection Agency (EPA)
identifies the most serious hazardous waste sites in
the nation. These sites are then placed on the
National Priorities List (NPL) and are targeted for
long-term federal clean-up activities. Carbon
tetrachloride has been found in at least 430 of the
1,662 current or former NPL sites. Although the
total number of NPL sites evaluated for this
substance is not known, the possibility exists that
the number of sites at which carbon tetrachloride is
found may increase in the future as more sites are
evaluated. This information is important because
these sites may be sources of exposure and exposure
to this substance may harm you.

When a substance is released either from a large
area, such as an industrial plant, or from a container,
such as a drum or bottle, it enters the environment.
Such a release does not always lead to exposure.
You can be exposed to a substance only when you
come in contact with it. You may be exposed by
breathing, eating, or drinking the substance, or by
skin contact.

If you are exposed to carbon tetrachloride, many
factors will determine whether you will be harmed.
These factors include the dose (how much), the
duration (how long), and how you come in contact
with it. You must also consider any other chemicals
you are exposed to and your age, sex, diet, family
traits, lifestyle, and state of health.

1.1 WHAT IS CARBON TETRACHLORIDE?

Carbon tetrachloride is a clear liquid that evaporates
very easily. Most carbon tetrachloride that escapes
to the environment is therefore found as a gas.
Carbon tetrachloride does not easily burn. Carbon
tetrachloride has a sweet odor, and most people can
begin to smell it in air when the concentration
reaches 10 parts carbon tetrachloride per million
parts of air (ppm). It is not known whether people
can taste it or, if they can, at what level. Carbon
tetrachloride is a manufactured chemical and does
not occur naturally in the environment,

Carbon tetrachloride has been produced in large
quantities to make refrigeration fluid and
propellants for aerosol cans. Since many
refrigerants and aerosol propellants have been found
to affect the earth's ozone layer, the production of
these chemicals is being phased out. Consequently,
the manufacture and use of carbon tetrachloride has
declined a great deal.

In the past, carbon tetrachloride was widely used as
a cleaning fluid (in industry and dry cleaning
establishments as a degreasing agent, and in
PUBLIC HEALTH STATEMENT
Carbon Tetrachloride
CAS#: 56-23-5
Division of Toxicology August 2005
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
households as a spot remover for clothing, furniture,
and carpeting). Carbon tetrachloride was also used
in fire extinguishers and as a fumigant to kill insects
in grain. Most of these uses were discontinued in
the mid-1960s. Until recently, carbon tetrachloride
was used as a pesticide, but this was stopped in
1986.

1.2 WHAT HAPPENS TO CARBON
TETRACHLORIDE WHEN IT ENTERS
THE ENVIRONMENT?

Because carbon tetrachloride evaporates easily,
most of the compound released to the environment
during its production and use reaches the air, where
it is found mainly as a gas. It can remain in air for
several years before it is broken down to other
chemicals. Small amounts of carbon tetrachloride
are found in surface water. Because it evaporates
easily, much of it will move from surface water to
the air within a few days or weeks. However, it
may be trapped in groundwater for longer periods.
Carbon tetrachloride is not expected to stick to soil
particles. If spilled onto the ground, much of it will
evaporate to the air. Some of it may also go into
groundwater, where it can remain for months before
it is broken down to other chemicals. It is not
expected to build up in fish. We do not know if it
builds up in plants.

1.3 HOW MIGHT I BE EXPOSED TO
CARBON TETRACHLORIDE?

Very low background levels of carbon tetrachloride
are found in air, water, and soil because of past and
present releases. Concentrations in air of 0.1 part
carbon tetrachloride per billion parts of air (ppb) are
common around the world, with somewhat higher
levels often found (0.2–0.6 ppb) in cities. Carbon
tetrachloride is also found in some drinking water
supplies, usually at concentrations less than 0.5 ppb.
Exposure to levels of carbon tetrachloride higher
than these typical "background" levels is likely to
occur only at specific industrial locations where
carbon tetrachloride is still used or near chemical
waste sites where emissions into air, water, or soil
are not properly controlled. Exposure at such sites
could occur by breathing carbon tetrachloride
present in the air, by drinking water contaminated
with carbon tetrachloride, or by getting soil
contaminated with carbon tetrachloride on the skin.
Young children may also be exposed if they eat soil
that contains carbon tetrachloride. Carbon
tetrachloride has been found in water or soil at
about 26% of the waste sites investigated under
Superfund, at concentrations ranging from less than
50 to over 1,000 ppb.

People who work with carbon tetrachloride are
likely to receive the greatest exposure to the
compound. The National Institute for Occupational
Safety and Health (NIOSH) estimates that 58,208
workers are potentially exposed to carbon
tetrachloride in the United States. The average
daily intake of carbon tetrachloride for the general
population is estimated to be 0.1 microgram (µg per
kg of body weight). The estimated average daily
amount that the general population may drink in
water is 0.01 µg per kg of body weight.

PUBLIC HEALTH STATEMENT
Carbon Tetrachloride
CAS#: 56-23-5
Division of Toxicology August 2005
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
1.4 HOW CAN CARBON TETRACHLORIDE
ENTER AND LEAVE MY BODY?

Carbon tetrachloride can enter your body through
your lungs if you breathe air containing carbon
tetrachloride, or through your stomach and
intestines if you swallow food or water containing
carbon tetrachloride. Carbon tetrachloride can also
pass through the skin into the body. When you
inhale carbon tetrachloride, over 30–40% of what
you inhale enters your body, where most of it
temporarily accumulates in body fat. Some can
enter the kidney, liver, brain, lungs, and skeletal
muscle. When you drink water contaminated with
carbon tetrachloride, about 85–91% of it can enter
your body. Much of the compound that enters your
body when you breathe it or drink water
contaminated with it leaves your body quickly, and
a lot of it can be found in your breath within a few
hours. Animal studies have shown that under
differing conditions, 34–75% of carbon
tetrachloride leaves the body in expired air, 20–62%
leaves the body in feces, and only low amounts
leave the body in the urine. Animal studies also
suggest that it may take weeks for the remainder of
the compound in the body to be eliminated,
especially that which has entered the body fat.
Most of the carbon tetrachloride is eliminated from
your body unchanged, but some of it may be
changed to other chemicals before removal from the
body (for example, chloroform, hexachloroethane,
and carbon dioxide). Chloroform and
hexachloroethane may themselves cause harmful
effects.

1.5 HOW CAN CARBON TETRACHLORIDE
AFFECT MY HEALTH?

Scientists use many tests to protect the public from
harmful effects of toxic chemicals and to find ways
for treating persons who have been harmed.

One way to learn whether a chemical will harm
people is to determine how the body absorbs, uses,
and releases the chemical. For some chemicals,
animal testing may be necessary. Animal testing
may also help identify health effects such as cancer
or birth defects. Without laboratory animals,
scientists would lose a basic method for getting
information needed to make wise decisions that
protect public health. Scientists have the
responsibility to treat research animals with care
and compassion. Scientists must comply with strict
animal care guidelines because laws today protect
the welfare of research animals.

Most information on the health effects of carbon
tetrachloride in humans comes from cases where
people have been exposed to relatively high levels
of carbon tetrachloride, either only once or for a
short period, for example, by accidental poisoning
or by working with the chemical in a confined space
without ventilation. Experiments have not been
performed on the effects of long-term exposure of
humans to low levels of carbon tetrachloride, so the
human health effects of such exposures are not
known.

The liver is especially sensitive to carbon
tetrachloride since it contains a large amount of the
enzymes that change the form of the chemical.
Some of the breakdown products may attack cell
proteins, interfering with the functions of the liver
PUBLIC HEALTH STATEMENT
Carbon Tetrachloride
CAS#: 56-23-5
Division of Toxicology August 2005
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
cells. Products that attack cell membranes may
result in the death of the cells. In mild cases, the
liver becomes swollen and tender, and fat builds up
inside the organ. In severe cases, liver cells may be
damaged or destroyed, leading to a decrease in liver
function. Such effects are usually reversible if
exposure is not too high or too long.

The kidney is also sensitive to carbon tetrachloride.
Less urine may be formed, leading to a buildup of
water in the body (especially in the lungs) and
buildup of waste products in the blood. Kidney
failure often was the main cause of death in people
who died after very high exposure to carbon
tetrachloride. Long-term breathing exposure to
carbon tetrachloride worsened age-related kidney
disease in rats.

Fortunately, if injuries to the liver and kidney are
not too severe, these effects eventually disappear
after exposure stops. This is because both organs
can repair damaged cells and replace dead cells.
Function usually returns to normal within a few
days or a few weeks after the exposure has stopped.

After exposure to high levels of carbon
tetrachloride, the nervous system, including the
brain, is affected. Such exposure can be fatal. The
immediate effects are usually signs of intoxication,
including headache, dizziness, and sleepiness
perhaps accompanied by nausea and vomiting.
These effects usually disappear within 1–2 days
after exposure stops. In severe cases, stupor or even
coma can result, and permanent damage to nerve
cells can occur.

Carbon tetrachloride also causes effects on other
tissues of the body, but these are not usually as
common or important as the effects on the liver,
kidney, and brain.

There have been no studies of the effects of carbon
tetrachloride on reproduction in humans, but studies
in rats showed that long-term inhalation may cause
decreased fertility.

Studies in animals have shown that swallowing or
breathing carbon tetrachloride over a period of
years increases the frequency of liver tumors. Mice
breathing carbon tetrachloride also developed
tumors of the adrenal gland. Studies have not been
performed to determine whether swallowing or
breathing carbon tetrachloride causes tumors in
humans, but it should be assumed that carbon
tetrachloride could produce cancer. The
Department of Health and Human Services (DHHS)
has determined that carbon tetrachloride may
reasonably be anticipated to be a carcinogen (i.e.,
cause cancer). The International Agency for
Research on Cancer (IARC) has classified carbon
tetrachloride in Group 2B, possibly carcinogenic to
humans. EPA has determined that carbon
tetrachloride is a probable human carcinogen.

Many reported cases of carbon tetrachloride toxicity
are associated with drinking alcohol. The frequent
drinking of alcoholic beverages increases the danger
of organ damage from carbon tetrachloride
exposure. This enhanced effect has been shown in
situations in which a group of workers were
exposed to carbon tetrachloride in air, but only
those who were heavy consumers of alcohol
became ill.

PUBLIC HEALTH STATEMENT
Carbon Tetrachloride
CAS#: 56-23-5
Division of Toxicology August 2005
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
1.6 HOW CAN CARBON TETRACHLORIDE
AFFECT CHILDREN?

This section discusses potential health effects in
humans from exposures during the period from
conception to maturity at 18 years of age.

Children and adults may be exposed to low levels of
carbon tetrachloride in drinking water. Small
children who live near factories that produce or use
carbon tetrachloride could accidentally eat some of
the chemical by putting dirty hands in their mouths,
but the amount of carbon tetrachloride in the soil is
thought to be too low to be harmful. Carbon
tetrachloride is no longer used in consumer
products, but children could breathe in vapors if
households are still using old supplies.

It is not known if the way in which carbon
tetrachloride is absorbed into and eliminated from
the body is different in children than it is in adults,
but the processes are likely to be similar. Compared
to adults, young children have lower amounts of the
enzyme that converts carbon tetrachloride to a
harmful chemical. The health effects of carbon
tetrachloride have not been studied in children, but
they are likely to be similar to those seen in adults
exposed to the chemical.

There is no direct evidence that maternal exposure
to carbon tetrachloride has a harmful effect on the
fetus in humans. A few human survey-type studies
suggest that maternal drinking water exposure to
carbon tetrachloride might possibly be related to
certain birth defects, such as low birthweight and
small size at birth. Information from animal studies
indicates that carbon tetrachloride may cause early
fetal deaths, but does not cause birth defects in
babies surviving to term. However, these animal
studies did not test for neurological damage in
exposed newborn babies.

One study calculated that carbon tetrachloride is
likely to pass from the maternal circulation into
breast milk. Thus, it is possible that children could
be exposed to carbon tetrachloride from breast
feeding, but the levels of exposure are likely to be
low.

1.7 HOW CAN FAMILIES REDUCE THE
RISK OF EXPOSURE TO CARBON
TETRACHLORIDE?

If your doctor finds that you have been exposed to
substantial amounts of carbon tetrachloride, ask
whether your children might also have been
exposed. Your doctor might need to ask your state
health department to investigate.

Although most consumer uses of carbon
tetrachloride have been banned, children may be
exposed to carbon tetrachloride in old consumer
household cleaning products. Removing these old
containers will reduce your family’s risk of
exposure to carbon tetrachloride. Household
chemicals should be stored out of the reach of
children to prevent accidental poisonings and skin
burns. Always store household chemicals in their
original containers. Never store household
chemicals in containers that children would find
attractive to eat and drink from, such as old soda
bottles. Keep your poison control center’s number
next to your phone.

PUBLIC HEALTH STATEMENT
Carbon Tetrachloride
CAS#: 56-23-5
Division of Toxicology August 2005
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
Sometimes older children sniff household chemicals
in an attempt to get high. Your children may be
exposed to carbon tetrachloride by intentionally
inhaling products containing it. Talk with your
children about the dangers of sniffing chemicals.

1.8 IS THERE A MEDICAL TEST TO
DETERMINE WHETHER I HAVE BEEN
EXPOSED TO CARBON
TETRACHLORIDE?

Several very sensitive and specific tests can detect
carbon tetrachloride in exposed persons. The most
convenient way is simply to measure carbon
tetrachloride in exhaled air, but carbon tetrachloride
can also be measured in blood, fat, or other tissues.
Because special equipment is needed, these tests are
not routinely performed in doctors' offices, but your
doctor can refer you to where you can obtain such a
test. Although these tests can show that a person
has been exposed to carbon tetrachloride, the test
results cannot be used to reliably predict whether
any bad health effects might result. Because carbon
tetrachloride leaves the body fairly quickly, these
methods are best suited to detecting exposures that
have occurred within the last several days.

1.9 WHAT RECOMMENDATIONS HAS THE
FEDERAL GOVERNMENT MADE TO
PROTECT HUMAN HEALTH?

The federal government develops regulations and
recommendations to protect public health.
Regulations can be enforced by law. The EPA, the
Occupational Safety and Health Administration
(OSHA), and the Food and Drug Administration
(FDA) are some federal agencies that develop
regulations for toxic substances. Recommendations
provide valuable guidelines to protect public health,
but cannot be enforced by law. The Agency for
Toxic Substances and Disease Registry (ATSDR)
and the National Institute for Occupational Safety
and Health (NIOSH) are two federal organizations
that develop recommendations for toxic substances.

Regulations and recommendations can be expressed
as “not-to-exceed” levels, that is, levels of a toxic
substance in air, water, soil, or food that do not
exceed a critical value that is usually based on
levels that affect animals; they are then adjusted to
levels that will help protect humans. Sometimes
these not-to-exceed levels differ among federal
organizations because they used different exposure
times (an 8-hour workday or a 24-hour day),
different animal studies, or other factors.

Recommendations and regulations are also updated
periodically as more information becomes available.
For the most current information, check with the
federal agency or organization that provides it.
Some regulations and recommendations for carbon
tetrachloride include the following:

To protect the general public from exposure to
carbon tetrachloride, the federal government has
limited or banned the use of this compound in most
common household products and fire extinguishers,
and has discontinued its use as a pesticide. To
protect workers who use carbon tetrachloride while
on the job, the OSHA has set a maximum
concentration limit in workplace air of 10 ppm for
an 8-hour workday over a 40-hour work week.
EPA has also set limits on how much carbon
tetrachloride can be released from an industrial
plant into waste water and is preparing to set limits
PUBLIC HEALTH STATEMENT
Carbon Tetrachloride
CAS#: 56-23-5
Division of Toxicology August 2005
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
on how much carbon tetrachloride can escape from
an industrial plant into outside air. To ensure that
drinking water supplies are safe, EPA has set a
Maximum Contaminant Level (MCL) for carbon
tetrachloride of 5 parts per billion (ppb), based on
analytical detection limits in drinking water.
Because carbon tetrachloride is possibly
carcinogenic to humans, a Maximum Contaminant
Level Goal (MCLG) of zero has been proposed.

1.10 WHERE CAN I GET MORE
INFORMATION?

If you have any more questions or concerns, please
contact your community or state health or
environmental quality department, your regional
Nuclear Regulatory Commission office, or contact
ATSDR at the address and phone number below.

ATSDR can also tell you the location of
occupational and environmental health clinics.
These clinics specialize in recognizing, evaluating,
and treating illnesses resulting from exposure to
hazardous substances.

Toxicological profiles are also available on-line at
www.atsdr.cdc.gov and on CD-ROM. You may
request a copy of the ATSDR ToxProfiles
CD-ROM by calling the information and technical
assistance toll-free number at 1-888-42ATSDR
(1-888-422-8737), by email at [e-mail], or
by writing to:

Agency for Toxic Substances and Disease Registry
Division of Toxicology
1600 Clifton Road NE
Mailstop F-32
Atlanta, GA 30333
Fax: [phone]

For-profit organizations may request a copy of final
profiles from the following:

National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Phone: [phone] or 1-703-605-6000
Web site: http://www.ntis.gov/

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
This Public Health Statement is the summary
chapter from the Toxicological Profile for Lead. It
is one in a series of Public Health Statements about
hazardous substances and their health effects. A
shorter version, the ToxFAQs™, is also available.
This information is important because this
substance may harm you. The effects of exposure
to any hazardous substance depend on the dose, the
duration, how you are exposed, personal traits and
habits, and whether other chemicals are present.
For more information, call the ATSDR Information
Center at 1-800-232-4636.
__________________________________________

This public health statement tells you about lead
and the effects of exposure to it.

The Environmental Protection Agency (EPA)
identifies the most serious hazardous waste sites in
the nation. These sites are then placed on the
National Priorities List (NPL) and are targeted for
long-term federal clean-up activities. Lead has been
found in at least 1,272 of the 1,684 current or
former NPL sites. Although the total number of
NPL sites evaluated for this substance is not known,
the possibility exists that the number of sites at
which lead is found may increase in the future as
more sites are evaluated. This information is
important because these sites may be sources of
exposure and exposure to this substance may harm
you.

When a substance is released either from a large
area, such as an industrial plant, or from a container,
such as a drum or bottle, it enters the environment.
Such a release does not always lead to exposure.
You can be exposed to a substance only when you
come in contact with it. You may be exposed by
breathing, eating, or drinking the substance, or by
skin contact.

If you are exposed to lead, many factors will
determine whether you will be harmed. These
factors include the dose (how much), the duration
(how long), and how you come in contact with it.
You must also consider any other chemicals you are
exposed to and your age, sex, diet, family traits,
lifestyle, and state of health.

1.1 WHAT IS LEAD?

Lead is a heavy, low melting, bluish-gray metal that
occurs naturally in the Earth's crust. However, it is
rarely found naturally as a metal. It is usually found
combined with two or more other elements to form
lead compounds.

Metallic lead is resistant to corrosion (i.e., not easily
attacked by air or water). When exposed to air or
water, thin films of lead compounds are formed that
protect the metal from further attack. Lead is easily
molded and shaped. Lead can be combined with
other metals to form alloys. Lead and lead alloys
are commonly found in pipes, storage batteries,
weights, shot and ammunition, cable covers, and
sheets used to shield us from radiation. The largest
use for lead is in storage batteries in cars and other
vehicles.

Lead compounds are used as a pigment in paints,
dyes, and ceramic glazes and in caulk. The amount
of lead used in these products has been reduced in
recent years to minimize lead’s harmful effect on
people and animals. Tetraethyl lead and tetramethyl
lead were once used in the United States as gasoline
PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
additives to increase octane rating. However, their
use was phased out in the United States in the
1980s, and lead was banned for use in gasoline for
motor vehicles beginning January 1, 1996.
Tetraethyl lead may still be used in gasoline for off-
road vehicles and airplanes. It is also still used in a
number of developing countries. Lead used in
ammunition, which is the largest non-battery end-
use, has remained fairly constant in recent years.
However, even the use of lead in bullets and shot as
well as in fishing sinkers is being reduced because
of its harm to the environment.

Most lead used by industry comes from mined ores
("primary") or from recycled scrap metal or
batteries ("secondary"). Lead is mined in the
United States, primarily in Alaska and Missouri.
However, most lead today is “secondary” lead
obtained from lead-acid batteries. It is reported that
97% of these batteries are recycled.

1.2 WHAT HAPPENS TO LEAD WHEN IT
ENTERS THE ENVIRONMENT?

Lead occurs naturally in the environment.
However, most of the high levels found throughout
the environment come from human activities.
Environmental levels of lead have increased more
than 1,000-fold over the past three centuries as a
result of human activity. The greatest increase
occurred between the years 1950 and 2000, and
reflected increasing worldwide use of leaded
gasoline. Lead can enter the environment through
releases from mining lead and other metals, and
from factories that make or use lead, lead alloys, or
lead compounds. Lead is released into the air
during burning coal, oil, or waste. Before the use of
leaded gasoline was banned, most of the lead
released into the U.S. environment came from
vehicle exhaust. In 1979, cars released 94.6 million
kilograms (208.1 million pounds) of lead into the
air in the United States. In 1989, when the use of
lead was limited but not banned, cars released only
2.2 million kg (4.8 million pounds) to the air. Since
EPA banned the use of leaded gasoline for highway
transportation in 1996, the amount of lead released
into the air has decreased further. Before the 1950s,
lead was used in pesticides applied to fruit orchards.
Once lead gets into the atmosphere, it may travel
long distances if the lead particles are very small.
Lead is removed from the air by rain and by
particles falling to land or into surface water.

Sources of lead in dust and soil include lead that
falls to the ground from the air, and weathering and
chipping of lead-based paint from buildings,
bridges, and other structures. Landfills may contain
waste from lead ore mining, ammunition
manufacturing, or other industrial activities such as
battery production. Disposal of lead-containing
products contribute to lead in municipal landfills.
Past uses of lead such as its use in gasoline are a
major contributor to lead in soil, and higher levels
of lead in soil are found near roadways. Most of the
lead in inner city soils comes from old houses with
paint containing lead and previous automotive
exhaust emitted when gasoline contained lead.

Once lead falls onto soil, it sticks strongly to soil
particles and remains in the upper layer of soil.
That is why past uses of lead such as lead in
gasoline, house paint, and pesticides are so
important in the amount of lead found in soil.

Small amounts of lead may enter rivers, lakes, and
streams when soil particles are moved by rainwater.
PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
Small amounts of lead from lead pipe or solder may
be released into water when the water is acidic or
“soft”. Lead may remain stuck to soil particles or
sediment in water for many years. Movement of
lead from soil particles into groundwater is unlikely
unless the rain falling on the soil is acidic or "soft".
Movement of lead from soil will also depend on the
type of lead compound and on the physical and
chemical characteristics of the soil.

Sources of lead in surface water or sediment include
deposits of lead-containing dust from the
atmosphere, waste water from industries that handle
lead (primarily iron and steel industries and lead
producers), urban runoff, and mining piles.

Some lead compounds are changed into other forms
of lead by sunlight, air, and water. However,
elemental lead cannot be broken down.

The levels of lead may build up in plants and
animals from areas where air, water, or soil are
contaminated with lead. If animals eat
contaminated plants or animals, most of the lead
that they eat will pass through their bodies.

1.3 HOW MIGHT I BE EXPOSED TO LEAD?

Lead is commonly found in soil especially near
roadways, older houses, old orchards, mining areas,
industrial sites, near power plants, incinerators,
landfills, and hazardous waste sites. People living
near hazardous waste sites may be exposed to lead
and chemicals that contain lead by breathing air,
drinking water, eating foods, or swallowing dust or
dirt that contain lead. People may be exposed to
lead by eating food or drinking water that contains
lead. Drinking water in houses containing lead
pipes may contain lead, especially if the water is
acidic or “soft”. If one is not certain whether an
older building contains lead pipes, it is best to let
the water run a while before drinking it so that any
lead formed in the pipes can be flushed out. People
living in areas where there are old houses that have
been painted with lead paint may be exposed to
higher levels of lead in dust and soil. Similarly,
people who live near busy highways or on old
orchard land where lead arsenate pesticides were
used in the past may be exposed to higher levels of
lead. People may also be exposed to lead when
they work in jobs where lead is used or have
hobbies in which lead is used, such as making
stained glass.

Foods may contain small amounts of lead.
However, since lead solder is no longer used in
cans, very little lead is found in food. Leafy fresh
vegetables grown in lead-containing soils may have
lead-containing dust on them. Lead may also enter
foods if they are put into improperly glazed pottery
or ceramic dishes and from leaded-crystal
glassware. Illegal whiskey made using stills that
contain lead-soldered parts (such as truck radiators)
may also contain lead. Cigarette smoke may also
contain small amounts of lead. The amount of lead
found in canned foods decreased 87% from 1980 to
1988 in the United States, which indicates that the
chance of exposure to lead in canned food from
lead-soldered containers has been greatly reduced.
Lead-soldered cans are still used in some other
nations. In the most recent studies, lead was not
detectable in most foods and the average dietary
intake of lead was about 1 microgram (a microgram
is a millionth of a gram) per kilogram of body
weight per day. Children may be exposed to lead
PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
by hand-to-mouth contact after exposure to lead-
containing soil or dust.

In general, very little lead is found in lakes, rivers,
or groundwater used to supply the public with
drinking water. More than 99% of all publicly
supplied drinking water contains less than
0.005 parts of lead per million parts of water (ppm).
However, the amount of lead taken into your body
through drinking water can be higher in
communities with acidic water supplies. Acidic
water makes it easier for the lead found in pipes,
leaded solder, and brass faucets to be dissolved and
to enter the water we drink. Public water treatment
systems are now required to use control measures to
make water less acidic. Plumbing that contains lead
may be found in public drinking water systems, and
in houses, apartment buildings, and public buildings
that are more than 20 years old. However, as
buildings age, mineral deposits form a coating on
the inside of the water pipes that insulates the water
from lead in the pipe or solder, thus reducing the
amount of lead that can leach into the water. Since
1988, regulations require that drinking water
coolers must not contain lead in parts that come into
contact with drinking water.

Breathing in, or swallowing airborne dust and dirt,
is another way you can be exposed to lead. In 1984,
burning leaded gasoline was the single largest
source of lead emissions. Very little lead in the air
comes from gasoline now because EPA has banned
its use in gasoline for motor vehicles. Other sources
of lead in the air include releases to the air from
industries involved in iron and steel production,
lead-acid-battery manufacturing, and nonferrous
(brass and bronze) foundries. Lead released into air
may also come from burning of solid waste that
contains lead, windblown dust, volcanoes, exhaust
from workroom air, burning or weathering of lead-
painted surfaces, fumes and exhaust from leaded
gasoline, and cigarette smoke.

Skin contact with dust and dirt containing lead
occurs every day. Recent data have shown that
inexpensive cosmetic jewelry pieces sold to the
general public may contain high levels of lead
which may be transferred to the skin through
routine handling. However, not much lead can get
into your body through your skin.

In the home, you or your children may be exposed
to lead if you take some types of home remedy
medicines that contain lead compounds. Lead
compounds are in some non-Western cosmetics,
such as surma and kohl. Some types of hair
colorants, cosmetics, and dyes contain lead acetate.
Read the labels on hair coloring products, use them
with caution, and keep them away from children.

People who are exposed at work are usually
exposed by breathing in air that contains lead
particles. Exposure to lead occurs in many jobs.
People who work in lead smelting and refining
industries, brass/bronze foundries, rubber products
and plastics industries, soldering, steel welding and
cutting operations, battery manufacturing plants,
and lead compound manufacturing industries may
be exposed to lead. Construction and demolition
workers and people who work at municipal waste
incinerators, pottery and ceramics industries,
radiator repair shops, and other industries that use
lead solder may also be exposed. Painters who sand
or scrape old paint may be exposed to lead in dust.
Between 0.5 and 1.5 million workers are exposed to
lead in the workplace. In California alone, more
than 200,000 workers are exposed to lead. Families
of workers may be exposed to higher levels of lead
PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
when workers bring home lead dust on their work
clothes.

You may also be exposed to lead in the home if you
work with stained glass as a hobby, make lead
fishing weights or ammunition, or if you are
involved in home renovation that involves the
removal of old lead-based paint.

1.4 HOW CAN LEAD ENTER AND LEAVE
MY BODY?

Some of the lead that enters your body comes from
breathing in dust or chemicals that contain lead.
Once this lead gets into your lungs, it goes quickly
to other parts of the body in your blood.

Larger particles that are too large to get into your
lungs can be coughed up and swallowed. You may
also swallow lead by eating food and drinking
liquids that contain it. Most of the lead that enters
your body comes through swallowing, even though
very little of the amount you swallow actually
enters your blood and other parts of your body. The
amount that gets into your body from your stomach
partially depends on when you ate your last meal. It
also depends on how old you are and how well the
lead particles you ate dissolved in your stomach
juices. Experiments using adult volunteers showed
that, for adults who had just eaten, the amount of
lead that got into the blood from the stomach was
only about 6% of the total amount taken in. In
adults who had not eaten for a day, about 60–80%
of the lead from the stomach got into their blood. In
general, if adults and children swallow the same
amount of lead, a bigger proportion of the amount
swallowed will enter the blood in children than in
adults. Children absorb about 50% of ingested lead.

Dust and soil that contain lead may get on your
skin, but only a small portion of the lead will pass
through your skin and enter your blood if it is not
washed off. You can, however, accidentally
swallow lead that is on your hands when you eat,
drink, smoke, or apply cosmetics (for example, lip
balm). More lead can pass through skin that has
been damaged (for example, by scrapes, scratches,
and wounds). The only kinds of lead compounds
that easily penetrate the skin are the additives in
leaded gasoline, which is no longer sold to the
general public. Therefore, the general public is not
likely to encounter lead that can enter through the
skin.

