WI0100357_Supporting Appendices, SOPs, etc._20140501

ID Task Name Duration Start Finish 2015
_ Mar Apr ayiJun I Jul JAugJSepJ Oct 1NovJ Dec Jan IFeblmarlApriMay Jun I Jul lAug Sepi Oct iNov
1 Notice to Proceed 1 day Tue 3/25/14 Tue 3/25/14
2 Kickoff Meeting 1 day Wed 4/16/14 Wed 4/16/14
3 ERH System Design 69 days Wed 3/26/14 Mon 6/30/14
4 75%Draft Design Submission 29 days Wed 3/26/14 Mon 5/5/14
5 NG Draft Comments 10 days Tue 5/6/14 Mon 5/19/14
6 Final Design 7 days Tue 5/20/14 Wed 5/28/14
7 EPA Review Period 23 days Thu 5/29/14 Mon 6/30/14
8 HASP 30 days Wed 3/26/14 Tue 5/6/14
9 Pre-Field Activities 51 days Tue 5/6/14 Tue 7/15/14
10 Material Procurement 30 days Tue 6/3/14 Mon 7/14/14
11 Permits 45 days Tue 5/6/14 Mon 7/7/14
12 Site Office Mob 2 days Mon 7/14/14 Tue 7/15/14 =
13 Building Survey 2 days Mon 7/7/14 Tue 7/8/14
14 Survey locations 2 days Wed 7/9/14 Thu 7/10/14
15 Utility Location 2 days Wed 7/9/14 Thu 7/10/14 =
16 Material Receiving 10 days Mon 7/7/14 Fri 7/18/14
17 Material Delivery 5 days Mon 7/7/14 Fri 7/11/14
18 Electrode Pre-fab 5 days Mon 7/14/14 Fri 7/18/14
19 Subsurface Installation 125 days Mon 8/4/14 Fri 1/23/15
20 Borehole Pre-Clearing 14 days Mon 8/4/14 Thu 8/21/14 -
21 PM Abandon/TMP conversion 5 days Mon 8/4/14 Fri 8/8/14
22 Electrode/TMP Install HSA 100 days Mon 8/11/14 Fri 12/26/14
23 Electrode Install Sonic 28 days Mon 8/11/14 Wed 9/17/14 —
24 New PM Well Install 10 days Mon 12/29/14 Fri 1/9/15
25 Horizontal VR Install 10 days Mon 1/12/15 Fri 1/23/15
Task External Milestone ♦ Manual Summary Rollup
Split Inactive Task Manual Summary
Project: Murphy NC Project Sched Milestone ♦ Inactive Milestone Start-only C
Date: Mon 5/5/14 Summary W Inactive Summary Finish-only
Project Summary : Manual Task 2 Deadline
External Tasks Duration-only Progress
Page 1

ID Task Name Duration Start Finish 12015
Mar Apr ayiJun I Jul JAugJSepJ Oct lNovi Dec Jan Feb MarJAprJMayJJun I Jul JAugJSepJ Oct Nov
26 Surface Installation 75 days Mon 1/26/15 Fri 5/8/15
27 Trench Excavation 15 days Mon 1/26/15 Fri 2/13/15
28 VR Header Construction 10 days Mon 2/16/15 Fri 2/27/15
29 Supply Cable Installation 10 days Mon 3/2/15 Fri 3/13/15
30 Temperature Monitoring 10 days Mon 3/16/15 Fri 3/27/15
System Installation
31 Drip System Installation 10 days Mon 3/30/15 Fri 4/10/15
32 Trench Backfilled 10 days Mon 4/13/15 Fri 4/24/15
33 Trench Paving 10 days Mon 4/27/15 Fri 5/8/15
34 Equipment Mobilization 67 days Mon 1/26/15 Tue 4/28/15
35 Equipment Delivery 2 days Mon 3/30/15 Tue 3/31/15
36 Fence Installation 2 days Wed 4/1/15 Thu 4/2/15 r
37 Equipment Setup 5 days Wed 4/1/15 Tue 4/7/15
38 Interlock connections 3 days Wed 4/8/15 Fri 4/10/15
39 Electrical Installation 30 days Mon 1/26/15 Fri 3/6/15 AWN
40 Thermox Installation 20 days Wed 4/1/15 Tue 4/28/15
41 Propane 5 days Wed 4/1/15 Tue 4/7/15
42 System Startup 10 days Mon 5/11/15 Fri 5/22/15
43 Verify Rotation 2 days Mon 5/11/15 Tue 5/12/15
44 Verify Interlocks 2 days Wed 5/13/15 Thu 5/14/15
45 Energize electrodes 6 days Fri 5/15/15 Fri 5/22/15
46 Operations 78 days Mon 5/25/15 Wed 9/9/15
47 ERH System Operations 73 days Mon 5/25/15 Wed 9/2/15
48 Remediation Evaluation 5 days Thu 9/3/15 Wed 9/9/15
49 Demobilization 42 days? Thu 9/10/15 Fri 11/6/15
50 Surface de-construction 40 days Thu 9/10/15 Wed 11/4/15
Task External Milestone ♦ Manual Summary Rollup
Split Inactive Task 7_ Manual Summary
Project: Murphy NC Project Sched Milestone ♦ Inactive Milestone G Start-only C
Date: Mon 5/5/14 Summary W Inactive Summary Finish-only
Project Summary : Manual Task 2 Deadline
External Tasks Duration-only Progress
Page 2

ID Task Name Duration Start Finish 2015
MarJAprJMaVJJun I Jul lAug Nov Dec I Jan I Febl Marl Apr IMayl Jun Jul I AugSep Oct Nov
51 Equipment demobilization 2 days Thu 11/5/15 Fri 11/6/15
52 Final Report 40 days Thu 9/10/15 Wed 11/4/15
53
54
55 *Durations in work days
56 (Monday-Friday)not
57 Calander days
58 Operations 7 days/week
Task External Milestone ♦ Manual Summary Rollup
Split Inactive Task Manual Summary
Project: Murphy NC Project Sched Milestone ♦ Inactive Milestone G Start-only C
Date: Mon 5/5/14 Summary W Inactive Summary Finish-only
Project Summary : Manual Task 2 Deadline
External Tasks Duration-only Progress
Page 3

TRS
Accelerating Value
Operations and Maintenance
Plan
Electrical Resistance Heating
Former Clifton Precision Facility
Murphy, North Carolina
Issued: May 2014
TRS Group, Inc.
PO Box 737
Longview,WA 98632 .•
www.thermalrs.com —��nd"g—

TABLE OF CONTENTS
FORMER CLIFTON PRECISION FACILITY MURPHY, NORTH CAROLINA...................I
1.0 INTRODUCTION...............................................................................................................A
2.0 SITE DESCRIPTION AND BACKGROUND...................................................................A
3.0 PROJECT OBJECTIVES....................................................................................................A
4.0 TREATMENT TECHNOLOGY DESCRIPTION..............................................................B
4.1 ERH REMEDIATION CONCEPT................................................................................B
4.2 SITE-SPECIFIC ERH DESIGN.....................................................................................B
4.3 ERH SYSTEM COMPONENTS...................................................................................C
4.3.1 Power Control Unit.....................................................................................................D
4.3.2 Electrodes....................................................................................................................D
4.3.3 Vapor Recovery............................................................................................................D
4.3.4 Electrode and Subsurface Drip Water.........................................................................D
4.3.5 Temperature Monitoring Points..................................................................................E
4.3.6 Steam Condenser System.............................................................................................E
4.3.7 Vapor Treatment..........................................................................................................F
4.3.8 Condensate Water Treatment......................................................................................F
4.3.9 Grounding Plan...........................................................................................................F
5.0 ERH SYSTEM START-UP AND OPERATIONS.............................................................F
5.1 PRE-START-UP ACTIVITIES............................................................................................G
5.2 START-UP.......................................................................................................................G
5.3 VOLTAGE SURVEYS........................................................................................................H
5.4 ERH SYSTEM OPERATIONS............................................................................................H
5.4.1 Power Control Unit......................................................................................................I
5.4.2 VR Blower.....................................................................................................................I
5.4.3 Condenser.....................................................................................................................I
6.0 INSPECTIONS AND MAINTENANCE.............................................................................J
6.1 INSPECTIONS ...................................................................................................................J
6.1.1 Pre-Operations.............................................................................................................J
6.1.2 Daily Inspections.........................................................................................................K
6.1.3 Weekly Inspections.......................................................................................................K
6.1.4 Other Inspections.........................................................................................................K
6.2 CONDENSERS AND COOLING TOWERS...........................................................................K
6.3 VAPOR RECOVERY BLOWER..........................................................................................L
7.0 SAMPLING AND MONITORING PLAN.........................................................................N
7.1 ELECTRONIC DATA COLLECTION...................................................................................N
7.2 MANUAL DATA COLLECTION........................................................................................0
7.3 AMPERAGE SURVEYS.....................................................................................................P
7.4 VOLTAGE SURVEYS........................................................................................................P
7.5 NOISE LEVELS. ...............................................................................................................Q
7.6 VAPOR RECOVERY MONITORING...................................................................................Q
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF ii
If TRS

7.6.1 Tedlar®Bag Sampling Procedure at Locations under Negative Pressure.........Error!
Bookmark not defined.
7.7 CONFIRMATORY SAMPLING..................................ERROR!BOOKMARK NOT DEFINED.
8.0 REPORTING.......................................................................................................................R
8.1 WEEKLY REPORTING.....................................................................................................R
8.2 COMPLIANCE REPORTING..............................................................................................R
8.3 FINAL REPORT................................................................................................................R
9.0 WASTE MANAGEMENT.................................................................................................R
10.0 SECURITY AND SITE ACCESS CONTROL................................................................... S
11.0 HEALTH AND SAFETY MANAGEMENT...................................................................... S
12.0 REFERENCES....................................................................................................................T
List of Tables
Table 1-1. TRS ERH Condenser System Maintenance Checklist...................................................K
Table 1-2.Vapor Recovery Blower Maintenance Schedule ..........................................................M
Table 2-1. Electronic Data Monitoring and Collection Points........................................................N
Table 2-2. Manual Data Collection.................................................................................................0
List of Figures
Figure 1 General Site Plan
Figure 2 Process Flow Diagram
Figures 3a-3d Process and Instrumentation Diagram(s)
Figure 4 Electrical One-Line Drawing
Figure 5 Electrode
Figure 6 Bedrock Electrode
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF iii
If TRS