Shortly after lead gets into your body, it travels in
the blood to the "soft tissues" and organs (such as
the liver, kidneys, lungs, brain, spleen, muscles, and
heart). After several weeks, most of the lead moves
into your bones and teeth. In adults, about 94% of
the total amount of lead in the body is contained in
the bones and teeth. About 73% of the lead in
children’s bodies is stored in their bones. Some of
the lead can stay in your bones for decades;
however, some lead can leave your bones and
reenter your blood and organs under certain
circumstances (e.g., during pregnancy and periods
of breast feeding, after a bone is broken, and during
advancing age).

Your body does not change lead into any other
form. Once it is taken in and distributed to your
organs, the lead that is not stored in your bones
leaves your body in your urine or your feces. About
99% of the amount of lead taken into the body of an
adult will leave in the waste within a couple of
PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
weeks, but only about 32% of the lead taken into
the body of a child will leave in the waste. Under
conditions of continued exposure, not all of the lead
that enters the body will be eliminated, and this may
result in accumulation of lead in body tissues,
especially bone.

1.5 HOW CAN LEAD AFFECT MY
HEALTH?

Scientists use many tests to protect the public from
harmful effects of toxic chemicals and to find ways
for treating persons who have been harmed.

One way to learn whether a chemical will harm
people is to determine how the body absorbs, uses,
and releases the chemical. For some chemicals,
animal testing may be necessary. Animal testing
may also help identify health effects such as cancer
or birth defects. Without laboratory animals,
scientists would lose a basic method for getting
information needed to make wise decisions that
protect public health. Scientists have the
responsibility to treat research animals with care
and compassion. Scientists must comply with strict
animal care guidelines because laws today protect
the welfare of research animals.

The effects of lead are the same whether it enters
the body through breathing or swallowing. The
main target for lead toxicity is the nervous system,
both in adults and children. Long-term exposure of
adults to lead at work has resulted in decreased
performance in some tests that measure functions of
the nervous system. Lead exposure may also cause
weakness in fingers, wrists, or ankles. Lead
exposure also causes small increases in blood
pressure, particularly in middle-aged and older
people. Lead exposure may also cause anemia. At
high levels of exposure, lead can severely damage
the brain and kidneys in adults or children and
ultimately cause death. In pregnant women, high
levels of exposure to lead may cause miscarriage.
High-level exposure in men can damage the organs
responsible for sperm production.

We have no conclusive proof that lead causes
cancer (is carcinogenic) in humans. Kidney tumors
have developed in rats and mice that had been given
large doses of some kind of lead compounds. The
Department of Health and Human Services (DHHS)
has determined that lead and lead compounds are
reasonably anticipated to be human carcinogens
based on limited evidence from studies in humans
and sufficient evidence from animal studies, and the
EPA has determined that lead is a probable human
carcinogen. The International Agency for Research
on Cancer (IARC) has determined that inorganic
lead is probably carcinogenic to humans. IARC
determined that organic lead compounds are not
classifiable as to their carcinogenicity in humans
based on inadequate evidence from studies in
humans and in animals.

1.6 HOW CAN LEAD AFFECT CHILDREN?

This section discusses potential health effects in
humans from exposures during the period from
conception to maturity at 18 years of age.

Studies carried out by the Centers for Disease
Control and Prevention (CDC) show that the levels
of lead in the blood of U.S. children have been
getting lower and lower. This result is because lead
PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
is banned from gasoline, residential paint, and
solder used for food cans and water pipes.
However, about 310,000 U.S. children between the
ages of 1 and 5 years are believed to have blood
lead levels equal or greater than 10 μg/dL, the level
targeted for elimination among young children in
the Unites States by 2010.

Children are more vulnerable to lead poisoning than
adults. Children are exposed to lead all through
their lives. They can be exposed to lead in the
womb if their mothers have lead in their bodies.
Babies can swallow lead when they breast feed, or
eat other foods, and drink water that contains lead.
Babies and children can swallow and breathe lead in
dirt, dust, or sand while they play on the floor or
ground. These activities make it easier for children
to be exposed to lead than adults. The dirt or dust
on their hands, toys, and other items may have lead
particles in it. In some cases, children swallow
nonfood items such as paint chips; these may
contain very large amounts of lead, particularly in
and around older houses that were painted with
lead-based paint. The paint in these houses often
chips off and mixes with dust and dirt. Some old
paint contains as much as 50% lead. Also,
compared with adults, a bigger proportion of the
amount of lead swallowed will enter the blood in
children.

Children are more sensitive to the health effects of
lead than adults. No safe blood lead level in
children has been determined. Lead affects children
in different ways depending on how much lead a
child swallows. A child who swallows large
amounts of lead may develop anemia, kidney
damage, colic (severe “stomach ache”), muscle
weakness, and brain damage, which ultimately can
kill the child. In some cases, the amount of lead in
the child’s body can be lowered by giving the child
certain drugs that help eliminate lead from the body.
If a child swallows smaller amounts of lead, such as
dust containing lead from paint, much less severe
but still important effects on blood, development,
and behavior may occur. In this case, recovery is
likely once the child is removed from the source of
lead exposure, but there is no guarantee that the
child will completely avoid all long-term
consequences of lead exposure. At still lower levels
of exposure, lead can affect a child’s mental and
physical growth. Fetuses exposed to lead in the
womb, because their mothers had a lot of lead in
their bodies, may be born prematurely and have
lower weights at birth. Exposure in the womb, in
infancy, or in early childhood also may slow mental
development and cause lower intelligence later in
childhood. There is evidence that these effects may
persist beyond childhood.

Children with high blood lead levels do not have
specific symptoms. However, health workers can
find out whether a child may have been exposed to
harmful levels of lead by taking a blood sample.
They can also find out how much lead is in a child’s
bones by taking a special type of x-ray of the finger,
knee, or elbow. This type of test, however, is not
routine.

1.7 HOW CAN FAMILIES REDUCE THE
RISK OF EXPOSURE TO LEAD?

If your doctor finds that you have been exposed to
substantial amounts of lead, ask whether your
children might also have been exposed. Your
doctor might need to ask your state health
department to investigate.
PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
The most important way families can lower
exposures to lead is to know about the sources of
lead in their homes and avoid exposure to these
sources. Some homes or day-care facilities may
have more lead in them than others. Families who
live in or visit these places may be exposed to
higher amounts of lead. These include homes built
before 1978 that may have been painted with paint
that contains lead (lead-based paint). If you are
buying a home that was built before 1978, you may
want to know if it contains lead based paint.
Federal government regulations require a person
selling a home to tell the real estate agent or person
buying the home of any known lead-based hazards
on the property. Adding lead to paint is no longer
allowed. If your house was built before 1978, it
may have been painted with lead-based paint. This
lead may still be on walls, floors, ceilings, and
window sills, or on the outside walls of the house.
The paint may have been scraped off by a previous
owner, but paint chips and lead-containing dust may
still be in the yard soil. Decaying, peeling, or
flaking paint can introduce lead into household dust
and the area where this is occurring should be
repainted. If your paint is decaying or your child
has symptoms of lead poisoning, you may want to
have your house tested for lead. In some states,
homeowners can have the paint in their homes
tested for lead by their local health departments.
The National Lead Information Center (1-800-532-
3394) has a listing of approved risk assessors
(people who have met certain criteria and are
qualified to assess the potential risks of a site) and
of approved testing laboratories (for soil, paint, and
dust).

Sanding surfaces painted with lead-based paint or
using heat to peel the paint may cause exposure to
high levels of lead. Many cases of lead poisoning
have resulted from do-it-yourself home renovations.
Therefore, any renovations should be performed by
a licensed contractor who will minimize exposure to
household members. It is important for the area
being renovated to be isolated from the rest of the
house because of lead-containing dust. The federal
government requires that contractors who test for or
remove lead must be certified by the EPA or an
EPA-approved state program. Ask to see
certifications of potential contractors. Your state
health department or environmental protection
division should be able to identify certified
contractors for you. The National Lead Abatement
Council (P.O. Box 535; Olney, MD 20932;
telephone [phone]) can also send you a list of
certified contractors.

Families can lower the possibility of children
swallowing paint chips by discouraging their
children from chewing or putting these painted
surfaces in their mouths and making sure that they
wash their hands often, especially before eating.
Lead can be found in dirt and dust. Areas where
levels of lead in dirt might be especially high are
near old houses, highways, or old orchards. Some
children have the habit of eating dirt (the term for
this activity is pica). Discourage your children from
eating dirt and other hand-to-mouth activity.

Non-Western folk remedies used to treat diarrhea or
other ailments may contain substantial amounts of
lead. Examples of these include: Alarcon,
Ghasard, Alkohl, Greta, Azarcon, Liga, Bali Goli,
Pay-loo-ah, Coral, and Rueda. If you give your
children these substances or if you are pregnant or
nursing, you may expose your children to lead. It is
wise to know the ingredients of any medicines that
you or your children use.

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
Older homes that have plumbing containing lead
may have higher amounts of lead in drinking water.
Inside plumbing installed before 1930 is most likely
to contain high levels of lead. Copper pipes have
replaced lead pipes in most residential plumbing.
You cannot see, taste, or smell lead in water, and
boiling your water will not get rid of lead. If you
have a water-lead problem, EPA recommends that
anytime water in a particular faucet has not been
used for 6 hours or longer, you should flush your
cold water pipes by running water until it is cold
(5 seconds–2 minutes). Because lead dissolves
more easily in warm water than in cold water, you
should only use cold water for drinking, cooking,
and preparing baby formula. You can contact your
local health department or water supplier to find out
about testing your water for lead. If your water
tests indicate a significant presence of lead, consult
your water supplier or local health department about
possible remedies.

You can bring lead home in the dust on your hands
or clothes if lead is used in the place where you
work. Lead dust is likely to be found in places
where lead is mined or smelted, where car batteries
are made or recycled, where electric cable sheathing
is made, where fine crystal glass is made, or where
certain types of ceramic pottery are made. Pets can
also bring lead into the home in dust or dirt on their
fur or feet if they spend time in places that have
high levels of lead in the soil.

Swallowing of lead in house dust or soil is a very
important exposure pathway for children. This
problem can be reduced in many ways. Regular
hand and face washing to remove lead dusts and
soil, especially before meals, can lower the
possibility that lead on the skin is accidentally
swallowed while eating. Families can lower
exposures to lead by regularly cleaning the home of
dust and tracked in soil. Door mats can help lower
the amount of soil that is tracked into the home;
removing your shoes before entering the home will
also help. Planting grass and shrubs over bare soil
areas in the yard can lower contact that children and
pets may have with soil and the tracking of soil into
the home.

Families whose members are exposed to lead dusts
at work can keep these dusts out of reach of
children by showering and changing clothes before
leaving work, and bagging their work clothes before
they are brought into the home for cleaning. Proper
ventilation and cleaning—during and after hobby
activities, home or auto repair activities, and hair
coloring with products that contain lead—will
decrease the possibility of exposure.

Lead-containing dust may be deposited on plant
surfaces and lead may be taken up in certain edible
plants from the soil by the roots; therefore, home
gardening may also contribute to exposure if the
produce is grown in soils that have high lead
concentrations. Vegetables should be well washed
before eating to remove surface deposits. Certain
hobbies and home or car repair activities like
radiator repair can add lead to the home as well.
These include soldering glass or metal, making
bullets or slugs, or glazing pottery. Some types of
paints and pigments that are used as facial make-up
or hair coloring contain lead. Cosmetics that
contain lead include surma and kohl, which are
popular in certain Asian countries. Read the labels
on hair coloring products, and keep hair dyes that
contain lead acetate away from children. Do not
allow children to touch hair that has been colored
with lead-containing dyes or any surfaces that have
come into contact with these dyes because lead
PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
compounds can rub off onto their hands and be
transferred to their mouths.

It is important that children have proper nutrition
and eat a balanced diet of foods that supply
adequate amounts of vitamins and minerals,
especially calcium and iron. Good nutrition lowers
the amount of swallowed lead that passes to the
bloodstream and also may lower some of the toxic
effects of lead.

1.8 IS THERE A MEDICAL TEST TO
DETERMINE WHETHER I HAVE BEEN
EXPOSED TO LEAD?

The amount of total lead in the blood can be
measured to determine if exposure to lead has
occurred. This test shows if you have been recently
exposed to lead. Lead can be measured in teeth or
bones by x-ray techniques, but these methods are
not widely available. These tests show long-term
exposures to lead. The primary screening method is
measurement of blood lead. Exposure to lead also
can be evaluated by measuring erythrocyte
protoporphyrin (EP) in blood samples. EP is a part
of red blood cells known to increase when the
amount of lead in the blood is high. However, the
EP level is not sensitive enough to identify children
with elevated blood lead levels below about
25 micrograms per deciliter (μg/dL). These tests
usually require special analytical equipment that is
not available in a doctor’s office. However, your
doctor can draw blood samples and send them to
appropriate laboratories for analysis.

1.9 WHAT RECOMMENDATIONS HAS THE
FEDERAL GOVERNMENT MADE TO
PROTECT HUMAN HEALTH?

The federal government develops regulations and
recommendations to protect public health.
Regulations can be enforced by law. The EPA, the
Occupational Safety and Health Administration
(OSHA), and the Food and Drug Administration
(FDA) are some federal agencies that develop
regulations for toxic substances. Recommendations
provide valuable guidelines to protect public health,
but cannot be enforced by law. The Agency for
Toxic Substances and Disease Registry (ATSDR)
and the National Institute for Occupational Safety
and Health (NIOSH) are two federal organizations
that develop recommendations for toxic substances.

Regulations and recommendations can be expressed
as “not-to-exceed” levels, that is, levels of a toxic
substance in air, water, soil, or food that do not
exceed a critical value that is usually based on
levels that affect animals; they are then adjusted to
levels that will help protect humans. Sometimes
these not-to-exceed levels differ among federal
organizations because they used different exposure
times (an 8-hour workday or a 24-hour day),
different animal studies, or other factors.

Recommendations and regulations are also updated
periodically as more information becomes available.
For the most current information, check with the
federal agency or organization that provides it.
Some regulations and recommendations for lead
include the following:

CDC recommends that states develop a plan to find
children who may be exposed to lead and have their
PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
blood tested for lead. CDC recommends that the
states test children:

• at ages 1 and 2 years;

• at ages 3–6 years if they have never
been tested for lead;

• if they receive services from public
assistance programs for the poor
such as Medicaid or the
Supplemental Food Program for
Women, Infants, and Children;

• if they live in a building or
frequently visit a house built before
1950;

• if they visit a home (house or
apartment) built before 1978 that has
been recently remodeled; and/or

• if they have a brother, sister, or
playmate who has had lead
poisoning.

CDC considers children to have an elevated level of
lead if the amount of lead in the blood is at least
10 μg/dL. Many states or local programs provide
intervention to individual children with blood lead
levels equal to or greater than 10 μg/dL. Medical
evaluation and environmental investigation and
remediation should be done for all children with
blood lead levels equal to or greater than 20 μg/dL.
Medical treatment (i.e., chelation therapy) may be
necessary in children if the lead concentration in
blood is higher than 45 μg/dL.

EPA requires that the concentration of lead in air
that the public breathes be no higher than
1.5 micrograms per cubic meter (μg/m3) averaged
over 3 months. EPA regulations no longer allow
lead in gasoline. The Clean Air Act Amendments
(CAAA) of 1990 banned the sale of leaded gasoline
as of December 31, 1995.

Under the Lead Copper Rule (LCR), EPA requires
testing of public water systems, and if more than
10% of the samples at residences contain lead levels
over 0.015 milligrams per liter (mg/L), actions must
be taken to lower these levels. Testing for lead in
drinking water in schools is not required unless a
school is regulated under a public water system.
The 1988 Lead Contamination Control Act (LCCA)
was created to help reduce lead in drinking water at
schools and daycare centers. The LCCA created
lead monitoring and reporting requirements for
schools, as well as the replacement of fixtures that
contain high levels of lead. However, the
provisions in the LCCA are not enforceable by the
federal government and individual states have the
option to voluntarily comply with these provisions
or create their own.

To help protect small children, the Consumer
Product Safety Commission (CPSC) requires that
the concentration of lead in most paints available
through normal consumer channels be not more
than 0.06%. The Federal Hazardous Substance Act
(FHSA) bans children’s products containing
hazardous amounts of lead.

The Department of Housing and Urban
Development (HUD) develops recommendations
and regulations to prevent exposure to lead. HUD
requires that federally funded housing and
renovations, Public and Indian housing be tested for
PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
lead-based paint hazards and that such hazards be
fixed by covering the paint or removing it. When
determining whether lead-based paint applied to
interior or exterior painted surfaces of dwellings
should be removed, the standard used by EPA and
HUD is that paint with a lead concentration equal to
or greater than 1.0 milligram per square centimeter
(mg/cm2) of surface area should be removed or
otherwise treated. HUD is carrying out
demonstration projects to determine the best ways
of covering or removing lead-based paint in
housing.

EPA has developed standards for lead-paint
hazards, lead in dust, and lead in soil. To educate
parents, homeowners, and tenants about lead
hazards, lead poisoning prevention in the home, and
the lead abatement process, EPA has published
several general information pamphlets. Copies of
these pamphlets can be obtained from the National
Lead Information Center or from various Internet
sites, including http://www.epa.gov/opptintr/lead.

OSHA regulations limit the concentration of lead in
workroom air to 50 μg/m3 for an 8-hour workday.
If a worker has a blood lead level of 50 μg/dL or
higher, then OSHA requires that the worker be
removed from the workroom where lead exposure is
occurring.

FDA includes lead on its list of poisonous and
deleterious substances. FDA considers foods
packaged in cans containing lead solders to be
unsafe. Tin-coated lead foil has been used as a
covering applied over the cork and neck areas of
wine bottles for decorative purposes and to prevent
insect infestations. Because it can be reasonably
expected that lead could become a component of the
wine, the use of such foil is also a violation of the
Federal Food, Drug, and Cosmetic Act. FDA has
reviewed several direct human food ingredients
(i.e., food dyes) and has determined them to be
“generally recognized as safe” when used in
accordance with current good manufacturing
practices. Some of these ingredients contain
allowable lead concentrations that range from 0.1 to
10 ppm.

1.10 WHERE CAN I GET MORE
INFORMATION?

If you have any more questions or concerns, please
contact your community or state health or
environmental quality department, or contact
ATSDR at the address and phone number below.

ATSDR can also tell you the location of
occupational and environmental health clinics.
These clinics specialize in recognizing, evaluating,
and treating illnesses that result from exposure to
hazardous substances.

Toxicological profiles are also available on-line at
www.atsdr.cdc.gov and on CD-ROM. You may
request a copy of the ATSDR ToxProfilesTM
CD-ROM by calling the toll-free information and
technical assistance number at 1-800-CDCINFO
(1-800-232-4636), by e-mail at [e-mail],
or by writing to:

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
Agency for Toxic Substances and Disease Registry
Division of Toxicology and Environmental
Medicine
1600 Clifton Road NE
Mailstop F-32
Atlanta, GA 30333
Fax: [phone]

Organizations for-profit may request copies of final
Toxicological Profiles from the following:

National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Phone: [phone] or 1-703-605-6000
Web site: http://www.ntis.gov/

1 CADMIUM
1. PUBLIC HEALTH STATEMENT
This public health statement tells you about cadmium and the effects of exposure to it.
The Environmental Protection Agency (EPA) identifies the most serious hazardous waste sites in the
nation. These sites are then placed on the National Priorities List (NPL) and are targeted for long-term
federal clean-up activities. Cadmium has been found in at least 1,014 of the 1,669 current or former NPL
sites. Although the total number of NPL sites evaluated for this substance is not known, the possibility
exists that the number of sites at which cadmium is found may increase in the future as more sites are
evaluated. This information is important because these sites may be sources of exposure and exposure to
this substance may harm you.
When a substance is released either from a large area, such as an industrial plant, or from a container,
such as a drum or bottle, it enters the environment. Such a release does not always lead to exposure. You
can be exposed to a substance only when you come in contact with it. You may be exposed by breathing,
eating, or drinking the substance, or by skin contact.
If you are exposed to cadmium or cadmium compounds, many factors will determine whether you will be
harmed. These factors include the dose (how much), the duration (how long), and how you come in
contact with it. You must also consider any other chemicals you are exposed to and your age, sex, diet,
family traits, lifestyle, and state of health.
***DRAFT FOR PUBLIC COMMENT***
CADMIUM 2

1. PUBLIC HEALTH STATEMENT

***DRAFT FOR PUBLIC COMMENT***
1.1 WHAT IS CADMIUM?

Description Metal found in the earth’s crust, associated with zinc, lead, and
copper ores.

Pure cadmium is a soft, silver-white metal. Cadmium chloride
and cadmium sulfate are soluble in water.

Uses
• Manufacturing

• Consumer products
Most cadmium used in the United States is extracted as a
byproduct during the production of other metals such as zinc,
lead, or copper. Cadmium is also recovered from used batteries.

Cadmium is used for the following:
• batteries (83%)
• pigments (8%)
• coatings and platings (7%)
• stabilizers for plastics (1.2%)
• nonferrous alloys, photovoltaic devices, and other uses
(0.8%)

For more information on the properties and uses of cadmium, see Chapters 4 and 5.

1.2 WHAT HAPPENS TO CADMIUM WHEN IT ENTERS THE ENVIRONMENT?

Sources Cadmium is emitted to soil, water, and air by non-ferrous metal mining
and refining, manufacture and application of phosphate fertilizers, fossil
fuel combustion, and waste incineration and disposal.

Cadmium can accumulate in aquatic organisms and agricultural crops.

Fate
• Air

• Soil

• Water

Cadmium (as oxide, chloride, and sulfate) will exist in air as particles or
vapors (from high temperature processes). It can be transported long
distances in the atmosphere, where it will deposit (wet or dry) onto soils
and water surfaces.

Cadmium and its compounds may travel through soil, but its mobility
depends on several factors such as pH and amount of organic matter,
which will vary depending on the local environment. Generally,
cadmium binds strongly to organic matter where it will be immobile in
soil and be taken up by plant life, eventually, entering the food supply.

Cadmium exists as the hydrated ion or as ionic complexes with other
inorganic or organic substances. Soluble forms migrate in water.
Insoluble forms of cadmium are immobile and will deposit and absorb to
sediments.

CADMIUM 3

1. PUBLIC HEALTH STATEMENT

***DRAFT FOR PUBLIC COMMENT***
1.3 HOW MIGHT I BE EXPOSED TO CADMIUM?

Food and
smoking—
primary sources
of exposure
In the United States, for nonsmokers the primary source of cadmium
exposure is from the food supply. People who regularly consume shellfish
and organ meats will have higher exposures. In general, leafy vegetables
such as lettuce and spinach, potatoes and grains, peanuts, soybeans, and
sunflower seeds contain high levels of cadmium.

Tobacco leaves accumulate high levels of cadmium from the soil.

The national geometric mean blood cadmium level for adults is 0.47 μg/L.
A geometric mean blood cadmium level of 1.58 μg/L for New York City
smokers has been reported. The amount of cadmium absorbed from
smoking one pack of cigarettes per day is about 1–3 μg/day. Direct
measurement of cadmium levels in body tissues confirms that smoking
roughly doubles cadmium body burden in comparison to not smoking.

Air Except for people living near cadmium-emitting industries, inhalation of
cadmium is not expected to be a major concern.

Water EPA has mandated that water suppliers control cadmium concentrations in
drinking water to <5 μg/L. Therefore, exposure to cadmium through public
drinking water sources is not a major concern.

Elevated cadmium levels in water sources in the vicinity of cadmium-
emitting industries (historical and current) have been reported. Aquatic
organisms will accumulate cadmium, possibly entering the food supply.
People who fish in local waters as a means of food should be cautious and
abide by any advisories.

Occupational
exposure
Highest risk of exposure from processes involving heating cadmium-
containing materials such as smelting and electroplating. Risk will vary
depending on the workplace.

Major route of exposure is through inhalation of dust and fumes or
incidental ingestion from contaminated hands, food, or cigarettes.

Exposure can be controlled through personal protective equipment, good
industrial hygiene practices, and control and reduction of cadmium
emissions.

In Chapter 6, you can find more information on how you might be exposed to cadmium.

CADMIUM 4
1. PUBLIC HEALTH STATEMENT
1.4 HOW CAN CADMIUM ENTER AND LEAVE MY BODY?
Enter your body
• Inhalation
• Ingestion
• Dermal
contact
About 25–60% of the cadmium you breathe will enter your body through
your lungs.
A small amount of the cadmium in food and water (about 5–10%) will enter
your body through the digestive tract. If you do not have enough iron or
other nutrients in your diet, you are likely to take up more cadmium from
your food than usual.
Virtually no cadmium enters your body through your skin.
Leave your body Most of the cadmium that enters your body goes to your kidney and liver
and can remain there for many years. A small portion of the cadmium that
enters your body leaves slowly in urine and feces.
Your body can change most cadmium to a form that is not harmful, but too
much cadmium can overload the ability of your liver and kidney to change
the cadmium to a harmless form.
More information on how cadmium enters and leaves the body is found in Chapter 3.
***DRAFT FOR PUBLIC COMMENT***

CADMIUM 5
1. PUBLIC HEALTH STATEMENT
1.5 HOW CAN CADMIUM AFFECT MY HEALTH?
Workers Breathing air with very high levels of cadmium can severely damage the
• Inhalation lungs and may cause death.
In the United States, where proper industrial hygiene is generally practiced,
inhaling very high levels of cadmium at work is expected to be rare and
accidental.
Breathing air with lower levels of cadmium over long periods of time (for
years) results in a build-up of cadmium in the kidney, and if sufficiently high,
may result in kidney disease.
Laboratory
animals
• Inhalation Damage to the lungs and nasal cavity have been observed in animals
exposed to cadmium.
Humans
• Oral Eating food or drinking water with very high cadmium levels severely
irritates the stomach, leading to vomiting and diarrhea, and sometimes
death.
Eating lower levels of cadmium over a long period of time can lead to a
build-up of cadmium in the kidneys. If the levels reach a high enough level,
the cadmium in the kidney will cause kidney damage.
Exposure to lower levels of cadmium for a long time can also cause bones
to become fragile and break easily.
Laboratory
animals
• Oral Kidney and bone effects have also been observed in laboratory animals
ingesting cadmium.
Anemia, liver disease, and nerve or brain damage have been observed in
animals eating or drinking cadmium. We have no good information on
people to indicate what levels people would need to eat or drink cadmium to
result in these diseases, or if they would occur at all.
Cancer Lung cancer has been found in some studies of workers exposed to
cadmium in the air and studies of rats that breathed in cadmium.
The U.S. Department of Health and Human Services (DHHS) has
determined that cadmium and cadmium compounds are known human
carcinogens. The International Agency for Research on Cancer (IARC) has
determined that cadmium is carcinogenic to humans. The EPA has
determined that cadmium is a probable human carcinogen.
More information on how cadmium can affect your health is found in Chapters 2 and 3.
***DRAFT FOR PUBLIC COMMENT***

CADMIUM 6
1. PUBLIC HEALTH STATEMENT
1.6 HOW CAN CADMIUM AFFECT CHILDREN?
This section discusses potential health effects in humans from exposures during the period from
conception to maturity at 18 years of age.
Effects in children The health effects seen in children from exposure to toxic levels of cadmium
are expected to be similar to the effects seen in adults (kidney, lung, and
intestinal damage depending on the route of exposure).
Harmful effects on child development or behavior have not generally been
seen in populations exposed to cadmium, but more research is needed.
A few studies in animals indicate that younger animals absorb more
cadmium than adults. Animal studies also indicate that the young are more
susceptible than adults to a loss of bone and decreased bone strength from
exposure to cadmium.
Cadmium is found in breast milk and a small amount will enter the infant’s
body through breastfeeding. The amount of cadmium that can pass to the
infant depends on how much exposure the mother may have had.
Birth defects We do not know whether cadmium can cause birth defects in people.
Studies in animals exposed to high enough levels of cadmium during
pregnancy have resulted in harmful effects in the young. The nervous
system appears to be the most sensitive target. Young animals exposed to
cadmium before birth have shown effects on behavior and learning. There
is also some information from animal studies that high enough exposures to
cadmium before birth can reduce body weights and affect the skeleton in
the developing young.
***DRAFT FOR PUBLIC COMMENT***

CADMIUM 7
1. PUBLIC HEALTH STATEMENT
1.7 HOW CAN FAMILIES REDUCE THE RISK OF EXPOSURE TO CADMIUM?
Do not smoke
tobacco products
Cadmium accumulates in tobacco leaves. The national geometric mean
blood cadmium level for adults is 0.47 μg/L. Mean blood cadmium levels for smokers have been reported as high as 1.58 μg/L.
Good Occupational exposure can be controlled through personal protective
occupational equipment, good industrial hygiene practices, and control and reduction of
hygiene cadmium emissions.
Children can be exposed to cadmium through parents who work in
cadmium-emitting industries. Therefore, good hygiene practices such as
bathing and changing clothes before returning home may help reduce the
cadmium transported from the job to the home.
Avoid cadmium Check and obey local fishing advisories before consuming fish or shellfish
contaminated from local waterways.
areas and food
Avoid hazardous waste sites.
Proper disposal of Dispose of nickel-cadmium batteries properly. Many states have laws in
cadmium-effect that ban the disposal of batteries as municipal waste. Recycle old
containing batteries whenever possible.
products
Contact your local waste and recycling authority on how to properly dispose
of paints and coatings.
Handle properly Do not allow children to play with batteries. If mishandled, batteries could
rupture.
Children may also swallow small nickel-cadmium batteries.
1.8 IS THERE A MEDICAL TEST TO DETERMINE WHETHER I HAVE BEEN EXPOSED TO
CADMIUM?
Detecting
exposure
Cadmium can be measured in blood, urine, hair, or nails. Urinary cadmium
has been shown to accurately reflect the amount of cadmium in the body.
Measuring
exposure
The amount of cadmium in your blood shows your recent exposure to
cadmium. The amount of cadmium in your urine shows both your recent
and your past exposure.
Cadmium levels in hair or nails are not as useful as an indication of when or
how much cadmium you may have taken in, partly because cadmium from
outside of your body may attach to the hair or nails.
Tests are also available to measure the amount of cadmium inside your liver
and kidneys.
***DRAFT FOR PUBLIC COMMENT***

8 CADMIUM
1. PUBLIC HEALTH STATEMENT
More information on how cadmium can be measured in exposed humans is presented in Chapters 3 and 7.
1.9 WHAT RECOMMENDATIONS HAS THE FEDERAL GOVERNMENT MADE TO
PROTECT HUMAN HEALTH?
The federal government develops regulations and recommendations to protect public health. Regulations
can be enforced by law. The EPA, the Occupational Safety and Health Administration (OSHA), and the
Food and Drug Administration (FDA) are some federal agencies that develop regulations for toxic
substances. Recommendations provide valuable guidelines to protect public health, but cannot be
enforced by law. The Agency for Toxic Substances and Disease Registry (ATSDR) and the National
Institute for Occupational Safety and Health (NIOSH) are two federal organizations that develop
recommendations for toxic substances.
Regulations and recommendations can be expressed as “not-to-exceed” levels, that is, levels of a toxic
substance in air, water, soil, or food that do not exceed a critical value that is usually based on levels that
affect animals; they are then adjusted to levels that will help protect humans. Sometimes these not-to­
exceed levels differ among federal organizations because they used different exposure times (an 8-hour
workday or a 24-hour day), different animal studies, or other factors.
Recommendations and regulations are also updated periodically as more information becomes available.
For the most current information, check with the federal agency or organization that provides it. Some
regulations and recommendations for cadmium include the following:
Drinking water The EPA has determined that exposure to cadmium in drinking water at a
concentration of 0.04 mg/L for up to 10 days is not expected to cause any
adverse effects in a child.
The EPA has determined that lifetime exposure to 0.005 mg/L cadmium in
drinking water is not expected to cause any adverse effects.
Consumer
products
The FDA has determined that cadmium levels in bottled water should not
exceed 0.005 mg/L.
Workplace air OSHA set a legal limit of 5 μg/m3 cadmium averaged over an 8-hour work
day.
More information on governmental rules regarding cadmium can be found in Chapter 8.
***DRAFT FOR PUBLIC COMMENT***

9 CADMIUM
1. PUBLIC HEALTH STATEMENT
1.10 WHERE CAN I GET MORE INFORMATION?
If you have any more questions or concerns, please contact your community or state health or
environmental quality department, or contact ATSDR at the address and phone number below.
ATSDR can also tell you the location of occupational and environmental health clinics. These clinics
specialize in recognizing, evaluating, and treating illnesses that result from exposure to hazardous
substances.
Toxicological profiles are also available on-line at www.atsdr.cdc.gov and on CD-ROM. You may
request a copy of the ATSDR ToxProfilesTM CD-ROM by calling the toll-free information and technical
assistance number at 1-800-CDCINFO (1-800-232-4636), by e-mail at [e-mail], or by writing
to:
Agency for Toxic Substances and Disease Registry

Division of Toxicology and Environmental Medicine

1600 Clifton Road NE

Mailstop F-32

Atlanta, GA 30333

Fax: [phone]

Organizations for-profit may request copies of final Toxicological Profiles from the following:
National Technical Information Service (NTIS)

5285 Port Royal Road

Springfield, VA 22161

Phone: [phone] or 1-703-605-6000

Web site: http://www.ntis.gov/

***DRAFT FOR PUBLIC COMMENT***
PUBLIC HEALTH STATEMENT
Chromium
CAS # 7440-47-3
Division of Toxicology and Environmental Medicine September 2008
______________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
This Public Health Statement is the summary chapter from the Toxicological Profile for Chromium. It is
one in a series of Public Health Statements about hazardous substances and their health effects. A shorter
version, the ToxFAQs™, is also available. This information is important because this substance may
harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, how you
are exposed, personal traits and habits, and whether other chemicals are present. For more information,
call the ATSDR Information Center at 1-800-232-4636.
____________________________________________________________________________________
This public health statement tells you about chromium and the effects of exposure to it.

The Environmental Protection Agency (EPA) identifies the most serious hazardous waste sites in the
nation. These sites are then placed on the National Priorities List (NPL) and are targeted for long-term
federal clean-up activities. Chromium has been found in at least 1,127 of the 1,699 current or former
NPL sites. Although the total number of NPL sites evaluated for this substance is not known, the
possibility exists that the number of sites at which chromium is found may increase in the future as more
sites are evaluated. This information is important because these sites may be sources of exposure and
exposure to this substance may harm you.

When a substance is released either from a large area, such as an industrial plant, or from a container,
such as a drum or bottle, it enters the environment. Such a release does not always lead to exposure. You
can be exposed to a substance only when you come in contact with it. You may be exposed by breathing,
eating, or drinking the substance, or by skin contact.

If you are exposed to chromium, many factors will determine whether you will be harmed. These factors
include the dose (how much), the duration (how long), and how you come in contact with it. You must
also consider any other chemicals you are exposed to and your age, sex, diet, family traits, lifestyle, and
state of health.

PUBLIC HEALTH STATEMENT
Chromium
CAS # 7440-47-3
Division of Toxicology and Environmental Medicine September 2008
______________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
1.1 WHAT IS CHROMIUM?

Description Chromium is a naturally-occurring element found in rocks, animals, plants,
and soil.

The three main forms of chromium are chromium(0), chromium(III), and
chromium(VI). Small amounts of chromium(III) are considered to be a
necessity for human health.

Uses
• manufacturing

• consumer
products

Chromium is widely used in manufacturing processes.

Chromium can be found in many consumer products such as:
• wood treated with copper dichromate.
• leather tanned with chromic sulfate.
• stainless steel cookware.

1.2 WHAT HAPPENS TO CHROMIUM WHEN IT ENTERS THE ENVIRONMENT?

Sources Chromium can be found in air, soil, and water after release from the
manufacture, use, and disposal of chromium-based products, and during
the manufacturing process.

Break down
• air

• water and soil
Chromium does not usually remain in the atmosphere, but is deposited
into the soil and water.

Chromium can change from one form to another in water and soil,
depending on the conditions present.

PUBLIC HEALTH STATEMENT
Chromium
CAS # 7440-47-3
Division of Toxicology and Environmental Medicine September 2008
______________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
1.3 HOW MIGHT I BE EXPOSED TO CHROMIUM?

Air exposure You can be exposed to chromium by breathing air containing it or drinking
water containing chromium. Releases of chromium into the air can occur
from:

• industries using or manufacturing chromium
• living near a hazardous waste facility that contains chromium
• cigarette smoke

Rural or suburban air generally contains lower concentrations of chromium
than urban air.

• <10 ng/m3 in rural areas
• 0–30 ng/m3 in urban areas
• as a result of smoking, indoor air contaminated with chromium can be
10–400 times greater than outdoor air concentrations

Water and soil Chromium is occasionally detected in groundwater, drinking water, or soil
samples. Some ways to be exposed to chromium include:

• drinking water containing chromium
• bathing in water containing chromium

Workplace air A large number of workers are potentially exposed to chromium. The
highest potential exposure occurs in the metallurgy and tanning industries,
where workers may be exposed to high air concentrations.

Food The general population is most likely to be exposed to trace levels of
chromium in the food that is eaten. Low levels of chromium(III) occur
naturally in a variety of foods, such as fruits, vegetables, nuts, beverages,
and meats.

PUBLIC HEALTH STATEMENT
Chromium
CAS # 7440-47-3
Division of Toxicology and Environmental Medicine September 2008
______________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
1.4 HOW CAN CHROMIUM ENTER AND LEAVE MY BODY?

Enter your body
• inhalation

• ingestion

• dermal
contact
When you breathe air containing chromium, some of the chromium will enter
your body through your lungs. Some forms of chromium can remain in the
lungs for several years or longer.

A small percentage of ingested chromium will enter the body through the
digestive tract.

When your skin comes in contact with chromium, small amounts of
chromium will enter your body.

Leave your body Chromium(VI) is changed to chromium(III) in the body. Most of the
chromium leaves the body in the urine within a week, although some may
remain in cells for several years or longer.

1.5 HOW CAN CHROMIUM AFFECT MY HEALTH?

This section looks at studies concerning potential health effects in animal and human studies.

Respiratory tract Chromium(VI) compounds are more toxic than chromium(III) compounds.
The most common health problem in workers exposed to chromium
involves the respiratory tract. These health effects include irritation of the
lining of the nose, runny nose, and breathing problems (asthma, cough,
shortness of breath, wheezing). Workers have also developed allergies to
chromium compounds, which can cause breathing difficulties and skin
rashes.

The concentrations of chromium in air that can cause these effects may be
different for different types of chromium compounds, with effects occurring
at much lower concentrations for chromium(VI) compared to chromium(III) .
However, the concentrations causing respiratory problems in workers are at
least 60 times higher than levels normally found in the environment.

Respiratory tract problems similar to those observed in workers have been
seen in animals exposed to chromium in air.

PUBLIC HEALTH STATEMENT
Chromium
CAS # 7440-47-3
Division of Toxicology and Environmental Medicine September 2008
______________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
Stomach and
Small Intestine
The main health problems seen in animals following ingestion of
chromium(VI) compounds are to the stomach and small intestine (irritation
and ulcer) and the blood (anemia). Chromium(III) compounds are much
less toxic and do not appear to cause these problems.

Male Reproductive
System

Sperm damage and damage to the male reproductive system have also
been seen in laboratory animals exposed to chromium(VI).

Cancer The International Agency for Research on Cancer (IARC) has determined
that chromium(VI) compounds are carcinogenic to humans. The National
Toxicology Program 11th Report on Carcinogens classifies chromium(VI)
compounds as known to be human carcinogens.

In workers, inhalation of chromium(VI) has been shown to cause lung
cancer. An increased in stomach tumors was observed in humans exposed
to chromium(VI) in drinking water.

In laboratory animals, chromium(VI) compounds have been shown to cause
tumors to the stomach,intestinal tract and lung.

1.6 HOW CAN CHROMIUM AFFECT CHILDREN?

This section discusses potential health effects in humans from exposures during the period from
conception to maturity at 18 years of age.

Effects in children There are no studies that have looked at the effects of chromium exposure
on children. It is likely that children would have the same health effects as
adults. We do not know whether children would be more sensitive than
adults to the effects of chromium.

Birth defects There are no studies showing that chromium causes birth defects in
humans. In animals, some studies show that exposure to high doses during
pregnancy may cause miscarriage, low birth weight, and some changes in
development of the skeleton and reproductive system. Birth defects in
animals may be related, in part, to chromium toxicity in the mothers.

PUBLIC HEALTH STATEMENT
Chromium
CAS # 7440-47-3
Division of Toxicology and Environmental Medicine September 2008
______________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
1.7 HOW CAN FAMILIES REDUCE THE RISK OF EXPOSURE TO CHROMIUM?

Avoid tobacco
smoke

Avoid older
pressure treated
lumber

Launder clothing
from work sites
Chromium is a component of tobacco smoke. Avoid smoking in enclosed
spaces like inside the home or car in order to limit exposure to children and
other family members.

In the past, pressure treated wood used chromated copper arsenate;
however, the use of this product in residential settings was discontinued
effective December 31, 2003. Avoiding older pressure treated lumber can
reduce your risk of exposure to chromium. You may also have your water
tested to ensure that you are not exposed to high levels of chromium.

Clothing or items removed from the workplace may contain chromium if you
are employed in a setting where occupational exposure is significant.
Therefore, common sense hygiene and laundry practices may help avoid
unnecessary exposures.

1.8 IS THERE A MEDICAL TEST TO DETERMINE WHETHER I HAVE BEEN EXPOSED TO
CHROMIUM?

Scientists use many tests to protect the public from harmful effects of toxic chemicals and to find ways
for treating persons who have been harmed.

Detecting
exposure
Since chromium is a required nutrient in the body and is normally present in
food, chromium is normally present in blood, urine, and body tissues.

Measuring
exposure
Higher than normal levels of chromium in blood or urine may indicate that a
person has been exposed to chromium. However, increases in blood and
urine chromium levels cannot be used to predict the kind of health effects
that might develop from that exposure.

1.9 WHAT RECOMMENDATIONS HAS THE FEDERAL GOVERNMENT MADE TO
PROTECT HUMAN HEALTH?

The federal government develops regulations and recommendations to protect public health. Regulations
can be enforced by law. The EPA, the Occupational Safety and Health Administration (OSHA), and the
Food and Drug Administration (FDA) are some federal agencies that develop regulations for toxic
PUBLIC HEALTH STATEMENT
Chromium
CAS # 7440-47-3
Division of Toxicology and Environmental Medicine September 2008
______________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
substances. Recommendations provide valuable guidelines to protect public health, but cannot be
enforced by law. The Agency for Toxic Substances and Disease Registry (ATSDR) and the National
Institute for Occupational Safety and Health (NIOSH) are two federal organizations that develop
recommendations for toxic substances.

Regulations and recommendations can be expressed as “not-to-exceed” levels. These are levels of a toxic
substance in air, water, soil, or food that do not exceed a critical value. This critical value is usually based
on levels that affect animals; they are then adjusted to levels that will help protect humans. Sometimes
these not-to-exceed levels differ among federal organizations because they used different exposure times
(an 8-hour workday or a 24-hour day), different animal studies, or other factors.

Recommendations and regulations are also updated periodically as more information becomes available.
For the most current information, check with the federal agency or organization that provides it.

Some regulations and recommendations for chromium include the following:

Levels in drinking
water set by EPA

The EPA has determined that exposure to chromium in drinking water at
concentrations of 1 mg/L for 1 day or 10 days is not expected to cause any
adverse effects in a child.

Levels in bottled
water set by FDA
The FDA has determined that the chromium concentration in bottled
drinking water should not exceed 0.1 mg/L.

Levels in
workplace air set
by OSHA
OSHA set a legal limit for chromium(VI) of 0.0005 mg/m3 chromium in air
averaged over an 8-hour work day, for chromium(III) of 0.5 mg/m3 chromium
in air averaged over an 8-hour work day, and for chromium(0) of 1.0 mg/m3
chromium in air averaged over an 8-hour work day.

1.10 WHERE CAN I GET MORE INFORMATION?

If you have any more questions or concerns, please contact your community or state health or
environmental quality department, or contact ATSDR at the address and phone number below.

PUBLIC HEALTH STATEMENT
Chromium
CAS # 7440-47-3
Division of Toxicology and Environmental Medicine September 2008
______________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
ATSDR can also tell you the location of occupational and environmental health clinics. These clinics
specialize in recognizing, evaluating, and treating illnesses that result from exposure to hazardous
substances.

Toxicological profiles are also available on-line at www.atsdr.cdc.gov and on CD-ROM. You may
request a copy of the ATSDR ToxProfilesTM CD-ROM by calling the toll-free information and technical
assistance number at 1-800-CDCINFO (1-800-232-4636), by e-mail at [e-mail], or by writing
to:

Agency for Toxic Substances and Disease Registry
Division of Toxicology and Environmental Medicine
1600 Clifton Road NE
Mailstop F-32
Atlanta, GA 30333
Fax: [phone]

Organizations for-profit may request copies of final Toxicological Profiles from the following:

National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Phone: [phone] or 1-703-605-6000
Web site: http://www.ntis.gov/

PUBLIC HEALTH STATEMENT
Arsenic
CAS#: 7440-38-2
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
This Public Health Statement is the summary
chapter from the Toxicological Profile for Arsenic.
It is one in a series of Public Health Statements
about hazardous substances and their health effects.
A shorter version, the ToxFAQs™, is also
available. This information is important because
this substance may harm you. The effects of
exposure to any hazardous substance depend on the
dose, the duration, how you are exposed, personal
traits and habits, and whether other chemicals are
present. For more information, call the ATSDR
Information Center at 1-800-232-4636.
__________________________________________
This public health statement tells you about arsenic
and the effects of exposure to it.

The Environmental Protection Agency (EPA)
identifies the most serious hazardous waste sites in
the nation. These sites are then placed on the
National Priorities List (NPL) and are targeted for
long-term federal clean-up activities. Arsenic has
been found in at least 1,149 of the 1,684 current or
former NPL sites. Although the total number of
NPL sites evaluated for this substance is not known,
the possibility exists that the number of sites at
which arsenic is found may increase in the future as
more sites are evaluated. This information is
important because these sites may be sources of
exposure and exposure to this substance may harm
you.

When a substance is released either from a large
area, such as an industrial plant, or from a container,
such as a drum or bottle, it enters the environment.
Such a release does not always lead to exposure.
You can be exposed to a substance only when you
come in contact with it. You may be exposed by
breathing, eating, or drinking the substance, or by
skin contact.

If you are exposed to arsenic, many factors will
determine whether you will be harmed. These
factors include the dose (how much), the duration
(how long), and how you come in contact with it.
You must also consider any other chemicals you are
exposed to and your age, sex, diet, family traits,
lifestyle, and state of health.

1.1 WHAT IS ARSENIC?

Arsenic is a naturally occurring element that is
widely distributed in the Earth’s crust. Arsenic is
classified chemically as a metalloid, having both
properties of a metal and a nonmetal; however, it is
frequently referred to as a metal. Elemental arsenic
(sometimes referred to as metallic arsenic) is a steel
grey solid material. However, arsenic is usually
found in the environment combined with other
elements such as oxygen, chlorine, and sulfur.
Arsenic combined with these elements is called
inorganic arsenic. Arsenic combined with carbon
and hydrogen is referred to as organic arsenic.

Most inorganic and organic arsenic compounds are
white or colorless powders that do not evaporate.
They have no smell, and most have no special taste.
Thus, you usually cannot tell if arsenic is present in
your food, water, or air.

Inorganic arsenic occurs naturally in soil and in
many kinds of rock, especially in minerals and ores
that contain copper or lead. When these ores are
heated in smelters, most of the arsenic goes up the
stack and enters the air as a fine dust. Smelters may
collect this dust and take out the arsenic as a
compound called arsenic trioxide (As2O3).
PUBLIC HEALTH STATEMENT
Arsenic
CAS#: 7440-38-2
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
However, arsenic is no longer produced in the
United States; all of the arsenic used in the United
States is imported.

Presently, about 90% of all arsenic produced is used
as a preservative for wood to make it resistant to
rotting and decay. The preservative is copper
chromated arsenate (CCA) and the treated wood is
referred to as “pressure-treated.” In 2003, U.S.
manufacturers of wood preservatives containing
arsenic began a voluntary transition from CCA to
other wood preservatives that do not contain arsenic
in wood products for certain residential uses, such
as play structures, picnic tables, decks, fencing, and
boardwalks. This phase out was completed on
December 31, 2003; however, wood treated prior to
this date could still be used and existing structures
made with CCA-treated wood would not be
affected. CCA-treated wood products continue to
be used in industrial applications. It is not known
whether, or to what extent, CCA-treated wood
products may contribute to exposure of people to
arsenic.

In the past, inorganic arsenic compounds were
predominantly used as pesticides, primarily on
cotton fields and in orchards. Inorganic arsenic
compounds can no longer be used in agriculture.
However, organic arsenic compounds, namely
cacodylic acid, disodium methylarsenate (DSMA),
and monosodium methylarsenate (MSMA), are still
used as pesticides, principally on cotton. Some
organic arsenic compounds are used as additives in
animal feed. Small quantities of elemental arsenic
are added to other metals to form metal mixtures or
alloys with improved properties. The greatest use
of arsenic in alloys is in lead-acid batteries for
automobiles. Another important use of arsenic
compounds is in semiconductors and light-emitting
diodes.

1.2 WHAT HAPPENS TO ARSENIC WHEN
IT ENTERS THE ENVIRONMENT?

Arsenic occurs naturally in soil and minerals and it
therefore may enter the air, water, and land from
wind-blown dust and may get into water from
runoff and leaching. Volcanic eruptions are another
source of arsenic. Arsenic is associated with ores
containing metals, such as copper and lead. Arsenic
may enter the environment during the mining and
smelting of these ores. Small amounts of arsenic
also may be released into the atmosphere from coal-
fired power plants and incinerators because coal and
waste products often contain some arsenic.

Arsenic cannot be destroyed in the environment. It
can only change its form, or become attached to or
separated from particles. It may change its form by
reacting with oxygen or other molecules present in
air, water, or soil, or by the action of bacteria that
live in soil or sediment. Arsenic released from
power plants and other combustion processes is
usually attached to very small particles. Arsenic
contained in wind-borne soil is generally found in
larger particles. These particles settle to the ground
or are washed out of the air by rain. Arsenic that is
attached to very small particles may stay in the air
for many days and travel long distances. Many
common arsenic compounds can dissolve in water.
Thus, arsenic can get into lakes, rivers, or
underground water by dissolving in rain or snow or
through the discharge of industrial wastes. Some of
the arsenic will stick to particles in the water or
sediment on the bottom of lakes or rivers, and some
PUBLIC HEALTH STATEMENT
Arsenic
CAS#: 7440-38-2
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
will be carried along by the water. Ultimately, most
arsenic ends up in the soil or sediment. Although
some fish and shellfish take in arsenic, which may
build up in tissues, most of this arsenic is in an
organic form called arsenobetaine (commonly
called "fish arsenic") that is much less harmful.

1.3 HOW MIGHT I BE EXPOSED TO
ARSENIC?

Since arsenic is found naturally in the environment,
you will be exposed to some arsenic by eating food,
drinking water, or breathing air. Children may also
be exposed to arsenic by eating soil. Analytical
methods used by scientists to determine the levels
of arsenic in the environment generally do not
determine the specific form of arsenic present.
Therefore, we do not always know the form of
arsenic a person may be exposed to. Similarly, we
often do not know what forms of arsenic are present
at hazardous waste sites. Some forms of arsenic
may be so tightly attached to particles or embedded
in minerals that they are not taken up by plants and
animals.

The concentration of arsenic in soil varies widely,
generally ranging from about 1 to 40 parts of
arsenic to a million parts of soil (ppm) with an
average level of 3–4 ppm. However, soils in the
vicinity of arsenic-rich geological deposits, some
mining and smelting sites, or agricultural areas
where arsenic pesticides had been applied in the
past may contain much higher levels of arsenic.
The concentration of arsenic in natural surface and
groundwater is generally about 1 part in a billion
parts of water (1 ppb), but may exceed 1,000 ppb in
contaminated areas or where arsenic levels in soil
are high. Groundwater is far more likely to contain
high levels of arsenic than surface water. Surveys
of U.S. drinking water indicate that about 80% of
water supplies have less than 2 ppb of arsenic, but
2% of supplies exceed 20 ppb of arsenic. Levels of
arsenic in food range from about 20 to 140 ppb.
However, levels of inorganic arsenic, the form of
most concern, are far lower. Levels of arsenic in
the air generally range from less than 1 to about
2,000 nanograms (1 nanogram equals a billionth of
a gram) of arsenic per cubic meter of air (less than
1–2,000 ng/m3), depending on location, weather
conditions, and the level of industrial activity in the
area. However, urban areas generally have mean
arsenic levels in air ranging from 20 to 30 ng/m3.

You normally take in small amounts of arsenic in
the air you breathe, the water you drink, and the
food you eat. Of these, food is usually the largest
source of arsenic. The predominant dietary source
of arsenic is seafood, followed by rice/rice cereal,
mushrooms, and poultry. While seafood contains
the greatest amounts of arsenic, for fish and
shellfish, this is mostly in an organic form of
arsenic called arsenobetaine that is much less
harmful. Some seaweeds may contain arsenic in
inorganic forms that may be more harmful.
Children are likely to eat small amounts of dust or
soil each day, so this is another way they may be
exposed to arsenic. The total amount of arsenic you
take in from these sources is generally about
50 micrograms (1 microgram equals one-millionth
of a gram) each day. The level of inorganic arsenic
(the form of most concern) you take in from these
sources is generally about 3.5 microgram/day.
Children may be exposed to small amounts of
arsenic from hand-to-mouth activities from playing
on play structures or decks constructed out of CCA-
treated wood. The potential exposure that children
PUBLIC HEALTH STATEMENT
Arsenic
CAS#: 7440-38-2
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
may receive from playing in play structures
constructed from CCA-treated wood is generally
smaller than that they would receive from food and
water.

In addition to the normal levels of arsenic in air,
water, soil, and food, you could be exposed to
higher levels in several ways, such as the following:

• Some areas of the United States contain
unusually high natural levels of arsenic in
rock, and this can lead to unusually high
levels of arsenic in soil or water. If you live
in an area like this, you could take in
elevated amounts of arsenic in drinking
water. Children may be taking in higher
amounts of arsenic because of hand-to-
mouth contact or eating soil in areas with
higher than usual arsenic concentrations.

• Some hazardous waste sites contain large
quantities of arsenic. If the material is not
properly disposed of, it can get into
surrounding water, air, or soil. If you live
near such a site, you could be exposed to
elevated levels of arsenic from these media.

• If you work in an occupation that involves
arsenic production or use (for example,
copper or lead smelting, wood treating, or
pesticide application), you could be exposed
to elevated levels of arsenic during your
work.

• If you saw or sand arsenic-treated wood, you
could inhale some of the sawdust into your
nose or throat. Similarly, if you burn
arsenic-treated wood, you could inhale
arsenic in the smoke.

• If you live in a former agricultural area
where arsenic was used on crops, the soil
could contain high levels of arsenic.

• In the past, several kinds of products used in
the home (rat poison, ant poison, weed
killer, some types of medicines) had arsenic
in them. However, most of these uses of
arsenic have ended, so you are not likely to
be exposed from home products any longer.

1.4 HOW CAN ARSENIC ENTER AND
LEAVE MY BODY?

If you swallow arsenic in water, soil, or food, most
of the arsenic may quickly enter into your body.
The amount that enters your body will depend on
how much you swallow and the kind of arsenic that
you swallow. This is the most likely way for you to
be exposed near a waste site. If you breathe air that
contains arsenic dusts, many of the dust particles
settle onto the lining of the lungs. Most of the
arsenic in these particles is then taken up from the
lungs into the body. You might be exposed in this
way near waste sites where arsenic-contaminated
soils are allowed to blow into the air, or if you work
with arsenic-containing soil or products. If you get
arsenic-contaminated soil or water on your skin,
only a small amount will go through your skin into
your body, so this is usually not of concern.

PUBLIC HEALTH STATEMENT
Arsenic
CAS#: 7440-38-2
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
Both inorganic and organic forms leave your body
in your urine. Most of the inorganic arsenic will be
gone within several days, although some will
remain in your body for several months or even
longer. If you are exposed to organic arsenic, most
of it will leave your body within several days.

1.5 HOW CAN ARSENIC AFFECT MY
HEALTH?

Scientists use many tests to protect the public from
harmful effects of toxic chemicals and to find ways
for treating persons who have been harmed.

One way to learn whether a chemical will harm
people is to determine how the body absorbs, uses,
and releases the chemical. For some chemicals,
animal testing may be necessary. Animal testing
may also help identify health effects such as cancer
or birth defects. Without laboratory animals,
scientists would lose a basic method for getting
information needed to make wise decisions that
protect public health. Scientists have the
responsibility to treat research animals with care
and compassion. Scientists must comply with strict
animal care guidelines because laws today protect
the welfare of research animals.

Inorganic arsenic has been recognized as a human
poison since ancient times, and large oral doses
(above 60,000 ppb in water which is 10,000 times
higher than 80% of U.S. drinking water arsenic
levels) can result in death. If you swallow lower
levels of inorganic arsenic (ranging from about
300 to 30,000 ppb in water; 100–10,000 times
higher than most U.S. drinking water levels), you
may experience irritation of your stomach and
intestines, with symptoms such as stomachache,
nausea, vomiting, and diarrhea. Other effects you
might experience from swallowing inorganic
arsenic include decreased production of red and
white blood cells, which may cause fatigue,
abnormal heart rhythm, blood-vessel damage
resulting in bruising, and impaired nerve function
causing a "pins and needles" sensation in your
hands and feet.

Perhaps the single-most characteristic effect of
long-term oral exposure to inorganic arsenic is a
pattern of skin changes. These include patches of
darkened skin and the appearance of small "corns"
or "warts" on the palms, soles, and torso, and are
often associated with changes in the blood vessels
of the skin. Skin cancer may also develop.
Swallowing arsenic has also been reported to
increase the risk of cancer in the liver, bladder, and
lungs. The Department of Health and Human
Services (DHHS) has determined that inorganic
arsenic is known to be a human carcinogen (a
chemical that causes cancer). The International
Agency for Research on Cancer (IARC) has
determined that inorganic arsenic is carcinogenic to
humans. EPA also has classified inorganic arsenic
as a known human carcinogen.

If you breathe high levels of inorganic arsenic, then
you are likely to experience a sore throat and
irritated lungs. You may also develop some of the
skin effects mentioned above. The exposure level
that produces these effects is uncertain, but it is
probably above 100 micrograms of arsenic per
cubic meter (μg/m3) for a brief exposure. Longer
exposure at lower concentrations can lead to skin
effects, and also to circulatory and peripheral
nervous disorders. There are some data suggesting
that inhalation of inorganic arsenic may also
PUBLIC HEALTH STATEMENT
Arsenic
CAS#: 7440-38-2
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
interfere with normal fetal development, although
this is not certain. An important concern is the
ability of inhaled inorganic arsenic to increase the
risk of lung cancer. This has been seen mostly in
workers exposed to arsenic at smelters, mines, and
chemical factories, but also in residents living near
smelters and arsenical chemical factories. People
who live near waste sites with arsenic may have an
increased risk of lung cancer as well.

If you have direct skin contact with high
concentrations of inorganic arsenic compounds,
your skin may become irritated, with some redness
and swelling. However, it does not appear that skin
contact is likely to lead to any serious internal
effects.