ABBREVIATIONS AND ACRONYMS
°C degrees Celsius
CFR Code of Federal Regulations
COC chemical of concern
CVOC chlorinated volatile organic compounds
DNAPL dense non-aqueous phase liquid
E-Stop emergency stop
ERH electrical resistance heating
' feet
' bgs feet below ground surfaceGAC granular activated carbon
gpm gallons per minute
hp horsepower
HSO Health and Safety Officer
HASP Health and Safety Plan
in Hg inches of Mercury
kW kilowatt
kWh kilowatt-hour
LGAC liquid-phase granular activated carbon
Moog Moog Components Group
Northrop Grumman Northrop Grumman Guidance and Electronics Company, Inc.
O&M operation and maintenance
OMP Operations Maintenance Plan
OSHA Occupational Safety and Health Administration
PCE tetrachloroethene
PCU power control unit
PID photoionization detector
PM Project Manager
QA quality assurance
QC quality control
SHSO Site Health and Safety Officer
SOP standard operating procedure
TMP temperature monitoring point
USEPA United States Environmental Protection Agency
UST underground storage tank
VAC voltage alternating current
VGAC vapor-phase granulated activated carbon
VR vapor recovery
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF iv
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1.0 INTRODUCTION
This Operations and Maintenance Plan(OMP)provides the technical aspects and approach for the
operation,maintenance, and system component and optimization monitoring of the electrical
resistance heating(ERH)treatment system at the Former Clifton Precision Facility in Murphy,NC
(herein referred to as the "Site"). ERH is an in situ thermal process which has been performed in the
State of North Carolina by TRS in the past. This site will focus on the thermal treatment of
chlorinated volatile organic compounds(CVOCs)in soil and groundwater.
TRS has been contracted by Northrop Grumman Guidance and Electronics Company, Inc. (Northrop
Grumman)under the direction of a project oversight team to design, install, operate, and maintain the
ERH system. This OMP has been prepared to describe the ERH system design, startup,operation
monitoring requirements, data recording and management processes, and project management
objectives for the Site.
The ERH treatment system is intended to operate at the site for approximately 3 to 4 months. During
this period,this OMP may be revised as required to meet changes in design,permit,or site conditions.
A hard copy of the revised document will be kept on-site in the power control unit(PCU)office.
2.0 SITE DESCRIPTION AND BACKGROUND
The site is currently occupied by Moog Components Group(Moog),which designs and manufactures
brush and brushless DC motors, synchros, resolvers, solenoids and air moving solutions for both
commercial and military markets. The site previously contained a 5,400-gallon concrete underground
storage tank(UST)that was identified as a potential source for VOCs in soil and groundwater
beneath the site. A hole was observed on the side of the UST during its removal in 1987. The
saturated zone soil and groundwater beneath the site is impacted by VOCs,primarily trichloroethene
and tetrachloroethene. Although dense non-aqueous phase liquid(DNAPL)has not been directly
observed on site,VOC concentrations in soil and groundwater samples indicate the potential presence
of DNAPL. The geology mainly consists of unconsolidated Saprolite consisting primarily of clayey
silts and silty sands. Depth of treatment of will be approximately 25 feet below ground surface(` bgs)
to varying depths or an average of approximately 70'. A general site layout is shown on Figure 1.
The site treatment zone consists of a surface area of approximately 23,000 square feet. A total
treatment volume of 37,000 cubic yards will be targeted for thermal treatment. Depth to water is
typically encountered at 25' bgs and is relatively slow moving and stable throughout the seasons. The
site thermal remediation system will consist of mostly below grade electrodes with trenches providing
pathways to the ERH equipment area. Electrodes located in the equipment area will be completed
tight to grade and routed under the ERH equipment.
3.0 PROJECT OBJECTIVES
The ERH project objectives for the treatment area are:
• Install ERH treatment system with minimal interruption to current ongoing Moog operations.
• Maintain a safe working environment for site staff and personnel surrounding the site.
Start up and operate,monitor, and maintain the ERH system within all permit and local
ordinance limits.
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 1
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• Remediate chlorinated volatile organic compounds (CVOC) in the treatment volume to
concentrations of 5,000 micrograms per liter in groundwater and 2,000 micrograms per
kilogram in soil.
• Safe and effective decommissioning and removal of ERH system equipment and components.
• Make appropriate disconnections and abandonment of utility piping used for ERH treatment
following completion of ERH.
4.0 TREATMENT TECHNOLOGY DESCRIPTION
ERH is the selected and approved in situ thermal process used for the remedial treatment of CVOCs
at the site.
4.1 ERH REMEDIATION CONCEPT
ERH is a process whereby soils and groundwater are heated by passing an electrical current through
the subsurface volume to be remediated. Electrical energy is introduced to the subsurface at
electrodes, and it is the resistance by the soil matrix to the flow of electricity between electrodes that
heats the subsurface and boils a portion of the soil moisture into steam. This in situ steam generation
occurs in all soil types,regardless of permeability. The heat generated by resistance to the induced
electrical current also evaporates the target contaminants. The in situ steam generated by ERH acts as
a carrier gas to sweep CVOCs to negative pressure vapor recovery(VR)wells.
Once the in situ production of steam starts, it becomes the driving mechanism for the transport of
contaminant vapors in the subsurface. Because steam is produced in situ and not injected during ERH,
the only driving force for steam migration is gravity,producing a buoyancy affect. The effect of
buoyancy on steam below the water table is to force it directly upward toward the surface similar to
bubbles rising through a column of water. The buoyancy force is very strong and,unless the steam is
trapped under a continuous impermeable soil horizon, it will find an upward path to the VR system.
Steam, contaminant vapors,non-aqueous-phase liquids, and groundwater can be recovered from the
subsurface into the VR system in a number of ways during ERH. The VR system can include VR
wells co-located with the electrodes, independent multiphase extraction wells, shallow horizontal VR
wells under the surface insulating cover, and hydraulic control wells.
Steam and soil vapors are then transported by plastic piping headers to the ERH condenser where the
recovered mixture is passed through a vapor/liquid separator and heat exchanger. The condensate
generated following the heat exchange is captured and conveyed for subsequent treatment and the
extracted air is treated using the best applicable technology or methods, such as vapor-phase granular
activated carbon(VGAC)or thermal oxidation.
4.2 SITE-SPECIFIC ERH DESIGN
The treatment area is somewhat irregular in shape and approximately 23,000 square feet in area with
a volume of 37,000 cubic yards. The treatment depth is defined as when refusal is encountered by the
hollow stem auger. This treatment depth definition is relevant to 96 electrode locations both vertical
and angle drilled. There are 16 electrodes that will be drilled 10' into the bedrock. These locations are
located along the Southern border of the treatment area. A multiple element electrode design will
supply the energy to target the different zones of resistance.
A total of 112 electrodes are to be installed in the treatment area with a co-located VR extraction
point in each electrode bore hole. In addition to the 112 co-located VR points,there will be an
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 2
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additional 4 near horizontal recovery points located under the Moog facility. These 4 vapor recovery
points are intended as a failsafe and supplemental capture system. All 116 vapor recovery points will
be connected via below grade conveyance piping to a vapor extraction system designed to provide
adjustable flow and vacuum to the subsurface.
During site remediation,the entire treatment zone will be heated simultaneously. The estimated
energy application required to achieve the soil and groundwater goals throughout both treatment
volumes is 5,160,000 kilowatt-hours(kWh). Based on an average power application of 2,600
kilowatts(kW),heating is estimated to last between 75 to 100 days.
The vapor recovery points will combine to recover air, steam, and contaminant vapors from the
treatment area. The rate of vapor recovery accelerates as temperatures in the subsurface approach the
boiling point of water. Fracture pathways in the subsurface soil matrix will be created by the
expansion of soil moisture as temperatures in this soil lens increase. The subsurface temperature will
be monitored using 13 temperature monitoring points(TMP). Each TMP location will have
approximately 10 sensors. The TMP sensors will begin at 20' bgs and will extend every 5' to the
depth of treatment in that area.
Steam,air, and CVOCs drawn from the subsurface will be conveyed through a multiple pipe header
to dedicated steam condenser units. Contaminant vapors will be treated with either a thermal oxidizer
or a VGAC system prior to being released to the atmosphere in accordance with air permit.
Recovered steam condensate from the condenser will be recycled as drip water to hydrate the
subsurface and keep the electrode borings moist.Non-recycled water will be used as make up water
in the condenser cooling towers. Depending on actual operating conditions, it may be necessary to
supplement treated condensate with potable water to ensure sufficient resources for the condenser
cooling loop and/or drip requirements.
4.3 ERH SYSTEM COMPONENTS
The ERH system consists of the primary components listed in Table 1 below. A summary of the ERH
process and supporting ancillary system components is also provided in the process flow diagram
illustrated on Figure 2.Additional detail pertaining to treatment system components, instrumentation
and operation is provided in the process and instrumentation diagrams shown on Figures 3a through
3d.
Table 1.ERH Primary System Components
Primary System Component Quantity
4,500-kW PCU 1
Step down transformers 5
Monitoring,control,and data acquisition system 1
Remote access and control system 1
Electrodes 112
ERH condenser 2
ERH cooling tower 4
40-hp vapor recovery blower 2
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 3
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10,000-lb VGAC vessels or 2
Thermal oxidizer with scrubber 1
TMPs 13
Thermocouples 130
VR wells, co-located with electrodes 112
Electrode wetting solenoids 112
LGAC vessels 4
*hp-horsepower
4.3.1 Power Control Unit
The PCU will deliver energy to the electrodes for soil and groundwater heating. The PCU is housed
in a weather-tight steel enclosure providing security and electrical insulation. A PCU is best
described as a variable transformer system capable of providing 100% duty cycle and is sized for a
maximum output of 4,500 M During ERH operation,the primary voltage is reduced to the
appropriate level for optimum subsurface heating. As the subsurface is heated,the primary voltage
typically changes and the PCU adjusts to those changes.
Standard 3-phase electrical power will be provided to the PCU from a new utility primary power
service. All ancillary ERH system equipment is powered from the PCU's electrical distribution panel
or an auxiliary electrical distribution panel, independent of the PCU. An electrical one-line drawing is
presented on Figure 4.
4.3.2 Electrodes
A total of 112 electrodes will deliver energy to the subsurface within the treatment area as shown in
96 electrodes will be constructed to a depth until auger refusal is reached. The conductive interval for
all 112 electrodes is 26' bgs. Typical construction details for each electrode design are shown on
Figures 5 and 6. The electrodes installed at the site will be comprised of both copper plate and 2-inch
carbon steel pipe. The downhole annulus around the electrode will be filled with metal elements,
carbon, and conductive shot, all of which are designed to withstand very high electrical current levels.
The average spacing between electrodes is approximately 15'.A 15-foot spacing will provide
adequate energy density within the estimated 100 days of operations.
All electrodes will be completed below grade and will be electrically isolated with a 10-inch-diameter
chlorinated polyvinyl chloride over-sleeve installed to 10' bgs. The electrode over-sleeve provides
electrical isolation to above grade system components and to site and facility personnel.
4.3.3 Vapor Recovery
Two 40-hp positive displacement blowers will apply vacuum to the VR conveyance piping system.
The blowers will pull steam, air, and CVOC vapors from the subsurface in the treatment areas
through the ERH steam condensers. Recovered air and contaminant vapors will pass through the
condensers and then conveyed to the vapor treatment system.
4.3.4 Electrode and Subsurface Drip Water
During operations,the area immediately surrounding each shallow treatment interval electrode
potentially loses soil moisture,which may reduce the effectiveness of the electrode. This dry out
condition is addressed by periodically adding drip water to the electrodes.
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 4
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Should steam extraction cause the upper portions of the treatment volumes to lose significant soil
moisture,the system design allows for a small amount of treated condensate or potable water to be
dripped back into the electrode boreholes to ensure that the soil immediately adjacent to the
conductive backfill stays moist and electrically conductive. During electrode installation, a 0.5-inch
copper drip line will be routed inside the borehole with the electrode into the conductive backfill.
Each individual drip line will be routed with the conveyance piping to a below grade trench for
surface connection. This water addition is not considered to be underground injection;the goal is to
keep the soil moist,not to pump water into an aquifer.A permit will likely be required to drip treated
condensate or potable water to the electrodes.
4.3.5 Temperature Monitoring Points
The 13 TMPs will be used to track the progress of the ERH remedial efforts. The TMPs consist of
analog thermocouples placed at 5-foot intervals within the treatment zone. Temperatures detected by
the thermocouples are converted to digital signals which are transmitted to a data logger located in the
PCU office. Each TMP will be routed with the conveyance piping to well vaults for surface
connection. The TMP casings are constructed from 1.25-inch-diameter steel pipe. The thermocouple
strings are coated in Teflon for heat and chemical resistance.
4.3.6 Steam Condenser System
The condenser system consists of an inlet air/water separation vessel, a plate and frame heat
exchanger,a condensate tank, a cooling tower, an outlet air/water separation system, and ancillary
pumps and controls. The vapor outlets of the condensers contain a mist eliminator that is 99 percent
efficient in removing droplets to a size of 10 microns.Automated condensate pumping functions are
monitored,controlled, and recorded by the PCU computer. It is also possible to monitor the
condenser system remotely.
Air and contaminant vapors are pulled from the condenser into the vapor treatment system by the
vacuum created by the VR blower. The inlet separation vessel removes water from the influent vapor
streams. Air and steam then enter the air side of the heat exchanger,where steam is converted to
condensate as heat is removed from the mixture.
The projected combined extraction rate once the heated subsurface has reached full boiling conditions
is approximately 1,120 standard cubic feet per minute (scfin)of air,which will produce about
7 gallons per minute (gpm)of condensate. The operation of an ERH condenser is based on Henry's
Law.As the fine water droplets condense from the steam,they do so in concentration equilibrium
with the gaseous phase that includes air. The dimensionless Henry's Law coefficient at a typical
condenser outlet temperature of 25 degrees Celsius (°C) is 0.699. Henry's Law can be rearranged to
calculate the percentage of PCE mass that will become dissolved in the condensed water as follows:
14.Ogpmx 3.785 l
l gal l x 100%—0.18%
14.Ogpm x 3.785 +0.699 x 1,500scfm x 28.32 s
gal ft
*gal—gallons;ft3—cubic feet
About 99.8 percent of the VOC mass that enters the condensers remains in the vapor phase and
continues on to the vapor treatment system. Because less than 0.2 percent of the VOC mass becomes
dissolved in the condensate, it will be collected in the condensate tank outlet separator and cost-
effectively treated onsite with small 200-lb liquid-phase granular activated carbon(LGAC)vessels.
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 5
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This site will require four LGAC vessels plumbed in series. Each condenser will have two LGAC
vessels in series.
The energy balance inside the condenser is such that the amount of water evaporated from the cooling
tower is slightly less than the amount of steam condensed. To the extent practical,the condensers are
operated as closed loop systems. The exact water balance is dependent upon the relative humidity
during the operational period. Water lost to evaporation needs to be replaced to maintain proper
operating levels in the cooling tower. By using the generated condensate for cooling tower water
makeup,potable water usage during treatment and wastewater for disposal can be reduced
significantly.
4.3.7 Vapor Treatment
The combined steam and air recovery rate from the ERH treatment areas and the supplemental SVE
wells will combine into the air stream is estimated to be 1,300 scfm of steam and 1,120 scfin of air.
The two 40-hp positive-displacement blowers used to convey the air stream to the treatment system
have a flow capacity of 3,000 scfm.
The VR stream will be treated using two different methods depending on stage of the project.A
thermal oxidizer with acid gas scrubber and VGAC will be used for vapor treatment. Two VGAC
vessels will be arranged in a series configuration. One vessel will serve as the primary absorber and
the other as the secondary polishing absorber. The VGAC vessels will likely only be used if an
extended operations period is selected and the cost of the thermal oxidizer is prohibitive.
4.3.8 Condensate Water Treatment
All condensate water generated at the site will be recycled through the condenser system.Non-
recycled water will be discharged to the Moog treatment plant or used as drip water.
4.3.9 Grounding Plan
The ERH PCU will be grounded per National Electrical Code requirements. Proper fuse or
appropriate overload protection will also be provided throughout the ERH PCU, output connections,
VR blower,condenser and cooling tower panels. Additionally all equipment will be bonded together
using with appropriate wire and appropriate grounding clamps.
Should step and touch voltage testing described in Section 5.3 identify voltage potentials exceeding
TRS limits for safe work environments,the power to the subsurface will immediately stop and the
voltage potential will be remedied. The type of remedy will be selected on a case by case basis. In
general the remedy will either incorporate isolating the item(s) so it could no longer be able to be
touched or dissipating it by grounding the item and/or installing neutral matting. Due to the
conductive interval beginning 25' bgs and engineered controls in the electrode design,minimal issues
are anticipated.
5.0 ERH SYSTEM START-UP AND OPERATIONS
ERH system startup will involve the inspection,testing,repair, and adjustment of all ERH system
components,process equipment and controls. A 95%system uptime will be targeted for the ERH
system. Downtime will be accrued when both vapor recovery blower units are non-operational.
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 6
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5.1 Pre-Start-Up Activities
Prior to installation and start-up, a final quality assurance (QA)inspection of all piping and electrical
connections will be made. The QA inspections and testing will be completed on the electrode cable
connections, drip solenoids, electrode cables, condenser components,transformer connections,TMP
field box connections,VR blowers, and PCU.All tanks, if applicable will be visibly inspected for
weld cracks or breaks, scrapes of protective coating, corrosion, structural damage, and inadequate
installation or construction such as cracks,punctures,and damaged fittings. The ERH condenser and
VR system will be inspected and made operational in accordance with TRS internal operations and
maintenance (O&M)manuals.
Start-up notification will be provided to the project team two weeks prior to operating the system.
TRS will complete Part 1 of the internal TRS Start-up Safety Checklist and all associated tasks prior
to commencing start-up operations. A copy of the TRS Start-up Safety Checklist is attached in
Appendix A of the Health and Safety Plan(HASP)included in the May 2014 TRS Design Report.
TRS will also follow the guidelines set forth in the scope of work Section 3.8.
5.2 Start-Up
The start-up period will span approximately one month. Actual time required for the entire start-up
phase may be longer or shorter dependent upon actual field conditions encountered. The first phase of
remediation consists of vapor recovery and treatment system operations without the application of
electrical energy to the treatment area. Before energy is first applied to the subsurface,the ERH
condenser and VR system will be made operational and optimized. All pressure,temperature, flow,
and remote monitoring equipment will be verified for correct operation. Alarm/interlock functionality
will also be confirmed. The data recording and management systems and communication protocols
will be tested and refined. The start-up period will also include the training of Site workers.
ERH start-up will be initiated by energizing the electrodes at a low applied voltage. With the
electrode field energized, operating parameters in the ERH PCU will be compared against known
standards, and step-and-touch and step-and-step voltage surveys (refer to Section 5.3)will be
completed throughout the area overlying and surrounding the treatment zone. Initial power
application and voltage survey protocols will be performed consistent with TRS internal standard
operating procedures (SOPs) for the Application of Electrical Power to ERH Sites and Voltage
Surveys,respectively. These SOPs are included in Appendix 4 of the May 2014 TRS Design Report.
If all operating conditions are within accepted standards as outlined in design documents and TRS
SOPS,the voltage to the electrode field will be slowly increased.With each significant increase in
applied voltage,operating parameters will be reviewed, and step-and-touch and step-and-step voltage
surveys will be performed again. If operating conditions are not within accepted limits, changes will
be made to the system configuration until they are once again acceptable. This iterative process can
take several days before the full design voltage is applied to the field for extended periods.
Once power application levels have reached optimum design conditions, final safety inspections and
data quality checks will be completed. Part II of the internal TRS Start-up Safety Checklist will be
completed and approved by TRS senior management to establish that the system is ready for
unattended operations. System interlocks will be verified at this time for correct operation. During
this process, operations of the ERH PCU will be observed while optimum voltage is applied to the
electrode field. Remote capabilities of the PCU and data acquisition system will then be verified.
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5.3 Voltage Surveys
To ensure the safe application of electrical energy to treat the subsurface soils, TRS will perform
voltage safety surveys initially, and as power is increased. These surveys are referred to as"step-and-
touch"and"step-and-step"voltage surveys. The purpose of these voltage safety surveys is to identify
the location(s)of possible voltage hazards on or directly adjacent to an operating ERH site. In
recording step-and-touch potentials,extra readings will be taken at locations where objects that could
carry voltage extend from the subsurface.Voltage surveys are described in greater detail in
Section 8.4 of this document. Maximum voltage limits for these surveys is included in the ERH
system design drawing package.
Once Part 11 of the internal TRS Safety Startup Checklist has been completed and approved,the site is
cleared for unattended operations and the system can be monitored and controlled remotely by
operations staff. Routine site visits will be conducted to perform site checks, equipment maintenance,
system optimization tasks, scheduled measurements and sampling activities. These routine visits will
occur daily during regular site hours and may be more frequent,dependent upon actual field
conditions encountered. As necessary,unscheduled site visits will be made to respond to variances in
operating parameters and system alarms.
During the heat up period, operational parameters such as power input, subsurface temperatures,
condensate production, and VOC concentrations in the recovered soil vapors will be measured. These
data will be used to assess the efficiency of the ERH system and allow TRS personnel to target
specific areas of the site and optimize the efficiency of the system. Periodically, electrodes, electrode
zones,or system operations will be reconfigured to control the amount and location of energy input to
the subsurface. These changes will be determined by TRS personnel based on review of operational
data collected and analyzed throughout the treatment operation.
It should be noted that this general operational plan is extremely variable. TRS will determine actual
operating parameters based on real-time data collected during operations. Operational decisions will
be determined to optimize the efficiency of the ERH system while maintaining the highest regard for
safety. The electrodes,piping, and system equipment have been designed to allow flexibility of
system operations.
The operational period of the ERH treatment system will continue until cleanup goals, as defined in
Section 3.0,have been met.
There are certain hazards associated with ERH during the remediation of soil and groundwater. These
hazardous include possible contact with hazardous voltage, steam,hot water, or hazardous chemicals.
Exposure to these hazards can be mitigated through engineering controls and strict adherence to
documented procedures and safety protocols, such as the following restrictions:
• Only trained,authorized personnel shall enter an ERH restricted area to complete project
tasking. If an ERH exclusion zone is created due to high voltage potential readings,no
personnel shall be permitted in this area during operations without authorization from the
TRS Project Manager(PM). Refer to the site-specific HASP for more information.
• At no time will a 110/120 volt extension cord from a line source be used in the equipment
area unless under the direction of TRS. An alternative power source such as a 12 volt
automotive battery or portable generator must be used.
• Outdoor work will cease in the event of an electrical storm. Personnel will seek shelter in a
metal building or enclosure if the potential for lightning strikes exist.
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• No drilling or digging shall occur within 100 ft. of any operating electrodes without written
approval by TRS.
5.3.1 Power Control Unit
PCU control and data acquisition are performed on a dedicated computer and associated
Ethernet-based controllers. Remote data acquisition software is used to collect and store subsurface
temperatures,power,voltage, amperage, and operational status data for the entire ERH system.
Offsite project personnel are able to view and download this information in real time using a high-
speed,wireless modem. The software also allows for control and/or monitoring of power application,
vapor condensation, and wastewater pumping functions. The PCU also is equipped with an
emergency stop (E-Stop)button on the outside of the PCU next to the main office entrance.
5.3.2 VR Blower
Blower operations,inspections and operational monitoring will be in accordance with TRS internal
O&M manual for blowers.Automated VR blower functions are monitored,controlled, and recorded
by the PCU computer. The VR blowers are safety interlocked to the PCU to shut down the
application of electrical energy to the subsurface should it cease to operate for any reason.
The blower is housed in a weather-tight steel enclosure that provides security and noise insulation.
When working on or around the blower,be aware of specific hazards which may include:
• Electrical hazards. There are two separate power supplies connected to each blower; one for
the main blower control power which is 3-phase,480 voltage alternating current(VAC) and a
separate 120VAC power supply for controls and interlocks. Always remove power and lock
out power to the blower when working on electrical devices. Be aware that interlock
electrical energy is likely provided from a different piece of equipment, such as the PCU.
• Vacuum/Pressure in Piping. The inlet piping to the blower will be under vacuums up to
12 inches of mercury(in Hg);these vacuums may become a hazard if piping ruptures. The
discharge piping of the blowers will be under pressure,and may become hazard if it ruptures.
Watch for leaks and any sign of piping fatigue when working on the blower and repair
promptly when discovered.
• Moving Parts. The motor and associated belts used to move air through the blower are
covered by a protective shroud,however, lock out and tag out procedures should be followed
when performing maintenance on the fan or its motor.Maintenance is the most reliable
method of minimizing repairs to a blower. Above all,a blower must be operated within its
specified rating limits,to obtain satisfactory service life.
5.3.3 Condenser
Condenser operations,inspections and operational monitoring will be in accordance with the internal
TRS Condenser O&M manual. The components of the condensers are housed in weather-tight, steel
enclosures that provide security and soundproofing. The condensers are interlocked to the PCU to
shut down energy application to the subsurface should they cease to operate for any reason. When
working around the condensers be aware of additional condenser specific hazards which may include:
• Electrical hazards: The main condenser control power is 480VAC (3-Phase).Always remove
power and lock out power to the condenser when working on electrical devices.
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• Steam &Heat hazards: During operation of the condenser steam and vapor at elevated
temperatures are continually being processed by the condensers and will elevate the
temperature of condenser process components. Be especially aware of the knock-out pots,the
heat exchanger, and any vapor stream piping.
• Pressurized Water/Piping hazards: The circulation piping used to cool the vapor stream and
the drip system piping used for electrode wetting is often under pressure and may become a
hazard if ruptured. Watch for leaks and any sign of piping fatigue when working in the
condenser and repair promptly when discovered.
• Slips and Trips: The complex network of piping contained in each condenser promotes
potential slip and trip hazards.Always move cautiously in and around the condenser and be
aware of slick and unstable surfaces. When inside the condenser building use the internal
walkways to access internal components.
6.0 INSPECTIONS AND MAINTENANCE
TRS will perform regularly scheduled inspections and maintenance on all equipment items for the
duration of ERH treatment, consistent with manufacturer's recommendations. Data gathered during
system monitoring,including visual inspections, may also indicate that additional maintenance will
be required. Each maintenance event will be recorded in an electronic log book that is specific to with
that piece of equipment. The log will include: the date the maintenance was performed,the task,parts
replaced, and who performed the task.
6.1 Inspections
Routine inspections by qualified personnel are an important component of TRS ERH treatment
system operations. Any concerns identified during inspections will be brought to the attention of the
TRS PM and an appropriate course of action,including repairs, shall be completed as soon as
possible.
6.1.1 Pre-Operations
Upon arrival to the project site and prior to installation, each tank and all ancillary tank support
equipment to be used during the operation of the ERH treatment system at the site was inspected for
the presence of weld cracks or breaks, scrapes of protective coating, and corrosion.No discrepancies
were identified.
Quality Assurance
Prior to start-up,the following QA checks will be completed:
• Inspect electrode installation and cable for damage and correct installation.
• Confirm that there are no flammable materials in the aboveground completion areas of the
treatment area.
• Ensure that the electrode over-sleeve, applicable only to above grades locations, is in good
condition.
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6.1.2 Daily Inspections
On a daily basis,personnel will confirm electronic data collection is occurring according to design.
This may be completed remotely by logging into the PCU. Based on available data,personnel will
also make any necessary changes to power application,vapor condensation, and pumping functions.
At the start of each work day,personnel will complete daily inspections of the ERH treatment system.
Daily inspections include completing visual inspection of the ERH treatment system equipment.
6.1.3 Weekly Inspections
As part of the Site HASP,personnel will complete a weekly work site inspection.During the weekly
visual inspections,personnel will also check the warning placards located around the site perimeter.
The"Danger High Voltage-Do not dig or drill" signs should be posted in English every 50'. Any
missing signage shall be replaced. The weekly inspection program also will include testing safety
interlocks of the security alarm system and routine inspections of the ERH treatment system
equipment.
6.1.4 Other Inspections
After large rain events, a thorough visual inspection of the site will be completed to ensure that no
water intrusion is causing poor ERH treatment system performance. VR performance will be
evaluated closely to confirm that the system is operating according to design parameters. Any
accumulated waters in the secondary containment area around the condenser and cooling tower will
be manually pumped through filtration filters and to the condensate treatment system. However,no
significant groundwater entrainment is anticipated at this site due to depth of vapor capture.
6.2 Condensers and Cooling Towers
Condenser and cooling tower operations,inspections and operational monitoring,trouble shooting,
and maintenance will be in accordance with TRS internal O&M manual. Internal manuals will not be
distributed digitally but will be available for review on site. Table 1-1 contains a maintenance
schedule for the condenser and the cooling tower. Close adherence to the schedule will increase the
life of the units and promote trouble-free operation.
Table 1-1.TRS ERH Condenser System Maintenance Checklist
Procedure Weekly or As Monthly
Needed
Condenser Maintenance Checklist
Inspect general condition of steam condenser. •
Check for surface corrosion of metal parts; interior and
exterior
Inspect Insulation for excessive wear,rips, or tears. •
Inspect heat exchanger for leaks. •
Inspect internal piping for leaks. •
Inspect recycle,blow down, condensate pumps for 0
security, leaks, excessive noise or vibration, and
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 11
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Procedure Weekly or As Monthly
Needed
excessive heat.
Inspect knock-out tank sight gage for damage and
transparency. •
Inspect/clean metal filter in"Y" strainer coming from
second knock-out tank(CAUTION: water may be •
hot!)
If applicable,inspect drip system filters for clogging and
filter housing for damage leaks. •
Inspect electrical connections for security. •
Cooling Tower Maintenance Checklist
Inspect general condition of cooling tower. •
Check water level in cold water basin. Adjust as
•
necessary.
Check float ball and make-up valve for proper operation. •
Check belt tension and general condition of V-belts. •
Add 1 gallon of bleach to the water in the basin(to
•
prevent mineral buildup).
Check the line voltage,motor amperage and fan wheel As needed
rpm.
Clean outside of blower motor to help assure proper
cooling. •
Lubricate blower bearings and fan motor using a low
pressure grease gun
Check blower wheel for dirt buildup which can cause
unbalance and vibration. •
Inspect and clean(rinse off)the low,high and high-high As needed
level switches.
Clean and flush cold water basin. As needed
Lubricate motor base and adjusting screw. As needed
6.3 Vapor Recovery Blower
Blower safety considerations, operations, inspections and operational monitoring,trouble shooting,
and maintenance will be in accordance with the TRS internal O&M manual. Basic maintenance
service needs are:
• Lubrication
• Checking for hot spots
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• Checking for increases or changes in vibration and noise
• Recording of operating pressures and temperatures.
Lubrication is normally the most important consideration and weekly checks of lubricant levels in the
gearbox and bearing reservoirs should be customary. Lubrication practices will be in accordance with
the manufacturer's instructions. Grease should be added to the drive end on the blower until new
grease comes out of the seals. The grease should be added using a hand-powered grease gun in order
to prevent damage to the seals by adding grease too quickly. The grease used for the blower drive end
and the motor bearings are not compatible. The blower motor should be lubricated with Shell Darina
II grease or equivalent lithium-base grease. In a belted drive system, check belt tension periodically
and inspect for frayed or cracked belts.
Table 1-2.Vapor Recovery Blower Maintenance Schedule
Procedure Weekly Monthly Bi-
monthly
Change oil after initial 1O0 hours of operation.
For blower with Grease Lubrication drive
ends, grease bearings with Shell Darina II. •
Check hour meter. Change oil every 2000
hours. •
Check lubricant levels in the gearbox and
bearing reservoirs •
Inspect inline filter housing. Replace
quarterly or more frequently if necessary. •
Inspect for surface corrosion. •
Inspect overall condition of blower(new,
worn, safety hazard, etc.). •
Inspect bolt/fittings for tightness. •
Check for Hot Spots. •
Check for increases or changes in vibration
•
and noise.
Inspect V-belts for damage/wear. Replace if
necessary.
Inspect Air Filter for serviceability. Replace
if necessary. •
Lubricate electric motor with Mobile
•
Polyrex grease.
Add grease with hand-powered gun to drive
end until new grease comes out of the seals •
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7.0 SAMPLING AND MONITORING PLAN
Data monitoring, collection, and management are critical components of the project. These activities
provide the information necessary for the project team to make informed decisions concerning the
safe, efficient,and effective operation of the ERH system. The types of sampling and monitoring to
be completed include:
• ERH treatment system operation data(electronic and manual), including pressures throughout
the treatment system and flow rates and total flows of both liquid and vapor phases.
• Amperage Surveys.
• Voltage Surveys.
• Noise Monitoring.
• Permit compliance sampling and monitoring.
The ERH system sampling schedule and laboratory method list is discussed in the Quality
Assurance/Quality Control(QA/QC)plan included as Appendix 1 of the May 2014 Design Report.
7.1 Electronic Data Collection
Electronic data collection will involve the use of a Windows-based personal computer to record
measurements at specified time intervals. The types of parameters to be monitored electronically
include information concerning energy input to the subsurface, subsurface temperatures, and the
treatment system vapor flow rate.A list of data parameters that are measured electronically is
presented in Table 2-1. To support the reporting requirements of the project, electronic data will be
transferred to a project database at regular intervals.
Table 2-1.Electronic Data Monitoring and Collection Points
Monitoring Location Units Instrument Monitoring Recording
Volts Continuous Daily
Amps Continuous Daily
Power Control Unit Electronic
kW Transducer Continuous Daily
kWh Continuous Daily
Vapor Stream Total Flow scfm Pitot tube and Continuous Daily
transducer
Field Vacuum
in Hg Analog gauge Continuous Daily
VR System Pressure
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 14
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Monitoring Location Units Instrument Monitoring Recording
PCU Transformer Room
PCU Control Room
Vapor Stream Temperatures Type"T"
Heat Exchanger Temperature
�C thermocouple
Continuous Daily
Stack Temperature
Subsurface Temperatures
7.2 Manual Data Collection
Manual data collection will be performed at monitoring locations that cannot be fitted with an electronic data
logger or where electronic data logging is not appropriate because the parameters change very slowly.In
general,temperature,electrical parameters,and flow conditions are collected electronically,while data such as
process pressures and flow are collected manually using a gauge. Table 2-2 identifies the measurements
collected manually,instrumentation used,and the frequency of monitoring.
Table 2-2.Manual Data Collection
Measurement Instrument Monitoring
System Component Temperature
VR System Pressure
Heat Exchanger Temperature and
Pressure
Analog gauge Daily
Cooling Tower Temperature and
Pressure
Condensate Discharge
Field vacuum
VR System Total Flow Pitot tube and MagnehelicTM Daily
System and Ambient Air Photoionization detector Daily
Monitoring
Electrode Drip(Total)
Condensate Production(Total)
Flow Totalizer Daily
Treated Liquid(Total by LGAC)
Cooling Tower Blow down(Total)
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Measurement Instrument Monitoring
Potable Water Usage(Total)
Noise Monitoring Handheld Sound Level Meter Periodically
7.3 Amperage Surveys
Electrode amperage surveys will be conducted frequently during start-up operations and at least
weekly throughout system operations in order to prevent electrode cable over-current. Because
changes in current to individual electrodes generally occurs slowly,trends developed from the
amperage surveys will be used to identify potential issues and implement resolutions.
TRS will monitor and evaluate the performance of each electrode at a minimum of once per week
during operations. The electrical current to each electrode will be measured using a standard
clamp-on ammeter. TRS will determine each electrode's performance based on voltage, current,
power density,power flux, and energy values. These data will not be reported,but are deemed
essential internal information for the optimization of the technology.
7.4 Voltage Surveys
The purpose of voltage safety tests is to identify the location(s) of possible voltage hazards on or
directly adjacent to an operating ERH site. As described in Section 5.3 of this section,voltage surveys
are completed during start-up operations immediately following each increase of power applied to the
electrodes. During operations,voltage surveys will continue on a weekly basis or any time an energy
application increase is made to confirm that conditions have not changed at the site. Personnel will
check locations of interest identified during voltage surveys performed during start-up and any new
points of interest.
The baseline and subsequent voltage survey shall include a minimum of 20 locations on the entire
perimeter fence and locations along the loading dock to the west and north outside of the ERH fence.
All areas that have pedestrian traffic or human interface will be checked for surface voltage. TRS also
will measure the voltage potentials on equipment and all gates. Should voltage potentials exceed the
TRS electrical safety policy limit, energy input into subsurface will be discontinued and mitigation
will be performed.
The TRS voltage limit applies a margin of safety beyond the Occupational Safety and Health
Administration(OSHA)limits and greatly reduces the possibility of an electrical safety incident
occurring during the application of ERH. A map of the specific voltage limits per site area is included
in the design drawings of the ERH Design Report.
If any voltage safety measurement indicates more than the maximum allowed voltage,use
engineering controls to achieve the TRS Electrical Safety Standard. Some typical engineering
controls to consider are:
• Isolation of locations exceeding the TRS Safety Limit by insulating or directly enclosing.
• Isolation of locations exceeding the TRS Safety Limit by restricting access to all personnel
when power is applied by establishing an ERH exclusion zone.No personnel shall enter an
ERH exclusion zone during ERH power application.
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• Isolation of locations exceeding the TRS Safety Limit by restricting access to only qualified
personnel when power is applied by establishing an ERH restricted zone.
• Creation of an equal potential zone to protect a worker standing within it from hazardous step
and touch potentials. Equipotential zones will not,however,protect employees who are either
wholly or partially outside the protected area.
If use of these engineering controls does not mitigate the high voltage safety concern, consult with
site management for an adequate and safe solution.
7.5 Noise levels
The Site is located within an operating manufacturing facility occupied by Moog. There are offices
and occupied buildings within a few feet of the ERH equipment area.Noise from the operation of
system equipment will comply with all local noise ordinances. A decibel meter will be used to ensure
noise restrictions are adhered to during construction, operation and demobilization of the ERH
system. Although no noise restrictions are set forth in the scope of work, TRS will strive to achieve a
90 decibel maximum noise tolerance at the fence line.Decibels measured inside the Moog facility
will be limited to 70 decibels that are directly related to ERH operations.
The 40-hp VR blowers and the ERH condensers used at the site will be enclosed in steel structures
lined with noise-reducing materials. These enclosures are specifically designed to lessen the
equipment noise and prevent excessive noise from emanating outside them. If decibel level limits are
exceeded at the site, additional sound abatement measures,including secondary enclosures and/or
sound reflection walls,will be used to comply with any noise ordinances.
To further assist with noise abatement,the ERH equipment compound will be surrounded by a metal
or wood fence with privacy screening that will act as a sound barrier.
Decibel meter readings will be collected and recorded during, operations to ensure that the total sound
pressure level in A-weighted decibels will not exceed nuisance levels.
7.6 Vapor Recovery Monitoring
During the operational phase of the project,the influent vapor stream(post-condenser)and the
treatment effluent stream will be sampled on a continuous basis; weekly with a summa canister and
each day TRS personnel is onsite. The summa canisters will be sampled by a lab and Tedlar bags in
the field using a photoionization detector(PID). The data collected will be used as a relative measure
of system performance. Analytical sampling will be performed based on air permit and/or guidelines.
7.7 Confirmatory Sampling
Confirmatory ground water sampling will be performed when the project team determines that clean
up goals have been achieved. There are key indicators that will determine when confirmatory
sampling takes place. The key indicators are VOC concentrations in air trended over time and energy
input. When the VOC concentrations in air have been reduced significantly and the estimated energy
input has been achieved, TRS will recommend that the ground water and soils be sampled per the
evaluation period in the scope of work.
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 17
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8.0 REPORTING
8.1 Weekly Reporting
Once into the operational phase,a weekly summary report of system operations will be submitted
electronically to the project team. In general,process data contained in this deliverable shall provide a
high level summary of system operation that can be used to update stakeholders on system progress.
Data included in the weekly summary report will contain:
• Information and data collected to date in written,tabular, and graphical format.
• VOC extraction rates and cumulative mass extracted.
• Hours of system operation.
• Summary of system uptime/downtime data and any adjustments.
• Electricity usage documentation.
• Subsurface and process monitoring data.
• Vapor treatment system data.
• Water disposal information.
• Planned future activities.
A secure project Web page will be constructed to allow project personnel to view recent site data and
to track the ERH remediation progress. Relevant site data will be collected,recorded, and uploaded to
the secure project Web page.All data will receive a quality control review to evaluate atypical,
irregular, and unexpected measurements. The results of these evaluations will be noted where
appropriate.
8.2 Compliance Reporting
Any air or water discharge reporting will be completed by TRS.
8.3 Final Report
A final report will be submitted in electronic form after all work has been completed at the site. The
report will include a narrative describing system design,permitting, installation, operation, sampling,
and decommissioning, and will provide as-built system drawings. The report will provide all system
data including process flow rates and flow volumes, contaminant mass removed, energy consumed,
and other relevant data. The report will document system performance and the achievement of
specified cleanup goals. Supplemental information pertinent to the construction and operation of the
treatment system such as construction logs, QA/QC inspections,boring logs, system drawings, and
equipment specifications,process monitoring records,operations logs, and system photographs will
also be incorporated into the report.
9.0 WASTE MANAGEMENT
When possible,waste materials will be recycled. Over the full course ERH treatment system
operations and associated sampling and maintenance activities,the waste streams that will be
generated include:
• Treated condensate and groundwater.
• Spent LGAC or VGAC, if applicable
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 18
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• System construction and decommissioning waste.
• Used personal protection equipment.
• General trash.
• Soil cuttings
• Trench spoils.
Operations waste generated during ERH will consist of treated groundwater, condensate, and spent
GAC. Treated groundwater and condensate requiring disposal will be sent to the onsite treatment
facility. The GAC vendor will transport and manage the used GAC by direction of TRS.
System construction and decommissioning waste will consist primarily of VR and water piping,
which is cut into manageable pieces and placed into a solid waste bin. This non-hazardous waste will
be combined with general,non-recyclable trash for disposal at a local landfill.
Personal protective clothing waste items will be segregated from the general trash waste stream and
will be evaluated for proper disposal. It is not anticipated that these items will be significant in
volume nor will they be classified as hazardous wastes.
10.0 SECURITY AND SITE ACCESS CONTROL
A chain-link security fence will be installed entirely around the electrode field and ERH equipment
prior to starting operations of the ERH equipment. This fence will inhibit entrance by unauthorized
personnel. Fencing will be located such that step-touch electrical potential measured on the fence
does not exceed 15 volts. TRS personnel will survey and document voltage at the perimeter of the
electrode field restricted zone.
To prevent injury to unauthorized personnel during operations, a motion detection security system
will be installed surrounding the ERH electrode field.As a crucial site safety component,when the
alarm to the PCU is triggered, it will instantly de-energize the electrode field. This component of the
security system will protect a possible intruder from injury. If unauthorized entry is detected, and the
PCU is shut down,an automated phone dialer will notify TRS personnel that the system was shut
down due to a security breach. If the shutdown was due to a false alarm,the system will be remotely
restarted following inspection using the security cameras and/or field personnel. If a true security
breach is observed,the local police department will be called to inspect the treatment area to ensure
the intruder is gone. Upon confirmation from the local police department,TRS may either restart the
system remotely or mobilize to the site to give the site a visual inspection prior to manually turning
the system back on.
11.0 HEALTH AND SAFETY MANAGEMENT
The project-specific HASP, included as Appendix 3 of the May 2014 Design Report, identifies the
policies and procedures to be implemented to protect Site workers and visitors. The plan complies
with the provisions of 29 Code of Federal Regulations(CFR)Part 1926 and 1910.
The HASP establishes, in detail,the protocols necessary for protecting workers, on-site personnel,
visitors, and potential off-site receptors from potential physical and chemical hazards encountered
during Site activities. Personnel shall be specifically briefed on hidden slip,trip,and fall hazards. All
field personnel, including subcontractor staff,that may have contact with Site soil, groundwater, soil
vapors or treatment residuals,will be qualified OSHA certified 40-hour Hazardous Waste Operations
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 19
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and Emergency Response Standard workers. This requirement includes maintaining annual 8-hour
refresher training,24-hour, on-the-job training,participation in a medical monitoring program, and 8-
hour specialized training for supervisors per 29 CFR 1919.120. Personnel working on or around
panels during ERH system operation will complete a National Fire Protection Association 70E Arc
Flash Safety Training course. An individual certified in basic first aid and CPR and trained in OSHA
Blood Borne Pathogen Standards will be on-site at all times when TRS team members or
subcontractors are present.
Prior to energizing the ERH system, a two-step Site Safety Inspection will be performed to ensure
personnel safety at the time of initial power application. The first phase of this inspection
demonstrates that all design safety features have been completed and are operating properly prior to
applying power to the subsurface. Examples of these safety features include access guards, interlocks
between system components, over level gauges, over temperature gauges, and power kill switches.
With the first phase of the inspection satisfactorily completed,the ERH system will be energized, and
the second inspection phase initiated. During this phase of the inspection,compliance with allowable
surface voltages under operating conditions is verified at increasing energy application voltages.
Surface voltage readings are recorded until the design input energy is reached. Any issues with
surface voltages above the TRS allowable limits will be resolved prior to unattended operation of the
ERH system.
The PCU is equipped with an emergency stop(E-Stop)button on the outside of the PCU next to the
main office entrance. Pressing the E-Stop button will immediately open the PCU disconnect and
power application to the electrodes will cease. Personnel will push the E-Stop button if the following
situations exist:
• Fire or indications of fire(e.g. smoke or heavy sparking) in the electrode field
• Fire or indications of fire(e.g. smoke or heavy sparking) in any ERH equipment
• Injury of any person in the ERH restricted zone due to electrical shock
• Any sparking or arcing in the electrode field.
12.0 REFERENCES
TRS Design Report May 2014, Murphy,NC.
Exhibit B Scope of Work,March 2013 Former Clifton Precision Facility
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 20
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Figures
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 21
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PRELIMINARY- DO NOT
USE FOR Li Wo1«TO�k MACHINE SHOP
CONSTRUCTION
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Figure 1. General Site Plan
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 22