Almost no information is available on the effects of
organic arsenic compounds in humans. Studies in
animals show that most simple organic arsenic
compounds (such as methyl and dimethyl
compounds) are less toxic than the inorganic forms.
In animals, ingestion of methyl compounds can
result in diarrhea, and lifetime exposure can damage
the kidneys. Lifetime exposure to dimethyl
compounds can damage the urinary bladder and the
kidneys.

1.6 HOW CAN ARSENIC AFFECT
CHILDREN?

This section discusses potential health effects in
humans from exposures during the period from
conception to maturity at 18 years of age.

Children are exposed to arsenic in many of the same
ways that adults are. Since arsenic is found in the
soil, water, food, and air, children may take in
arsenic in the air they breathe, the water they drink,
and the food they eat. Since children tend to eat or
drink less of a variety of foods and beverages than
do adults, ingestion of contaminated food or juice or
infant formula made with arsenic-contaminated
water may represent a significant source of
exposure. In addition, since children often play in
the soil and put their hands in their mouths and
sometimes intentionally eat soil, ingestion of
contaminated soil may be a more important source
of arsenic exposure for children than for adults. In
areas of the United States where natural levels of
arsenic in the soil and water are high, or in areas in
and around contaminated waste sites, exposure of
children to arsenic through ingestion of soil and
water may be significant. In addition, contact with
adults who are wearing clothes contaminated with
arsenic (e.g., with dust from copper- or lead-
smelting factories, from wood-treating or pesticide
application, or from arsenic-treated wood) could be
a source of exposure. Because of the tendency of
children to taste things that they find, accidental
poisoning from ingestion of pesticides is also a
possibility. Thus, although most of the exposure
pathways for children are the same as those for
adults, children may be at a higher risk of exposure
because of normal hand-to-mouth activity.

Children who are exposed to inorganic arsenic may
have many of the same effects as adults, including
irritation of the stomach and intestines, blood vessel
damage, skin changes, and reduced nerve function.
Thus, all health effects observed in adults are of
potential concern in children. There is also some
evidence that suggests that long-term exposure to
inorganic arsenic in children may result in lower IQ
scores. We do not know if absorption of inorganic
arsenic from the gut in children differs from adults.
PUBLIC HEALTH STATEMENT
Arsenic
CAS#: 7440-38-2
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
There is some evidence that exposure to arsenic in
early life (including gestation and early childhood)
may increase mortality in young adults.

There is some evidence that inhaled or ingested
inorganic arsenic can injure pregnant women or
their unborn babies, although the studies are not
definitive. Studies in animals show that large doses
of inorganic arsenic that cause illness in pregnant
females can also cause low birth weight, fetal
malformations, and even fetal death. Arsenic can
cross the placenta and has been found in fetal
tissues. Arsenic is found at low levels in breast
milk.

In animals, exposure to organic arsenic compounds
can cause low birth weight, fetal malformations,
and fetal deaths. The dose levels that cause these
effects also result in effects in the mothers.

1.7 HOW CAN FAMILIES REDUCE THE
RISK OF EXPOSURE TO ARSENIC?

If your doctor finds that you have been exposed to
substantial amounts of arsenic, ask whether your
children might also have been exposed. Your
doctor might need to ask your state health
department to investigate.

Many communities may have high levels of arsenic
in their drinking water, particularly from private
wells, because of contamination or as a result of the
geology of the area. The north central region and
the western region of the United States have the
highest arsenic levels in surface water and
groundwater sources, respectively. Wells used to
provide water for drinking and cooking should be
tested for arsenic. As of January 2006, EPA’s
Maximum Contaminant Level (MCL) for arsenic in
drinking water is 10 ppb. If you have arsenic in
your drinking water at levels higher that the EPA’s
MCL, an alternative source of water should be used
for drinking and cooking should be considered.

If you use arsenic-treated wood in home projects,
personal protection from exposure to arsenic-
containing sawdust may be helpful in limiting
exposure of family members. These measures may
include dust masks, gloves, and protective clothing.
Arsenic-treated wood should never be burned in
open fires, or in stoves, residential boilers, or fire
places, and should not be composted or used as
mulch. EPA’s Consumer Awareness Program
(CAP) for CCA is a voluntary program established
by the manufacturers of CCA products to inform
consumers about the proper handling, use, and
disposal of CCA-treated wood. You can find more
information about this program in Section 6.5.
Hand washing can reduce the potential exposure of
children to arsenic after playing on play structures
constructed with CCA-treated wood, since most of
the arsenic on the children’s hands was removed
with water.

If you live in an area with a high level of arsenic in
the water or soil, substituting cleaner sources of
water and limiting contact with soil (for example,
through use of a dense groundcover or thick lawn)
would reduce family exposure to arsenic. By
paying careful attention to dust and soil control in
the home (air filters, frequent cleaning), you can
reduce family exposure to contaminated soil. Some
children eat a lot of soil. You should prevent your
children from eating soil. You should discourage
your children from putting objects in their mouths.
Make sure they wash their hands frequently and
PUBLIC HEALTH STATEMENT
Arsenic
CAS#: 7440-38-2
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
before eating. Discourage your children from
putting their hands in their mouths or engaging in
other hand-to-mouth activities. Since arsenic may
be found in the home as a pesticide, household
chemicals containing arsenic should be stored out of
reach of young children to prevent accidental
poisonings. Always store household chemicals in
their original labeled containers; never store
household chemicals in containers that children
would find attractive to eat or drink from, such as
old soda bottles. Keep your Poison Control
Center’s number by the phone.

It is sometimes possible to carry arsenic from work
on your clothing, skin, hair, tools, or other objects
removed from the workplace. This is particularly
likely if you work in the fertilizer, pesticide, glass,
or copper/lead smelting industries. You may
contaminate your car, home, or other locations
outside work where children might be exposed to
arsenic. You should know about this possibility if
you work with arsenic.

Your occupational health and safety officer at work
can and should tell you whether chemicals you
work with are dangerous and likely to be carried
home on your clothes, body, or tools and whether
you should be showering and changing clothes
before you leave work, storing your street clothes in
a separate area of the workplace, or laundering your
work clothes at home separately from other clothes.
Material safety data sheets (MSDS) for many
chemicals used should be found at your place of
work, as required by the Occupational Safety and
Health Administration (OSHA) in the U.S.
Department of Labor. MSDS information should
include chemical names and hazardous ingredients,
and important properties, such as fire and explosion
data, potential health effects, how you get the
chemical(s) in your body, how to properly handle
the materials, and what to do in the case of
emergencies. Your employer is legally responsible
for providing a safe workplace and should freely
answer your questions about hazardous chemicals.
Your state OSHA-approved occupational safety and
health program or OSHA can answer any further
questions and help your employer identify and
correct problems with hazardous substances. Your
state OSHA-approved occupational safety and
health program or OSHA will listen to your formal
complaints about workplace health hazards and
inspect your workplace when necessary.
Employees have a right to seek safety and health on
the job without fear of punishment.

1.8 IS THERE A MEDICAL TEST TO
DETERMINE WHETHER I HAVE BEEN
EXPOSED TO ARSENIC?

Several sensitive and specific tests can measure
arsenic in your blood, urine, hair, or fingernails, and
these tests are often helpful in determining if you
have been exposed to above-average levels of
arsenic in the past. These tests are not usually
performed in a doctor’s office. They require
sending the sample to a testing laboratory.

Measurement of arsenic in your urine is the most
reliable means of detecting arsenic exposures that
you experienced within the last several days. Most
tests measure the total amount of arsenic present in
your urine. This can sometimes be misleading,
because the nonharmful forms of arsenic in fish and
shellfish can give a high reading even if you have
not been exposed to a toxic form of arsenic. For
this reason, laboratories sometimes use a more
PUBLIC HEALTH STATEMENT
Arsenic
CAS#: 7440-38-2
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
complicated test to separate “fish arsenic” from
other forms. Because most arsenic leaves your
body within a few days, analysis of your urine
cannot detect if you were exposed to arsenic in the
past. Tests of your hair or fingernails can tell if you
were exposed to high levels over the past 6–
12 months, but these tests are not very useful in
detecting low-level exposures. If high levels of
arsenic are detected, this shows that you have been
exposed, but unless more is known about when you
were exposed and for how long, it is usually not
possible to predict whether you will have any
harmful health effects.

1.9 WHAT RECOMMENDATIONS HAS THE
FEDERAL GOVERNMENT MADE TO
PROTECT HUMAN HEALTH?

The federal government develops regulations and
recommendations to protect public health.
Regulations can be enforced by law. The EPA, the
Occupational Safety and Health Administration
(OSHA), and the Food and Drug Administration
(FDA) are some federal agencies that develop
regulations for toxic substances. Recommendations
provide valuable guidelines to protect public health,
but cannot be enforced by law. The Agency for
Toxic Substances and Disease Registry (ATSDR)
and the National Institute for Occupational Safety
and Health (NIOSH) are two federal organizations
that develop recommendations for toxic substances.

Regulations and recommendations can be expressed
as “not-to-exceed” levels, that is, levels of a toxic
substance in air, water, soil, or food that do not
exceed a critical value that is usually based on
levels that affect animals; they are then adjusted to
levels that will help protect humans. Sometimes
these not-to-exceed levels differ among federal
organizations because they used different exposure
times (an 8-hour workday or a 24-hour day),
different animal studies, or other factors.

Recommendations and regulations are also updated
periodically as more information becomes available.
For the most current information, check with the
federal agency or organization that provides it.
Some regulations and recommendations for
ARSENIC include the following:

The federal government has taken several steps to
protect humans from arsenic. First, EPA has set
limits on the amount of arsenic that industrial
sources can release into the environment. Second,
EPA has restricted or canceled many of the uses of
arsenic in pesticides and is considering further
restrictions. Third, in January 2001, the EPA
lowered the limit for arsenic in drinking water from
50 to 10 ppb. Finally, OSHA has established a
permissible exposure limit (PEL), 8-hour time-
weighted average, of 10 μg/m3 for airborne arsenic
in various workplaces that use inorganic arsenic.

1.10 WHERE CAN I GET MORE
INFORMATION?

If you have any more questions or concerns, please
contact your community or state health or
environmental quality department, or contact
ATSDR at the address and phone number below.

ATSDR can also tell you the location of
occupational and environmental health clinics.
These clinics specialize in recognizing, evaluating,
PUBLIC HEALTH STATEMENT
Arsenic
CAS#: 7440-38-2
Division of Toxicology and Environmental Medicine August 2007
__________________________________________________________________________________________
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service
Agency for Toxic Substances and Disease Registry

www.atsdr.cdc.gov/ Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
and treating illnesses that result from exposure to
hazardous substances.

Toxicological profiles are also available on-line at
www.atsdr.cdc.gov and on CD-ROM. You may
request a copy of the ATSDR ToxProfilesTM
CD-ROM by calling the toll-free information and
technical assistance number at 1-800-CDCINFO (1-
800-232-4636), by e-mail at [e-mail], or
by writing to:

Agency for Toxic Substances and Disease Registry
Division of Toxicology and Environmental
Medicine
1600 Clifton Road NE
Mailstop F-32
Atlanta, GA 30333
Fax: [phone]

Organizations for-profit may request copies of final
Toxicological Profiles from the following:

National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Phone: [phone] or 1-703-605-6000
Web site: http://www.ntis.gov/

PAHs 1
1. PUBLIC HEALTH STATEMENT
This statement was prepared to give you information about polycyclic aromatic hydrocarbons
(PAHs) and to emphasize the human health effects that may result from exposure to them.
The Environmental Protection Agency (EPA) has identified 1,408 hazardous waste sites as the
most serious in the nation. These sites make up the National Priorities List (NPL) and are the
sites targeted for long-term federal clean-up activities. PAHs have been found in at least
600 of the sites on the NPL. However, the number of NPL sites evaluated for PAHs is not
known. As EPA evaluates more sites, the number of sites at which PAHs are found may
increase. This information is important because exposure to PAHs may cause harmful health
effects and because these sites are potential or actual sources of human exposure to PAHs.
When a substance is released from a large area, such as an industrial plant, or from a
container, such as a drum or bottle, it enters the environment. This release does not always
lead to exposure. You can be exposed to a substance only when you come in contact with it.
You may be exposed by breathing, eating, or drinking substances containing the substance or
by skin contact with it.
If you are exposed to substances such as PAHs, many factors will determine whether harmful
health effects will occur and what the type and severity of those health effects will be. These
factors include the dose (how much), the duration (how long), the route or pathway by which
you are exposed (breathing, eating, drinking, or skin contact), the other chemicals to which
you are exposed, and your individual characteristics such as age, sex, nutritional status, family
traits, lifestyle, and state of health.
1.1 WHAT ARE POLYCYCLIC AROMATIC HYDROCARBONS?
PAHs are a group of chemicals that are formed during the incomplete burning of coal, oil,
gas, wood, garbage, or other organic substances, such as tobacco and charbroiled meat. There
are more than 100 different PAHs. PAHs generally occur as complex mixtures (for example,
as part of combustion products such as soot), not as single compounds. PAHs usually occur
PAHs 2
1. PUBLIC HEALTH STATEMENT
naturally, but they can be manufactured as individual compounds for research purposes;
however, not as the mixtures found in combustion products. As pure chemicals, PAHs
generally exist as colorless, white, or pale yellow-green solids. They can have a faint,
pleasant odor. A few PAHs are used in medicines and to make dyes, plastics, and pesticides.
Others are contained in asphalt used in road construction. They can also be found in
substances such as crude oil, coal, coal tar pitch, creosote, and roofing tar. They are found
throughout the environment in the air, water, and soil. They can occur in the air, either
attached to dust particles or as solids in soil or sediment.
Although the health effects of individual PAHs are not exactly alike, the following 17 PAHs
are considered as a group in this profile:
• acenaphthene
• acenaphthylene
• anthracene
• benz[a]anthracene
• benzo[a]pyrene
• benzo[e]pyrene
• benzo[b]fluoranthene
• benzo[g,h,i]perylene
• benzo[j]fluoranthene
• benzo[k]fluoranthene
• chrysene
• dibenz[a,h]anthracene
• fluoranthene
• fluorene
• indeno[ 1,2,3-c,d]pyrene
• phenanthrene
• pyrene
These 17 PAHs were chosen to be included in this profile because (1) more information is
available on these than on the others; (2) they are suspected to be more harmful than some of
the others, and they exhibit harmful effects that are representative of the PAHs; (3) there is a
greater chance that you will be exposed to these PAHs than to the others; and (4) of all the
PAHs analyzed, these were the PAHs identified at the highest concentrations at NPL
hazardous waste sites.
PAHs 3
1. PUBLIC HEALTH STATEMENT
More information can be found on the chemical and physical properties of PAHs in Chapter
3 and on their use and disposal in Chapter 4.
1.2 WHAT HAPPENS TO POLYCYCLIC AROMATIC HYDROCARBONS WHEN
THEY ENTER THE ENVIRONMENT?
PAHs enter the environment mostly as releases to air from volcanoes, forest fires, residential
wood burning, and exhaust from automobiles and trucks. They can also enter surface water
through discharges from industrial plants and waste water treatment plants, and they can be
released to soils at hazardous waste sites if they escape from storage containers. The
movement of PAHs in the environment depends on properties such as how easily they
dissolve in water, and how easily they evaporate into the air. PAHs in general do not easily
dissolve in water. They are present in air as vapors or stuck to the surfaces of small solid
particles. They can travel long distances before they return to earth in rainfall or particle
settling. Some PAHs evaporate into the atmosphere from surface waters, but most stick to
solid particles and settle to the bottoms of rivers or lakes. In soils, PAHs are most likely to
stick tightly to particles. Some PAHs evaporate from surface soils to air. Certain PAHs in
soils also contaminate underground water. The PAH content of plants and animals living on
the land or in water can be many times higher than the content of PAHs in soil or water.
PAHs can break down to longer-lasting products by reacting with sunlight and other
chemicals in the air, generally over a period of days to weeks. Breakdown in soil and water
generally takes weeks to months and is caused primarily by the actions of microorganisms.
For more information on what happens to PAHs in the environment see Chapter 5.
1.3 HOW MIGHT I BE EXPOSED TO POLYCYCLIC AROMATIC
HYDROCARBONS?
PAHs are present throughout the environment, and you may be exposed to these substances at
home, outside, or at the workplace. Typically, you will not be exposed to an individual PAH,
but to a mixture of PAHs.
PAHs 4
1. PUBLIC HEALTH STATEMENT
In the environment, you are most likely to be exposed to PAH vapors or PAHs that are
attached to dust and other particles in the air. Sources include cigarette smoke, vehicle
exhausts, asphalt roads, coal, coal tar, wildfires, agricultural burning, residential wood
burning, municipal and industrial waste incineration, and hazardous waste sites. Background
levels of some representative PAHs in the air are reported to be 0.02-1.2 nanograms per
cubic meter (ng/m3; a nanogram is one-millionth of a milligram) in rural areas and
0.15-19.3 ng/m3 in urban areas. You may be exposed to PAHs in soil near areas where coal,
wood, gasoline, or other products have been burned. You may be exposed to PAHs in the
soil at or near hazardous waste sites, such as former manufactured-gas factory sites and
wood-preserving facilities. PAHs have been found in some drinking water supplies in the
United States. Background levels of PAHs in drinking water range from 4 to 24 nanograms
per liter (ng/L; a liter is slightly more than a quart).
In the home, PAHs are present in tobacco smoke, smoke from wood fires, creosote-treated
wood products, cereals, grains, flour, bread, vegetables, fruits, meat, processed or pickled
foods, and contaminated cow’s milk or human breast milk. Food grown in contaminated soil
or air may also contain PAHs. Cooking meat or other food at high temperatures, which
happens during grilling or charring, increases the amount of PAHs in the food. The level of
PAHs in the typical U.S. diet is less than 2 parts of total PAHs per billion parts of food
(ppb), or less than 2 micrograms per kilogram of food (µg/kg; a microgram is one-thousandth of a
milligram).
The primary sources of exposure to PAHs for most of the U.S. population are inhalation of
the compounds in tobacco smoke, wood smoke, and ambient air, and consumption of PAHs in
foods. For some people, the primary exposure to PAHs occurs in the workplace. PAHs have
been found in coal tar production plants, coking plants, bitumen and asphalt production plants,
coal-gasification sites, smoke houses, aluminum production plants, coal tarring facilities, and
municipal trash incinerators. Workers may be exposed to PAHs by inhaling engine exhaust
and by using products that contain PAHs in a variety of industries such as mining, oil
refining, metalworking, chemical production, transportation, and the electrical industry. PAHs
have also been found in other facilities where petroleum, petroleum products, or coal are used
PAHs 5
1. PUBLIC HEALTH STATEMENT
or where wood, cellulose, corn, or oil are burned. People living near waste sites containing
PAHs may be exposed through contact with contaminated air, water, and soil. For more
information on human exposure to PAHs, see Chapter 5.
1.4 HOW CAN POLYCYCLIC AROMATIC HYDROCARBONS ENTER AND LEAVE
MY BODY?
PAHs can enter your body through your lungs when you breathe air that contains them
(usually stuck to particles or dust). Cigarette smoke, wood smoke, coal smoke, and smoke
from many industrial sites may contain PAHs. People living near hazardous waste sites can
also be exposed by breathing air containing PAHs. However, it is not known how rapidly or
completely your lungs absorb PAHs. Drinking water and swallowing food, soil, or dust
particles that contain PAHs are other routes for these chemicals to enter your body, but
absorption is generally slow when PAHs are swallowed. Under normal conditions of
environmental exposure, PAHs could enter your body if your skin comes into contact with
soil that contains high levels of PAHs (this could occur near a hazardous waste site) or with
used crankcase oil or other products (such as creosote) that contain PAHs. The rate at which
PAHs enter your body by eating, drinking, or through the skin can be influenced by the
presence of other compounds that you may be exposed to at the same time with PAHs.
PAHs can enter all the tissues of your body that contain fat. They tend to be stored mostly in
your kidneys, liver, and fat. Smaller amounts are stored in your spleen, adrenal glands, and
ovaries. PAHs are changed by all tissues in the body into many different substances. Some
of these substances are more harmful and some are less harmful than the original PAHs.
Results from animal studies show that PAHs do not tend to be stored in your body for a long
time. Most PAHs that enter the body leave within a few days, primarily in the feces and
urine. More information on how PAHs enter and leave your body can be found in Chapters 2
and 6.
PAHs 6
1. PUBLIC HEALTH STATEMENT
1.5 HOW CAN POLYCYCLIC AROMATIC HYDROCARBONS AFFECT MY
HEALTH?
PAHs can be harmful to your health under some circumstances. Several of the PAHs,
including benz[a]anthracene, benzo[a]pyrene, benzo[b]fluoranthene, benzo[j]fluoranthene,
benzo[k]fluoranthene, chrysene, dibenz[a,h]anthracene, and indeno [1,2,3-c,d]pyrene, have
caused tumors in laboratory animals when they breathed these substances in the air, when
they ate them, or when they had long periods of skin contact with them. Studies of people
show that individuals exposed by breathing or skin contact for long periods to mixtures that
contain PAHs and other compounds can also develop cancer.
Mice fed high levels of benzo[a]pyrene during pregnancy had difficulty reproducing and so
did their offspring. The offspring of pregnant mice fed benzo[a]pyrene also showed other
harmful effects, such as birth defects and decreased body weight. Similar effects could occur
in people, but we have no information to show that these effects do occur.
Studies in animals have also shown that PAHs can cause harmful effects on skin, body fluids,
and the body’s system for fighting disease after both short- and long-term exposure. These
effects have not been reported in people.
The Department of Health and Human Services (DHHS) has determined that
benz[a]anthracene, benzo[b]fluoranthene, benzo[j]fluoranthene, benzo[k]fluoranthene,
benzo[a]pyrene, dibenz[a,h]anthracene, and indeno[ 1,2,3-c,d]pyrene are known animal
carcinogens. The International Agency for Research on Cancer (IARC) has determined the
following: benz[a]anthracene and benzo[a]pyrene are probably carcinogenic to humans;
benzo[b]fluoranthene, benzo[j]fluoranthene, benzo[k]fluoranthene, and indeno[ 1,2,3-c,d]pyrene
are possibly carcinogenic to humans; and anthracene, benzo[g,h,i]perylene, benzo[e]pyrene,
chrysene, fluoranthene, fluorene, phenanthrene, and pyrene are not classifiable as to their
carcinogenicity to humans. EPA has determined that benz[a]anthracene, benzo[a]pyrene,
benzo[b]fluoranthene, benzo[k]fluoranthene, chrysene, dibenz[a,h]anthracene, and
indeno[ 1,2,3-c,d]pyrene are probable human carcinogens and that acenaphthylene, anthracene,
PAHs 7
1. PUBLIC HEALTH STATEMENT
benzo[g,h,i]perylene, fluoranthene, fluorene, phenanthrene, and pyrene are not classifiable as
to human carcinogenicity. Acenaphthene has not been classified for carcinogenic effects by
the DHHS, IARC, or EPA. More information on the health effects associated with exposure
to PAHs can be found in Chapter 2.
1.6 IS THERE A MEDICAL TEST TO DETERMINE WHETHER I HAVE BEEN
EXPOSED TO POLYCYCLIC AROMATIC HYDROCARBONS?
In your body, PAHs are changed into chemicals that can attach to substances within the body.
The presence of PAHs attached to these substances can then be measured in body tissues or
blood after exposure to PAHs. PAHs or their metabolites can also be measured in urine,
blood, or body tissues. Although these tests can show that you have been exposed to PAHs,
these tests cannot be used to predict whether any health effects will occur or to determine the
extent or source of your exposure to the PAHs. It is not known how effective or informative
the tests are after exposure is discontinued. These tests to identify PAHs or their products are
not routinely available at a doctor’s office because special equipment is required to detect
these chemicals. More information on tests used to determine the presence of PAHs in your
body is presented in Chapters 2 and 6.
1.7 WHAT RECOMMENDATIONS HAS THE FEDERAL GOVERNMENT MADE TO
PROTECT HUMAN HEALTH?
The federal government has set regulations to protect people from the possible health effects
of eating, drinking, or breathing PAHs. EPA has suggested that taking into your body each
day the following amounts of individual PAHs is not likely to cause any harmful health
effects: 0.3 milligrams (mg) of anthracene, 0.06 mg of acenaphthene, 0.04 mg of
fluoranthene, 0.04 mg of fluorene, and 0.03 mg of pyrene per kilogram (kg) of your body
weight (one kilogram is equal to 2.2 pounds). Actual exposure for most of the United States
population occurs from active or passive inhalation of the compounds in tobacco smoke,
wood smoke, and contaminated air, and from eating the compounds in foods. Skin contact
PAHs 8
1. PUBLIC HEALTH STATEMENT
with contaminated water, soot, tar, and soil may also occur. Estimates for total exposure in
the United States population have been listed as 3 mg/day.
From what is currently known about benzo[a]pyrene, the federal government has developed
regulatory standards and guidelines to protect people from the potential health effects of
PAHs in drinking water. EPA has provided estimates of levels of total cancer-causing PAHs
in lakes and streams associated with a risk of human cancer development. If the following
amounts of individual PAHs are released to the environment within a 24-hour period, EPA
must be notified: 1 pound of benzo[b]fluoranthene, benzo[a]pyrene, or dibenz[a,h]anthracene;
10 pounds of benz[a]anthracene; 100 pounds of acenaphthene, chrysene, fluoranthene, or
indeno[ 1,2,3-c,d]pyrene; or 5,000 pounds of acenaphthylene, anthracene,
benzo[k]fluoranthene, benzo[g,h,i]perylene, fluorene, phenanthrene, or pyrene.
PAHs are generally not produced commercially in the United States except as research
chemicals. However, PAHs are found in coal, coal tar, and in the creosote oils, oil mists, and
pitches formed from the distillation of coal tars. The National Institute for Occupational
Safety and Health (NIOSH) concluded that occupational exposure to coal products can
increase the risk of lung and skin cancer in workers. NIOSH established a recommended
occupational exposure limit, time-weighted average (REL-TWA) for coal tar products of
0.1 milligram of PAHs per cubic meter of air (0.1 mg/m3) for a 10-hour workday, within a
40-hour workweek. The American Conference of Governmental Industrial Hygienists
(ACGIH) recommends an occupational exposure limit for coal tar products of 0.2 mg/m3 for
an 8-hour workday, within a 40-hour workweek. The Occupational Safety and Health
Administration (OSHA) has established a legally enforceable limit of 0.2 mg/m3 averaged
over an 8-hour exposure period.
Mineral oil mists have been given an IARC classification of 1 (sufficient evidence of
carcinogenicity). The OSHA Permissible Exposure Limit (PEL) for mineral oil mist is
5 mg/m3 averaged over an 8-hour exposure period. NIOSH has concurred with this limit, and
has established a recommended occupational exposure limit (REL-TWA) for mineral oil mists
PAHs 9
1. PUBLIC HEALTH STATEMENT
of 5 mg/m3 for a 10-hour work day, 40-hour work week, with a 10 mg/m3 Short Term
Exposure Limit (STEL).
More information on rules and standards for exposure to PAHs can be found in Chapter 7.
1.8 WHERE CAN I GET MORE INFORMATION?
If you have any more questions or concerns, please contact your community or state health or
environmental quality department or:
Agency for Toxic Substances and Disease Registry
Division of Toxicology
1600 Clifton Road NE, E-29
Atlanta, Georgia 30333
[phone]
This agency can also provide you with information on the location of occupational and
environmental health clinics. These clinics specialize in the recognition, evaluation, and
treatment of illness resulting from exposure to hazardous substances.

APPENDIX B

Field Screening Technology Examples for Contractors

APPENDIX C

Suggested Sampling Methods for Suspect Soils

Suggested Sampling Methods for Suspected Soil Impact

Use With Project-Specific Health and Safety Plan For Construction

Objective and Application

To provide suggested procedure for soil sample collection. To obtain a representative
soil sample for chemical analysis. This includes the documentation of sampling
methods, and protocols used for sample collection, processing, handling, and shipment.

Preperation For Sampling

Isolate or contain the material consistent with the Site Management Plan (SMP).
Observe the materials to be sampled and estimate the volume in cubic yards.
Determine number of requisite samples.

Contact the laboratory and discuss the parameters of testing and these procedures as
proposed. Specify that the testing must have acceptable detection limits that are
applicable to OVAP direct-contact soil standards.

Modify field procedures as required specific to the individual laboratory’s requirements.

Equipment

• Sampling device (split barrel sampler, hand auger, hand trowel, shovel, posthole
digger, tube sampler, etc.).
• Cleaning equipment such as clean buckets, distilled water and Alconox detergent, or
equivalent laboratory glassware detergent.
• Laboratory prepared sample containers, including 1 or 2 extra in case of accidental
breakage.
• Forms as “Soil/Groundwater Sampling Information Sheet”, laboratory-specific chain-
of-custody.
• Indelible ink pen.
• Stainless steel bowl.
• Plastic sheeting.
• Site map.
• Measuring wheel.
• Measuring tape of greater than 100 feet, marked in units of feet.
• Engineer’s level to read benchmark and record elevation relative to original
assessment ground surface.
• General hand tool box.
• Disposable surgical gloves and laminated tyvek coveralls, with disposable dust
mask. If solvent odors were detected in the original observations, refer to Contractor
Safety Plan for proper respiratory equipment upgrade and requisite training.
• Alcohol wipes.
• Camera and film to record sample locations.
• Thermometer to check temperature of shipping cooler during on-site storage and
prior to shipping.
• Trash bags for disposal of expendable supplies.

Procedures

Designate locations for the requisite number of samples. Stake the location and mark it
with a unique sampling number. If the material has been contained in drums or other
bulk containers, be sure the sample designation matches that of the container.

At each location prior to collecting the soil sample, put on a clean pair of disposable
gloves. Prepare a sampling form for each location. Complete the chain-of-custody prior
to sampling. Complete the sampling and placing of materials in containers in one
uninterrupted activity.
a) Preparation
• Contact the laboratory and obtain prepared sample containers.
• Receive chain-of-custody documents and instruction for completion from the
laboratory.
• Review safety and health plan of employer specific to chemicals of concern for
sampling activity.
b) Surface and Near Surface Sampling
• Determine sample location (set grid, if necessary)
• Determine the proper sampling device based on soil type, depth, sample type, etc.
• Collect each sample at the specified depth consistently for each sample.
c) Direct Sampling
• Transfer sample directly from the sampling device to the sample container.
• If evaluating for organic vapors, transfer half of sample to glass mason jar or plastic
bag for other field testing/screening. Always minimize the space for air to
accumulate in the jar or bag.
• Document visual and physical characteristics.
d) Composite Sampling (non-volatile only)
Decreases analytical cost but also decreases ability to detect low level contamination,
suitable for metals and evaluating changed conditions of site.
• Transfer equal volume/weight of sample from each location/depth to a stainless steel
mixing bowl.
• Use a hand trowel or spoon to mix the soil sample.
• If the samples size is very large, composite on a large sheet of clean plastic or
stainless steel cookie sheet pan, or mix equal volumes from numerous composite
samples.
• If soils are cohesive, break up volumes.
• Spread soil uniformly on plastic sheet or in bottom of stainless steel bowl or stainless
steel tray and divide into quarters.
• Obtain equal quantity of soil from each sample for transfer to sample container
(without mixing or break up)
e) Cleaning
• Decontamination procedures for tools includes Alconox or similar detergent scrub
followed by a clean water rinse between sample locations.
• Decontamination fluids are to be replaced between sample locations (each boring) to
reduce the potential for cross contamination.
f) Sample Preservation
• Store containers in cooler with ice, maintain from sampling through delivery to
laboratory at temperature of 40°F (~4°C) or less, but do not freeze.
g) Sample Documentation
• Complete the “Soil Sampling Information Sheet” and laboratory chain-of-custody
form. Data to be recorded includes sampling location, methodology, depth visual
and physical characteristics, time, and date.

OTHER SUPPORTING DOCUMENTS FOR CONTRACTOR REFERENCE:
• ASTM E1903-97 Standard Guide for Environmental Site Assessments: Phase II
Environmental Site Assessment Process.

APPENDIX D

Example of Health and Safety Plan

APPENDIX D: EXAMPLE SITE HEALTH AND SAFETY PLAN

The Province at UNC Greensboro
Spring Garden Road at Fulton Street
Greensboro, Guilford County, North Carolina
XYZ CONTRACTOR PROJECT No. XXXXXX

DEVELOPED BY: __________________________________________________________

APPROVED DATE:
_________________________________________________________

APPROVED BY: ___________________________________________________________

1.0 APPLICABILITY

This EXAMPLE Site Health and Safety Plan (SHSP) has been developed to define the
protocols and requirements to be followed by personnel while performing field activities at
the site indicated above. Immediately before site activities, the designated Site Safety and
Health Officer (SSHO) will conduct a safety briefing and review the contents of this Plan with
all personnel. Employees participating in this project will review this Plan and sign the
Acknowledgment of Instruction page before the start of project activity.

This Plan establishes the mandatory safety procedures and personal protection standards
pursuant to the Occupational Safety and Health Administration (OSHA) regulations 29 Code
of Federal Regulations (CFR) 1910.120. The Plan applies to all personnel conducting any
site work, as defined in 29 CFR 1910.120 (a). All personnel involved in the mentioned
activities must familiarize themselves with this Plan, comply with its requirements, and have
completed the required health and safety training and medical surveillance program
participation pursuant to 29 CFR 1910.120 prior to beginning any work on the site.

Subcontractors engaged in project activity at this site will comply applicable provisions of the
Occupational Safety and Health Act of 1970, the safety and health requirements set forth in
Occupational Safety and Health Administration regulation 29 CFR 1910.120, where applicable,
and any applicable state, city or local safety codes. Each subcontractor will be responsible for
supplying and utilizing necessary equipment required for safety precautions for the
subcontractor’s employees engaged in this project.

The subcontractor shall maintain an orderly and safe work area around equipment to minimize
the potential for accidents. In addition, the subcontractor shall provide whatever safety
barricades or warning devices are deemed necessary by OSHA to prevent accidents or injury to
field personnel and the general public.

Example Site Health and Safety Plan
Subcontractors engaged on this project site may utilize this Site Safety and Health Plan for their
employees, or each subcontractor may develop and utilize their own Site Safety and Health
Plan provided the provisions of the subcontractor’s Site Safety and Health Plan are at least as
stringent as the requirements contained in this Plan. Decisions regarding equivalence of safety
and health requirements shall be made by Terracon Project Manager and Corporate Safety and
Health Manager. Adoption of this Site Safety and Health Plan by subcontract employers shall
not relieve any site subcontractor for the responsibility for the health and safety of its
employees.

1.1 Site Background

The site is comprised of twenty-one parcels totaling approximately 10.515 acres. The
primary site address is 507 Jackson Street in Greensboro, Guilford County, North Carolina.
The Newman Machine property is developed with approximately 17 buildings. Some of the
buildings appeared to have additions constructed at different times. Newman Machine
manufactures woodworking equipment for the pulp and paper industry. The 507 Houston
Street property is developed with a commercial metal building and is occupied by a
company that buys and sells used restaurant equipment. The New Age Builders property is
developed with a commercial building and a warehouse building.

1.2 Chemicals of Concern

Based on previous analytical information obtained from soil and groundwater samples at the
project site, the primary chemicals of concern to personnel are metals (lead, chromium,
cadmium and arsenic), polynuclear aromatic hydrocarbons (PAHs) and chlorinated solvents
(carbon tetrachloride and tetrachloroethene) which have been detected in low
concentrations at the site. Lead in soils has been identified at concentrations as high as
5070 parts per million (ppm). Arsenic concentrations in soils have been detected at
concentrations as high as 255 ppm. Chromium was detected at levels as high as 262 ppm
while cadmium has been detected as high as 115 ppm. The solvents were detected at low
levels only in the groundwater at the site. Carbon tetrachloride was detected at a
concentration of 1.2 micrograms/Liter (ug/L) and tetrachlorothene (PCE) was detected at 2
ug/L. Table 1 summarizes the health and safety data for the primary contaminants of
concern at the site.

Table 1: Health and Safety Data for Potential Contaminants of Concern
Compound PEL/
TLV-
TWA1
Physical
Description
Route of
Exposure
Target Organs Notes

PCE
100
mg/m3
OSHA
Colorless Liquid
with a chloroform-
like odor
Inhalation; Ingestion;
Skin/Eye Contact;
Absorption
Eyes; Liver; CNS;
Skin; Blood;
Reproductive
System; Respiratory
System
Probable
Carcinogen
Example Site Health and Safety Plan
Table 1: Health and Safety Data for Potential Contaminants of Concern (continued)
Compound PEL/
TLV-
TWA1
Physical
Description
Route of
Exposure
Target Organs Notes

Carbon
Tetrachloride
10 mg/m3
OSHA
Colorless Liquid
with a “sweet”,
ether-like odor
Inhalation, skin
absorption,
ingestion, skin
and/or eye contact
Central nervous
system; eyes; lungs;
liver; kidneys; skin

Anticipated
Carcinogen

Lead
0.05
mg/m3

N/A
Inhalation; Ingestion;
Skin/Eye Contact
GI Tract; CNS;
Kidneys; Blood;
Gingival Tissue

Cadmium

0.005
mg/m3

N/A

Inhalation; Ingestion
Respiratory system;
kidneys; prostate;
blood

Chromium
1 mg/m3
N/A
Inhalation, ingestion,
skin and/or eye
contact
Eyes; skin;
respiratory system

Arsenic
0.01
mg/m3
(As metal)
Appearance and
odor vary
Inhalation; Ingestion Respiratory System;
Kidneys; Prostate;
Blood

Polynuclear
Aromatic
Hydrocarbons
0.2
mg/m3

Appearance and
odor vary
Inhalation; Ingestion Respiratory System,
blood, skin

1 PEL = Permissible Exposure Limit; TLV = Threshold Limit Value. Both values are based on an 8-hour time weighted average
exposure (TWA). PELs are established by OSHA as regulatory limits. TLVs are recommended exposure limits established by
the American Conference of Governmental Industrial Hygienists (ACGIH).
2 CNS = Central Nervous System
3 GI = Gastrointestinal
4 RBC = Red Blood Cells

Perchloroethylene
Permissible Exposure Limit
100 ppm OSHA PEL
200 ppm OSHA STEL
25 ppm ACGIH TLV
Perchloroethylene (tetrachloroethylene) is a clear, colorless, volatile liquid with an ether-like
odor. NIOSH considers perchloroethylene to be a potential human carcinogen.
Tetrachloroethylene causes central nervous system depression and liver damage. Defatting
action of the skin can lead to dermatitis. Unconsciousness, dizziness, headache, vertigo and
light narcosis have occurred in many instances after occupational exposure.

Carbon Tetrachloride
Permissible Exposure Limit
10 ppm OSHA PEL
200 ppm OSHA STEL
5 ppm ACGIH TLV
Carbon tetrachloride (tetrachloromethane) is a clear, colorless, non-flammable liquid with a
sweet, ether-like odor. EPA considers carbon tetrachloride to be a potential human
Example Site Health and Safety Plan
carcinogen. Exposure symptoms include: irritation eyes, skin; central nervous system
depression; nausea, vomiting; liver, kidney injury; drowsiness, dizziness, incoordination.

Lead
Permissible Limit
0.05 mg/m3 PEL
0.03 mg/m3 OSHA Action Level
Lead is a toxic heavy metal which may cause blood, kidney and nervous system disorders if
ingested. Metallic lead and lead contained in dusts are not readily absorbed through the skin.
However, skin contact with potentially contaminated site materials must be avoided

Cadmium
Permissible Limit
0.005 mg/m3 PEL
0.0025 mg/m3 OSHA Action Level
Cadmium is a toxic metal and a known carcinogen which can cause cancer and nervous
system disorders if ingested. Metallic cadmium and cadmium contained in dusts are not
readily absorbed through the skin but represent a potential inhalation hazard. Skin contact with
potentially contaminated site materials should be avoided. Exposure symptoms include:
pulmonary edema, dyspnea (breathing difficulty), cough, chest tightness, substernal (occurring
beneath the sternum) pain; headache; chills, muscle aches; nausea, vomiting, diarrhea;
anosmia (loss of the sense of smell), emphysema, proteinuria, mild anemia.

Chromium
Permissible Limit
1 mg/m3 PEL
0.0025 mg/m3 OSHA Action Level (hexavalent chromium)
Chromium (VI) is a toxic form of chromium. Exposure to chromium (VI) may cause lung
cancer, asthma, and damage to the nasal epithelia and skin. Chromium (VI) enters the body
by inhalation, ingestion, or absorption through the skin. Inhalation and skin absorption are
the primary routes of exposure. OSHA regards chromium (VI) compounds as carcinogens.
Exposure symptoms include: irritation eyes, skin; lung fibrosis.

Arsenic (Inorganic)
Permissible Exposure Limit
0.01 mg/m3 ACGIH --TLV

Arsenic is considered an occupational carcinogen (cancer causing agent) by OSHA. Arsenic
compounds may irritate the skin, eyes and mucous membranes. Symptoms of short term
(acute) exposure include itching, sore throat and numbness, burning or tingling of the
extremities beginning in the hands or feet.
Example Site Health and Safety Plan
Polynuclear Aromatic Hydrocarbons
(Coal Tar Pitch Volatiles – Heavy Machining Lubricants)
Permissible Exposure Limit
0.2 mg/m3 ACGIH TLV

Coal tar pitch volatiles are classified as human carcinogens by NIOSH and the ACGIH. They
are known to produce lung and skin cancer. Exposure to coal tar pitch volatiles has also
been associated with phototoxic skin reactions. Skin cancer has occurred in rats and mice
from repeated application of coal tar pitch volatiles such as benzo (a) pyrene. OSHA
defines "coal tar pitch volatiles" in 29 CFR 1910.1002 as the fused polycyclic hydrocarbons
that volatilize from the distillation residues of coal, petroleum (excluding asphalt), wood, and
other organic matter and includes substances such as anthracene, benzo(a)pyrene (BaP),
phenanthrene, acridine, chrysene, pyrene, etc.

2.0 HEALTH AND SAFETY ADMINISTRATION

The Project Manager will ultimately be responsible for verifying work is performed in
accordance with the safety and health provisions contained in this Plan. The designated Site
Health and Safety Officer (SSO) will monitor compliance with this Plan during field activities.
The SSO will report directly to the Project Manager. All field team members engaged in
project activities will be required to sign the Plan "Acknowledgment of Instruction" form. The
forms will be maintained on site by the SSO. The SSO will ensure that a copy of this Plan is
available on site for the duration of project activities.

Terracon and subcontractor task leaders will be responsible for:

• Providing subordinate personnel a copy of this Plan, and briefing them on its content.
• Enforcing the applicable provisions of this Plan.
• Inspecting and maintaining equipment in compliance with applicable federal, state or
local safety regulations.
• Enforcement of corrective actions.
• Investigation of accidents or injuries.

The following individuals will be responsible for implementation and enforcement of this Plan
for the Site:

TITLE NAME PHONE

Project Manager: _________________________ ____________

Health and Safety Manager: _________________________ ____________

Site Health and Safety Officer _________________________ ____________

Example Site Health and Safety Plan
If hazardous conditions develop during the course of project activity, the SSO, in conjunction
with the Health and Safety Manager, will coordinate actions required to safeguard site
personnel and members of the general public. Additional safety measures will be
communicated to project personnel, recorded in writing, and appended to this Plan.
3.0 MEDICAL SURVEILLANCE REQUIREMENTS

3.1 Introduction

Hazardous waste site workers can often experience high levels of physical stress. Their
daily tasks may expose then to toxic chemicals, physical hazards, biologic hazards, and in
some instances, radiation hazards. They may develop heat stress while wearing protective
equipment or working under temperature extremes, or face life-threatening emergencies
such as explosions and fires. Therefore, a medical program is essential to:

• Assess and monitor worker’s health and fitness both prior to employment and during the
course of the work
• Provide emergency and other treatment as needed; and
• Keep accurate records for future reference.

3.2 Medical Examinations

Personnel participating in this project will be enrolled in a health monitoring program in
accordance with the provisions of OSHA 29 CFR Part 1910.120 and 1910.134. Each project
participant will be certified by a Doctor of Medicine as fit for respirator and semi-
permeable/impermeable protective equipment use. Personnel will have received an
environmental physical examination within one year prior to the start of project activities.
Physical examinations will consist of the following services:

• Comprehensive personal, family and environmental exposure history;
• Physical exam by an M.D. Board Certified in Occupational Medicine;
• Chest X-ray (P/A only);
• Pulmonary Function (FVC, FEV1, other as needed);
• Resting EKG;
• CBC with differential and general urinalysis with microscopic;
• Visual acuity and audiometry per OSHA 29 CFR 1910.95; and
• Blood Chemistry (SMAC 24).

A report of medical findings will be provided to the employee. Medical surveillance records
will be maintained by the Contractor Health and Safety Manager. Certificates of Medical
Examination for project personnel will be maintained by the Contractor Health and Safety
Manager.

At the discretion of the consulting physician, an "exit" physical examination consisting of the
above services will be conducted at the completion of project activities or upon termination
Example Site Health and Safety Plan
of a project participant. Follow-up medical examinations will also be provided in the event of
job site injury or unprotected exposure to contaminants in excess of eight-hour time
weighted average permissible exposure limits (PELs).

4.0 EMPLOYEE TRAINING REQUIREMENTS

All personnel participating in this project must have completed 40 hour Hazardous Waste
Operations Training and at least three days of supervised field activity per requirements of
OSHA 29 CFR Part 1910.120. In addition, a current eight-hour annual refresher training
certificate will be required for personnel. Supervisory personnel will have completed eight
hours of specialized supervisory training. Training certificates for project personnel will be
maintained by the Contrackor Health and Safety Manager and/or the SSO on the Site during
field activities.

Before the start of site activities, project personnel will participate in a pre-project safety and
health briefing outlining the contents of this Plan. The personnel responsible for project
safety and health will be addressed, as will site history, scope of work, site control
measures, emergency procedures, and site communications. In addition, a detailed
discussion of site hazardous materials, air monitoring protocols, action levels for
upgrade/downgrade of personal protective equipment and level of protection to be employed
for each project task will be addressed.

Periodic "tailgate" safety and health briefings will be presented by the SSO at the start of
each work day. In addition to a general review of the proposed daily activity and safety
requirements, the results of previous air monitoring and any procedural changes will be
addressed.
5.0 RESPIRATORY PROTECTION PROGRAM

The purpose of the Respiratory Protection Program is prevention of personnel exposures to
potentially harmful contaminants in excess of published permissible exposure limits. All
respirators employed personnel will be NIOSH approved. Cartridges and filters for air
purifying respirators will be appropriate for the contaminant(s) of concern. Cartridge/filter
selection will be made by the Contractor Safety and Health Manager. Project personnel
required to wear respiratory protection will be medically cleared for respirator use, trained
and successfully fit tested in accordance with OSHA 29 CFR 1910.134.

At a minimum, air purifying respirator cartridges will be changed DAILY prior to use. More
frequent change of respirator cartridges will be based on the results of site air monitoring.
Under no circumstances will air purifying respirators be used in areas deficient in oxygen
(<19.5%), in areas classified as immediately dangerous to life and health (IDLH) or in areas
where contaminants have not been characterized. Respirators will be sanitized daily after
use.
Example Site Health and Safety Plan
6.0 HAZARD ANALYSIS

6.1 Chemical Hazards

The primary hazard to personnel engaged in site activities at this project site is potential
inhalation and/or accidental ingestion of lead, arsenic, cadmium, chromium contaminated dust
encountered on the site. The low levels of polynuclear aromatic hydrocarbons (heavy
machining lubricants) identified in prior soil samples pose minor skin contact hazards, but their
potential health effect to personnel is considered negligible.

Personnel should take precautions to reduce the potential for airborne dust during soil boring
activities. Use of good personal hygiene practices limiting the potential for hand to mouth
contact with site soils will further reduce the potential for ingestion of metals-contaminated soils.

Chlorinated compounds have only been identified in groundwater at the site. Construction
activities are not expected to expose personnel to groundwater.

6.2 Physical Hazards

Hazards typically encountered at construction sites will be a concern at this site. These hazards
include slippery ground surfaces, holes, the presence of jagged metal, broken machinery,
slip/trip/fall hazards, and operation of heavy machinery and equipment. Personnel should be
aware that as personal protective equipment increases, dexterity and visibility may be impacted
and performing some tasks may be more difficult.

Personnel will wear ANSI Class II or Class III traffic safety vests if activities are conducted within
10 feet of an active roadway. Equipment operators will wear safety glasses, hard hats and
safety footwear. Because heavy equipment can create major hazards at the job site, the
following procedures will be followed during soil boring activities:

• Underground utilities in the area where activities are occurring will be located and marked.
• No loose fitting clothing, jewelry or unsecured long hair is permitted near heavy equipment.
• Keep hands and feet away from all moving parts.
• Daily inspection of all ropes, cables and moving parts is mandatory.
• A first aid kit and fire extinguisher will be available at all times.
• No activities are permitted during impending electrical storms, tornadoes or when rain or
icing creates a hazardous work environment.
• Keep equipment at least 10 feet from overhead power lines. Use spotters to help operator
position whenever overhead hazards or other obstructions are present.

The SSO will review site physical hazards summarized with personnel working on the site by
the SSO. At no time will personnel carry out a task associated with this investigation in which
there is an eminent physical or health risk due to these hazards. Safety footwear will be
required on the site at all times due to potentially hazardous debris throughout the site.

Example Site Health and Safety Plan
6.3 Heat Stress

Whenever ambient temperature exceeds 70 degrees F and personal protective equipment
requirements are Level D or Level D modified, the following heat stress monitoring and
preventive measures will be implemented.

At least one gallon of water will be available for each field employee during each day of site
activity. The SSO and/or the Task Leader(s) will observe personnel for signs of heat stress
(excessive perspiration, flushed skin, nausea, etc.).

If such signs are observed, affected workers will be required to leave the contaminant zone,
loosen protective clothing and rest. During the rest period affected personnel will drink at
least one 8 oz. glass of cool water. Pulse will be checked at the beginning of the rest period.
Personnel will not return to work until pulse rate is less than 90.

6.4 Noise

The use of heavy machinery/equipment and operation may result in noise exposures that
require hearing protection. Exposure to noise can result in temporary hearing losses,
interference with speech communication, interference with complicated tasks or permanent
hearing loss due to repeated exposure to noise. During the investigative activities, Terracon
personnel will use hearing protection when sound levels interfere with normal communication at
a distance of more than 5 feet.

7.0 ACCIDENT PREVENTION

The Site Health and Safety Officer (SSO) has administrative responsibilities for enforcing the
provisions of this Plan. As a means of helping to prevent accidents, the SSO’s duties include
direction of the following:

• The SSO will hold daily safety briefings at the beginning of each day of site activity.

• The SSO will investigate and immediately report all Terracon accidents and injuries to the
Corporate Health and Safety Manager.

• Site activities will be conducted only during daylight hours.

• If site activities interrupt the normal flow of pedestrian or vehicular traffic, appropriate
barricades will be erected around the site. Safety orange work vests will be worn by
personnel working on the site.

• Eating, drinking, chewing gum or tobacco, smoking, or any practice that increases the
probability of hand-to-mouth transfer and ingestion of site materials is prohibited.

Example Site Health and Safety Plan
8.0 SITE CONTROL

An Exclusion Zone will be established around each work zone to reduce the potential spread of
contamination to clean areas. The Exclusion (contaminant) Zone established for this project site
should be considered to extend in a 20-foot radius surrounding the work zone. The Exclusion
Zone should be clearly marked with traffic cones, flags, ropes, surveyors tape (or other suitably
visible means) if establishment of such barricades may reasonably prevent entry of
unauthorized personnel. Personnel entering the Exclusion Zone should be required to meet the
training and medical surveillance requirements of OSHA 29 CFR 1910.120.

9.0 SITE COMMUNICATIONS

Personnel will maintain line-of-site contact with other team members. Donning of full-face air
purifying respirators may impair the ability to communicate verbally at distances greater than
approximately five feet. In the event that verbal communication is impaired, the following hand
signals will be used on site:

Signal Meaning/Definition
Hands clutching throat Can’t breath/out of air
Hands on top of head Need assistance
Thumbs up OK/I’m all right/I understand
Thumbs down NO/Negative
Arms waving upright Send help
Grip partner’s wrist Exit area immediately

The SSO will maintain a cellular telephone in the command vehicle at all times.

9.0 AIR MONITORING AND SITE ACTION LEVELS

This air monitoring protocol is designed to prevent personnel exposure to airborne
contaminants in excess of established permissible exposure limits. The results of field air
monitoring will be used to determine the continued adequacy of initial personal protective
equipment.

Air monitoring equipment required for petroleum contaminated sites will include the
following:

• Photoionization detector (PID) or flame ionization detector (FID)
• Particulate / aerosol monitoring instrument (i.e. Miniram)

Task Leader(s) will be knowledgeable in the operation of the photoionization detector. A
manual on the operation of the PID and the appropriate calibration kit will be mobilized to
the project site with the instrument. Photoionization detectors will be calibrated under field
Example Site Health and Safety Plan
conditions each day prior to use. Task Leaders are instructed to consult the manufacturer's
specifications for appropriate calibration gas and calibration techniques.

A photoionization detector (PID) will be used to determine approximate hydrocarbon vapor
concentrations in the BREATHING ZONE of site personnel. Continuous breathing zone air
monitoring will be conducted during initial phases of intrusive activities (i.e., boring,
excavation). If PID readings are less than 10 ppm, monitoring may be conducted at intervals
of 10 minutes. If initial PID readings exceed 10 ppm, or if hydrocarbon odors become
evident upon during auger advancement, continuous breathing zone air monitoring will be
conducted.

If sustained PID readings in the breathing zone exceed 25 ppm, personnel will upgrade to
respiratory protection as outlined below. Personnel will remain in air purifying respirators
until the photoionization detector readings in the breathing zone have fallen and stabilized
below 25 ppm.

A no visible emissions criteria will be established during excavation of impacted soils. If
excessive visible dust emissions are observed during excavating or loading operations, work
will be curtailed until the excavation area is lightly sprayed with potable water. Slow
movement of equipment and low bucket dump heights will be used to reduce the potential
for off-site migration of contaminated dusts.

Monitoring for particulates will be used in the absence of real-time screening technologies
for inorganic COCs (i.e. metals) identified at the site. Since the COCs are known to exist in
the soils / fill at the site, and since inorganic COCs are nonvolatile, any airborne
concentrations of COCs is expected to be associated with airborne dust. Particulate
screening will take place prior to the start of work activities and then hourly thereafter until
the work is completed or the workday ends.

9.1 Site Action Levels

Instrument Level D/D Modified Level C Site Evacuation

PID < 25 ppm > 25 ppm > 300 ppm

The Action Levels indicated above are for air in the breathing zone and NOT applicable to
vapor above containerized soil samples. The Action Levels are established to prevent
exposure to airborne petroleum hydrocarbon vapors in excess of established exposure
limits. Although the Action Levels indicated for Site Evacuation are within the protective
capacity of the respirator cartridges specified below, personnel will evacuate to the UPWIND
side of the site if the continuous breathing zone vapor concentrations exceed these limits.
The SSO will contact the Corporate Safety and Health Manager for discussion and re-
evaluation of personal protective equipment and air monitoring requirements if airborne
contamination exceeds Site Evacuation Action Levels. In the event that site evacuation is
Example Site Health and Safety Plan
required, a modification of this safety and health plan will be issued with contingencies for
combustible gas monitoring and upgrading to Level B personal protective equipment.

THIS PLAN IS NOT VALID FOR LEVEL B SITE ACTIVITIES.

10.0 PERSONAL PROTECTIVE EQUIPMENT REQUIREMENTS

The air monitoring regimen identified above will allow initial project activity to begin in
LEVEL D personal protective equipment to include:

• Hard Hat

• Protective Safety Boots (Hazmax, other as approved by S&H Mgr.)

• Protective Work Outer Gloves

• Nitrile or Latex Inner Liners

• Safety Eye Wear (ANSI Z-87 approved)

• Hearing Protection

If chemical saturated soils and potential splashing conditions develop during the course of
the assessment, personnel will upgrade to LEVEL D MODIFIED personal protective
equipment. Level D Modified personal protective equipment ensemble consists of the
above, plus:

• Polylaminated Tyvek Coveralls

• Tape Sleeves/Legs to Gloves and Boots

If air monitoring exceeds Action Level specified for upgrade to LEVEL C personal protective
equipment, personnel will don:

• Full Face Air Purifying Respirator

• Equipped with Combination Organic Vapor/Acid Gas/HEPA Cartridges

As no volatile organic compounds are present on this project site, air monitoring will not be
required during drilling operations. The only respiratory hazard anticipated is inhalation of
high concentrations of dusts generated by contaminated site soils. High dust concentrations
should not be generated by construction activities.

Example Site Health and Safety Plan
11.0 Dust Control

Many potential site contaminants in soils at this project site are non-volatile, that is, they do
not liberate vapors to the atmosphere. The principal exposure pathway to site contaminants
such as heavy metals (lead, arsenic) is through inhalation of contaminated dusts or through
accidental ingestion. Grading activities generate airborne dusts. Dust generation is to be
avoided at all times. If soils are dry and the potential for soils migrate through air is
increased, standard construction procedures for dust control should be used. This usually
takes the form of a light application of water periodically to moisten soils. In case of visible
dust and before dust controls are in place, workers should make use of disposable dust
masks as a precautionary measure.

12.0 DECONTAMINATION

Decontamination will be necessary whenever personnel or equipment enter and exit a site
Exclusion Zone to obtain soil and/or groundwater samples.

12.1 Personal Decontamination

Personnel decontamination will consist primarily of detergent washing and rinsing of
reusable personal protective outer gear. Coveralls will be removed by turning the clothing
inside out and placing them in a plastic trash bag which will be sealed and disposed of as
regular trash, preferably at the project site. Personnel must thoroughly wash hands, face
and forearms, and a full body shower is recommended as soon as possible upon leaving the
site.

Re-usable personal protective equipment such as gloves and boots will be washed with a
solution of anionic detergent and water followed by a clean water rinse. It is the
responsibility of the SSO to ensure the adequacy of decontamination prior to personnel or
equipment leaving the site.

In order to minimize the potential for carrying toxic particulates off-site which could later be
accidentally ingested by site workers or others, it is recommended that a clean change of
street clothing be brought to the site each workday. Clean clothing should be sealed in a
plastic bag until the end of shift. After completing decontamination or disposal of outer
protective equipment, clothing should be changed. Soiled clothing should be placed in a
plastic bag and sealed until laundered. Clothing soiled on site should be laundered
separately from all other clothing.
Example Site Health and Safety Plan

12.2 Equipment Decontamination

Decontamination of equipment will be performed to limit the off-site migration of
contaminated soils. All equipment will be cleaned prior to site entry to remove grease, oil
and encrusted soil. Decontamination of large equipment (backhoe excavation bucket) will
consist of physically removing gross contamination with shovels, brushes etc. followed by
detergent and water high pressure wash with a clean water rinse. Decontamination solutions
will be handled per client agreement. Decontamination of hand samplers and similar small
equipment will also be decontaminated with an anionic detergent wash followed by clean
water rinse.

13.0 SITE EMERGENCY RESPONSE

Nearest Hospital/Clinic: ____________________________________

Estimated Drive Time: ______________________________________

_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________

Ambulance: 911
Fire Department: 911
Police: 911
Project Manager:
Task Leader:
Safety and Health Manager:

13.1 Personal Injury

The SSO and/or Task Leader and at least one other individual on site will be appropriately
trained to administer first aid and CPR. A certificate issued by the American Red Cross,
National Safety Council or equivalent will be considered appropriate.