PRELIMINARY- DO NOT
USE FOR
CONSTRUCTION
REFER TO DRAWING SHEET P-7
F-------� -----------
AIR ?0 I
I
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ATMGGPHERE
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-------- ----- ----- ---�
REFER TO DRAWING SHEEP P� REFER TO DRAWING SHEET P-S REFER TO ORA7MNG SHEET PF
r ---------------7 r-------------- --, r ------------------------7
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TRy Y VAPOR RECOVERY AND CONDENSING
A.0-61q%h. PROCESS FLOW DIAGRAM
P2
Figure 2. Process Flow Diagram
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 23
TRS

,ZN
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PRELIMINARY- DO NOT
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NOTES
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w�Nrm�narcn lrancuerracrxx ELD
AO PRaGE55 AND INSTRUMENTATION❑IAGRAM
w P-0
Figure 3a. Process and Instrumentation
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 24
TRS

PETER iO PRAWING
W Lw.HG WARR TO
CCOLIHC TC/LER
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USE FOR s TI
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NOTES: raraEr.cuEmn Puc«,oP..rA�m
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P�
Figure 3b. Process and Instrumentation
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 25

0
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NOTES:
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m P-6
Figure 3c. Process and Instrumentation
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 26

n��RT
TMnaPxexe
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VALVE
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TRS xo wNo ec INSTRREA7MENT
Arcekraang l0fue � PROCESS AND INS7Ru nREN7HrI0N DIAGRAM
P-7
Figure 3d. Process and Instrumentation
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 27
TRS

lzazlu ollaa Nu
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PIXE OP
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USE FOR NOT1.E_ ONE-LINE DIAGRAM
Att5lRmting YGW w
CONSTRUCTION .-NN
6. M-11
Figure 4. Electrical One-Line
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 28
TRS

PRELIMINARY - DO NOT
USE FOR
CONSTRUCTION
VERTICAL ELECTRODE
ELECTRODE CABLE
caouND SURFACE
—— NEAT CEMENT GROUT
—— (5 GAL/90 LE)
J¢"REX PIPE
- 3'CPVC PIPE
SHARKBITE COUPLER
3"CPVC FEMALE ADAPTER
3'STAINLESS STEEL SCREEN
}4'COPPER DRIP TUBE
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——— 2'STEEL COUPLER
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3
—— i
4
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4'
2"K 21' STEEL PIPE
—— 5
5• CONDUCTIVE BACKFILL
8
2'STEEL CAP
-- 6'
10 O.D. REFUSAL
SZ GROUND WATER
BORING WIDTH EXAGGERATED FOR DETAIL
MARBLE ALL MATERIAL INSTALLED BY TREMMIE
BEDROCK BELOW THE WATER TABLE
oEds�o� n soaMancuFrou orsecisioN.ncam
—PN. DNA
TRS °aE
No.nvaeoveo VERTICAL ELECTRODE DETAIL
Accefemting Value mwmnN
M-2
Figure 5. Electrode
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 29
TRS

VERTICAL BEDROCK ELECTRODE PRELIMINARY - DO NOT
ELECTRODE CABLE USE FOR
GROUND SURFACE
CONSTRUCTION
—— NEAT CEMENT GROUT
—— (5 GAL/90 LB)
——— - JI{ PEX PIPE
�3°CPVC PIPE
-
-_—_ X2°SHARKBITE COUPLER
3°CPVC FEMALE ADAPTER
3°STAINLESS STEEL SCREEN
Yz°COPPER DRIP TUBE
—_—_ 3°CAP
SAPROLITE ——
2� 2°X 10.5' STEEL PIPE
2°STEEL COUPLER
Q 25, 3 SAND
——— 2"X 21'STEEL PIPE
2'STEEL COUPLER
41
2°X 21'STEEL PIPE
—— c55LCONDUCTIVE BACKFILL
2"STEEL CAP
6'
—— #3 SAND
-- CONDUCTIVE BACKFILL
7.
—— METAL PLATE
7'
MARBLE
BEDROCK
4 GROUND WATER sm
BORING WIDTH EXAGGERATED FOR DETAIL 10 O.D. EXTEND ELECTRODE 10' INTO BEDROCK
ALL MATERIAL INSTALLED BY TREMMIE
BELOW THE WATER TABLE
TRS oPoRm VERTICAL BED
ROCK
Aaelemf/ng Value ELECTRODE DETAIL
M 1
Figure 6. Bedrock Electrode
MUR55 OPERATION AND MAINTENANCE PLAN 051914 ACF 30
TRS

TRS STANDARD OPERATING
PROCEDURE
AWge.tft lam PROCEDURE No: 1.1
Procedure Title:
Lockout/Tagout (LOTO)
Author: TRS Team Issue Date: 5/7/08
Revisions:
Date Initials Revision Descri tion Revision#
06-23-09 LS Add PCU;changes throughout 1
12-13-10 LS Update responsibilities;minor language changes;different PCUs 2
Reviewed and Approved by(initial and date):
SOP/Revision# Health& Safety Operations
Original 5/7/08 5/7/08
REV 1 7/14/09 7/14/09
REV 2 �12/13/10 °"` 12/13/10
0
� t
DO NOT
OPERATE
EQUIPMENT
LOCKED OUT
'his 1 uL 1;1.dN nip truly L�r�n¢vud hy:
M1W1R:
Me:--------- afFl--------------
Fa treed Cam khan Pala.-----------
SOP 1.1 Lockout/Tagout REV 2 1 7� TR5

1.0 PURPOSE
This procedure establishes the standard lockout/tagout(LOTO)practices for isolating hazardous energy
sources whenever maintenance or servicing is done on machines or equipment at an electrical resistance
heating(ERH) site. The procedure details work practices to prevent the unexpected or unintentional
energization or start-up of machines or equipment or release of stored energy which could cause injury.
This LOTO procedure is written in accordance with 29 CFR 1910.147, 1926.417 and 1926.702.
2.0 SCOPE
Only personnel trained to the minimum requirements outlined in Section 7.1 of this standard operating
procedure(SOP)are authorized to conduct LOTO procedures. Authorized employees are required to
perform the lockout in accordance with this procedure.All TRS personnel and subcontractors working on
TRS projects are required to comply with the restrictions and limitations imposed upon them during the
use of LOTO. All personnel,upon observing a machine or piece of equipment which is locked out to
perform servicing or maintenance shall not attempt to start, energize, or use that machine or equipment.
All personnel shall use TRS LOTO devices(locks and tags) for the purpose of applying LOTO in
accordance with these procedures and for no other purpose. This procedure applies to all potential energy
sources/hazards. Some examples include:
• Work within electrically conductive portions of the ERH treatment area. To prevent serious
injury or death,when performing ANY intrusive tasks,ALL power to the field must be off.
Intrusive tasks may include work involving electrical power cables, electrode heads, or other
conductive portions of the ERH treatment area(and 50' surrounding). If there are two or
more power control units(PCUs) operating in tandem,ALL PCUs must have power to the
field turned off.
• Guards to be removed from powered machinery
• Work that requires entry(or putting hands,head, etc.)into any space where the moving parts
of powered machinery are exposed.
• Maintenance or inspection of pressurized vessels, compressed air tanks, or tanks containing
high temperature liquids
If the device being locked out is a plug device(e.g.power tools), LOTO procedures are not required as
long as the plug is under the exclusive control of servicing personnel.
The procedures outlined within this document are intended to serve as a guideline for site specific
activities for authorized persons trained per applicable Occupational Safety and Health Administration
(OSHA)requirements,proper use of site specific equipment,potential hazards, and site specific
documents including health and safety plans(HASPS). TRS does not assume responsibility for
unauthorized personnel using this document.
SOP 1.1 Lockout/Tagout REV 2 2 TRS

3.0 DEFINITIONS
Affected personnel—Any personnel whose job requires him/her to operate or use equipment on which
servicing or maintenance is being performed under lockout or tagout, or whose job requires
him/her to work in the area in which these activities are being performed. Affected personnel
must have received training on proper LOTO work procedures.
Authorized employee—Any designated employee who applies lockout or tagout equipment in order to
perform servicing or maintenance. This person must have completed the mandatory LOTO
training to be qualified as an authorized worker. Only an authorized worker installs and removes
his or her own lock and tag as required by this program.
Energy source -Any source of electrical,mechanical,hydraulic,pneumatic, chemical,thermal, stored or
other energy.
Energy isolating device—Device that prevents the transmission or release of hazardous energy or
hazardous materials. For LOTO purposes,isolating devices that provide visible indication of the
device's position are desirable. Examples include restraint blocks, electrical circuit breaker toggle
lockout device, disconnect switches, slide gates, slip blinds,or line valves.
ERH—Electrical Resistance Heating. ERH is a process whereby soils and groundwater are heated by
passing an electrical current through the subsurface volume to be remediated.
Lockout-The placement of a keyed device("lock") on an energy isolating device, in accordance with this
procedure,to prevent the unwanted activation of mechanical or electrical equipment. Lockout
ensures the equipment being controlled cannot be operated until the lock is removed.
Tagout-The practice of using tags in conjunction with locks to increase the visibility and awareness that
equipment is not to be energized or activated until such devices are removed. Tags cannot be
inadvertently or accidentally removed.
4.0 EQUIPMENT LIST
1) Applicable site specific design,installation and safety documents including process flow
diagrams (PFDs), Health and Safety Plans(HASPs),Activity Hazard Analysis(AHAs), and
workplans.
2) PPE appropriate for the Site. Refer to site specific HASP.
3) Site-Specific LOTO logbook forms and pen (recommend indelible). The logbook form is
included as an attachment to this SOP.
TRS
SOP 1.1 Lockout/Tagout REV 2 3

4) Individual locking device. Pictures of locks used by TRS are included in Section 5.3. These
locks can ONLY be used for the purpose of applying LOTO.
5) Tagout device. Tags are generally red in color with wording such as "DANGER-DO NOT
OPERATE" and must be able to withstand chemical and weather exposure. A picture of a
standard tag used by TRS is included in Section 5.3.
NOTE: Lockout devices and tagout devices shall be singularly identified; shall be the
only devices(s)used for controlling energy; shall not be used for other purposes; and
shall meet the following requirements as defined by 29 CFR 1910.147(c)(5)(ii): durable,
standardized, substantial, and identifiable.
6) Device used for attachment of tag. Device must be a non-reusable type, attachable by hand,
self-locking, and non-releasable device with a minimum unlocking strength of no less than 50
pounds(equivalent to a one-piece, all environment-tolerant nylon cable tie).
7) Snips or similar tool for safe removal of tagout device.
5.0 LOCKOUT/TAGOUT PROCEDURES
LOTO is performed in accordance with the following sections. Always keep non-essential personnel
away from the site until normal conditions have been established.
5.1 Prepare for Shutdown
1) Prior to commencing LOTO procedures, the Site Health and Safety Officer (SHSO) or TRS
staff member on-site must be notified. If there are no TRS personnel onsite, contact the site
Project Manager (PM) by telephone. The telephone number for the site contact is posted
inside the PCU office.
2) If this is an initial LOTO out for a piece of equipment or machinery, use the buddy system
and approach the situation in a way which minimizes your exposure to hazards. Use the
"Hazardous Energy Assessment" form at the end of this SOP to establish the energy hazards
associated with the equipment or machinery.
3) An authorized employee must determine which equipment requires LOTO. All operating
PCU's must be shut down and LOTO procedures applied if ANY intrusive tasks are to be
completed within conductive portions of the ERH treatment area(and 50' surrounding).
4) Notify all affected employees that servicing or maintenance is required on a specific machine
or equipment or within the ERH treatment area and that the machine or equipment must be
shut down and locked out to perform servicing or maintenance.
5.2 Shut Down and Isolate Equipment
5) The initial lockout/tagout log entry must be made in the project field notes. Note the repair or
maintenance being performed.
6) Shut down all affected machines or equipment in operation using the normal operating
controls or shutdown procedures(e.g., depress stop button,open switch, close valve). NOTE:
If affected equipment is located within the ERH treatment area, follow LOTO procedures
SOP 1.1 Lockout/Tagout REV 2 4 T

first for the PCU(s) in operation and then for the affected equipment. DO NOT enter the
ERH electrode field to complete ANY intrusive work until all PCUs have been locked
out and tagged out according to this SOP, all residual energy has been dissipated, and
voltage testing indicates it is safe to enter.
700 PCU Shutdown
a) Request the responsible TRS person to open contactor via the PCU control computer.
b) Turn the key to the"Disabled"Position. Remove the key and keep on your person. If
more than one person requires LOTO of the PCU, follow instructions in Section 5.8
for group LOTO procedures.
c) Follow procedures for Tagout in Section 5.3.
77
�TACroR
b0lfrRpL upCE crnlrnw
CONTROL MOpE OOM�iACTpR
MAN �Orx more [8a.�easex, LOCAL REMOTE �
DW
MpR11pL BYPASS
PHASE C aPHA .
2000 PCU Shutdown
a) Request the responsible TRS person to open contactor via the PCU control computer.
b) Prior to entering the ERH electrode field to perform ANY tasks, depress the RED
disconnect switch on the electrical control panel in the PCU office.
c) Remove the key and keep on your person. If more than one person requires LOTO of
the PCU, follow instructions in Section 5.8 for group LOTO procedures.
d) Follow procedures for Tagout in Section 5.3.
Do NOT}
LpF
-Ft ATE
a.w
SOP 1.1 Lockout/Tagout REV 2 5 ;� TR5

4500 PCU Shutdown
a) Request the responsible TRS person to open contactor via the PCU control computer.
b) Prior to entering the ERH electrode field to perform ANY tasks, depress the RED
disconnect switch on the electrical control panel in the PCU office.
c) Remove the key and keep on your person. If more than one person requires LOTO of
the PCU, follow instructions in Section 5.8 for group LOTO procedures.
d) Follow procedures for Tagout in Section 5.3.
�u ason=r
7) Activate the energy isolating device(s) so that the equipment or machine is isolated from the
energy source(s). For example, when tasking involves work on the ancillary equipment panel
at an ERH site, use a circuit breaker energy isolating device as shown below to prevent the
accidental switch of the circuit breaker to the"on"position.
8) If equipment is to be serviced, unlock the cover to the circuit box and turn off the disconnect
switches to the specific equipment being repaired or maintained. Ensure that a disconnect
switch, circuit breaker, valve, or other energy-isolating mechanism is in the SAFE or OFF
position.
5.3 Apply LOTO Devices
9) Lock and tag each energy isolating device with assigned individual locks/tags.
Each Lock
comes with'
only one _
keyY.
' MND to to `f- lo��
oc 60 axon nur ouT 4
u Mm I[40YI CD 10 RM61 (M lion RAW..:.
rti
TRS
SOP 1.1 Lockout/Tagout REV 2 6 r

10) Each authorized individual conducting maintenance or servicing must attach his or her lock
and tag to each energy-isolating device.
11) If utilizing energy isolating devices within a circuit box, lock the cover to the circuit box.
Each lock comes with only one key. Only the authorized employee who unlocked the circuit
box cover should retain the key.
12) Attach a weatherproof Tag to the lock with tagout device.
C)
DO NOT
OPERATE
EQUIPMENT
LOCKED OUT
RYIiW�Y■Y�H11 Y W i1r�
13) Record LOTO application in the LOTO logbook (attached to this document). The following
information should be recorded in the logbook and maintained on site with the site-specific
health and safety plan(HASP):
a) Name and signature of the individual who shut off the disconnect switches and is
performing the maintenance on the equipment.
b) Name of senior TRS person authorizing LOTO.
c) Equipment/Location of LOTO application.
d) Explanation of the work performed on the remediation equipment.
e) Time and date of lock out.
5.4 Control Stored Energy
14) All hazardous energy sources will need to be controlled. Ensure the correct piece(s) of
equipment is shutdown.
15) Potential energy must also be dissipated or minimized so that injury will not occur if released.
Stored or residual energy (such as that in capacitors, springs, elevated machine members,
rotating flywheels, hydraulic systems, and air, gas, steam, or water pressure, etc.) must be
dissipated or restrained by methods such as grounding, repositioning, blocking, bleeding
down, etc.
16) Where the possibility of induced or stored electrical energy exists, ground the phase
conductors or electrical circuit parts before touching them. Where it could be reasonably
anticipated that the conductors or circuit parts being de-energized could contact other
exposed energized conductors or circuit parts, apply ground-connecting devices rated for the
available fault duty.
TR5
SOP 1.1 Lockout/Tagout REV 2 7

5.5 Check Safe Condition
17) Ensure that the equipment is disconnected from the energy source(s)by first checking that no
personnel are exposed,then verify the isolation of the equipment by operating the push button
or other normal operating control(s) or by testing to make certain the equipment will not
operate. Caution: Return operating control(s) to neutral or "off' position after verifying the
isolation of the equipment.
18) Use an adequately rated voltage detector to test each phase conductor, or circuit path, to
verify they are de-energized. Before and after each test, determine that the voltage detector is
operating satisfactorily.
19) Document verification of"zero"energy in LOTO logbook.
5.6 Release from LOTO
20) After task completion, the authorized employee shall confirm that all tools and equipment
used during LOTO are accounted for and placed in a safe location.
21) If work was conducted within the ERH treatment area, the Authorized Employee will verify
that it has been returned to operational condition. The authorized person will conduct tests
and visual inspections, as necessary, to verify that all tools, electrical jumpers, shorts,
grounds, and other such devices have been removed.
22) The SHSO or TRS staff member on-site must be notified before removing LOTO devices. If
there are no TRS personnel onsite, contact the site PM by telephone. The telephone number
for the site contact is posted inside the PCU office.
23) Notify affected employees that the lockout devices are ready to be removed. If energizing the
ERH area, all personnel must move to positions away from the ERH treatment area prior to
the removal of LOTO devices. Document in LOTO logbook that these pre-release steps have
been completed.
24) Verify all equipment controls are in neutral positions.
25) Remove LOTO devices. Each device must be removed by the person who attached it.
26) Re-energize the machine or equipment. The disconnect switch for the PCU should be turned
on by inserting the key and turning it until the switch pops into the "out" position. The
responsible TRS person will then close the contactor via the PCU control computer.
27) Document Date and Time of LOTO removal. Confirm that equipment is functioning
properly.
5.7 End of Shift Procedures
If only one shift or individual is to work on the equipment or machine,the attached locks/tags remain in
place until maintenance/servicing is complete. If another shift continues the maintenance or service,the
authorized individuals from the off going and on-coming shifts conduct a turnover of the task. The off-
going shift personnel remove their locks and tags, and the on-coming shift personnel install their own
locks and tags in accordance with the LOTO procedure.
TRS
SOP 1.1 Lockout/Tagout REV 2 8

hi the event that team members will not be present at the project site at the same time and there is no
ability to manually swap locks at the same time,the original LOTO owner shall place the lockout key in
the site's key lockbox(i.e. the lockbox used to store the spare PCU door key and gate access keys). This
person shall notify the PM of the equipment lockout and key placement before leaving the site. The new
owner shall contact the PM prior to retrieving the key to confirm any changes in status. If there are no
changes,the new LOTO owner shall follow the steps to confirm proper LOTO of the equipment and
replace the previous LOTO devices with his or her own set.
5.8 Group LOTO
In the event that more than one individual requires the application of LOTO to a piece of equipment, a
group lockout procedure may be used. This can be accomplished by having one authorized employee
follow normal LOTO procedures and attach his/her lock(s)to the equipment. This authorized employee's
keys are then placed into a master lockbox. Each authorized employee affixes a personal LOTO device to
the group lockbox when work begins and removes those devices when work ceases on the machine or
equipment being serviced or maintained.
Where service or maintenance must be performed by non-TRS personnel during LOTO,the SHSO and
PM will review the project LOTO program with each subcontractor's safety representative during the
onsite safety training and inform the authorized and affected employees about any differences in the two
companies'procedures that may cause confusion.
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SOP 1.1 Lockou /Tagout REV 2 9 TRS

6.0 RESPONSIBILITIES
Role Responsibility
TRS Technical Group . Develop and implement LOTO program.
Lead . Periodically review and update program based on audit findings and
project feedback.
TRS Health and . Provide training and maintain documentation.
Safety Officer(HSO) . Reinforce the need to comply with requirements.
. Audit the effectiveness of LOTO program.
PM • Responsible for enforcing LOTO procedures on site.
• Conduct unscheduled field checks on use of LOTO.
. Maintain list of Authorized Employees.
. Ensure documentation of LOTO is maintained.
SHSO . Assist in implementation of LOTO onsite.
• Conduct orientations for subcontractors and employees.
• Coordinate training needs with TRS HSO.
. Assist with oversight of LOTO documentation.
. Review subcontractor LOTO plan and coordinate efforts.
Authorized Employees . Comply with LOTO procedure requirements.
. Install and remove your own LOTO devices.
. Do not install or remove another person's LOTO devices.
Affected Employees . Comply with LOTO procedure requirements.
. Do not install or remove another person's LOTO devices.
Subcontractors . Comply with LOTO procedure requirements.
. Do not install or remove another person's LOTO devices.
. Train subcontractor employees on LOTO procedures.
7.0 TRAINING
Training is an important component of the LOTO program to ensure that employees understand the
purpose of the program and to provide employees with the skills and knowledge to perform work safely.
Training for affected personnel and authorized employees is provided upon initial assignment and
annually thereafter.Additional retraining is provided if there is a change in equipment or procedures or if
inadequacies are observed in the individual's application of LOTO procedures. Subcontractors must train
their own employees.
7.1 Authorized Employees
Authorized employees receive annual training and testing on the purpose and use of the LOTO program.
Refresher training is to be provided by the TRS HSO. In addition to this basic training, authorized
employees are trained on site in the recognition of applicable hazardous energy sources,the type and
magnitude of energy available in the workplace,and the methods and means necessary for energy
SOP 1.1 Lockout/Tagout REV 2 10 7

isolation and control.Authorized personnel in LOTO are determined by the ERH PM and must, at a
minimum, complete the following requirements:
• Read this LOTO SOP and understand the general LOTO process and the specific
requirements of this SOP.
• Complete annual training on the purpose and use of the LOTO program as prescribed by the
TRS health and Safety Officer.
• Obtain onsite instruction by a knowledgeable person on the site-specific hazards related to the
control of hazardous energies.
• Be qualified and trained to perform the tasks requiring the use of this procedures.
• Sign the acknowledgement form attached to this SOP.
7.2 Affected Personnel
Affected Personnel receive annual training and testing on the purpose and use of the LOTO program.
Affected personnel will receive instructions about how the procedure works and how it may affect their
specific work operations. Refresher training is to be provided by the TRS Health and Safety Officer.
7.3 Other Personnel and Site Visitors
All personnel,including site visitors,who are or may be in an area where energy control procedures may
be used,will receive site-specific LOTO training during site orientation. Training includes general
information about LOTO procedures and about the prohibition relating to attempts to restart or re-
energize machines or equipment that is locked out or tagged out.
8.0 RECORD KEEPING
Training and basic knowledge testing documentation of TRS personnel will be maintained by the
Technical Group Leader for audit and compliance review purposes,for a minimum of three years
following personnel employment. Training documentation of non-TRS personnel will be documented on
the attached form and maintained on-Site by the TRS PM. A"List of Authorized Personnel"will be
maintained by the TRS PM.
The TRS PM also will maintain a record of all LOTO actions for that site in the site PCU office, and
updated weekly on the project server site. At a minimum, documentation will include the following
information:
• Initial date of Lock-out/Tag-out
• Description of machinery or equipment being secured
• Hazard/Malfunction
• Date that Lock-out/Tag-out Removed
• Comments(if any)
TRS
SOP 1.1 Lockout/Tagout REV 2 11