For minor injuries, such as cuts, burns, exhaustion, heat cramps, insect stings, etc., the
affected employee will be removed to an uncontaminated area. The SSO, Task Leader(s),
or other designated employee trained in first aid procedures will administer appropriate first
aid. If the injury warrants additional medical attention, the affected employee will be properly
decontaminated and transported to the nearest hospital or emergency medical facility.

Example Site Health and Safety Plan
For more serious injuries, the SSO, Task Leader(s), or designee will summon an ambulance
to the project site. No attempt will be made by project personnel to move the victim, without
the aid and/or instructions of qualified medical personnel.

Where air monitoring indicates the absence of toxic gases or vapors, the ambulance will be
directed to the affected employee. If site conditions warrant and as time permits, the wheels
of the ambulance will be decontaminated with high-pressure wash. The SSO or designee
will accompany the ambulance to the medical facility, and provide guidance concerning
additional decontamination that may be required for the injured employee, ambulance or
attendants.

Whenever an injury occurs on sites with contamination requiring personal protective
equipment greater than Level D modified, a minimum of two employees will don appropriate
equipment and proceed to the victim. An ambulance will be called immediately. If the extent
of injuries permits, the injured employee will be removed to fresh air. Appropriate first aid will
be administered.

If rescuer(s) assess that the victim cannot be removed without a stretcher or other
specialized equipment, the victim will be removed at the earliest possible moment by
appropriately attired personnel with the direction and/or assistance of qualified medical
response personnel. The injured employee will be immediately decontaminated and
transported to the nearest medical facility. A crew member designated by the SSO will
inform the ambulance crew of contaminants of concern and provide assistance with
additional decontamination if required.

13.2 Evacuation and Shutdown Procedures

The SSO will establish and notify site personnel of emergency "rally" points. In the event of
a site emergency, personnel will immediately exit the site and assemble at the designated
rally point. Evacuation routes will be dependent on site topography and wind conditions. The
routes will be selected and presented by the SSO if changes are required based on site
characteristics.

If emergency evacuation becomes necessary, the SSO will sound the emergency alarm
(e.g. support vehicle horn or compressed air horn). Personnel will safely shutdown all
electrical and mechanical equipment and quickly proceed to closest designated rally point.
The SSO will then account for each crew member on site.

In the event that an employee does not report to the designated rally point within 5 minutes
of the evacuation alarm, the SSO will perform an immediate assessment of site conditions. If
site conditions do not pose an immediate hazard to life or health, the SSO will initiate search
and rescue efforts utilizing two crew members attired in appropriate personal protective
equipment.

ACKNOWLEDGMENT OF INSTRUCTION

All personnel are required to sign the following acknowledgment of instruction form prior to
conducting project activities. This acknowledgment is not a waiver. It is the primary method
used in compiling environmental experience and contaminant exposure records for
personnel. Upon written request, a copy of your environmental work record will be provided
by the Corporate Safety and Health Manager.

I understand that this project involves the investigation of a project site where soils are
impacted by heavy metals (primarily lead with low-level arsenic), low level TCE and
poynuclear aromatic hydrocarbons (PAH). I have read this Safety and Health Plan and have
received instructions for safe work practices, personal protective equipment and air
monitoring requirements. I further understand that if I encounter unanticipated contamination
I am to leave the site and immediately notify the Project Manager and Corporate Safety and
Health Manager.

PROJECT NAME:

JOB No. : XXXXXXXXXX

Name (Please Print) Signature Date

_____________________________ ________________________ ______

_____________________________ ________________________ ______

_____________________________ ________________________ ______

_____________________________ ________________________ ______

_____________________________ ________________________ ______

_____________________________ ________________________ ______

_____________________________ ________________________ ______

_____________________________ ________________________ ______

_____________________________ ________________________ ______

Initial safety briefing performed by: _____________________________ Date:_________

Example Site Health and Safety Plan
ACKNOWLEDGMENT OF INSTRUCTION (con’t.)

For each subsequent field activity, field personnel shall acknowledge that the Safety and
Health Plan, with any revisions, has been reviewed and that the SSO has been identified by
completing the form below.

Print Name Signature Date Hrs. on-site Briefing By SSO

ATTACHMENT B

Soil Vapor Intrusion Barrier Specifications
LIQUID BOOT® GVB, version 4.0 1 © 2007 CETCO Liquid Boot Company
LIQUID BOOT® Brownfield Membrane/Liner
Section 2 | Version 4.0

These Specifications may have changed. Please contact CETCO Liquid Boot Company (CLB) at 714.384.0111 for the most recent version.

NOTE: If the membrane is to also perform as a waterproofing membrane, do not use this specification. Use the standard LIQUID BOOT® fluid-applied
waterproofing specification.

PART 1 - GENERAL

1.01 DESCRIPTION- General and Supplementary Conditions and Division 1- General Requirements applies to this section. Provide gas vapor barrier as
indicated, specified and required.

A. Work in this section - principal items include:
1. Gas vapor barrier providing protection from the following gases: Methane, other Hydrocarbon vapors in concentrations up to 20,000ppm,
Hydrogen Sulfide, Radon
2. Gas vapor barrier under single family homes.

B. Related work NOT in this section: excavation and backfilling, parge coat on masonry to receive gas vapor barrier membrane, mortar beds or concrete
toppings over gas vapor barrier membranes, latex waterproofing, damp-proofing, flashing and sheet metal, joint sealers, soil sterilant, gas collection
systems, gas monitoring, and drainage.

1.02 QUALITY ASSURANCE- Gas vapor barrier contractor/applicator shall be trained and approved by gas vapor barrier manufacturer, CETCO Liquid
Boot Company (CLB). A pre-installation conference shall be held prior to application of gas vapor barrier to assure proper substrate and installation
conditions, to include contractor, applicator, architect/engineer and special inspector.

1.03 SUBMITTALS (Refer to section 01300 for procedures)

A. Project Data - Submit manufacturer’s product data and installation instructions for specific application.

B. Samples - Submit representative samples of the following for approval:
1. Gas vapor barrier membrane material.
2. Protection Board and/or Protection Mat.
3. Prefabricated Drainage Mat.
4. Geotextiles.

1.04 DELIVERY, STORAGE AND HANDLING- Deliver materials to site in original unbroken packages bearing manufacturer’s label showing brand,
weight, volume, and batch number. Store materials at site in strict compliance with manufacturer’s instructions. Do not allow materials to freeze in
containers.

1.05 JOB CONDITIONS

A. Protect all adjacent areas not to receive gas vapor barrier. Where necessary, apply masking to prevent staining of surfaces to remain exposed
wherever membrane abuts to other finish surfaces.

B. Perform work only when existing and forecasted weather conditions are within manufacturer’s recommendations for the material and product used.

C. Minimum clearance of required for application of product: 90° spray wand- 2 feet / Conventional spray wand- 4 feet.

D. Ambient temperature shall be within manufacturer’s specifications. If winter conditions apply, we recommend the use space of heaters and necessary
cover (i.e. visqueen) to bring the ambient temperature to at least +45°F until the protection course and structural slab rebar or a mudslab protection
course has been placed.

E. All plumbing, electrical, mechanical and structural items to be under or passing through the gas vapor barrier shall be positively secured in their
proper positions and appropriately protected prior to membrane application.

F. Gas vapor barrier shall be installed before placement of reinforcing steel. When not possible, all exposed reinforcing steel shall be masked by
General Contractor prior to membrane application.

G. Expansion joints must be filled with a conventional waterproof expansion joint material.

H. Surface preparation shall be per manufacturer’s specification.

1.06 PRODUCT WARRANTY- CETCO Liquid Boot Company (CLB) warrants its products to be free of defects. This warranty only applies when the
LIQUID BOOT® is applied by CETCO Liquid Boot Company Approved Applicators and that the required respective CLB products (such as LIQUID
BOOT® UltraDrain. LIQUID BOOT® UltraShield, LIQUID BOOT® BaseFabric and LIQUID BOOT® GeoVent) are used. As factors, which affect the
LIQUID BOOT® GVB, version 4.0 2 © 2007 CETCO Liquid Boot Company
result obtained from this product, including weather, equipment utilized, construction, workmanship and other variables- are all beyond the
manufacturer's control, CLB warrants only that the material conforms to its product specifications. Under this warranty CLB will replace at no charge
any product not meeting these specifications within 12 months of manufacture, provided it has been applied in accordance with CLB’s written
directions for use recommended as suitable for this product. Warranties are available for a longer period upon request and mutual written consent.
This warranty is in lieu of any and all other warranties expressed or implied (including any implied warranty of merchantability or fitness for a
particular use), and CLB shall have no further liability of any kind including liability for consequential or incidental damages resulting from any defects
or delays caused by replacement or otherwise.

PART 2 - PRODUCTS

2.01 MATERIALS

A. Fluid applied gas vapor barrier system - LIQUID BOOT®; a single course, high build, polymer modified asphaltic emulsion. Water borne and spray
applied at ambient temperatures. A minimum thickness of 60 dry mils, unless specified otherwise as some cities and engineers may require a thicker
membrane. Non-toxic and odorless. LIQUID BOOT® Trowel Grade has similar properties with greater viscosity and is trowel applied. Manufactured
by CETCO Liquid Boot Company, Santa Ana, CA [phone].

C. Gas vapor barrier physical properties:

GAS VAPOR MEMBRANE TEST METHOD VALUE
Hydrogen Sulfide Gas Permeability ASTM D1434 None Detected
Benzene, Toluene, Ethylene, Xylene,
Gasoline, Hexane, Perchloroethylene
ASTM D543, D412, D1434
(tested at 20,000 ppm) Passed in gas permeability and weight change
Acid Exposure (10% H2SO4 for 90 days) ASTM D543 Less than 1% weight change
Radon Permeability Tested by US Dept. of Energy Zero permeability to Radon (222Rn)
Bonded Seam Strength Tests ASTM D6392 Passed
Micro Organism Resistance (Soil Burial)- average weight change, average
tensile strength change, average tensile stress change, average elongation
change, bonded seams, methane permeability
ASTM D4068-88 Passed
Methane Permeability ASTM 1434-82 Passed
Oil Resistance Test- average weight change, average tensile strength
change, average tensile stress change, average elongation change, bonded
seams, methane permeability
ASTM D543-87 Passed
Heat Aging- average tensile strength change, average tensile stress change,
average elongation change, bonded seams ASTM D4068-88 Passed
Dead Load Seam Strength City of Los Angeles Passed
Environmental Stress-Cracking ASTM D1693-78 Passed
PCE Diffusion Coefficient Tested at 6,000 mg/m3 2.74 x 10-14 m2/sec
TCE Diffusion Coefficient Tested at 20,000 mg/m3 8.04 x 10-14 m2/sec
WATERPROOFING TEST METHOD VALUE
Soil Burial ASTM E154-88 Passed
Water Penetration Rate ASTM D2434 <7.75 x 10-9 cm/sec
Water Vapor Permeability ASTM E96 0.24 perms
Water Vapor Transmission ASTM E96 0.10 grains/h-ft2
POTABLE WATER TEST METHOD VALUE
Toxicity Test 22 CCR 66696 Passed. CCR Bioassay—Flathead Minnow
Potable Water Containment ANSI/NSF 61 NSF Certified for tanks >300,000 gal
GENERAL INFORMATION TEST METHOD VALUE
Coefficient of Friction- geotextile both sides ASTM D5321 0.72
Cold Bend Test ASTM D146 Passed. No cracking at –25°F
Freeze-Thaw Resistance (100 Cycles) ASTM A742 Meets criteria. No spalling or disbondment
Accelerated Weathering & Ultraviolet Exposure ASTM D822 No adverse effect after 500 hours
Hydrostatic Head Resistance ASTM D751 Tested to 138 feet or 60 p.s.i
Elongation ASTM D412 1,332% - Ø reinforcement, 90% recovery
Elongation- 8oz. non-woven geotextile both sides ASTM D751 100% (same as geotextile tested separately)
Tensile Strength ASTM D412 58 p.s.i. without reinforcement
Tensile Strength-8oz. non-woven geotextile both sides ASTM D751 196 p.s.i. (same as geotextile tested separately)
Tensile Bond Strength to Concrete ASTM D413 2,556 lbs/ft2 uplift force
Puncture Resistance-8oz. non-woven geotextile both sides ASTM D4833 286 lbs. (Probe Travel= .756 in., same as geotextile tested separately)
Flame Spread ASTM E108 Class A with top coat (comparable to UL790)
Electric Volume Resistivity ASTM D257 1.91 x 1010 ohms-cm

LIQUID BOOT® GVB, version 4.0 3 © 2007 CETCO Liquid Boot Company
C. Agency Approvals:
• City of Los Angeles Research Report # 24860-Approved for “LIQUID BOOT® Membrane for Below-Grade Waterproofing and Gas Barrier”
• United States Navy-Approved for “LIQUID BOOT® for Use World Wide to Waterproof Earth-Covered Steel Ammunition Storage”
• NSF International-NSF/61 approved for “Potable Water Tank Liner”
• Canadian Construction Materials Board-Approved for “Waterproofing and Damp proofing”
• County of Los Angeles Department of public works-Approved for “LIQUID BOOT® Application as a Methane Gas Barrier”

D. LIQUID BOOT® 500- Contact CETCO Liquid Boot Company before specifying or bidding LIQUID BOOT® 500 to insure LIQUID BOOT® 500
is appropriate for the project. LIQUID BOOT® 500 may be used in lieu of LIQUID BOOT® (described in section 2.01 B. above) where the
membrane is not exposed to hydrostatic head pressure. The Agency Approvals in section 2.01 C above do not apply to LIQUID BOOT® 500. The
physical properties for LIQUID BOOT® 500 are as follows:

Note: LIQUID BOOT® 500 may tend to sag on vertical surfaces at higher ambient temperatures. When this condition occurs, use LIQUID
BOOT® at these locations.

WATERPROOFING TEST METHOD VALUE
Elongation ASTM D412 800%
Bond Seam Strength Tests ASTM D6392 Passed
Methane Permeability ASTM D1434 None detected
Water Vapor Permeability ASTM E96 0.18 perms

• Agency Approval- City of Los Angeles Research Report-RR 25549-Approved for “LIQUID BOOT® 500 Spray Applied Membrane for Below-Grade
Waterproofing and Gas Barrier”

E. Protection- On vertical surfaces, use LIQUID BOOT® UltraShield P-100 or other protections as approved by the manufacturer, project architect or
engineer. On horizontal surfaces, use LIQUID BOOT® UltraShield G-1000 or other protections as approved by the manufacturer, project architect or
engineer.

Due to the diverse jobsite conditions, all protection materials must be approved by the membrane manufacturer, including the use of the
LIQUID BOOT® UltraShield products.

F. Prefabricated Drain Mat- On vertical surfaces, use LIQUID BOOT® UltraDrain 6200. On horizontal surfaces, use LIQUID BOOT® UltraDrain 9000

G. Adhesive system for LIQUID BOOT® UltraShield and LIQUID BOOT® UltraDrain: Use LIQUID BOOT® UltraGrip.

H. Gas vapor vent piping- LIQUID BOOT® GeoVent system

I. Base Geotextile- LIQUID BOOT® BaseFabric T-40 non-woven geotextile, unless otherwise specified and approved by membrane manufacturer. The
heat-rolled side shall be used as the application surface. Some projects may require a heavier geotextile (LIQUID BOOT® BaseFarbic T-60.)

J. Cold Joints, Cracks, Form Tie Holes: Covered with Hardcast CRT 1602 Tape 3" wide.

PART 3 - EXECUTION

3.01 EXAMINATION- All surfaces to receive gas vapor barrier shall be inspected and approved by the applicator at least one day prior to commencing
work.

3.02 SURFACE PREPARATION- Provide 24 inch minimum clearance out from surfaces to receive the gas vapor barrier. The application surface shall be
prepared and provided to the applicator in accordance with manufacturer’s specifications listed below:

A. Concrete/Shotcrete/Masonry- Concrete surfaces shall be light broom finish or smoother, free of any dirt, debris, loose material, release agents or
curing compounds. Fill all voids more than 1/4 inch deep and 1/4 inch wide. Masonry joints, cold joints, and form joints shall be struck smooth. All
penetrations shall be prepared in accordance with manufacturer’s specifications. Provide a 3/4 inch minimum cant of LIQUID BOOT®, or other
suitable material as approved by manufacturer, at all horizontal to vertical transitions and other inside corners of 120° or less. Allow to cure overnight
before the application of LIQUID BOOT®. All cracks or cold joints greater than 1/16 inch must be completely grouted with non-shrink grout as
approved by engineer. Install Hardcast reinforcing tape over all cold joints, cracks and form tie holes (after holes and cracks are grouted).

B. Dirt & Gravel- The sub-grade shall be moisture conditioned and compacted to a minimum relative compaction of 90 percent or as specified by
civil/geotechnical engineer. The finished surface shall be smooth, uniform, free of debris and standing water. Remove all stones or dirt clods greater
than 1/4 inch. (NOTE: Aggregate sub-bases shall be rolled flat, free from any protruding sharp edges). Penetrations shall be prepared in accordance
with manufacturer’s specifications. All form stakes that penetrate the membrane shall be of rebar which shall be bent over and left in the slab.
Trenches shall be cut oversize to accommodate gas vapor barrier membrane and protection course with perpendicular to sloped sides and maximum
obtainable compaction. Adjoining grade shall be finish graded and compacted. Excavated walls shall be vertical or sloped back, free of roots and
protruding rocks. Specific sub-grade preparation shall be designed by a qualified civil or geotechnical engineer. If organic materials with potential for
growth (ie: seeds or grasses) exist within the sub-base, spray apply soil sterilant at the sterilant manufacturer's recommended rate.
LIQUID BOOT® GVB, version 4.0 4 © 2007 CETCO Liquid Boot Company
3.03 INSTALLATION

3.03.10 INSTALLATION ON CONCRETE/SHOTCRETE/MASONRY (Follow the procedures below carefully)

A. Refer to section 3.03.30, "Sealing Around Penetrations", for procedures to seal around penetrations.

B. Provide a ¾” minimum cant of LIQUID BOOT®, or other suitable material as approved by manufacturer, at all horizontal to vertical transitions and
other inside corners of 120° or less. Allow to cure overnight before the application of LIQUID BOOT®.

C Delineate a test area on site with a minimum dimension of 10 feet by 10 feet (3m by 3m). Apply LIQUID BOOT® to a thickness of 60 mils and let it
cure for 24 hours. Observe for blisters. If minor or no blistering occurs, proceed to the next step. (See note regarding blisters). If significant
blistering does occur, apply a thin (10 mil) tack coat of LIQUID BOOT® “A” side without catalyst to the entire concrete surface and allow to cure
before proceeding. (See also information regarding blister repair).

D. Spray apply LIQUID BOOT® to a 60 mil minimum dry thickness. Increase thickness to 100 dry mils if shotcrete is to be applied directly to membrane.
If a second coat is required, remove any standing water from the membrane before proceeding with the second application.

E. Do not penetrate membrane. Keep membrane free of dirt and debris and traffic until a protective cover is in place. It is the responsibility of the
General Contractor to insure that the membrane and the protection system are not penetrated.

F. After membrane has cured and checked for proper thickness and flaws, install protection material pursuant to manufacturer’s instructions.
NOTE: All testing or inspection to be performed prior to placing protection course.

NON-HORIZONTAL SURFACES: Spray on non-horizontal surfaces should begin at the bottom and work towards the top. This method allows the
product to adhere to the surface before hitting catalyst runoff.

NOTE: Due to the nature of concrete as a substrate, it is normal for some blistering to occur. This is caused by either concrete's tendency
to off-gas or water that is temporarily trapped between the concrete and the membrane. With time and the applied pressure of backfill or
over-slab, blisters will absorb into the concrete without detriment to the membrane. A small number of blister heads should be sampled
and checked for proper membrane thickness. If the samples have the minimum required membrane thickness, then the remaining blisters
should not be punctured or cut. If the samples have less than the minimum required membrane thickness, then the area can either be re-
sprayed to obtain the proper thickness, or the blisters can be cut out and the area re-sprayed or patched with LIQUID BOOT® Trowel
Grade.

3.03.20 INSTALLATION ON DIRT SURFACES AND MUDSLABS

A. Roll out LIQUID BOOT® BaseFabric geotextile on sub-grade with the heat-rolled side facing up. Overlap seams a minimum of 6 inches. Lay
geotextile tight at all inside corners. Apply a thin 10 mil tack coat of LIQUID BOOT® “A” side without catalyst within the seam overlap. Line trenches
with geotextile extending at least six inches (6") onto adjoining sub-grade if slab and footings are to be sprayed separately. Overlap seams a
minimum of 6 inches. Lay geotextile tight at all inside corners. Apply a thin 10 mil tack coat of LIQUID BOOT® “A” side without catalyst within the
seam overlap.

B. Minimize the use of nails to secure the geotextile to the dirt subgrade. Remove all nails before spraying membrane, if possible. Nails that cannot be
removed from the dirt subgrade are to be patched with geotextile or Hardcast reinforcing tape overlapping the nail head by a minimum of two inches
(2"). Apply a thin tack coat of LIQUID BOOT® under the geotextile patch, when patching with geotextile.

C. Refer to section 3.03.30, "Sealing Around Penetrations", for procedures to seal around penetrations.

D. Spray apply LIQUID BOOT® onto geotextile to a 60 mil minimum dry thickness. Increase thickness to 100 dry mils if shotcrete is to be applied
directly to membrane. If a second coat is required, remove any standing water from the membrane before proceeding with the second application.

E. Do not penetrate membrane. Keep membrane free of dirt, debris and traffic until a protective cover is in place. It is the responsibility of the General
Contractor to insure that the membrane and the protection system are not penetrated.

F. After membrane has cured and checked for proper thickness and flaws, install protection material pursuant to manufacturer’s instructions.
NOTE: All testing or inspection to be performed prior to placing protection course.

3.03.30 SEALING AROUND PENETRATIONS

3.03.31 OPTION 1

A. Clean all penetrations. All metal penetrations shall be sanded clean with emery cloth.

B. For applications requiring LIQUID BOOT® BaseFabric geotextile, roll out geotextile on sub-grade with the heat-rolled side facing up, overlapping
seams a minimum of six inches (6"). Cut the geotextile around penetrations so that it lays flat on the sub-grade. Lay geotextile tight at all inside
corners. Apply a thin (10 mil) tack coat of LIQUID BOOT® “A” side without catalyst within the seam overlap.

LIQUID BOOT® GVB, version 4.0 5 © 2007 CETCO Liquid Boot Company
C. At the base of penetration Install a minimum ¾ inch thick membrane cant of LIQUID BOOT®, or other suitable material as approved by manufacturer.
Extend the membrane at a 60 mil thickness three inches (3") around the base of penetration and up the penetration a minimum of three inches (3").
Allow to cure overnight before the application of LIQUID BOOT® membrane. (See attached manufacturer’s standard detail.)

D. Spray apply LIQUID BOOT® to an 60 mils minimum dry thickness around the penetration, completely encapsulating the collar assembly and to a
height of one and one half inches (1 1/2") minimum above the membrane as described in 3.03.31 C above. Spray apply LIQUID BOOT® to
surrounding areas as specified for the particular application. (SEE MANUFACTURER’S STANDARD DETAIL)

E. Allow LIQUID BOOT® to cure completely before proceeding to step "F".

F. Wrap penetration with polypropylene cable tie at a point two inches (2") above the base of the penetration. Tighten the cable tie firmly so as to
squeeze, but not cut, the cured membrane collar.

3.03.32 OPTION 2 (For Gas Vapor Membrane Only)

A. Clean all penetrations. All metal penetrations shall be sanded clean with emery cloth.

B. For applications requiring LIQUID BOOT® BaseFabric geotextile, roll out geotextile on sub-grade with the heat-rolled side facing up, overlapping
seams a minimum of six inches (6"). Cut the geotextile around penetrations so that it lays flat on the sub-grade. Lay geotextile tight at all inside
corners. Apply a thin (10 mil) tack coat of LIQUID BOOT® “A” side without catalyst within the seam overlap.

C. Spray-apply LIQUID BOOT® to surrounding areas as specified for the particular application to a 60 mil minimum dry thickness. At the base of
penetration Install a minimum 3/4 inch thick membrane cant of LIQUID BOOT®, or other suitable material as approved by manufacturer. Extend the
membrane at 60 mil thickness up the penetration a minimum of three inches (3"). Allow to cure overnight before proceeding to D (SEE
MANUFACTURER’S STANDARD DETAIL)

D. Spray apply LIQUID BOOT® the membrane at an 60 mil thickness three inches (3") around the base of penetration and up the penetration,
completely encapsulating the collar assembly, to a height of one and one half inches (1 1/2") minimum above the membrane as described in 3.03.32
C above. (SEE ATTACHED MANUFACTURER’S STANDARD DETAIL)

E. Allow LIQUID BOOT® to cure completely before proceeding to step "F".

F. Wrap penetration with polypropylene cable tie at a point two inches (2") above the base of the penetration. Tighten the cable tie firmly so as to
squeeze, but not cut, the cured membrane collar.

3.04 FIELD QUALITY CONTROL- Field Quality Control is a very important part of all LIQUID BOOT® applications. Applicators should check
their own work for coverage, thickness, and all around good workmanship before calling for inspections.

The membrane must be cured at least overnight before inspecting for dry-thickness, holes, shadow shrinkage, and any other membrane damage. If
water testing is to be performed, allow the membrane to cure at least 72 hours prior to the water test. When thickness or integrity is in question the
membrane should be tested in the proper manner as described below. However, over-sampling defeats the intent of inspections. Inspectors should
always use visual and tactile measurement to guide them. Areas suspected of being too thin to the touch should be measured with the gauges to
determine the exact thickness. With practice and by comparing tactile measurements with those of the gauges, fingers become very accurate tools.

3.04.10 ON CONCRETE/SHOTCRETE/MASONRY & OTHER HARD SURFACES

A. Membrane may be checked for proper thickness with a blunt-nose depth gauge, taking one reading every 500 square feet. Record the readings.
Mark the test area for repair, if necessary.

B. If necessary, test areas are to be patched over with LIQUID BOOT® to a 60 mils minimum dry thickness, extending a minimum of one inch (1")
beyond the test perimeter.

3.04.20 ON DIRT AND OTHER SOFT SUBSTRATES

A. Samples may be cut from the membrane and geotextile sandwich to a maximum area of 2 square inches. Measure the thickness with a mil-reading
caliper, per 500 sq. feet. Deduct the plain geotextile thickness to determine the thickness of LIQUID BOOT® membrane. Mark the test area for repair.

B. Voids left by sampling are to be patched with geotextile overlapping the void by a minimum of two inches (2"). Apply a thin tack coat of LIQUID
BOOT® under the geotextile patch. Then spray or trowel apply LIQUID BOOT® to a 60 mils minimum dry thickness, extending at least three inches
(3") beyond geotextile patch.

3.04.30 SMOKE TESTING FOR HOLES (Optional) - Holes or other breaches in the membrane can be detected by conducting a smoke test. This involves
pumping smoke under the membrane for a specified period of time, under a specified pressure, which varies from project to project. Contact CLB for
information about this test at 714-384-0111.
LIQUID BOOT® Brownfield Membrane/Liner
Standard Details

www.liquidboot.com
G1 BELOW GRADE WALLS

G 1.1 Zero Lot Line with Lagging
G 1.2 Membrane Lap Joints on Solid Substrate
G 1.3 Membrane Lap Joints on Geotextile

G2 BELOW GRADE UNDER SLAB

G 2.1 Under Slab and Walls
G 2.2 Under Slab and Walls
G 2.3 Footings and Grade Beams
G 2.4 Mudslabs
G 2.5 Membrane Lap Joints on Solid Substrate
G 2.6 Membrane Lap Joints on Geotextile
G 2.7 Pile Caps
G 2.8 Over Footings and Grade Beams

G3 BETWEEN SLAB

G 3.1 Between Slabs and Concrete Cold Joints
G 3.2 Membrane Lap Joints on Solid Substrate
G 3.3 Membrane Lap Joints on Geotextile

G4 PENETRATIONS

G 4.1 Penetrations with Solid Substrate
G 4.2 Penetrations with Solid Substrate (Option 2)
G 4.3 Penetrations on Earth or Gravel Subgrade (Option 1)
G 4.4 Penetrations on Earth or Gravel Subgrade (Option 2)
G 4.5 Soil Nails
G 4.6 Membrane Lap Joints on Solid Substrate

CETCO Liquid Boot Company • 1001 S. Linwood Ave. • Santa Ana, CA 92705 • Ph: 714-384-0111 • Fax: [phone] • www.liquidboot.com

LIQUID BOOT® GeoVent, version 1.3 1 © 2007 CETCO Liquid Boot Company

LIQUID BOOT® GeoVent Trenchless Gas Collection System
VERSION 1.2

These Specifications may have changed. Please contact CETCO Liquid Boot Company at 714.384.0111 for the most recent version.

PART 1: GENERAL

1.1 SUMMARY OF WORK- Work related to the Soil Venting System includes providing soil vapor extraction piping and LIQUID BOOT® Geovent
beneath the LIQUID BOOT® gas vapor membrane.

PART 2: PRODUCTS

2.1 MATERIALS

A. LIQUID BOOT® Geovent is a composite low profile pressure relief, collection and venting system (PRCVS) consisting of a 3-dimensional vent core
and wrapped with a non-woven needle punched filter fabric. This product meets the following specifications:

B. Trenchless Gas Collection System properties:

TEST METHOD TYPE OF TEST MINIMUM VALUE
ASTM D-1621 Compressive Strength 7500 psf
ASTM D-1777 Thickness 1.0 in.
ASTM D-4716 Core Flow 30 g/min/ft. width
ASTM D-4833 Puncture Strength 65 lbs.
ASTM D-4751 Apparent Opening Size (AOS) 70 US Sieve
ASTM D-4632 Grab Tensile Strength 100 lbs.
ASTM D-4632 Grab Tensile Elongation 50%
ASTM D-4533 Trapezoid Tear Strength 45 lbs.
ASTM D-4491 Permittivity 1.9 secֿ¹
ASTM D-4491 Permeability 0.21 cm/sec
ASTM D-4491 Flow Rate 140 gal. min. ft.²
ASTM D-4355 UV Resistance @500 hours 70%
ASTM D-3786 Mullen Burst Strength 210 psi
ASTM D-5261 Mass Unit Area 4.0 oz/yd²

C. LIQUID BOOT® Geovent end outlet

D. LIQUID BOOT® Geovent Interior Footing Sleeves
E. LIQUID BOOT® Geovent Fabric Reinforced Tape

PART 3: EXECUTION

3.1 INSTALLATION

A. Roll out LIQUID BOOT® Geovent per layout design as specified by Engineer.

B. Use prefabricated LIQUID BOOT® Geovent Sleeves where venting is to penetrate interior footings. See the detail describing LIQUID BOOT®
Geovent through footings.

C. At points of intersection, cut away geotextile to produce rectangular flaps. Interlock exposed dimple board in a Lego-like fashion. Fold flaps of
geotextile in a manner so that the dimple board is covered completely. Secure geotextile folds with LIQUID BOOT® Fiber Reinforced Tape so that
the geotextile is completely impermeable to sand fill.

D. Use LIQUID BOOT® Geovent End Outlet to attach to solid (imperforated) 2 inch diameter PVC pipe at penetration through building foundation. Seal/
grout piping at penetrations through foundation using approved methods. See the detail describing connection to a vent riser.

™Geo-Seal
Advanced Vapor Management Technology
www.landsciencetech.com
™Geo-SealGeo-Seal™ is an advanced composite gas vapor management technology (patent pending) designed to eliminate potential indoor air quality health risks associated with subsurface contaminant vapor intrusion. Geo-Seal is an ideal gas vapor management technology designed for use on Brownfi elds or any type of environmentally impaired site, i.e. manufacturing facilities, dry cleaners, gasoline service stations, landfi lls, etc. Geo-Seal is placed between the foundation of the building and the soil pad to eliminate vapor exposure pathways and stop contaminated vapors from permeating through the slab. Vapor management systems incorporating both Geo-Seal vapor barrier and Vapor-Vent ventilation provide industry leading sub-foundation vapor mitigation technology. By deploying these systems developers ensure a
healthy indoor environment while reducing the cost of site remediation
and expediting site construction.
Triple-Layer Protection
The triple-layer system used in Geo-Seal provides maximum
redundancy and protection against the formation of vapor pathways
both during and after installation. Such pathways can result from
chemically induced materials breakdown, punctures, and seam
weaknesses resulting from poor detail work and/or application
installation imperfections around penetrations. Geo-Seal also provides
unmatched protection from a range of contaminant vapors including
those from petroleum-based products and chlorinated hydrocarbons.
Field-Proven Technology
Geo-Seal is manufactured in partnership with E-Pro™ Systems which
has over 20 years experience in the building products industry and a
leading track record in barrier systems for vapor and waterproofi ng
applications.
Land Science Technologies
1011 Calle Sombra
Suite 110
San Clemente, CA 92673
Ph. 949-366-8000
Fax. [phone]
www.landsciencetech.com
Dual Chemical Resistant LayersThe BASE layer (bottom) and the BOND layer (top) are composed of a high-density polyethylene material bonded to a geo-textile on the out-facing side. High density polyethylene is known for chemical resistance, high tensile strength, excellent stress-crack resistance and for highly reliable subsurface containment. The geo-textile which is physically bonded to the chemical resistant layer accomplishes two goals; it allows the BOND layer to adhere to slab, and provides a friction course between the BASE layer and the soil. Spray Applied CORE Layer
The CORE layer is composed of a unique, elastic
co-polymer modifi ed asphaltic membrane which
also provides additional protection against vapor
transmission. This layer creates a highly-effective seal
around slab penetrations and eliminates the need for
mechanical fastening at termination points.
Chemical Resistance
The dual chemical resistant layers combined with
the spray CORE form a barrier resistant to the most
concentrated chemical pollutant vapors.
Enhanced Curing
Geo-Seal is “construction friendly” as the reduced
curing time of the Geo-Seal CORE layer and the
ability to apply it in cooler temperatures ensures quick
installation and minimizes the impact on construction
schedules.
Puncture ResistanceGeo-Seal forms a highly puncture resistant barrier that greatly reduces the chance of damage occurring after installation and prior to the placement of concrete.Removing Contained VaporsVapor-Vent can be used in conjunction with Geo-Seal to alleviate the buildup of vapors beneath structures as a result of vapor barrier implementation. Vapor-Vent can be utilized as an active or passive ventilation system depending on the requirements of the design engineer.
Certifi ed Applicator Network
The application of Geo-Seal and Vapor-Vent can be
performed by any one of many certifi ed applicators
throughout the country.
Service and Support
Geo-Seal representatives are available to provide job
and site specifi c assistance. A local representative can
ensure Geo-Seal and Vapor-Vent is installed as per the
specifi cation.
Geo-Seal™ Triple-Layer System (2 Chemical Resistant Layers + 1 Spray Applied Core Layer)321
1
2
3Land Science Technologies (LST) ™ is dedicated to providing advanced technologies for sustainable land development. A goal of LST is to provide innovative and technically sound development solutions for underutilized environmentally impaired properties, commonly referred to as Brownfi elds.
LST’s cost-effective, industry leading technologies
offer engineering fi rms and real estate developers
solutions to issues facing the development of
Brownfi elds today. LST is a division of
Regenesis, Inc., a global leader in groundwater
and soil remediation technologies since 1994.
™Geo-Seal
www.regenesis.com
3.5625 in
™Geo-Seal 4
4
Geo-Seal CORE is the spray-applied, middle layer of the Geo-Seal barrier that ensures proper sealing of potential vapor pathways. Problematic pipe penetrations and effective seals at termination points are easily detailed and sealed with the utilization of the CORE Layer.Geo-Seal BOND is the proprietary top layer that
completes the triple layered
Geo-Seal barrier.
The BOND layer
serves two purposes;
it helps protect the
system from getting
punctured
after
installation
and provides
the fi nal layer
of chemical
resistance.
Vapor-Vent:
•When used with Geo-Seal
provides maximum protection
against contaminated vapor
•Eliminates the need for trenching
•Cost-effective compared to pipe and
gravel systems
•Eliminates long-term costs when confi gured
as a passive system
•Allows for rapid installation
Application DiagramDiagram LabelsGeo-Seal BASE is the foundational, chemical resistant, bottom layer that is rolled out onto the exposed soil surface. This layer is applied with a geo-textile side facing down to provide greater friction with the soil surface. The Geo-Seal BASE Layer is a high-quality substrate and enables the second, spray-applied CORE Layer to be free of shadowing and pinholes.
™Geo-Seal
Advanced Vapor Management Technology
www.landsciencetech.com
™Geo-SealGeo-Seal™ is an advanced composite gas vapor management technology (patent pending) designed to eliminate potential indoor air quality health risks associated with subsurface contaminant vapor intrusion. Geo-Seal is an ideal gas vapor management technology designed for use on Brownfi elds or any type of environmentally impaired site, i.e. manufacturing facilities, dry cleaners, gasoline service stations, landfi lls, etc. Geo-Seal is placed between the foundation of the building and the soil pad to eliminate vapor exposure pathways and stop contaminated vapors from permeating through the slab. Vapor management systems incorporating both Geo-Seal vapor barrier and Vapor-Vent ventilation provide industry leading sub-foundation vapor mitigation technology. By deploying these systems developers ensure a healthy indoor environment while reducing the cost of site remediation and expediting site construction. Triple-Layer Protection The triple-layer system used in Geo-Seal provides maximum
redundancy and protection against the formation of vapor pathways
both during and after installation. Such pathways can result from
chemically induced materials breakdown, punctures, and seam
weaknesses resulting from poor detail work and/or application
installation imperfections around penetrations. Geo-Seal also provides
unmatched protection from a range of contaminant vapors including
those from petroleum-based products and chlorinated hydrocarbons.
Field-Proven Technology
Geo-Seal is manufactured in partnership with E-Pro™ Systems which
has over 20 years experience in the building products industry and a
leading track record in barrier systems for vapor and waterproofi ng
applications.
Land Science Technologies
1011 Calle Sombra
Suite 110
San Clemente, CA 92673
Ph. 949-366-8000
Fax. [phone]
www.landsciencetech.com
Dual Chemical Resistant LayersThe BASE layer (bottom) and the BOND layer (top) are composed of a high-density polyethylene material bonded to a geo-textile on the out-facing side. High density polyethylene is known for chemical resistance, high tensile strength, excellent stress-crack resistance and for highly reliable subsurface containment. The geo-textile which is physically bonded to the chemical resistant layer accomplishes two goals; it allows the BOND layer to adhere to slab, and provides a friction course between the BASE layer and the soil. Spray Applied CORE Layer
The CORE layer is composed of a unique, elastic
co-polymer modifi ed asphaltic membrane which
also provides additional protection against vapor
transmission. This layer creates a highly-effective seal
around slab penetrations and eliminates the need for
mechanical fastening at termination points.
Chemical Resistance
The dual chemical resistant layers combined with
the spray CORE form a barrier resistant to the most
concentrated chemical pollutant vapors.
Enhanced Curing
Geo-Seal is “construction friendly” as the reduced
curing time of the Geo-Seal CORE layer and the
ability to apply it in cooler temperatures ensures quick
installation and minimizes the impact on construction
schedules.
Puncture ResistanceGeo-Seal forms a highly puncture resistant barrier that greatly reduces the chance of damage occurring after installation and prior to the placement of concrete.Removing Contained VaporsVapor-Vent can be used in conjunction with Geo-Seal to alleviate the buildup of vapors beneath structures as a result of vapor barrier implementation. Vapor-Vent can be utilized as an active or passive ventilation system depending on the requirements of the design engineer.
Certifi ed Applicator Network
The application of Geo-Seal and Vapor-Vent can be
performed by any one of many certifi ed applicators
throughout the country.
Service and Support
Geo-Seal representatives are available to provide job
and site specifi c assistance. A local representative can
ensure Geo-Seal and Vapor-Vent is installed as per the
specifi cation.
Geo-Seal™ Triple-Layer System (2 Chemical Resistant Layers + 1 Spray Applied Core Layer)321
1
2
3Land Science Technologies (LST) ™ is dedicated to providing advanced technologies for sustainable land development. A goal of LST is to provide innovative and technically sound development solutions for underutilized environmentally impaired properties, commonly referred to as Brownfi elds.
LST’s cost-effective, industry leading technologies
offer engineering fi rms and real estate developers
solutions to issues facing the development of
Brownfi elds today. LST is a division of
Regenesis, Inc., a global leader in groundwater
and soil remediation technologies since 1994.
™Geo-Seal
www.regenesis.com
3.5625 in
™Geo-Seal 4
4
Geo-Seal CORE is the spray-applied, middle layer of the Geo-Seal barrier that ensures proper sealing of potential vapor pathways. Problematic pipe penetrations and effective seals at termination points are easily detailed and sealed with the utilization of the CORE Layer.Geo-Seal BOND is the proprietary top layer that
completes the triple layered
Geo-Seal barrier.
The BOND layer
serves two purposes;
it helps protect the
system from getting
punctured
after
installation
and provides
the fi nal layer
of chemical
resistance.
Vapor-Vent:
•When used with Geo-Seal
provides maximum protection
against contaminated vapor
•Eliminates the need for trenching
•Cost-effective compared to pipe and
gravel systems
•Eliminates long-term costs when confi gured
as a passive system
•Allows for rapid installation
Application DiagramDiagram LabelsGeo-Seal BASE is the foundational, chemical resistant, bottom layer that is rolled out onto the exposed soil surface. This layer is applied with a geo-textile side facing down to provide greater friction with the soil surface. The Geo-Seal BASE Layer is a high-quality substrate and enables the second, spray-applied CORE Layer to be free of shadowing and pinholes.
Dual Chemical Resistant LayersThe BASE layer (bottom) and the BOND layer (top) are composed of a high-density polyethylene material bonded to a geo-textile on the out-facing side. High density polyethylene is known for chemical resistance, high tensile strength, excellent stress-crack resistance and for highly reliable subsurface containment. The geo-textile which is physically bonded to the chemical resistant layer accomplishes two goals; it allows the BOND layer to adhere to slab, and provides a friction course between the BASE layer and the soil. Spray Applied CORE Layer
The CORE layer is composed of a unique, elastic
co-polymer modifi ed asphaltic membrane which
also provides additional protection against vapor
transmission. This layer creates a highly-effective seal
around slab penetrations and eliminates the need for
mechanical fastening at termination points.
Chemical Resistance
The dual chemical resistant layers combined with
the spray CORE form a barrier resistant to the most
concentrated chemical pollutant vapors.
Enhanced Curing
Geo-Seal is “construction friendly” as the reduced
curing time of the Geo-Seal CORE layer and the
ability to apply it in cooler temperatures ensures quick
installation and minimizes the impact on construction
schedules.
Puncture ResistanceGeo-Seal forms a highly puncture resistant barrier that greatly reduces the chance of damage occurring after installation and prior to the placement of concrete.Removing Contained VaporsVapor-Vent can be used in conjunction with Geo-Seal to alleviate the buildup of vapors beneath structures as a result of vapor barrier implementation. Vapor-Vent can be utilized as an active or passive ventilation system depending on the requirements of the design engineer.
Certifi ed Applicator Network
The application of Geo-Seal and Vapor-Vent can be
performed by any one of many certifi ed applicators
throughout the country.
Service and Support
Geo-Seal representatives are available to provide job
and site specifi c assistance. A local representative can
ensure Geo-Seal and Vapor-Vent is installed as per the
specifi cation.
Geo-Seal™ Triple-Layer System (2 Chemical Resistant Layers + 1 Spray Applied Core Layer)321
1
2
3Land Science Technologies (LST) ™ is dedicated to providing advanced technologies for sustainable land development. A goal of LST is to provide innovative and technically sound development solutions for underutilized environmentally impaired properties, commonly referred to as Brownfi elds.
LST’s cost-effective, industry leading technologies
offer engineering fi rms and real estate developers
solutions to issues facing the development of
Brownfi elds today. LST is a division of
Regenesis, Inc., a global leader in groundwater
and soil remediation technologies since 1994.
™Geo-Seal
www.regenesis.com
3.5625 in
™Geo-Seal 4
4
Geo-Seal CORE is the spray-applied, middle layer of the Geo-Seal barrier that ensures proper sealing of potential vapor pathways. Problematic pipe penetrations and effective seals at termination points are easily detailed and sealed with the utilization of the CORE Layer.Geo-Seal BOND is the proprietary top layer that
completes the triple layered
Geo-Seal barrier.
The BOND layer
serves two purposes;
it helps protect the
system from getting
punctured
after
installation
and provides
the fi nal layer
of chemical
resistance.
Vapor-Vent:
•When used with Geo-Seal
provides maximum protection
against contaminated vapor
•Eliminates the need for trenching
•Cost-effective compared to pipe and
gravel systems
•Eliminates long-term costs when confi gured
as a passive system
•Allows for rapid installation
Application DiagramDiagram LabelsGeo-Seal BASE is the foundational, chemical resistant, bottom layer that is rolled out onto the exposed soil surface. This layer is applied with a geo-textile side facing down to provide greater friction with the soil surface. The Geo-Seal BASE Layer is a high-quality substrate and enables the second, spray-applied CORE Layer to be free of shadowing and pinholes.
™Geo-SealAdvanced Vapor Management Technology
www.landsciencetech.com
™Geo-SealGeo-Seal™ is an advanced composite gas vapor management technology (patent pending) designed to eliminate potential indoor air quality health risks associated with subsurface contaminant vapor intrusion. Geo-Seal is an ideal gas vapor management technology designed for use on Brownfi elds or any type of environmentally impaired site, i.e. manufacturing facilities, dry cleaners, gasoline service stations, landfi lls, etc. Geo-Seal is placed between the foundation of the building and the soil pad to eliminate vapor exposure pathways and stop contaminated vapors from permeating through the slab. Vapor management systems incorporating both Geo-Seal vapor barrier and Vapor-Vent ventilation provide industry leading sub-foundation vapor mitigation technology. By deploying these systems developers ensure a healthy indoor environment while reducing the cost of site remediation and expediting site construction. Triple-Layer Protection The triple-layer system used in Geo-Seal provides maximum redundancy and protection against the formation of vapor pathways both during and after installation. Such pathways can result from chemically induced materials breakdown, punctures, and seam weaknesses resulting from poor detail work and/or application installation imperfections around penetrations. Geo-Seal also provides unmatched protection from a range of contaminant vapors including those from petroleum-based products and chlorinated hydrocarbons.Field-Proven TechnologyGeo-Seal is manufactured in partnership with E-Pro™ Systems which
has over 20 years experience in the building products industry and a
leading track record in barrier systems for vapor and waterproofi ng
applications.
Land Science Technologies
1011 Calle Sombra
Suite 110
San Clemente, CA 92673
Ph. 949-366-8000
Fax. [phone]
www.landsciencetech.com
Geo-Seal Gas Vapor Barrier
Section 2
Version 1.07

PART 1 – GENERAL

1.1 RELATED DOCUMENTS

A. Drawings and general provisions of the Contract, including General and Supplementary
Conditions and Division 1 Specification Sections, apply to this Section.

1.2 SUMMARY

A. This Section includes the following:

1. Substrate preparation.
2. Gas Vapor Barrier components.
3. Seam Sealer and accessories.

B. Related Sections: The following Sections contain requirements that relate to this Section:

1. Division 2 Section “Earthwork”, “Pipe Materials”, “Sub-drainage systems”.
2. Division 3 Section “Cast-in-Place Concrete” for concrete placement, curing, and
finishing.
3. Division 5 Section “Expansion Joint Cover Assemblies”, for expansion-joint covers
assemblies and installation.

1.3 PERFORMANCE REQUIREMENTS

A. General: Provide a gas vapor barrier system that prevents the passage of methane gas
and volatile organic compounds vapors and complies with physical requirements as
demonstrated by testing performed by an independent testing agency of manufacturer’s
current gas vapor barrier formulations and system design.

1.4 SUBMITTALS

A. Submit Product Data for each type of gas vapor barrier, including manufacturer’s printed
instructions for evaluating and preparing the substrate, technical data, and tested physical
and performance properties.

B. Project Data - Submit Shop Drawings showing extent of gas vapor barrier, including details
for overlaps, flashing, penetrations, and other termination conditions.

C. Samples – Submit representative samples of the following for approval:

1. Gas vapor barrier components.

D. Installer Certificates – Submit certificates signed by manufacturer certifying that Installers
comply with requirements under the “Quality Assurance” Article.

1.5 QUALITY ASSURANCE

A. Installer Qualifications: Engage an experienced Installer who has been trained and
certified in writing by gas vapor barrier manufacturer EPRO Services, Inc. for the
installation of the Geo-Seal System.

B. Manufacturer Qualification: Obtain gas vapor barrier materials and system components
from a single manufacturer EPRO Services, Inc.

C. Field Sample: Apply gas vapor barrier system field sample to 100 sq./ft. (9.3 sq./m.) of field
area demonstrate application, detailing, thickness, texture, and standard of workmanship.

1. Notify engineer or special inspector one week in advance of the dates and times when
field sample will be prepared.
2. If engineer or special inspector determines that field sample, does not meet
requirements, reapply field sample until field sample is approved.
3. Retain and maintain approved field sample during construction in an undisturbed
condition as a standard for judging the completed methane barrier and waterproofing.
An undamaged field sample may become part of the completed Work.

D. Pre-installation Conference: A pre-installation conference shall be held prior to application
of the gas vapor barrier system to assure proper site and installation conditions, to include
contractor, applicator, architect/engineer, other trades influenced by gas vapor barrier
installation and special inspector (if any).

1.6 DELIVERY, STORAGE, AND HANDLING

A. Deliver materials to Project site as specified by manufacturer labeled with manufacturer’s
name, product brand name and type, date of manufacture, shelf life, and directions for
storing and mixing with other components.

B. Store materials as specified by the manufacturer in a clean, dry, protected location and
within the temperature range required by manufacturer. Protect stored materials from
direct sunlight. If freezing temperatures are expected, necessary steps should be taken to
prevent the freezing of the Geo-Seal CORE component.

C. Remove and replace material that cannot be applied within its stated shelf life.

1.7 PROJECT CONDITIONS

A. Protect all adjacent areas not to be installed on. Where necessary, apply masking to
prevent staining of surfaces to remain exposed wherever membrane abuts to other finish
surfaces.

B. Perform work only when existing and forecasted weather conditions are within
manufacturer’s recommendations for the material and application method used.

C. Minimum clearance of 24 inches is required for application of product. For areas with less
than 24-inch clearance, the membrane may be applied by hand using Geo-Seal DETAIL.

D. Ambient temperature shall be within manufacturer’s specifications. (Greater than
+45ºF/+7ºC.) Consult manufacturer when desiring to apply Geo-Seal CORE below
45ºF/7ºC.

E. All plumbing, electrical, mechanical and structural items to be under or passing through the
waterproof membrane shall be positively secured in their proper positions and
appropriately protected prior to membrane application.

F. Gas vapor barrier shall be installed before placement of fill material and reinforcing steel.
When not possible, all exposed reinforcing steel shall be masked by General Contractor
prior to membrane application.

G. Stakes used to secure the concrete forms shall not penetrate the membrane after it has
been installed. If stakes need to puncture the membrane after it has been installed, the
necessary repairs need to be made by the certified Geo-Seal applicator. To confirm the
staking procedure is in agreement with the manufactures recommendation, contact
manufacturer.

1.8 WARRANTY

A. General Warranty: The special warranty specified in this Article shall not deprive the
Owner of other rights the Owner may have under other provisions of the Contract
Documents, and shall be in addition to, and run concurrent with, other warranties made by
the Contractor under requirements of the Contract Documents.

B. Special Warranty: Submit a written warranty signed by gas vapor barrier manufacturer and
installer agreeing to repair or replace gas vapor barrier that does not meet requirements or
that does not remain methane gas or volatile organic compound vapor tight within the
specified warranty period. Warranty does not include failure of gas vapor barrier due to
failure of substrate prepared and treated according to requirements or formation of new
joints and cracks in the attached to structures that exceed 1/16 inch (1.6 mm) in width.

1. Warranty Period: 1 year after date of Substantial Completion. Longer warranty periods
are available upon request and when expressed in writing by the manufacturer.

PART 2 – PRODUCTS

2.1 MANUFACTURERS

A. Geo-Seal; EPRO Services, Inc., Wichita, KS, 800-882-1896

1. Geo-Seal BASE sheet layer
2. Geo-Seal CORE spray layer
3. Geo-Seal BOND protection layer

2.2 GAS VAPOR BARRIER MATERIALS

A. Fluid applied methane barrier/waterproofing system – Geo-Seal CORE; a single course,
high build, polymer modified, asphalt emulsion. Waterborne and spray applied at ambient
temperatures. A nominal thickness of 60 dry mils, unless specified otherwise. Non-toxic
and odorless. Geo-Seal DETAIL has similar properties with greater viscosity and is roller
or brush applied. Manufactured by EPRO Services, Inc.

B. Fluid applied gas vapor barrier physical properties.

Geo-Seal CORE – TYPICAL CURED PROPERTIES (MEMBRANE ONLY)

Tensile Strength ASTM 412 32 psi
Elongation ASTM 412 4140%
Resistance to Decay ASTM E 154 Section 13 4% Perm Loss
Accelerated Aging ASTM G 23 No Effect
Moisture Vapor Transmission ASTM E 96 .026 g/sq. ft. /hr.
Hydrostatic Water Pressure ASTM D 751 26 psi
Perm rating ASTM E 96 (US Perms)0.21
Methane transmission rate ASTM D 1434 0
Adhesion to Concrete & Masonry ASTM C 836 & ASTM C 704 11 lbf./inch
Hardness ASTM C 836 80
Crack Bridging ASTM C 836 No Cracking
Low Temp. Flexibility ASTM C 836-00 No Cracking at –20ºC
Resistance to Acids:
Acetic 30%
Sulfuric and Hydrochloric 13%
Temperature Effect:
Stable 248ºF
Flexible 13ºF

Geo-Seal CORE DETAIL – TYPICAL CURED PROPERTIES

Resistance to Decay ASTM E 154 Section 13 9% Perm Loss
Accelerated Aging ASTM G 23 No Effect
Moisture Vapor Transmission ASTM E 96 .026 g/sq. ft. /hr.
Hydrostatic Water Pressure ASTM D 751 28 psi
Perm rating (US Perms)ASTM E 96 0.17
Methane transmission rate ASTM D 1434 0
Adhesion to Concrete & Masonry ASTM C 836 7 lbf./inch
Hardness ASTM C 836 85
Crack Bridging ASTM C 836 No Cracking
Low Temp. Flexibility ASTM C 836-00 No Cracking at –20ºC
Resistance to Acids:
Acetic 30%
Sulfuric and Hydrochloric 13%
Temperature Effect:
Stable 248ºF
Flexible 13ºF

2.3 AUXILIARY MATERIALS

A. Sheet Flashing: 60-mil reinforced modified asphalt sheet good with double-sided adhesive.

B. Reinforcing Strip: Manufacturer’s recommended polypropylene and polyester fabric.

C. Seam Detailing Sealant Mastic: Geo-Seal DETAIL, a high or medium viscosity polymer
modified water based asphalt material.

1. Back Rod: Closed-cell polyethylene foam.

2.4 GAS VAPOR BARRIER

A. Sheet Course Usage

1. On Base layer, use Geo-Seal BASE course and/or other base sheet as required or
approved by the manufacturer.

2. On Top layer, use Geo-Seal BOND layer and/or other protection as required or
approved by the manufacturer.

B. Geo-Seal BOND and BASE physical properties.

ART 3 – EXECUTION
.1 EXAMINATION
A. Examine substrates, areas, and conditions under which gas vapor barrier will be applied,

.2 SURFACE PREPARATION
A. Verify substrate is prepared according to manufacturer’s recommendations. On a
te is

B. Mask off adjoining surfaces not receiving methane barrier/waterproofing to prevent spillage

.3 PREPARATIONS AND TREATMENT AT TERMINATIONS AND PENETRATIONS
A. Prepare vertical and horizontal surfaces at terminations, at penetrations through gas vapor

B. Apply two coats of Geo-Seal DETAIL on both sides of top and bottom protection course

1. Terminations should be treated 6 inches up vertical and 6 inches on horizontal.
s onto
Properties Test Method Results
Film Thickness 5 mil
Composite Thickness 18 mil
Water Vapor Permeability ASTM E 96 0.214
Dart Impact ASTM D 1790 >1070 gms, method A
594 gms, method B
Puncture Properties Tear ASTM B 2582 MD 11,290 gms
ASTM B 2582 TD 13,150 gms

P

3

with installer present, for compliance with requirements. Do not proceed with installation
until unsatisfactory conditions have been corrected.
3

horizontal surface, the substrate should be free from material that could potentially
puncture the gas vapor barrier installation. Contact manufacturer to confirm substra
within manufactures recommendations.
or over spray affecting other construction.

3

barrier to manufacturer’s recommendations.
layers (30 mil each) and embed a joint reinforcing strip in preparation coat and apply a
second coat over embedded joint reinforcing strip ensuring its complete saturation and
covering.
2. Penetrations should be treated in a 6-inch radius around penetration and 3 inche
penetrating object.

3.4 METHANE BARRIER/PROTECTION COURSE BOTTOM INSTALLATION
A. Install Geo-Seal BASE over substrate material in one direction with six-inch overlaps
Secure the Geo-Seal BASE seams by applying Geo-Seal CORE between the 6”

GAS VAPOR BARRIER APPLICATION
A. Set up spray equipment according to manufacturer’s instructions and place spray-markers

B. Mix materials according to manufacturer’s instructions.

C. Start installing gas vapor barrier in presence of manufacturer’s technical representative.

D. Apply Geo-Seal CORE spray according to manufacturer’s recommendations.

E. Apply one spray coat of Geo-Seal CORE to obtain a seamless membrane from pinholes or

F. Apply gas vapor barrier to prepared wall terminations and to the horizontal surface of the

G. Verify film thickness of gas vapor barrier every 100 sq./ft. (9.3 sq./m).

.6 METHANE BARRIER/PROTECTION COURSE TOP INSTALLATION
A. Install Geo-Seal BOND protection course perpendicular to the direction of the bottom
perations.

B. Secure Geo-Seal BOND protection course seams by overlapping seams a minimum of 6”.

.8 FIELD QUALITY CONTROL
A. Membrane may be checked for coverage with a lightly oiled, needle nose depth gauge,

B. Test areas are to be patched over with Geo-Seal CORE to an 60 mil minimum dry

B.
overlapped sheets.
3.5

in field of bottom protection course.
shadows, with an average dry film thickness of 60 mils (1.2 mm).
bottom protection course to a thickness indicated by the placed spray-markers and
according to manufacturer’s recommendations and details.

3

course with overlapped seams over nominally cured membrane no later than
recommended by manufacturer and before starting subsequent construction o
3

taking four (4) readings over a one square inch area, every 500 square feet. Record the
minimum reading. Mark the test area for repair.
thickness, extending a minimum of one inch (1”) beyond the test perimeter.
C. Smoke Testing is highly recommended and is the ideal way to test the seal created around
penetrations and terminations. Smoke Testing is conducted by pumping non-toxic smoke
underneath the Geo-Seal gas vapor barrier and then repairing the areas where smoke
appears.

3.9 CURING, PROTECTING, AND CLEANING

A. Cure waterproofing according to manufacturer’s recommendations, taking care to prevent
contamination and damage during application stages and curing.

B. Clean spillage and soiling from adjacent construction using cleaning agents and
procedures recommended by manufacturer of affected construction.