TRS
AIC�d2ratirtg V�ahre
Hazardous Energy Assessment
Evaluate the equipment for all hazardous potential energy sources and check the left hand box if present.For each,describe the
magnitude/type of energy,danger zone(the part(s)of the equipment where the energy is found),and the isolation points.A
description on how to control each identified hazardous energy must be described in the procedure
Types of energy Type/Magnitude Danger zone isolation
❑ A:Electrical-low voltage
(<50 V)
❑ B:Electrical-mid voltage
(50-600 V)
❑ C:Electrical -high voltage
(>600 V)
D:Chemical-explosion,
❑ pressure,extreme heat,fire,
corrosive,reactive,oxidizer,
toxic,etc.
E:Pressure-hydraulic,
❑ pneumatic
(>1 arm)
❑ F:Vacuum
G:Mechanical-capable of
crushing,pinching,cutting,
snagging,striking
H:Thermal-high
❑ temperature-surface
temperature(>60°C),hot
liquids,steam
L:Stored energy-flywheel,
❑ springs,differences in
elevation,capacitors,
batteries,etc.
M:Emergency power-does
the equipment maintain an
emergency power
/uninterruptible power
supply?
❑ N:Other-describe
SOP 1.1 Lockout/Tagout REV 2

TRS
AIC�d2ratirtg V�ahre
SOP 1.1 LOTO Training Acknowledgment
All personnel that receive training on this procedure will review and sign the acknowledgement
form contained in this section.
I have been trained by TRS Group, Inc. (TRS) to perform lockout and tagout (LOTO) of
energized equipment. By signing this document, trainee acknowledges that SOP 1.1 LOTO
has been read and the contents of the document are understood. Trainee has received hands-
on training from a competent person who is authorized to use and instruct others on LOTO
application at TRS project sites.
Date Training Acknowledgement TRS Trainer
SOP 1.1 Lockout/Tagout REV 2

LOCKOUT/TAGOUT LOG TRS Group,Inc.
TRS 2325 Hudson Street
Project Site Longview,WA 98632
Accelerating Volue Project Manager(PM)
PM Contact Info www.thermalrs.com
PRIOR to
Date& restart,clear Date& Confirm
Person Description of Affected Time Verified area,notify Time proper
applying Equipment/ Tasking to be persons LOTO Zero PM&affected LOTO equipment
LOTO Approval Location Completed notified? Applied Energy? persons Removed function? Comments
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
SOP1-1_LOTO Logbook.xlsx Page of

LOCKOUT/TAGOUT LOG TRS Group,Inc.
TRS 2325 Hudson Street
Project Site Longview,WA 98632
Accelerating Volue Project Manager(PM)
PM Contact Info www.thermalrs.com
PRIOR to
Date& restart,clear Date& Confirm
Person Description of Affected Time Verified area,notify Time proper
applying Equipment/ Tasking to be persons LOTO Zero PM&affected LOTO equipment
LOTO Approval Location Completed notified? Applied Energy? persons Removed function? Comments
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
SOP1-1_LOTO Logbook.xlsx Page of

TRS STANDARD OPERATING
PROCEDURE
AWek1YtftVQbc PROCEDURE No: 1.2
Procedure Title:
Application of Electrical Power to ERH Sites
Author: TRS Team Issue Date: 01/09/2006
Revisions:
Date Initials Revision Description Revision#
06-22-09 LS SOP standardization;additional procedures 1
Reviewed and Approved by(initial and date):
SOP/Revision# Health& Safety Operations
Original 1/9/06
REV 1 " 7/28/09 �" 7/28/09
I JAL
TRS
SOP 1.2 Electrical Application REV 1 1

l.0 PURPOSE
This standard operating procedure(SOP) establishes the safe work practices to be followed during the
application of electrical power to the subsurface during electrical resistance heating(ERH). Safety is
paramount in all activities performed during the course of ERH application. The procedures outlined in
this SOP must be followed to assure personnel,TRS clients, and the general public is protected from the
inherent hazards associated with application of electrical power to the subsurface. This SOP is written in
accordance with 29 CFR 1910.303(g)(2)(i) and 29 CFR 1910.269(II)(C).
This SOP is designed to work in conjunction with the TRS electrical safety policy(TRS,2006):
The application of electrical power to the subsurface during ERH shall be conducted
in compliance with the TRS electrical safety standard.Under no circumstances shall
ERH application be allowed to continue with any Touch Potential voltage exceeding
the TRS electrical safety standard. The ERH startup checklist must be completed and
approved prior to initiating unattended site operations.
2.0 SCOPE
This SOP is intended to be used in conjunction with SOP 1.1 Lockout/Tagout(LOTO), SOP 1.3 Voltage
Surveys and the TRS electrical safety policy(TRS,2009a,2009b,and 2006). Only personnel trained to
the minimum requirements outlined in Section 7.0 of this SOP, and the requirements outlined in SOP 1.1
and 1.3 are authorized to apply electrical power to the subsurface at TRS ERH project sites.
A competent person is required to perform the application of power in accordance with this procedure.
All TRS personnel and subcontractors working on TRS projects are required to comply with the
restrictions and limitations imposed upon them by a competent person during project start-up and during
application of LOTO procedures as described in Section 5.4.
While there is no OSHA standard which applies specifically to ERH,29 CFR 1910.303(g)(2)(i)and 29
CFR 1910.269(II)(C)requires guarding live parts if they exceed 50 volts. The TRS administrative
electrical safety policy limit for voltage potential is:
15 volts alternating current(VAC)for all Touch and Step Potentials
30 VAC for all Step and Step Potentials
This SOP applies to the application of electrical power to the subsurface during ERH. Occupational
Health and Safety Administration(OSHA) electrical safety limits, and the more stringent TRS
administered electrical safety limits must be followed when electrical power is applied to the subsurface.
This limit applies a margin of safety beyond the OSHA limits and greatly reduces the possibility of an
electrical safety incident occurring during the application of ERH.
This procedure does not apply to the connection of the main power supply to the PCU. This connection
shall be completed by a qualified,licensed,electrician. This SOP also does not apply to the wiring of
SOP 1.2 Electrical Application REV 1 2 TRS

system components which shall be completed by a competent person.All system connections must be
completed prior to utilizing the procedures identified in this SOP.
3.0 DEFINITIONS
Competent Person—Any designated TRS employee who has been trained in proper procedures for the
application of energy to the subsurface at ERH sites. This person must have completed the
mandatory training outlined in Section 7.0 to be qualified as a competent person.
ERH—Acronym for Electrical Resistance Heating. ERH is a process whereby soils and groundwater are
heated by passing an electrical current through the subsurface volume to be remediated. Electrical
energy is introduced to the subsurface at electrodes, and it is the resistance of the soil matrix to
the flow of electricity between electrodes that heats the subsurface.
ERH Exclusion Zone—An area established to prevent access by all personnel while power is applied to
the subsurface. This zone will have a locked access point with immovable boundaries and shall
only be entered following LOTO procedures. Approval by the TRS Vice President(VP)of
Operations or Senior Project Manager(PM)is required prior to access with power applied. Proper
signage delineating the area shall be posted. This area has the possibility of exceeding the
administrative potential voltage limit during ERH application.No personnel shall ever enter the
area while power is applied.
ERH Public Zone—This area is outside of the ERH restricted zone and may be accessible to the public.
This zone has a Touch Potential Limit of 15 VAC and no location shall exceed 15 VAC when
referenced to utility ground.
ERH Restricted Zone—An area established to permit access to only authorized personnel who have been
properly trained or who are escorted by properly trained personnel. This area will have a clearly
defined boundary that restricts access,but may consist of movable boundaries (such as temporary
chain-link fencing). Proper signage delineating the area shall be posted. This area has a Step and
Touch voltage potential limit of 15 volts alternating current(VAC) and no location shall exceed
120 VAC when referenced to utility ground.
LOTO—An acronym for the safety procedure known as Lockout/Tagout. LOTO is the practice of using a
tag for visibility and awareness in conjunction with placement of a keyed device("lock")on an
energy isolating device, in accordance with SOP 1.1,to prevent the unwanted activation of
mechanical or electrical equipment. Lockout ensures the equipment being controlled cannot be
operated until the lock is removed.
Multimeter—An electronic measuring instrument with several measurement capabilities. A typical
multimeter may measures voltage, current and resistance. There are two categories of
multimeters,analog multimeters and digital multimeters.
Step and Step Potential—The voltage between the feet of a person standing next to an energized,
grounded object or in the energized treatment area.
Step and Touch Potential—The voltage between the foot and hand of a person in contact with an
energized object.
TRS
SOP 1.2 Electrical Application REV 1 3

Voltage-For the purpose of ERH voltage surveys,the term"voltage"refers to the difference in electrical
potential between two points.
4.0 EQUIPMENT LIST
1) Site specific design, installation and safety documents including process flow diagrams (PFDs),
Health and Safety Plans(HASPS),Activity Hazard Analysis(AHAs), and workplans.
2) Personal protective equipment(PPE)appropriate for the Site. Refer to the site specific HASP.
3) TRS ERH Start-up Safety Checklist.
4) Multimeter with amperage and voltage measuring capability
PC
6�(1�
am
5) Site-specific current survey spreadsheet(example templates provided as attachments to this SOP)
and pen(an indelible pen is recommended).
6) LOTO equipment as described in SOP 1.1.
7) Voltage survey equipment as described in SOP 1.3.
5.0 ELECTRICAL POWER APPLICATION PROCEDURES
ERH system designs will identify engineering controls to minimize the exposure to voltage hazards.
These design components will be incorporated during ERH system construction and will be documented,
as necessary, in Work Plans, drawings, and other project documents.
To assist in the implementation of the TRS Electrical Safety Policy,the following ERH specific
procedures for the application of power to the subsurface have been developed.
TRS
SOP 1.2 Electrical Application REV 1 4

5.1 Installation Check
Prior to energizing any components of the ERH treatment system, a competent person shall complete a
final visual inspection to ensure that the system has been properly constructed per design documents. Any
concerns and deviations from the design shall be corrected and documented in the daily construction
report(DCR)prior to initiating start-up activities.
5.2 Start-Up Checklist Part 1
The TRS ERH Startup Checklist, a two-part startup safety checklist,will be completed and recorded on
all ERH applications. Part 1 shall be completed and approved by the TRS VP of Operations, Operations
Group Manager, or a Senior PM prior to the initial application of electrical power to the subsurface. A
copy of Part 1 of the safety checklist shall be submitted to the Project Engineer.
The start-up checklist is an internal checklist maintained with this SOP. Items covered in part 1 of the
start-up checklist include documentation of the following:
• all subsurface lines through the treatment area;
• comparison of cable voltage ratings with anticipated electrode voltage;
• electrode conductive interval;
• ERH equipment grounding and/or insulation;
• delineation and identification of the surface exclusion zone;
• description of exclusion zone components and signage;
• description of the surface grid;
• details of electrode vaults and monitoring well casings and vaults;
• identification and description of neutral zones;
• average depth to water;
• safety equipment onsite;
• "No dig"notification completed for the site; and
• on site safety and security systems.
5.3 Initial Start-Up and Power Increases
Following approval of part 1 of the start-up checklist from the VP Operations, operations group manager
or Senior PM,the PCU(s) shall operate at the lowest settings under the direct supervision of a competent
person. During this initial phase of start-up,the ERH system shall not operate unattended. For each PCU
SOP 1.2 Electrical Application REV 1 5 TRS

in operation at the ERH site,the competent person shall collect and document the following readings:
voltage, current, and power.
5.3.1 Current survey
The current survey is an important component of initial testing to ensure that the ERH system is operating
according to design expectations. Current readings at each electrode shall then be collected and
documented. Readings collected during the current survey shall be compared against design expectations
and equipment limitations.
5.3.2 Voltage survey
Voltage safety tests,referred to as"utility-ground","step-and-touch"and"step-and-step"voltage surveys,
must be performed while the PCU is operating at the lowest setting.Voltage survey procedures are
detailed in TRS Standard Operating Procedure 1.3 Voltage Surveys. The purpose of these voltage surveys
is to determine the voltage potentials at location(s) of possible voltage hazards on or directly adjacent to
the operating ERH site.
If any voltage safety measurement exceeds the TRS maximum allowed voltage, consider using the
following engineering controls to achieve the TRS Electrical Safety Standard:
• Isolation of locations exceeding the TRS Safety Limit by insulating or directly enclosing.
• Remove voltage potential by grounding techniques, such as chicken wire mats near fences, and
grounding wire installation between metal fence posts.
• Isolation of locations exceeding the TRS Safety Limit by restricting access to qualified personnel
when power is applied by establishing an ERH restricted zone.
• Isolation of locations exceeding the TRS Safety Limit by restricting access to all personnel when
power is applied by establishing an ERH exclusion zone.
If the competent person is unable to mitigate the voltage concerns identified with the voltage surveys,
he/she shall contact his/her supervisor to discuss potential options. Document any system changes or
methods used to limit the voltage hazard(s). Conduct the voltage survey again to ensure that all safety
concerns have been mitigated.
5.3.3 Power Increases
Once all operational and safety concerns identified during initial start-up have been resolved,the
competent person shall ensure that all personnel are notified of the planned increase in power. The
competent person will then increase the voltage output settings on the PCU. The competent person will
then complete a new current survey and voltage surveys by repeating the procedures described in Sections
5.3.1 and 5.3.2. These steps(i.e. increase power output,current survey,voltage surveys, mitigation of
high voltage safety concerns) shall be repeated until the system is safely operating at or near design
expectations.
5.4 "Wetted Site" Voltage Survey
Once the system has been fully optimized based on the power application, amperage surveys, and voltage
surveys described in Section 5.3, a"wetted site"voltage survey should be completed. The purpose of the
SOP 1.2 Electrical Application REV 1 6 TRS

"wetted site"voltage survey is to check normal operating parameters in the event of a rainfall,and ensure
that additional voltage hazards will not be created by the addition of water to the project treatment area.
This procedure does not need to be completed if the ERH electrode area is located indoors and will not be
exposed to water at any time. The procedures listed below shall be followed when completing the"wetted
site"voltage survey:
• An authorized person must perform lockout/tagout(LOTO)procedures on the PCU as described
in SOP 1.1
• Water shall be evenly sprayed across the treatment area to simulate surface water accumulation
during rainfall.Note: The"wetted site"voltage survey may be completed following an actual rain
event(instead of spraying water across the treatment area), as long as that rain even occurs during
the start-up phase of the project.
• The authorized person who placed the LOTO devices shall ensure that all personnel are in safe
locations prior to energizing the PCU.
• The authorized person who placed the LOTO devices on the PCU shall remove the devices as
outlined in SOP 1.1.
• Complete and document a voltage survey as described in SOP 1.3.
5.5 Start-Up Checklist Part 2
As mentioned in Section 5.2,the two-part Startup Checklist will be completed and recorded on all ERH
applications. Part 2 shall be completed and approved by the TRS VP of Operations, Operations Group
Manager,or Senior PM prior to unattended operations.A copy of Part 2 of the safety checklist shall be
submitted to the Project Engineer.
The start-up checklist is an independent checklist maintained with this SOP. Items covered in part 2 of the
start-up checklist include documentation of:
• typical voltage applied to the field and duration of consistent operations;
• current survey(s)conducted throughout the duration of start-up procedures;
• voltage surveys conducted throughout the duration of start-up procedures;
• highest observed current in neutral wire, if applicable;
• operational measurements and any anomalous measurements;
• changes made to operations due to anomalous measurements;
• any voltage survey measurements in excess of TRS limits;
• the boundaries or delineation of an ERH exclusion zone; and
• the boundaries or delineation of the ERH restricted zone.
TRS
SOP 1.2 Electrical Application REV 1 7

6.0 RESPONSIBILITIES
Once electricity has been applied to an ERH site,no person shall enter the ERH electrode field to
complete ANY intrusive work until all PCUs have been locked out and tagged out according to SOP 1.1,
all residual energy has been dissipated, and voltage testing indicates it is safe to enter.
Role Responsibility
• Develop and implement procedures for application of electrical power to
the subsurface.
TRS VP Operations • Periodically review and update program based on audit findings and project
feedback.
• Ensure personnel are properly trained and maintain training documentation.
• Assist VP Operations with administration of training requirements.
TRS Health and Safety Officer(HSO) . Reinforce the need to comply with requirements.
• Audit the effectiveness of the procedures contained in this SOP.
• Enforce SOP procedures on site.
• Conduct unscheduled field checks on implementation of SOP procedures.
PM • Maintain list of Competent Persons.
• Ensure documentation of procedures followed during application of
electrical power to the subsurface is maintained.
• Assist in implementation of SOP procedures.
Site Health and Safety • Conduct orientations for subcontractors, employees,and site visitors.
Officer(SHSO) • Coordinate training needs with TRS HSO and VP Operations.
• Assist with oversight of site-specific documentation.
• Develop and implement the site-specific electrical application plan in
accordance with this SOP.
Competent Person e participate in AHAs.
• Conduct inspections following electrical application to subsurface.
Qualified Electrician • Establish main power supply connection to PCU.
(Licensed Electrician- • Perform electrical work safely, according to instructions and training
Generally Contracted) received,and in compliance with requirements.
• Safely perform work in the vicinity of ERH sites.
Affected Employees • DO NOT work within ERH treatment area during the application/start-up of
electrical power to the subsurface.
• Comply with all TRS requirements.
Subcontractors • DO NOT work within ERH treatment area during the application/start-up of
electrical power to the subsurface.
• Train subcontractor employees.
TRS
SOP 1.2 Electrical Application REV 1 8

7.0 TRAINING
Training is an important component of electrical safety at ERH sites to ensure that employees understand
the purpose of the program and to provide employees with the skills and knowledge to perform work
safely. Subcontractors must train their own employees.
7.1 Competent Persons
A Competent Person in the application of electrical power to the subsurface is determined by the VP of
Operations and must, at a minimum, complete the following requirements:
• Read this SOP and understand the general process and the specific requirements of this SOP.
• Complete annual training on the purpose and use of this SOP as prescribed by the TRS VP
Operations.
• Obtain onsite instruction by a knowledgeable person on the site-specific hazards.
• Trained to recognize potential hazards and methods and means necessary for hazard control.
• Be qualified and trained to perform the tasks requiring the use of this procedure.
• Sign the acknowledgement form attached to this SOP.
Competent Persons receive annual training and testing on the purpose and use of the procedures outlined
in this SOP.Additional retraining is provided if there is a change in equipment or procedures or if
inadequacies are observed in the individual's application of procedures. Training is to be provided and
documented by the VP of Operations.
7.2 Other Personnel and Site Visitors
All personnel, including site visitors, affected personnel, clients, and subcontractors,who are or may be in
the area during initial application of energy to the subsurface shall be trained on site hazards and
delineation and purpose of the exclusion zone prior to energy application. Training includes general
information about project site and procedure hazards, delineation and purpose of the exclusion zone,and
site-specific safety precautions. If present during the"wetted site"voltage survey,these individuals will
also receive training regarding LOTO procedures and about the prohibition relating to attempts to restart
or re-energize machines or equipment that is locked out or tagged out.
8.0 RECORD KEEPING
Training and basic knowledge testing documentation will be maintained by the TRS VP Operations for
audit and compliance review purposes, for a minimum of three years following the close of a project.
SOP 1.2 Electrical Application REV 1 9 TRS

A list of Competent Persons will be maintained by the TRS ERH remediation site PM. A copy of the list
will be posted in the PCU office or site office. The TRS PM also will maintain a record of the TRS ERH
start-up Safety Checklist.
9.0 REFERENCES
Thermal Remediation Services, Inc (TRS Group, Inc.), 2006. Policy for the Application of
Electrical Power to the Subsurface, Rev 0. January.
TRS Group, Inc., 2009a. SOP 1.1, Lockout/Tagout(LOTO), Rev 1. July.
TRS Group, Inc., 2009b. SOP 1.3 Voltage Survey, Rev 2. July.
TRS
SOP 1.2 Electrical Application REV 1 10

TRS
Training Acknowledgment
Application of Electrical Power to Subsurface at ERH Sites
All personnel that receive training on this procedure will review and sign the acknowledgement form
contained in this section.
I have been trained by TRS Group,Inc. (TRS) to perform application of electrical
power to the subsurface at electrical resistance heating (ERH)project sites.By signing
this document,trainee acknowledges that SOP 1.2 has been read and the contents of
the document are understood. Trainee has received hands-on training from a
competent person who is authorized to use and instruct others on energy application
at TRS project sites.
Date Training Acknowledgement TRS Trainer
SOP 1.2 Electrical Application REV 1

TRS STANDARD OPERATING
PROCEDURE
^ t Vd�rc PROCEDURE No: 1.3
Procedure Title:
Voltage Surveys
Author: TRS Team Issue Date: 2/28/09
Revisions:
Date Initials Revision Description Revision#
08/18/09 LS additional pictures;editorial changes 2
08/13/10 LS Clarify stop task thresholds;update roles;editorial changes 3
Reviewed and Approved by(initial and date):
SOP/Revision# Health& Safety Operations
Original 02/28/09 02/28/09
REV 1 06/24/09 06/24/09
REV 2 08/18/09 08/18/09
REV 3 ��" �08A3/10 ° 08/13/10
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SOP 1.3 Voltage Surveys REV 3 1 �' :

1.0 PURPOSE
The purpose of this Standard Operating Procedure(SOP) is to provide uniform guidance for the
measurement and recording of voltage safety tests on TRS Group, Inc. (TRS) electrical resistance heating
(ERH)project sites. These tests are referred to as"step-and-touch"and"step-and-step"voltage surveys.
The purpose of these voltage safety tests is to identify the location(s)of possible voltage hazards on or
directly adjacent to an operating ERH site. This electrical safety procedure is written in accordance with
29 CFR 1910.303(g)(2)(i)and 29 CFR 1910.269(11)(C).
2.0 SCOPE
Only competent persons trained to the minimum requirements outlined in Section 7.1 of this SOP are
authorized to conduct voltage surveys. Competent persons are required to perform the surveys in
accordance with this procedure. All TRS personnel and subcontractors working on TRS projects are
required to comply with the restrictions and limitations imposed upon them by the competent person
while voltage surveys are being conducted.
This SOP is not intended for determining voltage isolation involved with lock and tag practices or other
maintenance activities. Refer to SOP 1.1 Lockout/Tagout(LOTO)for those procedures.
2.1 OSHA Electrical Standards
The Occupational Safety and Health Administration's(OSHA)mission is to ensure the safety and health
of America's workers by setting and enforcing standards. While OSHA has established numerous
standards for electrical safety,the following standards form the basis of the TRS administrated electrical
safety limits.
2.1.1 Guarding of live parts- 1910.303(g)(2)(i)
Except as required or permitted elsewhere in this subpart, live parts of electric equipment operating at 50
volts or more will be guarded against accidental contact by approved cabinets or other forms of approved
enclosures, or by any of the following means [1910.303(g)(2)(i)(A)]: by location in a room,vault, or
similar enclosure that is accessible only to qualified persons.
2.1.2 Protection from Step and Touch Potentials-Appendix C 1910.269(II)(C)
Several methods may be used to protect employees from hazardous ground-potential gradients,including
equipotential zones,insulating equipment, and restricted work areas.
1) The creation of an equipotential zone will protect a worker standing within it from hazardous step
and touch potentials. Such a zone can be produced through the use of a metal mat connected to
the grounded object. In some cases, a grounding grid can be used to equalize the voltage within
the grid. Equipotential zones will not, however, protect employees who are either wholly or
partially outside the protected area. Bonding conductive objects in the immediate work area can
also be used to minimize the potential between the objects and between each object and ground.
(Bonding an object outside the work area can increase the touch potential to that object in some
cases,however.)
SOP 1.3 Voltage Surveys REV 3 2 TRS