ATTACHMENT C

Environmental Covenant Example and Public Notice Guidelines

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES

IN THE MATTER OF: [Name of Prospective Developer]

UNDER THE AUTHORITY OF THE ) BROWNFIELDS AGREEMENT re:
BROWNFIELDS PROPERTY REUSE ACT ) [site name]
OF 1997, N.C.G.S. § 130A-310.30, et seq. ) [site address]
[BF Project Number]

I. INTRODUCTION

This Brownfields Agreement ("Agreement") is entered into by the North Carolina Department of
Environment and Natural Resources ("DENR") and [name of Prospective Developer] (collectively the
"Parties") pursuant to the Brownfields Property Reuse Act of 1997, N.C.G.S. § 130A-310.30, et seq. (the
"Act").

[Introductory information, consistent with Statement of Facts, about Prospective Developer, its
address, its business form and where it’s chartered, and its proposed use of property, with location
and brief description of property.] A map showing the location of the property, which is the subject of
this Agreement is attached hereto as Exhibit 1.

The Parties agree to undertake all actions required by the terms and conditions of this Agreement. The
purpose of this Agreement is to settle and resolve, subject to reservations and limitations contained in
Section VIII (Certification), Section IX (DENR’s Covenant Not to Sue and Reservation of Rights) and
Section X (Prospective Developer’s Covenant Not to Sue), the potential liability of [name of Prospective
Developer] for contaminants at the property which is the subject of this Agreement.

The Parties agree that [name of Prospective Developer]’s entry into this Agreement, and the actions
undertaken by [name of Prospective Developer] in accordance with the Agreement, do not constitute an
admission of any liability by [name of Prospective Developer].

The resolution of this potential liability, in exchange for the benefit [name of Prospective Developer] shall
provide to DENR, is in the public interest.

II. DEFINITIONS

Unless otherwise expressly provided herein, terms used in this Agreement which are defined in the Act or
elsewhere in N.C.G.S. 130A, Article 9 shall have the meaning assigned to them in those statutory
provisions, including any amendments thereto.

1. "Property" shall mean the Brownfields Property which is the subject of this Agreement, and which is
described and depicted in Exhibit 1 of this Agreement.

2."Prospective Developer" shall mean [name of Prospective Developer].

III. STATEMENT OF FACTS

3. [Facts relating to the Property that are relevant; and that do not relate to actions or parties that
are outside of this Agreement.] The Property comprises ____ acres. Prospective Developer has committed
itself to redevelopment for no uses other than _____________________________.

4. The Property is bordered to the north by [_________________ ] [land used for ______________ ]
["and owned by ___________], to the south by ______________, to the east by ______________, and to
the west by ________________.
a. Prospective Developer obtained or commissioned the following reports, referred to hereinafter
as the "Environmental Reports," regarding the Property:

Title Prepared by Date of Report

5. For purposes of this Agreement, DENR relies on the following representations by Prospective Developer
as to prior use of the Property:

a. [List of representations here]

6. The most recent environmental sampling at the Property reported in the Environmental Reports occurred
on _________________, 200_. The following table(s) set forth, for contaminants present at the Property
above unrestricted use standards, the maximum concentration found at each sample location and the
applicable standard:

a. Groundwater contaminants (in micrograms per liter, the equivalent of parts per billion), the
standards for which are in Title 15A of the North Carolina Administrative Code, Subchapter
2L, Rule .0202:

Groundwater
Contaminant
Sample Location Date of Max.
Concentration
Sampling
Maximum
Concentration
above Std.
(mg/L)
Standard
(mg/L)

b. Soil contaminants (in milligrams per kilogram, the equivalent of parts per million), the
standards for which are derived using the Guidelines of the Inactive Hazardous Sites Branch of
DENR’s Superfund Section:

Soil
Contaminant
Sample
Location
Depth Date of Max.
Concentration
Sampling
Maximum
Concentration
above Std.
(mg/kg)
Standard
(mg/kg)

7. For purposes of this Agreement DENR relies on Prospective Developer’s representations that
Prospective Developer's involvement with the Property has been limited to obtaining or commissioning the
Environmental Reports, preparing and submitting to DENR a Brownfields Letter of Intent dated
______________, 200_, and the following:

8. On ___________, 200_, Prospective Developer [purchased][contracted to purchase] the Property (if
either applies)

9. Prospective Developer has provided DENR with information, or sworn certifications regarding that
information on which DENR relies for purposes of this Agreement, sufficient to demonstrate that:

a. Prospective Developer and any parent, subsidiary, or other affiliate has substantially complied
with federal and state laws, regulations and rules for protection of the environment, and with the
other agreements and requirements cited at N.C.G.S. § 130A-310.32(a)(1);

b. As a result of the implementation of this Agreement, the Property will be suitable for the uses
specified in the Agreement while fully protecting public health and the environment;

c. Prospective Developer's reuse of the Property will produce a public benefit commensurate with
the liability protection provided Prospective Developer hereunder;

d. Prospective Developer has or can obtain the financial, managerial and technical means to fully
implement this Agreement and assure the safe use of the Property; and

e. Prospective Developer has complied with all applicable procedural requirements.

10. Prospective Developer has paid the $2,000 fee to seek a brownfields agreement required by N.C.G.S. §
130A-310.39(a)(1). Pursuant to N.C.G.S. § 130A-310.39(a)(2), the procedure upon which Prospective
Developer and DENR have agreed for payment of the full cost to DENR and the North Carolina
Department of Justice ("DOJ") of all activities related to this Agreement is that Prospective Developer shall
pay any amount by which DOJ’s hours, multiplied by $36.24, exceed the $2,000 fee referenced above in
this paragraph. (DENR has incurred no costs.)

IV. BENEFIT TO COMMUNITY

11. The redevelopment of the Property proposed herein would provide the following public benefits:

a. A return to productive use of the Property;[use only where property’s idle]

b. An increase in the Property’s productivity;[use where property’s currently in use]

_. A spur to additional community redevelopment, through improved neighborhood appearance
and otherwise;[use where surrounding area’s depressed]

_. [Use where # known: "approximately __"] jobs;

_. Tax revenue for affected jurisdictions;

_. ["Additional" (if applicable)]["retail"]["office"][other?] space for the area; and

_. "Smart growth" through use of land in an already developed area, which avoids development of
land beyond the urban fringe ("greenfields").

_. Additional benefits supplied by PD

V. WORK TO BE PERFORMED

12. [Include here provisions relating to agency approvals, reporting, any required financial
assurances, any petroleum underground storage tanks, etc, and:

a. Any remediation to be conducted on the property, including:
i. A description of specific areas where remediation is to be conducted.

ii. The remediation method or methods to be employed.

iii. The resources that Prospective Developer will make available.

iv. A schedule of remediation activities.

v. Applicable remediation standards.

vi. A schedule and the method or methods for evaluating the remediation.]

__. By way of the Notice of Brownfields Property referenced below in paragraph __, Prospective
Developer shall impose the following land use restrictions under the Act, running with the land, to make
the Property safe for the uses specified in this Agreement while fully protecting public health and the
environment.

_. No use other than the following may be made of the Property: [list use(s) we’ve approved]

_. Surface water and underground water at the Property may not be used for any purpose without the
approval of DENR or its successor in function.

_. No activities that encounter, expose, remove or use groundwater (for example, installation of water
supply wells, fountains, ponds, lakes or swimming pools, or construction or excavation activities that
encounter or expose groundwater) may occur on the Property without prior sampling and analysis of
groundwater to the satisfaction of DENR or its successor in function in any areas proposed for such
activities, and submittal of the analytical results to DENR or its successor in function. If such results
disclose to DENR or its successor in function contamination in excess of North Carolina’s groundwater
quality standards, the proposed activities may not occur without the approval of DENR or its successor in
function on such conditions as DENR or its successor in function imposes, including at a minimum
compliance with plans and procedures, approved pursuant to applicable law, to protect public health and
the environment during the proposed activities.

_. Soil underlying paved surfaces and buildings at the Property may not be exposed without prior sampling
and analysis of such soil to the satisfaction of DENR or its successor in function, and submittal of the
analytical results to DENR or its successor in function. If such results disclose contamination in excess of
the applicable standards as determined by DENR or its successor in function, the soil may not be exposed
without the approval of DENR or its successor in function on such conditions as DENR or its successor in
function imposes, including at a minimum compliance with plans and procedures, approved pursuant to
applicable law, to protect public health and the environment during the activities that would expose such
soil.

_. Soil not previously sampled for contaminants may not be exposed without a minimum of five (5)
business days advance written notice to DENR or its successor in function. At the time such soil is
exposed, DENR or its successor in function may inspect and sample, or require sampling of, the exposed
soil for contaminants. If soil contamination is discovered that DENR or its successor in function determines
would likely contaminate groundwater even if capped, or that may pose an imminent threat to public health
or the environment if exposed, as much soil as DENR or its successor in function requires shall be removed
and disposed of in accordance with applicable law, and any other actions that DENR or its successor in
function requires to make the Property suitable for the uses specified in this Agreement while fully
protecting public health and the environment shall be taken. If soil contamination is discovered that DENR
or its successor in function determines would not contaminate groundwater if capped, or pose an imminent
threat to public health or the environment if exposed, as much soil as DENR or its successor in function
requires shall be removed and disposed of in accordance with applicable law or capped to the satisfaction
of DENR or its successor in function.
_. Soil, landscaping and contours at the Property may not be disturbed without the approval of DENR or its
successor in function, except for mowing and pruning of above-ground vegetation.

_. No mining may be conducted on or under the Property, including, without limitation, extraction of coal,
oil, gas or any other minerals or non-mineral substances.

_. No basements may be constructed on the Property unless they are, as determined by DENR or its
successor in function, vented in conformance with applicable building codes.

_. None of the contaminants known to be present in the environmental media at the Property, including
those listed in paragraph __ of this Agreement, may be used or stored at the Property without the prior
approval of DENR or its successor in function, except in de minimis amounts for cleaning and other routine
housekeeping activities.

_. The Property may not be used as a park or for sports of any kind, including, but not limited to, golf,
football, soccer and baseball, without the approval of DENR or its successor in function.

_. The Property may not be used for agriculture, grazing, timbering or timber production.

_. The Property may not be used as a playground, or for child care centers or schools.

_. The Property may not be used for kennels, private animal pens or horse-riding. _. During January of each
year after this Agreement becomes effective, the then current owner of any part of the Property shall submit
a notarized Land Use Restrictions Update to DENR or its successor in function certifying that the Notice of
Brownfields Property containing these land use restrictions remains recorded at the _____________
County, North Carolina Register of Deeds’ office, and that the land use restrictions are being complied with
[Add here any additional items PD needs to certify annually].

__. [Use if applicable.] Within thirty (30) days after the effective date of this Agreement, Prospective
Developer shall notify DENR that it is ready to effect the abandonment of all groundwater monitoring
wells, injection wells, recovery wells, piezometers and other man-made points of groundwater access at the
Property in accordance with Subchapter 2C of Title 15A of the North Carolina Administrative Code.
Unless DENR notifies Prospective Developer within ten (10) days of receiving such notification to refrain
from such abandonment, Prospective Developer shall effect said abandonment and shall, within thirty (30)
days after concluding such abandonment, provide DENR a report setting forth the procedures and results.

__. The desired result of the above-referenced ["remediation and" if there’s active remediation] land
use restrictions is to make the Property suitable for the uses specified in the Agreement while fully
protecting public health and the environment.

__. The guidelines, including parameters, principles and policies within which the desired results are to be
accomplished are the Guidelines of the Inactive Hazardous Sites Branch of DENR’s Superfund Section, as
embodied in their most current version.

__. The consequences of achieving or not achieving the desired results will be that the Property is or is not
suitable for the uses specified in the Agreement while fully protecting public health and the environment.

VI. ACCESS/NOTICE TO SUCCESSORS IN INTEREST

__. Commencing upon the [date that it acquires title to the Property]["effective date of this
Agreement" if Prospective Developer already owns Property], Prospective Developer agrees to provide
to DENR, its authorized officers, employees, representatives, and all other persons performing response
actions under DENR oversight, an irrevocable right of access at all reasonable times to the Property and to
any other property to which access is required for the implementation of response actions at the Property, to
the extent access to such other property is controlled by the Prospective Developer, for the purposes of
performing or overseeing response actions at the Property under applicable law. DENR agrees to provide
reasonable notice to the Prospective Developer of the timing of response actions to be undertaken at the
Property. Notwithstanding any provision of this Agreement, DENR retains all of its authorities and rights,
including enforcement authorities related thereto, under the Act and any other applicable statute or
regulation, including any amendments thereto.

__. DENR has approved, pursuant to N.C.G.S. § 130A-310.35, a Notice of Brownfields Property for the
Property containing, inter alia, the land use restrictions set forth in Section V (Work to Be Performed) of
this Agreement and a survey plat of the Property. Pursuant to N.C.G.S. § 130A-310.35(b), within 15 days
of the effective date of this Agreement Prospective Developer shall file the Notice of Brownfields Property
in the County, North Carolina Register of Deeds’ office. Within three days thereafter, Prospective
Developer shall furnish DENR a copy of the documentary component of the Notice containing a
certification by the register of deeds as to the Book and Page numbers where both the documentary and plat
components of the Notice are recorded, and a copy of the plat with notations indicating its recordation.

__. This Agreement shall be attached as Exhibit A to the Notice of Brownfields Property. Subsequent to
recordation of said Notice, any deed or other instrument conveying an interest in the Property shall contain
the following notice: "The property which is the subject of this instrument is subject to the Brownfields
Agreement attached as Exhibit A to the Notice of Brownfields Property recorded in the __________
County land records, Book ____, Page ____." A copy of any such instrument shall be sent to the persons
listed in Section XV (Notices and Submissions), though financial figures related to the conveyance may be
redacted.

__. The Prospective Developer shall ensure that assignees, successors in interest, lessees and sublessees of
the Property shall provide the same access and cooperation. The Prospective Developer shall ensure that a
copy of this Agreement is provided to any current lessee or sublessee on the Property as of the effective
date of this Agreement and shall ensure that any subsequent leases, subleases, assignments or transfers of
the Property or an interest in the Property are consistent with this Section, Section V (Work to be
Performed) and Section XI (Parties Bound/Transfer of Covenant) of this Agreement.

VII. DUE CARE/COOPERATION

__. The Prospective Developer shall exercise due care at the Property with respect to regulated substances
and shall comply with all applicable local, State, and federal laws and regulations. The Prospective
Developer agrees to cooperate fully with any remediation of the Property by DENR and further agrees not
to interfere with any such remediation. DENR agrees, consistent with its responsibilities under applicable
law, to use reasonable efforts to minimize any interference with the Prospective Developer's operations by
any such remediation. In the event the Prospective Developer becomes aware of any action or occurrence
which causes or threatens a release of contaminants at or from the Property, the Prospective Developer
shall immediately take all appropriate action to prevent, abate, or minimize such release or threat of release,
and shall, in addition to complying with any applicable notification requirements under N.C.G.S. 130A-
310.1 and 143-215.84, and Section 103 of CERCLA, 42 U.S.C. § 9603, or any other law, immediately
notify DENR of such release or threatened release.

VIII. CERTIFICATION

__. By entering into this agreement, the Prospective Developer certifies that, without DENR approval, it
will make no use of the Property other than that committed to in the Brownfields Letter of Intent dated
______________________ by which it applied for this Agreement. That use is
___________________________________________. Prospective Developer also certifies that to the best
of its knowledge and belief it has fully and accurately disclosed to DENR all information known to
Prospective Developer and all information in the possession or control of its officers, directors, employees,
contractors and agents which relates in any way to any regulated substances at the Property and to its
qualification for this Agreement, including the requirement that it not have caused or contributed to the
contamination at the Property.

IX. DENR’S COVENANT NOT TO SUE AND RESERVATION OF RIGHTS

__. Unless one of the following applies, Prospective Developer shall not be liable to DENR, and DENR
covenants not to sue Prospective Developer, for remediation of the Property except as specified in this
Agreement:

a. The Prospective Developer fails to comply with this Agreement.

b. The activities conducted on the Property by or under the control or direction of the Prospective
Developer increase the risk of harm to public health or the environment, in which case Prospective
Developer shall be liable for remediation of the areas of the Property, remediation of which is
required by this Agreement, to the extent necessary to eliminate such risk of harm to public health
or the environment.

c. A land use restriction set out in the Notice of Brownfields Property required under N.C.G.S.
130A-310.35 is violated while the Prospective Developer owns the Property, in which case the
Prospective Developer shall be responsible for remediation of the Property to current standards.

d. The Prospective Developer knowingly or recklessly provided false information that formed a
basis for this Agreement or knowingly or recklessly offers false information to demonstrate
compliance with this Agreement or fails to disclose relevant information about contamination at
the Property.

e. New information indicates the existence of previously unreported contaminants or an area of
previously unreported contamination on or associated with the Property that has not been
remediated to current standards, unless this Agreement is amended to include any previously
unreported contaminants and any additional areas of contamination. If this Agreement sets
maximum concentrations for contaminants, and new information indicates the existence of
previously unreported areas of these contaminants, further remediation shall be required only if the
areas of previously unreported contaminants raise the risk of the contamination to public health or
the environment to a level less protective of public health and the environment than that required
by this Agreement.

f. The level of risk to public health or the environment from contaminants is unacceptable at or in
the vicinity of the Property due to changes in exposure conditions, including (i) a change in land
use that increases the probability of exposure to contaminants at or in the vicinity of the Property
or (ii) the failure of remediation to mitigate risks to the extent required to make the Property fully
protective of public health and the environment as planned in this Agreement.

g. The Department obtains new information about a contaminant associated with the Property or
exposures at or around the Property that raises the risk to public health or the environment
associated with the Property beyond an acceptable range and in a manner or to a degree not
anticipated in this Agreement.

h. The Prospective Developer fails to file a timely and proper Notice of Brownfields Property
under N.C.G.S. 130A-310.35.

__. Except as may be provided herein, DENR reserves its rights against Prospective Developer as to
liabilities beyond the scope of the Act, including those regarding petroleum underground storage tanks
pursuant to Part 2A, Article 21A of Chapter 143 of the General Statutes.

__. This Agreement does not waive any applicable requirement to obtain a permit, license or certification,
or to comply with any and all other applicable law, including the North Carolina Environmental Policy Act,
N.C.G.S. § 113A-1, et seq.

X. PROSPECTIVE DEVELOPER'S COVENANT NOT TO SUE

__. In consideration of DENR’s Covenant Not To Sue in Section IX of this Agreement and in recognition
of the absolute State immunity provided in N.C.G.S. § 130A-310.37(b), the Prospective Developer hereby
covenants not to sue and not to assert any claims or causes of action against DENR, its authorized officers,
employees, or representatives with respect to any action implementing the Act, including negotiating,
entering, monitoring or enforcing this Agreement or the above-referenced Notice of Brownfields Property.

XI. PARTIES BOUND & TRANSFER/ASSIGNMENT NOTICE

__. This Agreement shall apply to and be binding upon DENR, and on the Prospective Developer, its
officers, directors, employees, and agents. Each Party’s signatory to this Agreement represents that she or
he is fully authorized to enter into the terms and conditions of this Agreement and to legally bind the Party
for whom she or he signs.

__. No later than fourteen (14) days prior to any transfer or assignment by Prospective Developer of any
interest in the Property, Prospective Developer shall provide in writing to DENR the transferee or
assignee’s name, mailing address, telephone and facsimile numbers, and e-mail address.

XII. DISCLAIMER

__. This Agreement in no way constitutes a finding by DENR as to the risks to public health and the
environment which may be posed by regulated substances at the Property, a representation by DENR that
the Property is fit for any particular purpose, nor a waiver of Prospective Developer’s duty to seek
applicable permits or of the provisions of N.C.G.S. § 130A-310.37.

__. This Agreement does not confer any rights, benefits or obligations that are not conferred by N.C.G.S. §
130A-310.33(a)(1)-(5)’s provision of the Act’s liability protection to certain persons to the same extent as
to a prospective developer.

XIII. DOCUMENT RETENTION

__. The Prospective Developer agrees to retain and make available to DENR all business and operating
records, contracts, site studies and investigations, and documents relating to operations at the Property, for
ten years following the effective date of this Agreement, unless otherwise agreed to in writing by the
Parties. At the end of ten years, the Prospective Developer shall notify DENR of the location of such
documents and shall provide DENR with an opportunity to copy any documents at the expense of DENR.

XIV. PAYMENT OF ENFORCEMENT COSTS

__. If the Prospective Developer fails to comply with the terms of this Agreement, including, but not
limited to, the provisions of Section V (Work to be Performed), it shall be liable for all litigation and other
enforcement costs incurred by DENR to enforce this Agreement or otherwise obtain compliance.

XV. NOTICES AND SUBMISSIONS

__. Unless otherwise required by DENR or a Party notifies the other Party in writing of a change in contact
information, all notices and submissions pursuant to this Agreement shall be sent by prepaid first class U.S.
mail, as follows:

a. For DENR:

_____________________
N.C. Division of Waste Management
Brownfields Program
401 Oberlin Road, Suite 150
Raleigh, NC 27605

b. For Prospective Developer:

Name
Company
Address
City, State, ZIP

Notices and submissions sent by prepaid first class U.S. mail shall be effective on the third day following
postmarking. Notices and submissions sent by hand or by other means affording written evidence of date of
receipt shall be effective on such date.

XVI. EFFECTIVE DATE

__. This Agreement shall become effective on the date the Prospective Developer signs it, after receiving it,
signed, from DENR. Prospective Developer shall sign the Agreement within seven (7) days following such
receipt.

XVII. TERMINATION OF CERTAIN PROVISIONS

__. If any Party believes that any or all of the obligations under Section VI (Access/Notice to Successors in
Interest) are no longer necessary to ensure compliance with the requirements of the Agreement, that Party
may request in writing that the other Party agree to terminate the provision(s) establishing such obligations;
provided, however, that the provision(s) in question shall continue in force unless and until the Party
requesting such termination receives written agreement from the other Party to terminate such provision(s).

XVIII. CONTRIBUTION PROTECTION

__. With regard to claims for contribution against Prospective Developer in relation to the subject matter of
this Agreement, Prospective Developer is entitled to protection from such claims to the extent provided by
N.C.G.S. § 130A-310.37(a)(5)-(6). The subject matter of this Agreement is all remediation taken or to be
taken and response costs incurred or to be incurred by DENR or any other person in relation to the
Property.

__. The Prospective Developer agrees that, with respect to any suit or claim for contribution brought by it
in relation to the subject matter of this Agreement, it will notify DENR in writing no later than 60 days
prior to the initiation of such suit or claim.

__. The Prospective Developer also agrees that, with respect to any suit or claim for contribution brought
against it in relation to the subject matter of this Agreement, it will notify DENR in writing within 10 days
of service of the complaint on it.

XVIV. PUBLIC COMMENT

__. This Agreement shall be subject to a public comment period of at least sixty days starting the day after
publication of the approved summary of the Notice of Intent to Redevelop a Brownfields Property required
by N.C.G.S. § 130A-310.34 in the North Carolina Register, or the day after publication of the same in a
newspaper of general circulation serving the area in which the Property is located, whichever occurs later.
After expiration of that period, or following a public meeting if DENR holds one pursuant to N.C.G.S. §
130A-310.34(c), DENR may modify or withdraw its consent to this Agreement if comments received
disclose facts or considerations which indicate that this Agreement is inappropriate, improper or
inadequate.

IT IS SO AGREED:

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES

By: ____________________________________________________________________________
Linda M. Culpepper Date
Deputy Director, Division of Waste Management

IT IS SO AGREED:

[Name of Prospective Developer]

By: ____________________________________________________________________________
Name typed or printed: Date
Title typed or printed:
GUIDANCE - THE PUBLIC NOTICE PHASE OF THE NC BROWNFIELDS PROCESS

This guidance is provided to facilitate Prospective Developer’s (“PD’s”) compliance with the
statutory requirements regarding the public notice aspects of the NC brownfields process. These
requirements have recently been revised, and this guidance has been updated accordingly
(September 1, 2009). Substantive revisions are highlighted in yellow. Because they are integral
to this process, a description of the brownfields documents precedes the description of PD’s
responsibilities regarding public notice. In order to ensure the safe reuse of properties being
redeveloped under the NC Brownfields Program (NCBP), the Brownfields Property Reuse Act
of 1997 requires the preparation of the following four brownfields documents:

Brownfields Agreement (BFA) – A contract and covenant-not-to-sue between PD and the
NC Department of Environment and Natural Resources (“DENR”) that: 1) provides details
regarding the PD, its intended reuse of the brownfields Property, and the history of and
contamination at the Property, 2) describes what work the PD must perform and what land
use restrictions will be imposed at the Property, 3) explains the liability protection that the
BFA provides to the PD, and 4) describes conditions under which PD may be required to
perform additional remediation at the Property;

Notice of Brownfields Property (NBP) – A four to five page document that recites certain
statutory provisions, provides basic information regarding the brownfields Property and the
planned redevelopment project, and lists the land use restrictions that will be imposed at the
Property to help ensure its safe reuse. The recordation of the NBP allows these restrictions to
run with the land. The NBP has three exhibits: Exhibit A - the Brownfields Agreement;
Exhibit B – the survey plat; and Exhibit C – the legal description of the Property;

Notice of Intent to Redevelop a Brownfields Property (NI) – A generic, one-page
document that functions as a cover letter to introduce the other brownfields documents (the
NI and the other documents, when taken together, comprise the “full” Notice of Intent to
Redevelop a Brownfields Property, that package of information PD makes available for the
public’s review during the public comment period); and

Summary of the Notice of Intent to Redevelop a Brownfields Property (SNI) – A one-
page document that summarizes the information in the full Notice of Intent. The SNI is the
document used by the PD to satisfy the statutory Public Notice requirements, which are as
follows: 1) physically posting the SNI in a conspicuous location(s) at the Property, 2)
mailing or delivering the SNI to the property owners contiguous to the Brownfields Property,
and 3) publishing the SNI in a newspaper with circulation in the area of the brownfields
Property.

The initial drafts of the four Brownfields documents, i.e., the BFA, NBA, NI, SNI, will be
prepared by the NCBP and submitted to the PD for their review. After the terms of these four
documents have been agreed upon and are acceptable to both parties (including the NCBP
project manager having in-hand an “approvable” survey plat, Exhibit B to the NBP), Rob
Gelblum, or the then-current NCBP attorney, will notify PD that the brownfields project is
approved to proceed to public notice. The following is a detailed description of PD’s
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responsibilities in order to fully comply with the statutory provisions regarding the public notice
phase of the NCBP brownfields process.

Pre-Public Comment Actions
For a period of at least 30 days, PD must make available for the public’s review the “full NI
package,” which consists of the following elements: 1) the one-page NI, 2) the draft NBP and its
three Exhibits, 3) the draft BFA, 4) the survey plat, and 5) the legal description. Before the
public comment period can begin, PD must complete the following five actions in accordance
with N.C.G.S. § 130.310.34.(a):

1. Provide a copy of the full NI to all local governments having jurisdiction over the subject
brownfields Property, such as to the offices of the city and county manager;
2. Provide a copy of the full NI to the location, as specified in the SNI, where the full NI will
be available for public review, if different than the local government offices, above.
Frequently, a public library or the City Manager’s Office are used for this purpose;
3. Arrange for the publication of the SNI in a newspaper of general circulation serving the area
in which the Property is located;
4. Mail or deliver a copy of the SNI to each owner of property contiguous to the brownfields
property as identified on the Brownfields plat. If PD intends to mail the SNI, the Program
deems the use of USPS’ certified mail as sufficient documentation of the statutory mailing
requirement. If PD intends to deliver the SNI, the Program would require the dated
signature of said owner acknowledging its receipt of the SNI.
5. Conspicuously post the SNI at the Property. In order to facilitate the SNI’s readability, we
recommend that a version of the SNI printed with a larger font size be used for the SNI’s
physical posting at the Property. Additionally, to provide some protection from the
elements, we recommend the SNI be placed inside a sealed, clear plastic sleeve at the time
of posting.

Public Comment Start Date
All five elements of the full NI package [1) the one-page NI, 2) the draft NBP, and its three
Exhibits, 3) the draft BFA, 4) the survey plat, and 5) the legal description] must be in a form
acceptable to both parties before PD can be authorized by the program to proceed to public
notice and the public comment phase of the brownfields agreement process. In accordance with
N.C.G.S. § 130.310.34.(b), a public comment period of at least 30 days begins on the latest
date of PD’s completion of the SNI’s newspaper publication, posting, and mailing or
delivering. In order to determine the start date of the public comment period, NCBP will require
a clear accounting from PD (via email or other correspondence) as to the dates it completed the
required newspaper publication, posting, and mailing or delivering of the SNI. The latest of
these dates is “day zero” and the first counting day of public comment will be the day following
day zero.

PD’s Confirmation Correspondence
Finally, PD must confirm that the above-listed five pre-public comment actions have been
completed by providing to DENR confirmatory documentation as follows:

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For the placement of the full NI at local government offices and any other location where the
full NI will be available for public review, preferably provide a letter from each such office
or location confirming receipt of the full NI from the PD, but at a minimum provide copies
of PD’s letter of transmittal to each such office or location;
For the publication of the SNI in the newspaper, preferably provide an affidavit of
publication from the publishing entity, but at a minimum provide a photocopy of the actual
SNI as published that also indicates the name of the publishing entity and the date of
publication;
For the mailing or delivering of the SNI to owners of property contiguous to the Brownfields
Property:
Mailing option - for each owner of record of contiguous property, a copy the stamped
receipt provided by USPS indicating the date of the certified mailing and the
recipient’s name and address.
Delivering option - the dated signature of each owner acknowledging physical receipt
of the SNI; and finally
For the posting of the SNI at the Property, provide dated correspondence with attached
photographs, one close-up and one more distant, of the actual SNI as posted at the Property.

If you have any questions or require additional information regarding the public notice phase of
the NC brownfields process, please contact the project manager assigned to your redevelopment
project.