2) The use of insulating equipment, such as rubber gloves, can protect employees handling grounded
equipment and conductors from hazardous touch potentials. The insulating equipment must be
rated for the highest voltage that can be impressed on the grounded objects under fault conditions
(rather than for the full system voltage).
3) Restricting employees from areas where hazardous step or touch potentials could arise can protect
employees not directly involved in the operation being performed. Employees on the ground in
the vicinity of transmission structures should be kept at a distance where step voltages would be
insufficient to cause injury. Employees should not handle grounded conductors or equipment
likely to become energized to hazardous voltages unless the employees are within an
equipotential zone or are protected by insulating equipment.
While there is no OSHA standard which applies specifically to ERH,the above standards for guarding
live parts if they exceed 50 volts serves our intended safety purpose. If any voltage safety measurement
meets or exceeds the OSHA standard of 50 volts,the voltage survey and power application will be
immediately stopped. Power application and voltage surveys will not resume until the potential hazard
has been mitigated.
2.2 TRS Electrical Safety Standard
The entire electrical industry strives to keep electrical energy from contacting the ground. Because ERH
applies electrical energy to the subsurface or ground,the TRS administrative electrical safety policy sets
conservative limits to prevent personnel exposure to hazardous voltage at ERH sites.
The TRS administrative electrical safety policy limit for exposed voltage on an operating ERH site is:
15 volts alternating current(VAC)for all Touch Potentials
30 VAC for all Step and Step Potentials
This limit applies a margin of safety beyond the OSHA limits and greatly reduces the possibility of an
electrical safety incident occurring during the application of ERH.
3.0 DEFINITIONS
Competent Person—Any designated employee who has been trained in proper procedures for the
application of energy to the subsurface at ERH sites. This person must have completed the
mandatory training outlined in Section 7.1 to be qualified as a competent person.
ERH—Acronym for Electrical Resistance Heating. ERH is a process whereby soils and groundwater are
heated by passing an electrical current through the subsurface volume to be remediated.
ERH Exclusion Zone—An area established to prevent access to site hazards by all personnel during ERH
operations.An ERH Exclusion Zone has the possibility of exceeding the administrative potential
voltage limit during ERH application. Proper signage delineating the area shall be posted(e.g.,
"Danger-High Voltage-Keep Out"). Areas having a step and touch voltage potential greater than
15 volts alternating current(VAC)must be located within an ERH Restricted Zone to prevent
SOP 1.3 Voltage Surveys REV 3 3 TRS

public access and be identified and guarded to limit exposure to potential hazards by site
personnel. Equipment control compartments,power control units(PCUs)transformer
compartments, and stepdown and autotransformers must have immovable boundaries and a
locked access point to prevent unintended access. The following guidelines related to access to
ERH Exclusion Zones shall be followed by all personnel:
1. If site activities can be completed without power application,Remove all hazardous energy
sources from the ERH Exclusion Zone and apply LOTO in accordance with SOP 1.1.
2. If site activities require entering into an ERH exclusion zone during power application(for
example, during"powered"data collection),the true buddy system will be utilized. Only
authorized and competent persons may enter the ERH exclusion zone. The AHA will include
personal protective equipment(PPE)requirements for entering the zone.
3. Where the true buddy system is not possible and voltage potentials do not exceed 50 volts,
personnel shall contact the Senior Project Manager(Sr. PM)or higher technical manager for
authorization to access the ERH Exclusion Zone. The Sr.PM or Technical Manager will
determine appropriate procedures for the specific access required. If voltage potentials exist
above 50 volts, site-specific AHA's will be developed for tasking within the exclusion zone.
4. Personnel shall NEVER enter the transformer compartment of the PCU when the PCU
contactor is closed. In the event that tasking requires accessing any other ERH Exclusion
Zone while energy is being applied(e.g.,troubleshooting a control panel),Personnel shall use
the true buddy system and don all proper PPE before entering the area.
ERH Public Zone—This area is outside of the ERH restricted zone and may be accessible to the public.
This zone has a Touch Potential Limit of 15 VAC and no location shall exceed 15 VAC when
referenced to utility ground.
ERH Restricted Zone—An area established to permit access to only authorized personnel who have been
properly trained or who are escorted by properly trained personnel during all phases of a TRS
ERH project. Trained personnel must complete the TRS ERH Restricted Zone Authorization
form. This area will have a clearly defined boundary that restricts access,but may consist of
movable boundaries(such as temporary chain-link fencing). This area has a Step and Touch
voltage potential limit of 15 VAC and no location shall exceed 120 VAC when referenced to
utility ground. On TRS ERH sites,the ERH Restricted Zone is generally delineated by the site
perimeter security fence.
LOTO—(Lockout/Tagout)The practice of using a tag for visibility and awareness in conjunction with
placement of a keyed device("lock")on an energy isolating device, in accordance with SOP 1.1,
to prevent the unwanted activation of mechanical or electrical equipment. Lockout ensures the
equipment being controlled cannot be operated until the lock is removed.
Step-and-Step—the reference points of a possible circuit a person would from as the result of walking.
The reference points are each foot at the distance between footsteps. Both reference points are
locations on the ground(not objects located on the ground).
TRS
SOP 1.3 Voltage Surveys REV 3 4

Step-and-Touch—the reference points of a possible circuit a person would from as the result of typical
movement or physical actions. For example, a person standing at a fence gate entrance and
touching the fence gate with their hand. The reference points would be the person's feet in
contact with the ground surface and their hand reaching out and touching the fence gate.
Step Potential—The voltage between the feet of a person standing next to an energized, grounded object.
Touch Potential—The voltage between the foot(or hand) of a person in contact with an energized object.
Voltagey—a safety investigation to determine the presence, or lack of potentially hazardous voltage
exposure on an ERH site
4.0 EQUIPMENT LIST
1) TRS Voltage Survey Form(see attached for template)and pen.Recommend indelible pen.
2) PPE appropriate for the Site. Refer to the site specific Health and Safety Plan(HASP).
3) Calibrated hand held voltage meter with probes.
4) Two non-conductive extension rods (e.g., dowel rods). The rods will be attached to the voltage
meter probes for reaching tight areas, simulating walking strides, limiting personnel exposure to
hazards, and preventing back injury while repeatedly bending over to contact the ground or other
conductive surfaces.
5) Site specific design, installation and safety documents including process flow diagrams (PFDs),
Site-Specific HASP,Activity Hazard Analysis(AHA),and Site Workplans.
6) Map of ERH treatment area and surrounding area.
5.0 VOLTAGE SURVEY PROCEDURES
Approach all voltage survey measurements in a way which minimizes exposure to the electrical hazard.
Always keep non-essential personnel away from the site until safe operating conditions have been
established. Avoid standing in water when taking voltage measurements. If this is the initial voltage
survey, apply a low voltage(lowest voltage output setting on the power control unit [PCU])to the ERH
field for the first round of measurements. The buddy system must be used to complete the initial voltage
survey.
TRS
SOP 1.3 Voltage Surveys REV 3 5

The voltage safety survey is site-specific. In general, a minimum of 20 voltage readings should be
collected at locations across the site for future reference.
1) Obtain a handheld digital voltmeter and verify operation of the meter. Refer to the operating
instructions for the meter for verification steps.
2) Use tape to attach each voltage meter probe to the end of a dowel rod.
111 ,
3) With the handheld volt meter in the alternating current (AC) voltage measurement mode, check
proper reading output by confirming the voltage reading of 120 VAC from one of the standard
outlets in the PCU(refer to Section 5.3).
4) Secure the site allowing only those necessary to conduct the voltage safety survey to remain on
site.
5) Apply 50V or apply voltage to the electrodes at the minimum voltage output setting of the PCU,
based on its configuration.
6) Collect the first step-and-touch voltage measurement upon exit of the control room of the PCU by
placing the red probe on the door and the black probe on the ground(refer to Section 5.1).
NOTE: If any voltage safety measurement meets or exceeds the OSHA standard of
50 volts,immediately retreat to the PCU along the safe path completed and stop
power application to the electrodes. TRS staff will then work to mitigate the voltage
potential associated with the exceedances of the 50 VAC limit. Following completion of
voltage potential mitigation,power will be applied to the electrodes and testing will be
resumed—the area noted to have exceeded the 50VAC limit will be re-tested.
SOP 1.3 Voltage Surveys REV 3 6 T

7) Begin walking around the treatment area perimeter and collecting step-and-touch(refer to section
5.1) and step-and-step (refer to Section 5.2)measurements throughout the site.
8) The step-and touch and step-and-step voltage measurements are for personnel safety. Be realistic
when determining the span between the sensing probes while making voltage measurements. It is
not realistic to expect a person to reach out more than five or six feet to make contact with
another surface.
9) When placing the black probe to the ground, place the probe on dirt and avoid rocks or debris as
this may interfere with proper readings.
10) If any voltage safety measurement indicates more than the maximum allowed voltage, use
engineering controls to achieve the TRS Electrical Safety Standard. Some typical engineering
controls to consider are:
■ Isolation of locations exceeding the TRS Safety Limit by insulating or directly enclosing.
■ Isolation of locations exceeding the TRS Safety Limit by restricting access to all
personnel when power is applied by establishing an ERH exclusion zone.No personnel
shall enter an ERH exclusion zone during ERH power application.
■ Isolation of locations exceeding the TRS Safety Limit by restricting access to only
qualified personnel when power is applied by establishing an ERH restricted zone.
■ The creation of an equipotential zone will protect a worker standing within it from
hazardous step and touch potentials. Such a zone can be produced through the use of a
metal mat connected to the grounded object. In some cases, a grounding grid can be used
to equalize the voltage within the grid. Equipotential zones will not,however,protect
employees who are either wholly or partially outside the protected area. Bonding
conductive objects in the immediate work area can also be used to minimize the potential
between the objects and between each object and ground. (Bonding an object outside the
work area can increase the touch potential to that object in some cases,however.)
If use of these engineering controls does not mitigate the high voltage safety concern,consult
with site management for an adequate and safe solution.
11) Document any system changes or methods used to limit the high voltage hazard(s). Conduct the
voltage survey again to ensure that all safety concerns have been mitigated.
5.1 Step-and-Touch Voltage Survey
The following guidelines shall be used to ensure accurate voltage measurements and establishing safe
practices when completing the step-and-touch voltage survey measurements:
7R5
SOP 1.3 Voltage Surveys REV 3 7

• When collecting a reading from a specific object,place the red probe on the object having a
potential voltage safety concern and the black probe on the ground(i.e., dirt surface). Be certain
that the voltage probe makes a good connection to the item being measured.
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• If the item being tested is metal,put the probe on an unpainted portion of the metal object that is
free from rust. If an area free from paint or rust does not exist,use the end of the rod to scratch a
bare spot on the metal in order to get an accurate reading.
• Check all commonly used surfaces such as,but not limited to: fence post, entry/exit doors and
equipment. Consider that these touch voltage potentials will increase linearly with increased
voltage applied to the field.
• Particular emphasis will be placed upon metal objects within and adjacent to the ERH area
because of their electrically conductive properties. In addition to metal objects, electrode surface
seals, soil,piping and valves as well as other items not normally considered electrically
conductive must be considered for measurement. These items should also be checked relative to
each other.
000
TRS
SOP 1.3 Voltage Surveys REV 3 8

• Also keep in mind that the results acquired during a voltage safety survey during dry conditions
may vary significantly from measurements taken when the ground is wet after a rain or other wet
event. Typical locations of interest on an ERH site may include:
■ Exposed soil
■ Equipment frames(utility ground)
■ Electrode seals
■ Wet soil
■ Metal building siding(utility ground)
■ Door and window frames
■ Fences and gates, light poles
■ Anything metal protruding from the ground
This is a partial list of possibilities and each ERH site will be voltage safety surveyed on an
individual basis reflecting the specific features of the site.
• Record voltage survey findings by marking the location on the map with a unique identifier and
documenting the voltage measurement on the voltage survey form with the same identifier.
5.2 Step-and-Step Voltage Survey
The step-and-step voltage survey is intended to create reference points of a possible circuit a person
would complete as the result of walking.After completing the initial readings on the shell and handle of
the PCU,begin walking a perimeter around the treatment area. Use the extended probes to simulate
walking while measuring. Record any voltage reading higher than 5 volts by marking the location on the
map with a unique identifier and documenting the voltage measurement on the voltage survey form with
the same identifier. These are considered step-and-step measurements.
5.3 Utility-Ground Voltage Survey
The utility-ground voltage survey is a specific type of step-and-touch voltage survey. To complete the
utility-ground voltage survey, attach the specially fabricated extension cord to the black lead on the volt
meter. The extension cord can be connected to a utility ground, or the ground coming in from the primary
service. An outlet inside the PCU will work for this. Repeat the steps in Section 5.1 and visit the same site
locations but collect voltages referenced to utility ground.
6.0 RESPONSIBILITIES
Once electricity has been applied to an ERH site,no person shall enter the ERH electrode field to
complete ANY intrusive work until all PCUs have been locked out and tagged out according to SOP 1.1,
all residual energy has been dissipated, and voltage testing indicates it is safe to enter.
SOP 1.3 Voltage Surveys REV 3 9 TRH

Role Responsibility
• Develop and implement procedures for voltage surveys.
TRS Technical Group • Periodically review and update program based on audit findings and project
Leader feedback.
• Ensure personnel are properly trained and maintain training documentation.
• Assist Technical Group Leader with administration of training
TRS Health and requirements.
Safety Officer(HSO) • Reinforce the need to comply with requirements.
• Audit the effectiveness of the procedures contained in this SOP.
• Enforce SOP procedures on site.
• Conduct unscheduled field checks on implementation of SOP procedures.
Project Manager(PM) * Maintain list of Competent Persons.
• Ensure documentation of voltage surveys as outlined in Section 8.0.
• Assist in implementation of SOP procedures.
Site Health and Safety • Conduct orientations for subcontractors, employees, and site visitors.
Officer(SHSO) • Coordinate training needs with TRS HSO and Technical Group Leader.
• Assist with oversight of site-specific documentation.
• Participate in training requirements related to this SOP.
• Provide feedback on SOP revisions to the Technical Group Leader or HSO.
• Develop and implement the site-specific voltage survey plan.
• Participate in AHAs.
• Develop and document engineering controls used to remove high voltage
concerns identified during voltage survey.
Competent Person , Mitigate any voltage potentials above 15 VAC before increasing power
application or allowing unattended site operations.
• Safely retrace steps and stop power application immediately if voltage
potential exceeds 50 volts at any location. Mitigate the voltage hazard
before resuming power application.
• Safely perform work in the vicinity of ERH sites.
Affected Employees • DO NOT work within ERH treatment area during the application/start-up of
electrical power to the subsurface.
• Comply with all TRS requirements.
Subcontractors • DO NOT work within ERH treatment area during the application/start-up of
electrical power to the subsurface.
7.0 TRAINING
Training is an important component of safety at ERH sites to ensure that personnel understand the
purpose of the program and to provide employees with the skills and knowledge to perform work safely.
SOP 1.3 Voltage Surveys REV 3 10 TRS

7.1 Competent Persons
A Competent Person in the completion of voltage surveys is determined by the Technical Group Leader
and must, at a minimum, complete the following requirements:
• Read this SOP and understand the general process and the specific requirements of this SOP.
• Complete annual training on the purpose and use of this SOP as prescribed by the TRS Technical
Group Leader.
• Obtain onsite instruction by a knowledgeable person on the site-specific hazards.
• Trained to identify locations of interest when completing voltage surveys.
• Trained to recognize potential hazards and methods and means necessary for hazard control.
• Be qualified and trained to perform the tasks requiring the use of this procedure.
• Sign the acknowledgement form attached to this SOP.
• Personnel conducting the"wetted site"voltage survey(refer to SOP 1.2)must be trained as an
authorized employee in LOTO procedures as outlined in SOP 1.1 in order to shut down the ERH
system prior to the application of water to the site.
Competent Persons receive annual training and testing on the purpose and use of the procedures outlined
in this SOP. Additional retraining is provided if there is a change in equipment or procedures or if
inadequacies are observed in the individual's application of procedures. Training is to be provided and
documented by the Technical Group Leader.
7.2 Other Personnel and Site Visitors
All personnel, including site visitors, affected personnel, clients, and subcontractors,who are or may be
on site while voltage surveys are being conducted will be trained on site hazards,activity hazards and safe
work zones. Training will include general information about project site and procedure hazards,the
delineation and purpose of the restricted and exclusion zones, and site-specific safety precautions.
Nonessential personnel will not enter ERH restricted zones while voltage surveys are being completed.
If present during the"wetted site"voltage survey,these individuals will also receive training regarding
LOTO procedures and about the prohibition relating to attempts to restart or re-energize machines or
equipment that is locked out or tagged out.
8.0 RECORD KEEPING
Training and basic knowledge testing documentation will be maintained by the TRS Technical Group
Leader for audit and compliance review purposes,for a minimum of three years following the close of a
project.
TRS
SOP 1.3 Voltage Surveys REV 3 11

A"List of Authorized Personnel"will be maintained by the TRS ERH remediation site PM.A copy of the
list will be posted in the PCU office or site office.
The TRS PM also will maintain a record of all voltage surveys collected for that site in project files. At a
minimum,documentation will include the following information:
• Type of voltage survey being conducted
• Date and time of voltage survey
• Names of personnel conducting voltage surveys
• PCU general operating parameters
• General description of moisture content in soil
• Locations of voltage measurements and respective readings
• Methods or changes used to mitigate safety hazards identified during voltage survey
• Confirmation readings that voltage hazard has been controlled
9.0 REFERENCES
Thermal Remediation Services, Inc (TRS Group, Inc.), 2006. Policy for the Application of
Electrical Power to the Subsurface, Rev 0. January.
TRS Group, Inc., 2009a. SOP 1.1, Lockout/Tagout(LOTO), Rev 1. July.
TRS Group, Inc., 2009b. SOP 1.2 Electrical Application, Rev 1. June.
TRS
SOP 1.3 Voltage Surveys REV 3 12

TRS
AIC�d2ratirtg V�ahre
Voltage Survey Training Acknowledgment
All personnel that receive training on this procedure will review and sign the acknowledgement
form contained in this section.
I have been trained by TRS Group, Inc. (TRS) to perform voltage surveys at TRS ERH
project sites in accordance with SOP 1.3. By signing this document, trainee
acknowledges that SOP 1.3 Voltage Surveys has been read and the contents of the
document are understood. Trainee has received hands-on training from a competent
person who is authorized to use and instruct others on voltage surveys TRS project
sites.
Date Training Acknowledgement TRS Trainer
SOP 1.3 Voltage Surveys REV 3

TRS VOLTAGE SURVEY
AcrelemYing Value
Maximum allowable observed voltage is
15 volts for all touch potentials and 30 volts for all step and step potentials.
Proj ect: Inspector:
Date/time: PCU output Voltage: vAC
1.On initial startup,set PCU output to be less than 50 volts. Input M
2.Mark the location for each reading on a site map with the respective location number from this sheet.
3.Describe the test locations,indicating the points contacted with the probes.
4.After logging step-voltages,collect and record utility ground voltage observations.
Voltage Detection Points Voltage
Location Reading
Number Black Probe Red Probe (volts)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
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S0P1-3 Voltage Survey FormAs Page of

TRS STANDARD OPERATING
PROCEDURE
A&,9L*&k9 wfut' PROCEDURE No: 4.7
Procedure Title: MUR55 Hot Groundwater Sampling
Author: TRS Team Issue Date: 05/27/14
Revisions:
Date Initials Revision Description Revision#
Reviewed and Approved by(initial and date):
SOP/Revision# Health & Safety Operations
Original' 05/27/14 05/27/14
_ r
TRS
SOP 4.7 Hot Groundwater Sampling MUR55.docx 1

1.0 PURPOSE
The purpose of this standard operating procedure(SOP) is to provide uniform procedures for the safe and
representative collection of groundwater samples during or after the application of Electrical Resistance
Heating(ERH). This procedure specifically addresses sampling of groundwater that has been heated due
to the ERH process.
2.0 SCOPE
This SOP serves as a guideline for the collection of groundwater samples during the application of ERH
using modified low-flow sampling procedures. This SOP draws information from the United States
Environmental Protection Agency(USEPA)Region 4 groundwater sampling operating procedure
(SESDPROC-3 01-R3) and the USEPA groundwater issue paper,Low-Flow(minimal drawdown)
Ground-Water Sampling Procedure (Puls and Barcelona, 1996)with modifications to accommodate
groundwater temperatures that have been drastically elevated as a result of ERH application.Whenever
possible, SESDPROC-3 01-R3 should be followed. Only personnel trained to the minimum requirements
outlined in Section 7.0 of this SOP are authorized to collect hot groundwater samples at TRS ERH project
sites.
The USEPA guidance document recommends continual monitoring of water levels during the purge and
sample process to ensure that minimal drawdown is occurring(Puls and Barcelona, 1996). Due to the
safety hazards associated with opening well heads at active ERH project sites, groundwater level
measurements(depth to groundwater)will not be collected as part of hot groundwater sampling activities.
If the TRS project site has been constructed with pressure transducers to monitor groundwater gradients,
readings from the transducers will be monitored as feasible to minimize groundwater drawdown. If
previous sampling records or hydrogeologic data is available,this information shall be used to develop
target flow rates for the groundwater sampling effort.
These procedures assume that dedicated tubing and pumping systems have been established prior to
application of electrical energy to the subsurface. If intrusive work is required to complete the sampling
efforts, an additional activity hazard analysis(AHA)must be created and reviewed with the TRS Health
and Safety Officer(HSO) and the project manager(PM). Samples collected using this SOP are generally
used for optimizing system performance.
TRS Group,Inc.(TRS) does not assume responsibility for non-TRS personnel using this SOP. TRS
Group,Inc. (TRS)personnel shall use this procedure in conjunction with site-specific sample
analysis plans and permit requirements.These are standard(i.e.,typically applicable)operating
procedures which may be varied or changed as required, dependent on site conditions, equipment
limitations,permit requirements or limitations imposed by the procedure. The ultimate procedures,
including any deviations from this SOP, shall be documented on the groundwater sampling form.
Groundwater sampling typically is performed while the power application to the treatment area is shut off
and locked out by a competent person in accordance with TRS SOP 1.1 Lockout/Tagout(LOTO; TRS
2009). The decision regarding the application of energy to the subsurface during groundwater sampling
SOP 4.7 Hot Groundwater Sampling MUR55.docx 2 TRS

will be determined on a case-by-case basis dependent on specific site conditions and engineering controls.
Refer to the site specific Health and Safety Plan(HASP) and consult with the PM and Site Health and
Safety Officer(SHSO) for site specific requirements and restrictions.
3.0 DEFINITIONS
Authorized employee—Any designated employee who locks out or tags out equipment in order to
perform servicing or maintenance. This person must have completed the mandatory LOTO
training described in SOP 1.1 LOTO to be qualified as an authorized worker. Only an authorized
worker installs and removes his or her own lock and tag as required by this program.
Competent Person—Any designated employee who has been trained in proper procedures for the
application of energy to the subsurface at ERH sites. This person must have completed the
mandatory training outlined in Section 7.0 to be qualified as a competent person.
ERH—Electrical Resistance Heating. ERH is a process whereby soils and groundwater are heated by
passing an electrical current through the subsurface volume to be remediated.
Bladder Pump—Submersible pump with external control unit used for pumping fluids at greater depths.
The bladder pump consists of an internal flexible bladder that is positioned within a rigid pump
body constructed of stainless steel. The inner bladder is equipped with one-way inlet and outlet
valves and passively fills with water when the pump is at depth by virtue of hydrostatic pressure.
Following the fill cycle, compressed air from a cylinder or compressor at the wellhead is
delivered to the pump through tubing and is used to compress the bladder. The applied pressure
then causes the flexible bladder to compress and closes the bottom check valve, forcing water
from the bladder into the discharge tubing. During a vent cycle,the pressure is released from the
drive tubing. The bladder returns to its initial state as water re-enters the pump,while the top
check valve prevents water already in the discharge tubing from falling back into the bladder. The
pumping sequence consists of repeated fill/compress cycles,using a pneumatic controller
positioned at the wellhead.
J -7. %"Z2_
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SOP 4.7 Hot Groundwater Sampling MUR55.docx 3 TRS

LOTO—Lockout/Tagout. The practice of using a tag for visibility and awareness in conjunction with
placement of a keyed device ("lock") on an energy isolating device, in accordance with SOP 1.1,
to prevent the unwanted activation of mechanical or electrical equipment. Lockout ensures the
equipment being controlled cannot be operated until the lock is removed.
Low-Flow Purging—A USEPA approved purge and sample method used to minimize stress on the
formation(minimal drawdown)which results in less mixing of stagnant casing water with
formation water. Additional advantages of using low-flow purging methods include the
following:
• Samples are more representative of actual contaminant loading.
• Disturbance at the sampling point is minimal which minimizes sampling artifacts.
• Less operator variability occurs between sampling events.
• Decreased amount of investigation-derived waste(IDW) is produced.
• Need for filtration is reduced.
• Sample consistency is increased.
Flow-rates during low-flow purging/sampling are site-specific,based on hydrology,but are
generally in the order of 0.1 to 0.5 L/min. Proper screen location, screen length,well construction
and well development techniques may impact the effectiveness of low-flow purging. (Puls and
Barcelona, 1996)
Multi-probe and Flow-Through Cell—The flow through cell allows for in-line sampling of water quality
parameters with the Multi-probe to determine stabilization for water sampling. At a minimum,
groundwater quality parameters include pH, conductivity,temperature,turbidity, and dissolved
oxygen(DO). Examples of multiprobes used for collecting water quality parameters include the
Horiba U-22 and YSI 556 (shown below).
i
Peristaltic Pump—A positive displacement pump used for pumping fluids. Generally, flexible tubing is
fitted inside a circular pump casing.A rotor with a number of"rollers", "shoes" or"wipers"
attached to the external circumference compresses the flexible tube. As the rotor turns,the part of
tube under compression closes thus forcing the fluid to move through the tube.
SOP 4.7 Hot Groundwater Sampling MUR55.docx 4 TRS

Trip Blank—The purpose of trip blanks it to identify any potential contamination of samples during
sample handling and shipment. These blanks are prepared in the laboratory by filling a volatile
organic analysis (VOA)bottle with distilled/deionized water. Trip blanks shall accompany
shipment of empty bottles to the site and shipment of samples back to the laboratory.
VOA Vials—EPA recommended glass sampling containers used to collect liquid samples for laboratory
analysis. VOA vials have a nominal volume of 40 mL and are manufactured of clear or amber
borosilicate glass. Depending on type of analysis being conducted,the VOA vials may contain
small amounts of preservative when shipped from the laboratory. When collecting samples in
VOA vials, fill the vial completely full(ensure that a meniscus has formed at the top of the vial
before securing the cap) and check that there are no air bubbles in the closed sample. If there is a
preservative present,use caution to not overfill the vial.
4.0 EQUIPMENT LIST
The required equipment for groundwater sampling may differ from this SOP based on the requirements
set by the local regulatory oversight agency. Typically,the required equipment will be as follows:
1) Groundwater Sampling Field Form and indelible pen.
2) Safety Glasses with side shields. Additional option: full face-shield (wear over safety
glasses)
3) Chemically resistive gloves (latex or neoprene). Gloves serve a dual purpose to maintain
sample integrity and for dermal protection of the sampler.
SOP 4.7 Hot Groundwater Sampling MUR55.docx 5 � TRS

4) Additional option: leather or cotton outer gloves should be worn to protect against water
having high temperatures (wear over inner latex gloves and under extra-large neoprene
gloves).
5) Site specific personal protective equipment (PPE) requirements. Refer to site specific
HASP.
6) Pump and operating components.
• Peristaltic pump utilized when the depth to water is 20 feet below ground surface (ft bgs)or
less. Dedicated tubing shall be installed prior to ERH application.
• Dedicated bladder pump with compressed air for depth to groundwater greater than 20 feet.
Dedicated pumps shall be installed prior to ERH application.
7) Tubing (should be installed prior to ERH application to target depth)
• Disposable TeflonTM and Silicone tubing(MasterflexTM) for use with the peristaltic pump.
Silicone tubing should be used only above the ground surface at the pump head in order to
minimize potential for degradation by contaminants. The silicone tubing is then connected
to the Teflon tubing,which extends to the target treatment depth within the well. The
downhole tubing and wellhead installation must be complete prior to commencing ERH for
safety reasons.
• Dedicated bladder pumps and tubing if using a bladder pump.
8) Power supply(12 volt automotive battery or similar, or portable generator).
9) Cooler with ice.
10) 10-ft length of/4-inch stainless steel tubing
11)One-ft length of four-inch diameter pipe
12)Tray or container for ice bath.
13)Field water quality measuring equipment w/flow-through cell or similar device for
monitoring groundwater parameters (pH, conductivity, ORP, temperature, DO, etc.) and
calibration standards.
14)Particulate filter. This should only be used as necessary. High temperature water may
cause increased turbidity in extracted groundwater.
15)Turbidity meter.
16)Buckets for purge water.
17)Sample containers (with preservative as required by the laboratory analytical method),
labels, and chain-of-custody forms (as required by the laboratory for the analysis). Pre-
printed labels are generally available from the laboratory if requested in advance.
18)Scissors or tubing cutter(for cutting tubing lengths).
19)Packaging material and shipping labels.
SOP 4.7 Hot Groundwater Sampling MUR55.docx 6 TRS

20)LOTO equipment as described in TRS SOP 1.1.
5.0 HOT GROUNDWATER SAMPLING PROCEDURES
Groundwater purging is generally accepted as a required component of groundwater sampling in order to
remove non-representative water from the well casing(Puls and Barcelona, 1996). Low-flow purging and
sampling techniques will be used to minimize the impact on groundwater chemistry and collect
representative samples. This technique also reduces the amount of investigation derived waste (IDW)
produced from a well.
5.1 Safety Considerations
There are certain hazards associated with ERH during the remediation of soil and groundwater. These
hazardous include possible contact with hazardous voltage, steam,hot water, or hazardous chemicals.
Exposure to these hazards can be mitigated through engineering controls and strict adherence to
documented procedures and safety protocols, such as the following restrictions:
• At no time will a 110/120 volt extension cord from a line source be used in an energized
electrode field.An alternative power source such as a 12 volt automotive battery or portable
generator must be used when samples will be collected with electrical energy applied to the
subsurface. Typically, ground water sampling is performed while the ERH is offline and locked
out.
• Extreme temperatures and steam may be encountered when collecting groundwater samples;the
use of the proper personal protective equipment(PPE) is mandatory and caution is advised.
• Dedicated tubing and pumping systems shall be established prior to application of electrical
energy to the subsurface.
• The ERH PCU system should be turned off and LOTO applied during groundwater sampling
activities.
• Refer to the site specific Sampling and Analysis Plans (SAPs) and HASP for site specific
requirements and restrictions.
5.2 Ice Bath Construction
Groundwater heated through the ERH process presents both a potential safety hazard and a potential
concern for collecting representative samples. If a boiling or near-boiling liquid is collected in a volatile
organic analysis (VOA)vial,the formation of air bubbles as the sample cools within the VOA vial
renders the sample non-representative.Additionally,hot liquids collected in the VOA vial may result in
failure of the VOA septum.
The ice bath is designed to cool the groundwater prior to sampling while limiting the impact on
groundwater chemistry and contaminant concentrations. Cooling the groundwater prior to sampling
allows for both the safe handling of highly elevated water temperatures and prevents the formation of
volatile organic compound(VOC)bubbles in the VOA vial after sample collection.
SOP 4.7 Hot Groundwater Sampling MUR55.docx 7 TRS.

Prior to initial sampling, a cooling coil shall be constructed by wrapping a 10-ft length of/4-inch stainless
steel tubing 6 full turns around a 4-inch diameter pipe. The ends of the tubing shall be fashioned such that
both ends of the tubing extend upward,as shown in the figure below.
r---me
TO PEWTALTM
WELL PIMP AND W PL1N6
V44
3 GALLM KEW
5.3 Pumps
Peristaltic pumps are used for purging and sampling wells that have a depth to water of 20-ft bgs or less.
A dedicated 1/4-inch Teflon TM sample tube will be set within the well and a '/4-inch dedicated sample
valve will be installed at the surface with a"T"prior to the peristaltic pump head for the purpose of
collecting samples. Installation of the sample valve is mandatory in order to prevent steam from escaping
from the well during ERH application. Installation of the downhole Teflon TM tubing must occur prior to
ERH operations. Based on well construction details,the depth to the center of the screen from the top of
the well head should be calculated. Tubing will be measured and installed equal to place the tubing inlet
as close to the center of the screened interval as possible.
Pneumatically operated bladder pumps will be used for purging and sampling wells that with depth to
water greater than 20 feet. The well head completion will be modified to allow for two tubes to pass
independently through the sealed well head assembly. One tube will be used to deliver compressed air to
the pump and the other tube will be used for sample recovery.
Either dedicated bladder pumps with Teflon TM tubing or dedicated TeflonTM tubing for use with a
peristaltic pump will be installed prior to initiating heating of the ERH treatment volume. The use of pre-
installed, dedicated sample equipment will reduce the risk of exposure to steam,hot water, or
contaminants, since the well head will not have to be opened.
Regardless of which pumping system is used,the pump-intake shall be located in the middle or slightly
above the middle of the screened interval. If the pump-intake is too close to the bottom of the well,
increased entrainment of solids may occur. Pump-intake placement should only be used at the top of the
water column in unconfined aquifers screened across the water table,where this is the desired sampling
point. By placing the intake in the middle or near-middle of the screened interval,the amount of mixing
between the overlaying stagnant casing water with the water within the screened interval is minimized.
5.4 Groundwater Sampling
SOP 4.7 Hot Groundwater Sampling MUR55.docx 8 TRS

The TRS project team should coordinate, in advance,with all applicable parties to schedule an ERH
system shutdown. The PM and SHSO shall determine a site-specific shutdown period. Sampling shall be
completed in order from the wells having the lowest anticipated concentrations of contaminants of
concern(COC)to wells having the highest anticipated COC concentrations (from exterior wells to
boundary control wells to wells located within the source area).
The groundwater sampling procedure is as follows:
1) Calibrate probes used to monitor water quality parameters according to the
manufacturer's instructions (as necessary). Calibration frequencies should adhere to the
manufacturer's recommendations.
2) Cease power application to the treatment area and perform LOTO procedures on the ERH
PCU if required by site specific protocols. Note: LOTO application shall only be
completed by personnel who have been trained and certified by TRS according to SOP
1.1.
3) Confirm that the pump inlet (end of tubing for peristaltic pump or screened opening on
the bladder pump) is located within the screened interval.
4) Connect 1/4-inch sample tubing from the valve on the well to the cooling coil and place
the coil in a bucket or cooler with ice to form the ice bath as described in Section 5.2.
5) Connect the pump to the cooling coil. For wells with a depth to water less than 20 feet,
connect the cooling coil and peristaltic pump to the monitoring wellhead. For wells having
a depth to water greater than 20-ft bgs, connect pump controls to the previously deployed
bladder pump and connect the cooling coil and compressed air source.
6) Connect the cooling coil discharge tubing to a flow-through cell with the calibrated meter
probes/sensors securely held in the flow-through cell.
7) Connect tubing from the discharge of the flow-through cell to the purge water collection
bucket.
PUMPING SET-UP WITH PERISTALTIC PUMP
Y4' TUBING y,. TUBING
Yi TEELON y' TUBING Ye" TUBING
TUBING
FILTER
PERISTALTIC
PUMP
COOLING COIL PURGE WATER
FLEW THROUGH DISCHARGE
MONITORING SAMPLE CELL CONTAINER
WELL COLLECTION
SOP 4.7 Hot Groundwater Sampling MUR55.docx 9 TRS,

PUMPING SET-UP WITH SUBMERSIBLE PUMP
�' TUBING TUBING
3'i' TEFLON y' TUBING
TUBING
CONTROL 0
BO}f FILTER
MONITORING
WELL
PURGE WATER
COOLING COIL
FLOW THROUGH DISCHARGE
CELL CONTAINER
FROM TO PERISTALTIC
NOfW
WELL
PUW AND 54XPLTXG
ICE WATER
[DOLING"ATX
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8) Begin purging the well at a low- flow rate. Target pumping rates should generally be in
the order of 0.1 to 0.5 liters per minute (L/min) to ensure stabilization of parameters and
reduce mixing of formation water with stagnant well casing water. (Puls and Barcelona,
1996). Depending on site parameters and pumping method used, maintaining a steady
low-flow rate may require pumping up to a rate of 1 L/min. Adjustments to the pumping
rate are best made within the first 15 minutes of purging to minimize purging time.
9) The pumping rate is recorded on purge data sheets every 3 to 5 minutes during purging.
Any adjustments to the pumping rate are recorded. At the initiation of well purging and
after recording pumping rates, water quality parameters are measured and recorded with a
multi-parameter water quality meter equipped with a flow-through cell. The measured
water quality parameters are temperature, turbidity, specific conductance, pH, DO, and
oxygen reduction potential (ORP or Redox). Pumping shall continue until the water
quality parameters have stabilized (refer to Section 5.4.1) or the minimum purge volume
has been removed(refer to Section 5.4.2).
10)After all water quality parameters have stabilized (refer to Section 5.4.1) and the
minimum purge volume is purged (refer to Section 5.4.2), sampling may begin. If all
parameters have stabilized, but turbidity remains above 10 NTUs, decrease the pump rate
and continue monitoring. If the pump rate cannot be reduced and turbidity remains above
10 NTUs, the information will be recorded and sampling initiated. For low yield wells,
sampling commences as soon as the well has recovered sufficiently to collect the
SOP 4.7 Hot Groundwater Sampling MUR55.docx 10 TRS

appropriate volume for the anticipated samples. If well purging has caused the well to
become dry, refer to Section 5.4.3 for sampling procedures.
11)Disconnect the tubing from the inlet side of the flow-through cell. The tubing from the
pump outlet will be used to fill the groundwater sample bottles. Samples for VOCs shall
be collected first followed by semi-volatile organic compounds (SVOCs). All other
parameters should be collected in order from most volatile to least.
12)Groundwater samples including quality control (QC) samples are labeled and preserved
per the site-specific Sampling and Analysis Plan (SAP).
13)All pertinent information will be documented in the sample log book and on the chain of
custody forms including: date, time of sample, sample identification, analysis being
completed, and any other information deemed relevant to the sample results. The
following additional information shall be documented in the sample logbook: time at
beginning and end of well purging, flow rate and any changes during the well purge,
equipment used for well purge, and water quality parameter readings used to determine
sample time.
14)Package and ship samples with a laboratory supplied trip blank to the offsite laboratory
for analysis.
15)Meters used for groundwater sampling effort shall be decontaminated according to
manufacturer recommendations. Dispose of decontamination liquids and purge water in
accordance with site-specific documents.
5.4.1 Water Quality Parameters
Readings are recorded on the purge data sheets every 3 to 5 minutes. Field parameters are monitored until
stabilization occurs. Unless local regulatory requirements differ,readings are generally considered stable
when three consecutive readings are within the following criteria:
• Specific conductance readings within 5 percent
• pH within+/-0.1 standards units
• DO readings within 10 percent
• Turbidity of 10 NTUs (note this may be difficult to obtain due to high turbidity that may
occur with high temperature water)
5.4.2 Minimum Purge Volume
The minimum purge volume is three times the static saturated well volume. The equation to calculate the
minimum purge volume is:
V=7.48*rw2(td-dtw)
Where V=one purge volume in gallons; rw=radius of well casing in feet;td=total depth of well in feet;
dtw=typical depth to groundwater in feet.
SOP 4.7 Hot Groundwater Sampling MUR55.docx 11 TRS

5.4.3 Dry Well Sampling
If well purging has caused the well to become dry,the following procedures will be used to sample the
well and allow for recharge:
1)A column of water is drawn in the cooling coil tubing with the pump.
2) The well sample valve and the peristaltic pump inlet valve are closed and the pump shut
off.
3) The cooling coil is disconnected from the well sample valve.
4) The cooling coil is carefully removed from the ice bath.
5) The pump inlet valve is opened.
6) The sample is decanted into the sample vials from the pump end of the tubing via gravity
flow.
The process is repeated until the sample volume is collected. Any other sample fractions(cations, anions)
are sampled from the well end of the cooling coil tubing.
6.0 RESPONSIBILITIES
Role Responsibility
TRS Technical Group • Develop and implement SOPs
Lead • Periodically review and update procedures based on project feedback
TRS HSO • Provide training and maintain training documentation.
• Assist SHSO with modifying SOP to meet site specific HASP and SAP
requirements.
• Work with PM to develop AHA for any intrusive work required to
complete groundwater sampling efforts.
PM • Review procedures in conjunction with site specific SAP requirements
and scope of work(SOW). Coordinate changes to procedures as
necessary.
• Schedule and coordinate sampling effort. Ensure adequate supplies are
available.
• Work with HSO to develop AHA for any intrusive work required to
complete groundwater sampling efforts.
SHSO • Conduct orientations for subcontractors and employees
• Coordinate training needs with TRS HSO
• Review procedures in conjunction with site specific HASP. Coordinate
changes to procedures as necessary to maintain safe working procedures.
Sampling Personnel • Complete training to the level of competent person prior to initiating
sampling activities.
• Follow procedures and document information related to groundwater
sampling effort as identified in this SOP, including and deviations from
the SOP.
SOP 4.7 Hot Groundwater Sampling MUR55.docx 12 TRS

7.0 TRAINING
Training in SOPS is provided upon initial assignment and annually thereafter. Practical training is
provided on a project-specific basis. Additional retraining is provided if there is a change in procedures or
if inadequacies are observed in the individual's application of procedures.
Competent persons in hot groundwater sampling are determined by the ERH PM and SHSO and must, at
a minimum, complete the following requirements:
• Read this SOP (SOP 3.1) and understand the general process and the specific requirements
of this SOP.
• Sign the training acknowledgement form.
• Obtain onsite instruction by a knowledgeable person on the task-specific hazards associated
with hot groundwater sampling and the methods used to control these hazards.
• Obtain onsite instruction by a knowledgeable person on important technical components of
the hot groundwater sampling program to ensure the collection of representative samples.
8.0 RECORD KEEPING
These are standard(i.e.,typically applicable)procedures which may be varied or changed as required,
dependent on site conditions, equipment limitations,permit requirements or limitations imposed by the
procedure. The ultimate procedures used during any sampling event,including any deviations from these
procedures, shall be documented in the sample logbook.AHA's developed for any intrusive work
conducted in conjunction with this SOP shall be maintained with the groundwater sample logbook.
Calibrations of water quality meters used to measure water quality readings shall be completed according
to the manufacturer's recommendations. Calibration results shall be maintained in a written log kept at the
site throughout the operational phase of the project.
At a minimum,the following information shall be maintained in the sample logbook related to well
purging and groundwater sample collection:
• date,
• sample/purge location identification,
• type of pump used for well purge,
• duration of well purge,
• sample time,
• flow rate (including changes throughout purge),
• meter(s)used for collection of water quality parameters and calibration documentation,
• water quality parameter readings,
• volume of purge water collected prior to sampling,
• sample identifications and analysis to be performed,
SOP 4.7 Hot Groundwater Sampling MUR55.docx 13 TRS

• chain of custody number,
• shipping information,
• procedures used for equipment decontamination,
• deviations from this SOP, and
• any other information deemed relevant to the sample results.
Copies of chains of custody forms and shipping documentation shall be maintained and kept with the
sample log book.
9.0 REFERENCES
Puls, R.W. and M.J. Barcelona, 1996, Low-Flow(Minimal Drawdown) Ground-Water Sampling
Procedure, EPA/540/S-95/504.
SESD Operating Procedure Groundwater Sampling,2013, SESDPROC-301-R3,EPA Region 4
SOP 4.7 Hot Groundwater Sampling MUR55.docx 14 TRS

TRS
Aa[2d2ratirrg wtuc•
SOP 3.1 Hot Groundwater Sampling
Training Acknowledgment
All personnel that receive training on this procedure will review and sign the acknowledgement
form contained in this section.
I have been trained by TRS Group, Inc. (TRS) to perform non-intrusive hot groundwater
sampling at ERH project sites. By signing this document, trainee acknowledges that SOP 3.1
Hot Groundwater Sampling has been read and the contents of the document are understood.
Trainee has received hands-on training from a competent person who is authorized to use
and instruct others on sampling procedures at TRS project sites.
Training
Date Acknowledgement TRS Trainer

6 TRS STANDARD OPERATING PROCEDURE
No: 3.2
" lAd'ue PROCEDURE
Procedure Title:
HOT SOIL SAMPLING
Author: TRS Team Issue Date: 4/22/08
Revisions:
Date Initials Revision Description Revision#
01-04-10 LS Add Scope,responsibilities,training,definitions,recordkeeping 1
5-6-14 TP Added caution concerning hot water,steam expulsion 2
Reviewed and Approved by(initial and Hate):
SOP/Revision# Health& Safety Operations
Original 4/22/08 4/22/08
REV 1 1/4/10 1/4/10
REV 2 5/22/14 5/22/14
a .
I
TRS
SOP 3.2 Hot Soil Sampling REV 2 1 nrPaewkW

1.0 PURPOSE
The purpose of this Standard Operating Procedure(SOP)is to provide a procedure for the safe collection
of representative soil samples during, or after,the application of Electrical Resistance Heating(ERH).
This procedure specifically addresses sampling of soil that has been heated as a result of the ERH process.
2.0 SCOPE
This SOP serves as a guideline for the collection of soil samples during, or after,the application of ERH.
To minimize the risk due to electrical hazards, lockout/tagout(LOTO)procedures must be applied to the
ERH power control unit(PCU)throughout the duration of the soil sampling effort. Only authorized
persons trained in procedures and requirements described in SOP 1.1 are permitted to conduct LOTO on
TRS equipment. Samples collected using this SOP are generally used for evaluating treatment
effectiveness, and/or confirming treatment goals have been met.
TRS Group,Inc. (TRS)personnel shall use this procedure in conjunction with site-specific sample
analysis plans,the site-specific Health and Safety Plan (HASP), and permit requirements.These are
standard(i.e.,typically applicable) operating procedures,which may be varied or changed as required,
dependent on site conditions, equipment limitations,permit requirements or limitations imposed by the
procedure. The ultimate procedures,including any deviations from this SOP, shall be documented in the
soil sampling form.
3.0 DEFINITIONS
Authorized Employee—Any designated employee who locks out or tags out equipment in order to
perform servicing or maintenance. This person must have completed the mandatory LOTO
training described in SOP 1.1 LOTO to be qualified as an authorized worker. Only an authorized
worker installs and removes his or her own lock and tag as required by this program.
Competent Person—Any designated employee who has been trained in proper procedures for the
application of energy to the subsurface at ERH sites. This person must have completed the
mandatory training outlined in Section 7.0 to be qualified as a competent person.
ERH—Electrical Resistance Heating is a process whereby soils and groundwater are heated by passing an
electrical current through the subsurface volume to be remediated.
LOTO—Lockout/Tagout. The practice of using a tag for visibility and awareness in conjunction with
placement of a keyed device ("lock") on an energy isolating device,in accordance with SOP 1.1,
to prevent the unwanted activation of mechanical or electrical equipment. Lockout ensures the
equipment being controlled cannot be operated until the lock is removed.
4.0 EQUIPMENT LIST
1) Soil Sampling Field Form and pen(recommend indelible).
2) Drill rig and related equipment. Soil sampling is best achieved using a direct push drill rig
such as a Geoprobe®. Geoprobe®Dual Tube Sampling Systems are efficient methods of
TRS
SOP 3.2 Hot Soil Sampling REV 2 2 0§ nrPaewkW

collecting continuous soil cores with the added benefit of a cased hole, especially at depths
greater than 20 feet below ground surface(ft bgs).
3) Ice bath for soil samples. An example is a cooler filled with ice. The cooler(or container)
must be equipped with an opening at the bottom to allow water from melting ice to drain.
4) Standard cooking thermometer. Calibrated to both 0°C and 100°C.
5) LOTO equipment as described in TRS SOP 1.1.
6) Sample containers, labels, and chain-of-custody forms(as required by the laboratory for the
analysis).
7) Safety Glasses with side shields.Additional option: full face-shield(wear over safety glasses)
8) Hearing protection adequate for sampling equipment decibel level.
9) Latex gloves. Additional option: cotton or leather outer gloves (wear over inner latex gloves).
10) Site-specific personal protective equipment(PPE)requirements. Refer to site-specific HASP.
11) Packaging material and shipping labels.
5.0 HOT SOIL SAMPLING PROCEDURES
A soil-sampling event begins with the shutdown and application of LOTO to the PCU. This is done to
prevent any electrical hazards between the steel drill string and sampling personnel. The vapor recovery
system should continue to operate to maintain capture of steam in the subsurface,rather than allowing it
to exit through the sample borehole. Interim and final soil sampling is best achieved using a direct push
drill rig such as a Geoprobe®. As the probe casing is extracted from the subsurface, it should be
considered to be very hot, and handled with proper precaution and personal protective equipment.
Choose a sample sleeve consistent with the conditions being encountered. For example if sample location
temperature is elevated above 100C then a steel sleeve will be a better choice than a Teflon sleeve as the
Teflon sleeve will become soft and deform at elevated temperatures. Consult engineering for the
appropriate sleeve.
TRS
SOP 3.2 Hot Soil Sampling REV 2 3 nrPaewkW

5.1 Safety Considerations
There are certain hazards associated with ERH during the remediation of soil and groundwater. These
hazardous include possible contact with hazardous voltage, steam,hot water,hot soil, other hot surfaces,
or hazardous chemicals. Exposure to these hazardous can be mitigated through engineering controls and
strict adherence to documented procedures and safety protocols such as the following restrictions:
• The ERH PCU system must be turned off and LOTO applied during soil sampling activities.
• High temperatures,hot waster and steam may be encountered when collecting subsurface soil
samples;the use of the proper PPE is mandatory and caution is advised.
• Contaminant vapors may be present at the borehole during sampling.
• Personnel shall be trained on hazards and engineering controls associated with drilling before
beginning sampling operations. Potential hazards include rotating equipment, overhead loads, and
slips trips and falls.
Refer to the site-specific Sampling and Analysis Plans(SAPs) and HASP for site-specific requirements
and restrictions.
Caution: Exposure to hot groundwater and steam possible
The removal of water and soil from the sample borehole can change the temperature/pressure equilibrium
conditions existing in the borehole prior to drilling and sampling by reducing the hydrostatic head in the
borehole allowing hot water and steam to eject from the borehole. Review the site conditions prior to
commencing drilling or boring. If sampling soil beneath the groundwater surface level elevation,always
remove the boring equipment and samples slowly from the boring to allow the borehole conditions to
safely re-equilibrate.
Stop and complete the attached Site Sampling Evaluation Checklist(attached)before proceeding with this
procedure.
5.2 Hot Soil Sampling Procedures
Sampling shall be completed in order from sample locations having the lowest anticipated concentrations
of contaminants of concern(COC)to locations having highest anticipated COC concentrations(i.e.;
outside treatment area,treatment area boundary, locations within the source area). The steps outlined
below must be followed for both interim and final hot soil sampling.
1) Telephone the TRS PM the day prior to sampling to schedule a remote shutdown.A shutdown
period of at least 12 hours is preferred prior to soil sampling.
2) An authorized person shall apply LOTO to the ERH PCU by site-specific instructions.Note:
Only personnel who have been trained and certified by TRS in LOTO procedures can complete
this procedure.
3) Position drill rig in the area to be sampled and perform a visual check for any safety concerns.
Potential concerns include: high voltage lines,uneven terrain,underground utilities, and egress
limitations with rig placement.
TRS
SOP 3.2 Hot Soil Sampling REV 2 4 nrPaewkW

Mr
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4) Hand auger, or air knife the first five feet of the boring to clear location for potential buried
utilities.
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' !
r
5) Advance the push sampler to the depth required and collect samples. The sample sleeves used
must be made of Teflon®,brass, or stainless steel. Sample sleeves made of other materials such
as acrylic or other materials can melt and bias sample results.
d
TRS
SOP 3.2 Hot Soil Sampling REV 2 5 A"L- wkre

6) The sample sleeves must be capped immediately and placed into the ice bath to begin the cool
down process. Water from melting ice must be allowed to drain, as the sample sleeves should not
be submerged at any time.
i.+
7) The sample sleeves should be cooled until the soil nears ambient temperature(approximately
20°C or 70°F). A standard cooking thermometer can be inserted through the end cap for
temperature monitoring. The sample sleeve may be opened and sampled once near-ambient
temperatures have been reached.
k .
8) Soil samples including quality control(QC)samples are collected, labeled,preserved and shipped
per the site-specific Sampling and Analysis Plan and SW-846 Method 5035.
9) Plugging/sealing of the soil borehole will be in accordance with Federal, State, and Local
regulatory and client requirements.
10) Soil cuttings not consumed in the sampling process will be disposed of according to Federal,
State, and Local regulatory and client requirements.
TRS
SOP 3.2 Hot Soil Sampling REV 2 6 nrPaewkW

6.0 RESPONSIBILITIES
Role Responsibility
• Develop and implement SOPS
VP Operations • Periodically review and update procedures based on project feedback
• Provide training and maintain training documentation
• Assist VP Operations with providing training and maintaining training
documentation.
TRS HSO o Assist Site Health and Safety Officer(SHSO)with modifying SOP to
meet site-specific HASP requirements.
• Review procedures in conjunction with site-specific sample
requirements and scope of work(SOW). Coordinate changes to
PM procedures as necessary.
• Schedule and coordinate sampling effort. Ensure adequate supplies are
available.
• Conduct orientations for subcontractors and employees
SHSO • Coordinate training needs with TRS HSO
• Review procedures in conjunction with site-specific HASP. Coordinate
changes to procedures as necessary to maintain safe working procedures.
• Complete training to the level of competent person prior to initiating
sampling activities.
Sampling Personnel o Follow procedures and document information related to soil sampling
effort as identified in this SOP,including and deviations from the SOP.
7.0 TRAINING
Training in SOPS is provided upon initial assignment and annually thereafter. Additional retraining is
provided if there is a change in procedures or if inadequacies are observed in the individual's application
of procedures. Subcontractors must train their own employees. LOTO training requirements for personnel
are outlined in SOP 1.1.
U RECORD KEEPING
These are standard(i.e.,typically applicable)procedures,which may be varied or changed as required
dependent on site conditions, equipment limitations,permit requirements, site-specific hazards, or
limitations imposed by the procedure. The ultimate procedures used during any sampling event, including
any deviations from these procedures, shall be documented in the sample logbook.
TRS
SOP 3.2 Hot Soil Sampling REV 2 7 nrPaewkW

At a minimum,the following information shall be maintained in the sample logbook related to hot soil
sampling at ERH project sites:
• Date;
• Sample identification and corresponding location;
• Sample time;
• Sample identifications and analysis to be performed;
• Chain of custody number;
• Shipping information;
• Deviations from this SOP, and;
• Any other information deemed relevant to the sample results.
Copies of chains of custody forms and shipping documentation shall be maintained and kept with the
sample logbook.
9.0 REFERENCES
TRS Group, Inc., 2013. SOP 1.1, Lockout/Tagout (LOTO), Current Rev.
US EPA Test Methods for Evaluating Solid Waste, Physical/Chemical Methods SW-846,
Most Recent Version(Method 5035)
TRS
SOP 3.2 Hot Soil Sampling REV 2 8 nrPaewkW

TRS
Atttirrg Vfohre
SOP 3.2 Hot Soil Sampling
Training Acknowledgment
All personnel that receive training on this procedure will review and sign the acknowledgement
form contained in this section.
I have been trained by TRS Group, Inc. (TRS) to perform hot soil sampling at TRS ERH
project sites. By signing this document, trainee acknowledges that SOP 3.2 Hot Soil
Sampling has been read and the contents of the document are understood. Trainee has
received hands-on training from a competent person who is authorized to use and instruct
others on sampling procedures at TRS project sites.
Date Training Acknowledtement TRS Trainer
SOP 3-2 Hot Soil Sampling Rev 2(MAB signed) Site Sampling Evaluation Checklist

T
Atttirrg Vfohre
RS
Site Sampling Evaluation Checklist
Project#:
Date:
Subsurface Conditions
1) Are soil samples being recovered from beneath the groundwater surface?
2) What is the depth to groundwater at the time of sampling?
3) How deep below the groundwater surface elevation are we sampling?
4) What are the current temperatures at or near each boring location?
5) Are there confining layers on site? Clay or silt over saturated zone sand for example.
6) Use the figure below to determine where the sites actual temperatures fit on the boiling point
curve.
Water Boiling point (°C)
100 105 110 115 120 125 130 135 140
0
-10
-20
v
� -30
N
-40
p -50
a�
00
t -60
a
m
-70
-80
7) Actual temperature for each depth elevation that is higher in value than the temperatures
represented by this curve suggest a temperature value greater than the hydrostatic boiling point of
water.
SOP 3-2 Hot Soil Sampling Rev 2(MAB signed) Site Sampling Evaluation Checklist

ELECTRICAL RESISTANCE HEATING DESIGN PACKAGE
FORMER CLIFTON PRECISION FACILITY
1995 STATE ROAD 141
MURPHY, NORTH CAROLINA
Prepared by:
TRS
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MACHINE SHOP
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Y-5 AREA 1 ELECTRODE LAYOUT BRUSHLM m
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- o°
a
• � P-3 PROCESS FLOW MASS BALANCE P�
' P-4 FIELD PROCESS AND INSTRUMENTATION DIAGRAM
P-5 CONDENSER PROCESS AND INSTRUMENTATION DIAGRAM
f P-6 COOLING TOWER PROCESS AND INSTRUMENTATION DIAGRAM
P-7 VAPOR TREATMENT PROCESS AND INSTRUMENTATION DIAGRAM
M-1 VERTICAL ELECTRODE DETAIL
M-2 VERTICAL BEDROCK ELECTRODE DETAIL
SITE LOCATION MAP M-3 ANGLED BEDROCK ELECTRODE DETAIL
• M-5 VERTCALEMONTOR MOLECTRODE NITORING WELL DETAIL ETAIL SITE PLAN y
0 1 50
NORTH CAROLINA M-6 ANGLED MONITORING WELL DETAIL
M-7 VERTICAL TEMPERATURE MONITORING POINT DETAIL APPROXIMATE SCALE N FEET
M-8 ANGLED TEMPERATURE MONITORING POINT DETAIL
M-9 ADDITIONAL VAPOR RECOVERY WELL DETAIL
M-10 TRENCH SECTION DETAIL
M-11 ONE-LINE DIAGRAM

PRELIMINARY - DO NOT MACHINE SHOP
USE FOR Water Tank
CONSTRUCTION
Drain CONSTRUCTION
HP-20
e GW-8B 315' HP-15 140'
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MIN BUILDING
F MAX TCE GROUNDWATER
1p� 400 CONCENTRATION AT DEPTH
(U9/k9)
17 TEMPERATURE MONITORING
POINT
GW-6B 15 ANGLED TEMPERATURE
47' MONITORING POINT
GW-6D
ee
GW-6S
BHP-22 0 MW CONVERTED INTO TMP
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
A.PEABODY
/VORTHROP GRUMMAN CHECKED BY
N TRSNOT APPROVED SITE PLAN
Accelerating Value PROJECT MANAGER
0 25 50 D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
04/29/14 MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY `,
SCALE IN FEET PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET T Iw
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE

PRELIMINARY - DO NOT MACHINE SHOP
USE FOR Water Tank
5016 S Oo
CONSTRUCTION
R15 R016 F�17 R18
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DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
T■ A.PEABODY
NORTHROP GRUMMAN CHECKED BY
N TRSNOT APPROVED ELECTRODE LAYOUT
Accelerating Value PROJECT MANAGER
0 25 50 D.SMALL
APPROVED FOR CONSTRUCTION DATE 04/29/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AN THE BY
D
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SCALE IN FEET PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET Y—L
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE 1

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DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
A.PEABODY
NORMROP GRUMMAN CHECKED BY
N TRS NOT APPROVED VERTICAL ELECTRODE LAYOUT
Accelerating value PROJECT MANAGER
0 20 40 D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
04/29/14 MUR55
L� CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY `, ^
SCALE IN FEET PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET V— K
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE 1 VVV

PRELIMIN Y - DO NOT ,0K15
U S FOR � Parch
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DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
A.PEABODY
NORTHROP GRUMMAN CHECKED BY
�7
A� TRS NOT APPROVED ANGLED ELECTRODE LAYOUT
Accelerating Value PROJECT MANAGER
0 16 32 D.SMALL
APPROVED FOR CONSTRUCTION DATE 04/29/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
SCALE IN FEET PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET Y-4
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE

3) PM-3D/o 300 PPM
Ramp
PM-5S 400
J13 J 14 J 6PM-3S J17 J18 J19
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QO QO QO BEDROCK ELECTRODE
-
P� PRELIMINARY DO NOT 4
B06 B07 B08 B09 B 10 USE FOR ADDITIONAL VAPOR
RECOVERY WELL
CONSTRUCTION
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
A.PEABODY
NORTHROP GRUMMAN CHECKED BY
N TRSNOTAPPROVED AREA 1 ELECTRODE LAYOUT
Accelerating Value PROJECT MANAGER
0 12 24 D.SMALL
APPROVED FOR CONSTRUCTION DATE 04/29/14 PROJECT MUR55
�T CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY r
SCALE IN FEET PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET Y-'l
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE VVV

PRELIMINARY - DO 1
O MACHINE SHOP
Water Tank
CONSTRUCTION
GW-88
Road
Q17
P 14
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30
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DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
A.PEABODY
NORMROP GRUMMAN CHECKED BY
N TRS NOT APPROVED TRENCHING PLAN
Accelerating Value PROJECT MANAGER
0 20 40 D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
04/29/14 MUR55
L� CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY `, /�
SCALE IN FEET PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET V-6
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE 1 lJ

Road
PRELIMINARY - DO NOT
Q17 USE FOR
P14 RUCTION
O �N OH TOT O
of
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DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
A.PEABODY
/VORMROP GRUMMAN CHECKED BY
N TRSNOT APPROVED EQUIPMENT LAYOUT
Accelerating Value PROJECT MANAGER
0 5 10 ipffl
D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
04/29/14 MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY `,
SCALE IN FEET PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET V��
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE 1

UTILITY GROUND
SURVEY APPLIES
EVERYWHERE.
=90 WET SURVEY
PERFORMED
OUTSIDE AND WITHIN
5' OF INSIDE OF
DOORWAYS.
MACHINE SHOP
10V STEP&STEP,
STEP&TOUCH LIMIT
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A
DESIGNED BYFOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
NORTHROP GRUMMANN TRS A.PEDBY
CHECKED BY
NOT APPROVED ERH VOLTAGE LIMITIS
Accelerating Value PROJECT MANAGER
0 30 60 D.SMALL
APPROVED FOR CONSTRUCTION DATE 05/20/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
SCALE IN FEET PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET Y_r�
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE V

LEGEND
PRELIMINARY - DO NOT
USE FOR - - - ELECTRONIC SIGNAL COMPUTERTA OPERATED
AND CONTROLSITMONITORING,
CONSTRUCTION ELECTRICAL CABLE FCN
NiA HARDWIRE CONTROLS
OPROCESS LINE LABELING
SEE SHEET P-2 FOR DESCRIPTION PI PRESSURE INDICATOR
SOLENOID PCV PRESSURE CONTROL VALVE
IIyyIVV FE FLOW ELEMENT
101 BALL VALVE
FI FLOW INDICATOR
N BUTTERFLY VALVE
FQI FLOW QUANTITY INDICATOR
SAMPLE PORT FT FLOW TRANSMITTER
CHECK VALVE FQI FLOW QUANTITY INDICATOR
SELF-CONTAINED LI LEVEL INDICATOR
PRESSURE REGULATOR
LSH LEVEL SWITCH HIGH
SPIGOT LSHH LEVEL SWITCH HIGH-HIGH
BACKFLOW PREVENTER LSL LEVEL SWITCH LOW
FLANGE LSLL LEVEL SWITCH LOW-LOW
TAH TEMPERATURE ALARM HIGH
XX��_XX PIPING SPEC.#CHANGE
TE TEMPERATURE ELEMENT
PUMP TSL TEMPERATURE SWITCH LOW
�/- BLOWER TI TEMPERATURE INDICATOR
TSH TEMPERATURE SWITCH HIGH
O
O ROTARY LOBE BLOWER YC CONTROLLER
T THERMOCOUPLE
DIAPHRAGM PUMP CS CARBON STEEL
CPVC SCH 40.CPVC PIPE
PEX PEX TUBING
COMPRESSED AIR FILTER
FCV FLOW CONTROL VALVE
NOTE: THIS IS AN ALL INCLUSIVE LEGEND SHEET. DESIGNED BY FOR FORMER CLIFTON PRECISION FACILITY
NOT ALL SYMBOLS WILL APPEAR ON EACH SHEET. J.SEEMAN
DRAWN BY MURPHY,NORTH CAROLINA
TRS J.SEEMAN
CHECKED BY PROCESS AND INSTRUMENTATION DIAGRAM
NOTAPPROVED
Accelerating Value PROJECT MANAGER LEGEND
D.SMALL
APPROVED FOR CONSTRUCTION DATE 05/20/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR ��
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE

PRELIMINARY - DO NOT
USE FOR
CONSTRUCTION
REFER TO DRAWING SHEET P-7
COMBUSTION 20
AIR
I
BLEED AIR 4 0 5 6 SCRUBBER 21 DISCHARGE TO
O ATMOSPHERE
THERMALVAPOR
BLOWER TREATMENT SYSTEM
(TYPICAL OF 2) 19
2 SCRUBBER SCRUBBER
L - - - - - - - - - - - - - - MAKE-UP WATER - 18- - - - - - - - SLOWDOWN- - - -
REFER TO DRAWING SHEET P-4 REFER TO DRAWING SHEET P-5 REFER TO DRAWING SHEET P-6
I I I I I
1 II
I I I 8 AIR OUT I
CONDENSER
:�>
(TYPICAL OF 2) I I 9
10
3 17 I I COOLING
TOWER 11 MAKE-UP WATER
12 LGAC I I (TYPICAL OF 4)
-_ 14 I I I I
13 16 SLOWDOWN WATER I I I
AIR IN 7
II CIRCULATING DRIP SYSTEM
�YAPOR RECOVERYTYPICAL
OF116 WELLS
FOR ELECTRODE WETTING
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
TRS J.SEEMAN
CHECKED BY VAPOR RECOVERY AND CONDENSING
NOT APPROVED
Accelerating Value PROJECT MANAGER PROCESS FLOW DIAGRAM
D.SMALL
APPROVED FOR CONSTRUCTION DATE 05/20/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR P-2
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE

PRELIMINARY - DO NOT
USE FOR
CONSTRUCTION
Process Stream Location Air Water Vapor Water TCE Chlorine Atoms Temperature Pressure
Description # (lb/min) (scfm) (lb/min) (scfm) (lb/min) (gpm) (lb/min) (ppm) (lb/min) (ppm) o C o F (A from
barometric)
Extracted air and steam from vapor recovery system 1 84 1,120 45.8 976 15 1.8 5.10E-02 71.29 0.0413 58 80 176 5" Hg Vac
Discharge air from condenser after steam removal 2 84 1,120 2.3 49 0 0 5.09E-02 128.10 0.0413 104 30 86 8" Hg Vac
Condensate discharge from condenser to LGAC 3 0 0 0 0 58.8 7.1 1.0E-04 1.75 0.0001 1.42 30 86 10 psig
Condensate discharge after LGAC 17 0 0 0 0 58.8 7.1 5.1E-06 0.09 4.2E-06 0.07 30 86 10 psig
Bleed air to rotary lobe blower 4 15 200 0.1 3 0 0 0 0 0 0 16 60 N/A
Discharge air from rotary lobe blower 5 99 1,320 2.42 52 0 0 0.051 109 0.0413 88 60 140 1 psig
Discharge air from thermal vapor treatment system 6 118 1570 2.42 52 0 0 2.5E-03 4.62 4.1E-02 3.74 204 400 N/A
Cooling air into cooling tower 7 4500 60,000 42.19 898 0 0 0 0 0 0 16 60 N/A
Air exhaust from cooling tower 8 4500 60,000 53 1135 0 0 0 0 0 0 17 62 N/A
Recirculation water from heat exchanger to cooling tower 9 0 0 0 0 9,961 1,196 1.0E-04 1.0E-02 8E-05 8.4E-03 17 62 10 psig
Cooling water to condenser heat exchanger and Scrubber 10 0 0 0 0 9,996 1,200 5.1E-06 5.1E-04 4.2E-06 4.2E-04 14 57 10 psig
Make-up water for cooling tower from potable source 11 0 0 0 0 8 1.0 0 0 0 0 20 68 15 psig
Water for drip system and blowdown 12 0 0 0 0 94 11.3 4.8E-08 5.1E-04 4E-08 4.2E-04 20 68 10 psig
Water to drip recirculation system 13 0 0 0 0 4 0.5 2.1E-09 5.1E-04 2E-09 4.2E-04 20 68 10 psig
Moving water in drip recirculation system 14 0 0 0 0 83 10 4.3E-08 5.1E-04 3E-08 4.2E-04 20 68 70 psig
Drip water to electrodes 15 0 0 0 0 4.2 0.5 0 0 0 0 20 68 70 psig
Blowdown water 16 0 0 0 0 53.2 6.4 2.5E-07 4.7E-03 2E-07 3.8E-03 20 68 70 psig
Scrubber make-up water 18 0 0 0 0 36.7 4.4 1.9E-08 5.1E-04 2E-08 4.2E-04 20 68 10 psig
Scrubber blowdown water 19 0 0 0 0 29.3 3.5 1.8E-06 6.2E-02 4E-02 1407 49 120 10 psig
Combustion air to thermal vapor treatment system 20 18.75 250 0.2 4 0 0 0 0 0 0 16 60 N/A
Discharge air from scrubber to atmosphere 21 117.75 1,570 10 204 0 0 2.5E-03 9.2 0.0021 7 49 120 N/A
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
1. LOCATIONS INDICATED IN THIS TABLE CORRESPOND TO THE LOCATION NUMBERS PROVIDED ON SHEET P-1. TRS
J.SEEMAN
CHECKED BY
NOT APPROVED PROCESS FLOW MASS BALANCE
Accelerating Value PROJECT MANAGER
D.SMALL
APPROVED FOR CONSTRUCTION DATE 05/20/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR �]_�
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE r

DATA ACQUISITION
AND COMPUTER
CONTROLS
YC
ERH POWER ELECTRODE CABLES
CONTROL UNIT SDTX
r - - - - - - - - PSL PSL REFER TO DRAWING
F 401 402 SHEET P-5
O AIR AND STEAM TO
1 CONDENSER PRIMARY
REFER TO DRAWING I REFER TO DRAWING SEPARATOR
SHEET P-5 I SHEET P-5
ELECTRODE DRIP I ELECTRODE DRIP
RECIRCULATION LOOP 13 14 RECIRCULATION LOOP
FROM P-503 JPEX
TO P-503
ELEMENT
T
T
T
T
PRELIMINARY - DO NOT
T
USE FOR
CONSTRUCTION
TYPICAL OF 13 TEMPERATURE MONITORING POINTS
TYPICAL OF 112 ELECTRODES
WITH CO-LOCATED VR WELLS
BY
NOTES: DESIGNED
SEEMAN FOR
FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
1. SEETHE ELECTRODE AND TEMPERATURE MONITORING POINT DETAILS FOR TRS
J.SEEMAN
MORE INFORMATION ON THEIR CONSTRUCTION. CHECKED BY FIELD
NOT APPROVED
Accelerating Value PROJECT MANAGER PROCESS AND INSTRUMENTATION DIAGRAM
D.SMALL
APPROVED FOR CONSTRUCTION DATE 05/20/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR �]_�
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE r

REFER TO DRAWING
SHEET P-6
9 COOLING WATER TO
COOLING TOWER
AUTOMATED
CONTROLS AND
SHUTDOWNS
COOLING AIR AND CONDENSED C _ C FQI
WATER OUT STEAM OUT — — —
2 504
TE I I FT DATA ACQUISITION
501 TI PI TSH I I 503 CONT OMSUTER
502 502 502
TI PI I I
501 501 I TE FE REFER TO DRAWING
REFER TO DRAWING 503 503 SHEET P-6
SHEET P-4 HEAT
EXCHANGER I COOLED AIR
AIR AND STEAM FROM V-501 I 2 TO BLOWER
VAPOR RECOVERY 1
STEAM AND SH �— 6"CS�f
CPVC ~8"CS AIR COOLING V-502 502
PRIMARY I
SEPARATOR WATERIN LSH
WATER LEVEL SEE NOTE 1
SECONDARY 502
EQUALIZATION LINE SEPARATOR
LSL F
502
O
O FILTER
REFER TO DRAWING
SHEET P-6 O STRAINER O O s LGAC 17
COOLING WATER FROM 10
COOLING TOWER
P-502
P-501 JDRIP LINE
ND BLOWDOWN PI PI
REFER TO DRAWING
508 FILTER 509 SHEET P-4
O 13 O TO DRIP SYSTEM
0 PCV
BLADDER
FI 509 PI TANK TI
P-503 REFER TO DRAWING
FQI 510 509 509 SHEET P-4
PRELIMINARY - DO NOT _ C 508
2 14 Q V-509 Q FROM DRIP SYSTEM
USE FOR S YC
- - - - - - - TE TI
CONSTRUCTION FQI 510 510
509
Q BLOWDOWN WATER
N.C.
NOTES. DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
1. BOTH VAPOR
2 AND LSHRECOVERY
BLOWER.
SHUTDOWN TRS
J.SEEMAN CONDENSER
THE VAPOR RECOVERY BLOWER. CHECKED BY
NOT APPROVED
Accelerating Value PROJECT MANAGER PROCESS AND INSTRUMENTATION DIAGRAM
D.SMALL
APPROVED FOR CONSTRUCTION DATE 05/20/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR �]_�
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE r

DATA ACQUISITION
AND COMPUTER
CONTROLS
NC
— — — — — — — — — — — — — 1 — — — — — —
AIR EXITING — — — — — — — — — — TE 8 AIR EXITING
COOLING TOWER COOLING To
601 602
REFER TO DRAWING I REFER TO DRAWING
SHEETS P-5 SHEETS P-5
COOLING WATER I COOLING WATER
FROM CONDENSER 9 FROM CONDENSER 9
COOLING TOWER I COOLING TOWER
AIR INTO _ AIR INTO _
COOLING TOWER / � COOLING TOWER /
BLOWER
(B-601) BLOWER
(B-602) L—F
COOLING TOWER SUMP I COOLING TOWER SUMP
II
ORREFER TO NOTE 1 SH REFER TO NOTE 2 —
2
TSL REFER TO t OTE 1 / REFER TO NOTE 3 _ I REFER TO DRAWING
602 I 601LSH SHEET 5
_ ALARM SHUTS DOWN
LSL 2 FC11 � 2 PUMPS P-501 AND P-502
601 — 601 MAKEUP SOLENOID 601
COOLING WATER OPENS ON LOW
REFER TO DRAWING — SUMP TANK SLL LEVEL ALARM — — — —
SHEET P-5 601 REFER TO NOTE4
PRELIMINARY - DO NOT COOLING WATER $
TO CONDENSER 10
USE FOR HEAT EXCHANGER 11 O POTABLE WATER
FOR MAKEUP
CONSTRUCTION
NOTES. DESIGNED FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
1. TSL-601 AUTOMATICALLY SHUTS DOWN THE COOLING TOWER TRS
J.SEEMAN
FAN AT 45'F.TSL-602 TURNS ON AN IMMERSION HEATER IN CHECKED BY COOLING TOWER
THE COOLING TOWER SUMP. NOT APPROVED
2. LSHH SHUTS DOWN SYSTEM. Accelerating Value PROJECT MANAGER PROCESS AND INSTRUMENTATION DIAGRAM
3. LSH OPENS BLOWDOWN SOLENOID AT CONDENSER. D.SMALL
4. LSL-601 MUST BE AT LEAST 2 FEET ABOVE PUMP INTAKE. APPROVED FOR CONSTRUCTION DATE 05/20/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
F
OPERTYOFTRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR �]-�`ISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE r V

DISCHARGE TO
ATMOSPHERE
VACUUM
RELIEF
VALVE
TO BE USED WHEN LOWER
CONCENTRATIONS ARE VGAC VGAC
BEING REMOVED 21 DISCHARGE TO
BL
ATMOSPHERE
:EED AIR ��F�ILTER
SILENCER - - YC — — — — — — — —
I I I
6
I I I
s
701
REFER TO DRAWING SAMPLE T I �I� FS
SHEET P-5 PORT I S 704
AIR FROM CONDENSER 2 _CS
O 5 I 703
SECONDARY SEPARATOR
FILTER O I QUENCH SCRUBBER
I C-702 THERMAL VAPOR C-703 $S
TREATMENT SYSTEM 19 SCRUBBER BLOWDOWN
40 HP 702 S-703
ROTARY LOBE
BLOWER I _ PH S
(TYPICAL OF 2) 20 P-704 I 702 SCRUBBER 704
SUMP 'N
— — ON
702 SL
704
I
25%NAOH
I
COMBUSTION AIR TOTE
APPROXIMATELY
CAUSTIC 0.23 GPM OF Q cn — — — — — — — — J
PUMP 25%SOLUTION S
P-702 -704
18
PRELIMINARY - DO NOT
USE FOR MAKE-UP WATER
FOR SCRUBBER
CONSTRUCTION
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
TRS
J.SEEMAN
CHECKED BY VAPOR TREATMENT
NOT APPROVED
Accelerating Value PROJECT MANAGER PROCESS AND INSTRUMENTATION DIAGRAM
D.SMALL
APPROVED FOR CONSTRUCTION DATE 05/20/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR �]_�
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE r

PRELIMINARY - CEO NOT
VERTICAL ELECTRODE USE FOR
ELECTRODE CABLE CONSTRUCTION
GROUND SURFACE TEFLON TUBE
NEAT CEMENT GROUT
— — (5 GAL/90 LB)
Y" PEX PIPE
— — — 3" FIBERGLASS PIPE
d
Y" SHARKBITE COUPLER
3" FIBERGLASS FEMALE ADAPTER
3" STAINLESS STEEL SCREEN
Y" COPPER DRIP TUBE
—_ —_ 3" CAP
SAPROLITE
2" BLACK IRON THREADED CAP WITH WELDED TAB
2" X 3' STEEL PIPE
2 ' F 2" STEEL COUPLER
- - - -
- — — #3 SAND
— — — 2" X 21' STEEL PIPE
- - - 3
- - 3 '
— — z
z
— — w
— — w
4 '
2" STEEL COUPLER
4 '
2" X 21' STEEL PIPE
- - 5 '
— — 5 ' CONDUCTIVE BACKFILL
- - 6 '
2" STEEL CAP
10 O.D. REFUSAL
SZ GROUND WATER
BORING WIDTH EXAGGERATED FOR DETAIL
MARBLE ALL MATERIAL INSTALLED BY TREMMIE
BEDROCK BELOW THE WATER TABLE
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
T A.PEABODY
CHECKEDD BY
NOT APPROVED VERTICAL ELECTRODE DETAIL
Accelerating Value PROJECT MANAGER
D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
05/09/14 MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY I� /I A
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET I\/I I
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE V

PRELIMINARY - CEO NOT
VERTICAL BEDROCK ELECTRODE USE FOR
ELECTRODE
GROUND SURFACE
TEF ONTUABLE
BE CONSTRUCTION
— — NEAT CEMENT GROUT
— — (5 GAL/90 LB)
— — 5'
PEX PIPE
3" FIBERGLASS PIPE
SHARKBITE COUPLER
3" FIBERGLASS FEMALE ADAPTER
i
_ _ _ = 3" STAINLESS STEEL SCREEN
COPPER DRIP TUBE
_ — - 3" CAP
SAPROLITE 2 2" BLACK IRON THREADED CAP WITH WELDED TAB
2" X 3' STEEL PIPE
— — — — 2" STEEL COUPLER
#3 SAND
— — — 2" X 21' STEEL PIPE
- - - 3
- - 3 '
4 '
2" STEEL COUPLER
4 '
— I
2" X 21' STEEL PIPE
- - 5
- - w
- - z
- - z
w
- - g
W 5 � i CONDUCTIVE BACKFILL
I
6 '
2" STEEL CAP
- - 6 '
— — #3 SAND
SZ GROUND WATER CONDUCTIVE BACKFILL
BORING WIDTH EXAGGERATED FOR DETAIL — -
- — METAL PLATE
ALL MATERIAL INSTALLED BY TREMMIE — —
BELOW THE WATER TABLE
7 '
MARBLE
BEDROCK
- 8 '
10 O.D. EXTEND ELECTRODE 10' INTO BEDROCK
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
TRS
A.PEABODY
CHECKEDD BY
NOT APPROVED VERTICAL BEDROCK ELECTRODE DETAIL
Accelerating Value PROJECT MANAGER
D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
05/09/14 MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY I� /I !�
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET I\/I�L
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE V

PRELIMINARY - DO NOT
ANGLED BEDROCK ELECTRODE USE FOR
100 CONSTRUCTION
ND SURFACE TEFLON TUBE
GROU
— — NEAT CEMENT GROUT (5 GAL/90 LB)
ELECTRODE CABLE
5' 5' ?i
3" FIBERGLASS PIPE
— — 1/2" PEX PIPE
10' 10' 3" FIBERGLASS FEMALE ADAPTER
1/2" SHARKBITE COUPLER
1 15, 3" STAINLESS STEEL SCREEN
— — Y" COPPER DRIP TUBE
2" BLACK IRON THREADED CAP WITH WELDED TAB
SAPROLITE 2 , 20,
— — #3 SAND
- - - 2 , SZ 25'
— — 2" X 21' STEEL PIPE
— — 3 ' 30' 2" STEEL COUPLER
- - 35L 35'
— — 4 , 40'
4 , 46
2" X 21' STEEL PIPE
— — 50,
— — 5 '
2" STEEL COUPLER
— — 5 , 56
— — 6 . 6y CONDUCTIVE BACKFILL
— — a
- - Uj
zz g5'
— — 65'
— — z
w
w 2" X 21' STEEL PIPE
— — 70'
— — 2" STEEL CAP
— — 7 5'
— — 75' #3 SAND
—_ —_ MARBLE
BEDROCK
80'
80' CONDUCTIVE BACKFILL
METAL PLATE
85'
85'
SZ GROUND WATER
BORING WIDTH EXAGGERATED FOR DETAIL
g0 ALL MATERIAL INSTALLED BY TREMMIE
90' BELOW THE WATER TABLE
MARBLE
BEDROCK 10 O.D.
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
TRS
A.PEABODY
CHECKEDD BY
NOT APPROVED ANGLED BEDROCK ELECTRODE DETAIL
Accelerating Value PROJECT MANAGER
D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
05/09/14 MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY I� /I ^
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET I\/I�3
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE V

PRELIMINARY - DO NOT
USE FOR
ANGLED ELECTRODE CONSTRUCTION
100
GROUND SURFACE TEFLON TUBE
— — NEAT CEMENT GROUT (5 GAL/90 LB)
ELECTRODE CABLE
5 5 3" FIBERGLASS PIPE
— — 1/2" PEX PIPE
10' 10' 3" FIBERGLASS FEMALE ADAPTER
1/2" SHARKBITE COUPLER
3" STAINLESS STEEL SCREEN
— — Y" COPPER DRIP TUBE
2" BLACK IRON THREADED CAP WITH WELDED TAB
SAPROLITE 2 , 201
— — #3 SAND
— — 2" X 21' STEEL PIPE
— — 3 ' 30' 2" STEEL COUPLER
- - 35L
36
— — 4 , 40'
— a
LU
— W
Z_
z 4 , 46
Z
W
a
it 2" X 21' STEEL PIPE
— — 501
- - 5 '
2" STEEL COUPLER
— — 5 , 56
— — ' 60 6 CONDUCTIVE BACKFILL
— — 65'
— — 65'
— —
2" X 21' STEEL PIPE
70.
— — 70
— — 2" STEEL CAP
— — 76
75' REFUSAL
MARBLE V GROUND WATER
BEDROCK BORING WIDTH EXAGGERATED FOR DETAIL
ALL MATERIAL INSTALLED BY TREMMIE
80' BELOW THE WATER TABLE
85'
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
T A.PEABODY
CHECKEDD BY
NOT APPROVED ANGLED ELECTRODE DETAIL
Accelerating Value PROJECT MANAGER
D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
05/09/14 MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY I� /I A
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET I\/I�4
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE V

PRELIMINARY - DO NOT
USE FOR
PM CONSTRUCTION
MONITORING WELL
man s mnm
— — 5'
— — 6" CPVC OVERSLEEVE
— — — MONITORING WELLS WILL BE INSTALLED 2' LESS THAN THE TOTAL DEPTH OF
— — — THE SHALLOWEST OF OF THE THREE NEARBY ELECTRODES
— — 10� 4" SS NPT COUPLER Iron rove,
FD Cefm s Wee ID mDft n z" feet CMnRefNffI16IW .
PM-1 2 PM-18 Sha—ft ew un ewkh 40-65 Agbkg 6f der mW PM-ID' Dep Rnmo eD-tm huid q,eeue.er.a
PM4 2 PM,25 5l"—Repcilh 30-55 Memlex Mph VOCe demmda
pm-211 Dw Repeleh W-96 HNIA
— — — 4" SS PIPE (MPT PM, : ems" 25_ mow ,° " ""
pm�DX MPT)
2 P"s U#dmdRepdnh aD-6fi GW-U�.vee Gw.gS ans
P6Li9 8edrvgk 85-105 GW.69
PMv` 2 PM-68 2.*—R�pol Replan -W.h f5-45 GW-3B efd
vM-5B Deep R.Orth 55-70 GW-30
Pm-5 2 pM-w ShaA R"cW 26-40 Replerw rwle GW-75 end
PMCB Bedeck 55-76 GW_78
SAPROLITE
NEAT CEMENT GROUT PhN6 SMM RepoYh f6-3D 'M-fl.d.-N edi VOC
— — — 20 (5 GAL/90 LB) pw?r 2 PM-71 Bedeck 40-SD eeeaenve6eee
PMA I Ph1-95 Snello.•Repdilh 55-30 Monitor da:ngredhrm VOC
PM:96 Bedr"ek a0-60 rmeenbaudn
�! '-.vy1n6111rd xell,term•n,��K d.nauk ihn dr wrll�w III!w ugrrr eo nw..�lri,u.uiw.v�w�
25' 3' THICK HYDRATED BENTONITE ANNULAR SEAL Q GROUND WATER
— — — MONTEREY #1 FILTER SAND BORING WIDTH EXAGGERATED FOR DETAIL
EXTENDING 3' ABOVE SCREENED INTERVAL
— — — 30' 4" SS NPT COUPLER
35' 4" SS NPT COUPLER (SSC4)
.Y
in
40'
45' —
_ — 4" SS WELLSCREEN (MPT X MPT)
— — z 50' = 0.010 SLOT (WSS4)
z
LU
—_ —_ F- 4" SS WELDED PLATE
-
55-
MARBLE
BEDROCK Q GROUND WATER
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
TRS
A PEBODY
CHECKED
BY VERTICAL MONITORING
NOT APPROVED
Accelerating Value PROJECT MANAGER WELL DETAIL
D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
05/15/14 MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY I� /I r
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET I\/I—e'1
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE V VVV

PRELIMINARY - DO NOT
USE FOR
PM-1S CONSTRUCTION
25°ANGLED MW
GROM SURFACE
6" CPVC OVERSLEEVE
5'
— 5
10•
4" SS PIPE (MPT X MPT)
— — 15• 15
4" SS NPT COUPLER
SAPROLITE 2d
— — 20'
4" SS PIPE (MPT X MPT)
— — — Q - 25 (400S40304L)
NEAT CEMENT GROUT
— — (5 GAL/90 LB)
— — 30 3' THICK HYDRATED BENTONITE ANNULAR SEAL
— — — sy MONTEREY #1 FILTER SAND
— — EXTENDING 3' ABOVE SCREENED INTERVAL
35'
— — 4" SS NPT COUPLER (SSC4)
40•
4" SS NPT COUPLER (SSC4)
— as
— r
45• °S.
W r;
F- 50' c.
— — F- 55 4" SS WELLSCREEN (MPT X MPT)
— — w ?; 0.010 SLOT (WSS4)
- -
w
w 55'
F-
g0
—_ —_ 4" SS WELDED PLATE
'R
60• 05
— — 65'
MONITORING WELLS WILL BE INSTALLED 2' LESS THAN THE TOTAL DEPTH OF
THE SHALLOWEST OF OF THE THREE NEARBY ELECTRODES
— — screen
— — $Z GROUND WATER Loipmn case: wpno Monnonn zones I"reel commeRrelRaeoeak
BORING WIDTH EXAGGERATED FOR DETAIL PM-1 2 PM 1S Sh.lw,R
PMID• DmR.pd eo-im d btff w e.en.w"�n
PM-2 2 PM,2S Shelew Repclith 3D-55 M-fle hqh VOC.d.n .dM
PM.2D OW RepelM as-RS HP.18
PMJ' 2 P" shag R"am 25-50 A14—IM w. .M.M m
PM=9p' DW Repo& 65-95 enfhfmwr erd Euild.y
PL" y PMa3 SM.a.Repdeh .p-66- Repleq .G.41,and
PmAs 6edmd 35-106 1 GW-B
PM.S 2 PM5G Sh.Rcw Repdilh 15-45 R.*- -,W. GW-M and
PM58 D pR-ord, 55-iG GW-SO
PM3 2 Pk"Ns Se.lb*R.peiW 26-40 Replace wdh GW-75 and
PM-0 it d—k 55-75 GW-713
PM-7 2 PM-75 Shahs.RwpM 15-30 Mm4w6 npr AwAVBC
PM-iB 8ad—k /p_!0 cenc.naaF—
PM- 2 PMAS Sh.Rewpei R. lh alder$5-30 Mdaw.pr.d1.MVOC
Mae Rwi—k .o-w ep ntrabene
•-rtryr-d�Ikd+elV.nwnil dir dw ihn dr wll.will M.4W o�Mn
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
TRS
A PEBODY
CHECKED
BY ANGLED MONITORING
NOT APPROVED
Accelerating Value PROJECT MANAGER WELL DETAIL
D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
05/15/14 MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY I� /I /�
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET I\/I—Yl
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE V V

PRELIMINARY - DO NOT
USE FOR
VERTICAL TMP
(TYPICAL OF 9) CONSTRUCTION
GROUND SURFACE
7 1-1/2"CPVC PIPE
i--i-1/2"CPVC FEMALE ADAPTER
--1-1/2"BI TMP CASING
(PROVIDEDBYTRS)
1-1/2"BI COUPLER
io'
NEAT CEMENT GROUT
---
(5 GAL/90 LB)
15'-
SAPROLITE 1-1/2"BI COUPLER
20'-
TA
25'-
I-1/2"BI TMP CASING
30'- (PROVIDED BY TRS)
--mii
35'-
1 1/2"BI COUPLER
40'-
45'-
1-1/2"BI TMP CASING
-J PROVIDED BY TRS)
> 50'--
w
LU
z
F-
z
LU
< 55'-- T
LU
1-1/2"BI COUPLER
6W.-
65'-- T
1-1/2"BI TMP CASING
-----(PROVIDED BY TRS)
70'--
T.-
75'--
T THERMOCOUPLE MARBLE
BEDROCK
IN ADDITION TO INSTALLING NEW TMPS,
SZ GROUND WATER 1-1/2"BI CAP THERMOCOUPLES WILL BE PLACED IN WELLS
BORING WIDTH EXAGGERATED 801- RW-1D, GW-513, GW-2D, GW-8B, AND GW-31)
FOR DETAIL AND THEN GROUTED IN PLACE
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
TRS
A.PEABODY
CHECKED BY VERTICAL TEMPERATURE
NOT APPROVED
Accelerating Value PROJECT MANAGER MONITORING POINT DETAIL
D.SMALL I
APPROVED FOR CONSTRUCTION DATE PROJECT
05/09/14 1 MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE M-7

PRELIMINARY - DO NOT
USE FOR
15°ANGLED TEMPERATURE CONSTRUCTION
MONITORING POINT
GROUND SURFACE
1-1/2"CPVC PIPE
1-1/2"CPVC FEMALE ADAPTER
5, 5 1-1/2"BI TMP CASING
(PROVIDED BY TRS)
- - - •i
1-1/2"BI COUPLER
10' 10
NEAT CEMENT GROUT
r �(5 GAU90 LB)
- - 15' 15
— — SAPROLITE 20�-
Zo'
- - -
26' 1-1/2"BI TMP CASING
- 25' (PROVIDED BY TRS)
1-1/2"BI COUPLER
30' y
i
35'
40
40'
�Y
45 1-1/2"BI TMP CASING
_ (PROVIDED BY TRS)
45'
1-1/2"BI COUPLER
— — a
- - w
w 50' j.,
LU
Z
- - Z
Z
U.]
w 55'
60'
1-1/2"BI TMP CASING
4• '.t (PROVIDED BY TRS)
65'
1-1/2"BI COUPLER
-70
70'
1-1/2"BI TMP CASING
(PROVIDED BY TRS)
75' :i
— — THERMOCOUPLE
SZ GROUND WATER g0
6o' BORING WIDTH EXAGGERATED FOR DETAIL
}
65
1-1/2"BI CAP
- 65 REFUSAL
MARBLE
BEDROCK
DESIGNED BYFOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
TRS
A.PEBODY
CHECKEDD BY ANGLED TEMPERATURE
NOT APPROVED
Accelerating Value PROJECT MANAGER MONITORING POINT DETAIL
D.SMALL
APPROVED FOR CONSTRUCTION DATE PROJECT
05/12114 MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY ^
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET M-TG
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE VVV

PRELIMINARY - DO NOT
740 ANGLE VR WELL
(TYPICAL OF 4) USE FOR
CONSTRUCTION
GROUND SURFACE
3"CPVC PIPE
3"CPVC COUPLER
3"CPVC SCREEN `0
tA
A •xy Y T.; 3"CPVC COUPLER
10 h �.. 3"CPVC SCREEN
3"CPVC CAP
15'
— — h
— — o
�o
20'
— — — � - 25'
30'
— — — SZ GROUND WATER
— — BORING WIDTH EXAGGERATED FOR DETAIL
35'
40'
DESIGNED BYFOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
TRS
A B
CHECKK E D D BY
NOT APPROVED VAPOR RECOVERY POINT DETAIL
Accelerating Value PROJECT MANAGER
D.SMALL
APPROVED FOR CONSTRUCTION DATE 05/09/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY /�
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET M-9
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE

PRELIMINARY - DO NOT
USE FOR
TYPICAL TRENCH SECTION CONSTRUCTION
24"
a a
°
°
°
THERMAL CONDUCTIVE FILL
° a
a
°
N Q °
4a Q
• •� as •
THERMOCOUPLE BUNDLE
°
° D 3" VAPOR RECOVERY PIPE
a ° a
• 0 • • • 0 • 0 ELECTRODE CABLE
G
0 O O • O • •<0 • 1/2" PEX FOR DRIP TUBE
DESIGNED BY FOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
DRAWN BY MURPHY,NORTH CAROLINA
TRS A.PEABODY
CHECKEDD BY
NOT APPROVED TRENCH DETAIL
Accelerating Valoe PROJECT MANAGER
D.SMALL
APPROVED FOR CONSTRUCTION DATE 05/09/14 PROJECT MUR55
CONFIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
PROPERTY OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET M-10
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE

SERVICE DROP
12.47,13.2,or 13.8 KV
DESIGN AND
FUSE INSTALLATION
BY UTILITY
POLE TOP
METERING BY
UTILITY I #2 SOW
#2 SOW(4-WIRE) (4-WIRE)
— ERH CONDENSER CDT-16;SUPPLIED BY TRS(77 FLA)—
PCU 4500-1 I
SUPPLIED BY TRS I I MS8
DESIGN AND INSTALLATION BY UTILITY AND/OR SUB-CONTRACTOR SERVICE REQUIREMENTS: CB-6.3A
47,13.2,or 13.8 KV I I I
TEMPORARY SERVICE CONNECTION-PREFER OVERHEAD COMPLETION 12.12. FULL LOAD AMPS OL7
CB-30A CB-25A CB-25A )CB-15A CB-15A CB-15A CB-20A I I 480 V
3 PHASE x,120 V
NO NEUTRAL REQUIRED VFD1 VFD2 VFD3 �M314 MS416 M507 H, H3 H2 H°480 V I I
— — — — —
I OL100; I OL104I I OL108I OL200 OL204 OL208 x x x, I I 40 HP
DISCONNECT 120 V I
12.47,13.2,or 13.8 KV I I I J I I CB-6A
250A h2OA �°300 kVA;3 PHASE I I I I TMS9
^->=x max'480 VAC
I I 15 HP 10 HP 10 HP 1.5 HP 1 HP .33 H I I OL8
1/0 BARE MAIN
COPPER I CONTACTOR CB-50A CB14-80A CB-15A CB13-80A I I RECYCLE COOLING COOLING CONDENSATE DRIP EXHAUST 7.5 MA
CB-15A CB12-80A CB-50A CB11-80A I I PUMP TOWER TOWER FAN PUMP PUMP FAN CONTROL:NSER
CB7-15 I I 21 FLA FAN 14 FLA 3 FLA 2 FLA 1 FLA
I / 0l of / / o/ / / / 14 FLA POWER I I 1/4 HP
VARIABLE
/ / / /Ll
/ / / / / I 16 FLAOUTPU I I I
3 PHASE
- - - - - — — — — — — — - - J L - - - - - - - - - - - - - - - - - - - 1PRIMARY)- - - J L - - - - - - - J
I ERH BLOWER B-5-40-3
235 to 858 VAC J SUPPLIED BY TRS
(52 FLA/25 kW)
112 ELECTRODES #12 SOW ERH THERMAL VAPOR
HEATING LOAD- DES kW (4-WIRE) TREATMENT
#2 SOW(4-WIRE) #2 SOW(4-WIRE) #14 SOW(4-WIRE) (10.4 FLA/6 kW)
— — — — — — — — — — — — — — — — — — — — — — — — — r — — — — — — - F — — — — — — — — — — — — — —
I I I I II I I I
I I MS8 CB-6.3A
5 5 8 A 6A 6A CB-30A CB-25A CB-25A CB-15A CB-15A CB-15A CB-20A I I 6A 1.5A 10A 5 A
I I OL7
MS MS VFDI VFD2 VFD3 M314 MS416 M507 H,, a z ,H°480 V I I "' "' "°480 V 1 I MC-601 MC-602 SIC H "a "a "° 480 V
OL OL OL I OL100I I OL104I I OL108I OL200 OL204 OL208 �mh��m1 x x,120 V 1 I OL-601 OL-602 VFD 0220 x,�xa 120 V
MS 0 "� °X1 120 V I I 40 HP CB-6A
MS9 I I 2 HP 1/3 HP 3 HP
15 HP 10 HP 10 HP 1.5 HP 1 HP 33 H
OL8 NEUTRALIZING
5 HP 1.5 HP 1.5 HP I RECYCLE COOLING COOLING CONDENSATE DRIP EXHAUST 7.5 kVA I I I I SOLUTION NaOH COMBUSTION TRANSFORMER
PUMP TOWER TOWER FAN PUMP PUMP FAN CONDENSER I CONTROL RECIRCULATION DELIVERY AIR 1.6 FLA
I I I
21 FLA FAN 14 FLA 3 FLA 2 FLA 1 FLA PUMP PUMP BLOWER
PUMP FAN-1 FAN-2 I I 14 FLA POWER I I 1/4 HP I I 3.4 FLA 0.6 FLA 3.7 FLA
7.6 FLA 3.2 FLA 3.2 FLA I I 16 FLA
L - - - - - - - - - J ` — — — — — — — — — — — — — — — — — — — PRIMARY)— — ` - - - - - - - J ` - - - - - - - - - - -
PCU 4500 COOLING UNIT ERH CONDENSER CDT-15;SUPPLIED BYTRS(77 FLA) ERH BLOWER B-11-40-7
SUPPLIED BY TRS(14.3 FLA)
SUPPLIED BY TRS
(52 FLA/25 kW)
DESIGNED BYFOR
J.SEEMAN FORMER CLIFTON PRECISION FACILITY
PRELIMINARY D O NOT DRAWN BY MURPHY,NORTH CAROLINA
T J.SEEMAN
USE FOR RSCHECKED BY
NOT CHECKED ONE-LINE DIAGRAM
Accelerating Yalu PROJECT MANAGER
D.S
CONSTRUCTION
APPROVEDVED FOR CONSTRUCTION DATE 05/01/14 PROJECT TWA39
EIE
FIDENTIAL:INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE BY
OF TRS GROUP,INC.NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED,USED OR SHEET M-11 TED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP,INC.LONGVIEW,WA. DATE

TRS
Accelerating Value
Health and Safety Plan
Electrical Resistance Heating
Former Clifton Precision Facility
1995 State Road 141
Murphy, North Carolina
Issued: May 2014
Title Signature Date
Michael Brown
TRS Group, Inc.
TRS H&S Officer
Chris Blundy
TRS Group, Inc.
Sr. Project Manager
r. ! TRS Group,Inc. ••
mur55 hasp 052114 aqf,, PO Box 737• Longview,WA 98632 www.thermalrs.com —Cwboniund.org—

TABLE OF CONTENTS
HEALTH AND SAFETY PLAN SUMMARY.....................................................................................6
1.0 INTRODUCTION....................................................................................................................10
2.0 SITE INFORMATION.............................................................................................................11
2.1. SITE DESCRIPTION................................................................................................................11
2.2. SCOPE OF WORK................................................................................................................... 12
3.0 HAZARD ANALYSIS............................................................................................................. 12
3.1. SUBSURFACE UTILITIES........................................................................................................ 12
3.2. POTENTIAL CHEMICAL HAZARDS.........................................................................................13
3.3. POTENTIAL PHYSICAL AND BIOLOGICAL HAZARDS.............................................................16
3.4. ERH SYSTEM OPERATIONAL HAZARDS...............................................................................16
3.4.1. Electrical Voltages.......................................................................................................16
3.4.2. High Temperatures.......................................................................................................17
3.4.3. Steam............................................................................................................................17
3.5. ACTIVITY HAZARDS ANALYSIS............................................................................................18
4.0 PERSONAL SAFETY,HAZARD CONTROL,AND INJURY PREVENTION...................18
4.1. SITE RULES...........................................................................................................................18
4.1.1. General Housekeeping.................................................................................................19
4.1.2. Fire Protection and Prevention....................................................................................19
4.1.3. General Field Activities................................................................................................19
4.1.4. Signs/Labels..................................................................................................................19
4.1.5. Eating/Drinking/Smoking.............................................................................................20
4.1.6. Sanitation......................................................................................................................20
4.2. SITE CONTROL MEASURES...................................................................................................20
4.2.1. Site Security..................................................................................................................20
4.2.2. Construction and Sampling Work Zones......................................................................21
4.3. HEAT STRESS........................................................................................................................21
4.4. COLD STRESS........................................................................................................................22
4.5. VEHICLE SAFETY..................................................................................................................22
4.6. EQUIPMENT AND MACHINE GUARDING...............................................................................23
4.7. DRILLING..............................................................................................................................23
4.8. CONFINED SPACE ENTRY .....................................................................................................24
4.9. FALL PROTECTION................................................................................................................24
4.10. HOT WORK.......................................................................................................................25
4.11. EXCAVATION AND TRENCHING........................................................................................25
4.12. HOISTING AND RIGGING...................................................................................................25
4.13. MATERIAL HANDLING......................................................................................................26
4.13.1. Moving/Lifting..............................................................................................................26
4.13.2. Spill Prevention and Containment................................................................................26
4.13.3. Material Transfer Safety...............................................................................................26
5.0 PPE PROGRAM......................................................................................................................27
5.1. HEARING PROTECTION AND NOISE CONTROL......................................................................27
5.2. EYE PROTECTION..................................................................................................................27
5.3. DERMAL PROTECTION..........................................................................................................27
5.4. CONSTRUCTION SAFETY.......................................................................................................27
mur55 hasp 052114 ad

5.5. PPE PROGRAM-RESPIRATORY..............................................................................................28
5.5.1. Anticipated Levels of Protection...................................................................................28
5.5.2. Personal Monitoring....................................................................................................28
5.5.3. Worker Exposure Limits...............................................................................................29
5.5.4. Maintenance and Storage.............................................................................................30
6.0 TRS ERH-SPECIFIC SAFETY PROCEDURES ....................................................................30
6.1. ERH SYSTEM OPERATIONS..................................................................................................31
6.1.1. ERH Start-Up...............................................................................................................31
6.1.2. ERH Emergency System Shut Down.............................................................................31
6.2. ERH OPERATIONS WORK ZONES.........................................................................................31
6.3. LOCKOUT/TAGOUT...............................................................................................................32
7.0 DECONTAMINATION...........................................................................................................32
7.1. PERSONAL DECONTAMINATION PROCEDURES.....................................................................32
7.2. VEHICLE AND EQUIPMENT DECONTAMINATION..................................................................33
7.3. DECONTAMINATION DURING MEDICAL EMERGENCIES .......................................................33
8.0 HAZARD COMMUNICATION..............................................................................................33
8.1. CHEMICAL INVENTORY LIST AND MSDSS...........................................................................34
8.2. LABELING HAZARDOUS CHEMICAL CONTAINERS ...............................................................34
9.0 MEETINGS AND INSPECTIONS..........................................................................................34
9.1. PRE-CONSTRUCTION SAFETY MEETING...............................................................................34
9.2. PRE-OPERATIONS SAFETY MEETING....................................................................................35
9.3. DAILY TAILGATE HEALTH AND SAFETY MEETINGS............................................................35
9.4. GENERAL SITE SAFETY INSPECTIONS...................................................................................36
9.5. SAFE BEHAVIOR OBSERVATIONS.........................................................................................36
10.0 ROLES,RESPONSIBILITIES,AND AUTHORITY .............................................................36
10.1. PROJECT MANAGER..........................................................................................................36
10.2. SITE HEALTH AND SAFETY OFFICER................................................................................37
10.3. FIELD PERSONNEL............................................................................................................38
10.4. SUBCONTRACTORS ...........................................................................................................38
10.5. STOP WORK ORDERS........................................................................................................38
11.0 TRAINING...............................................................................................................................39
11.1. GENERAL HAZARDOUS WASTE OPERATIONS TRAINING.................................................39
11.2. ELECTRICAL SAFETY TRAINING.......................................................................................39
11.3. CRANE AND LIFT TRUCK OPERATOR TRAINING...............................................................40
11.4. RESPIRATORY TRAINING..................................................................................................40
11.5. COMPETENT PERSON TRAINING.......................................................................................40
11.6. OTHER TRAINING..............................................................................................................41
11.7. MEDICAL SURVEILLANCE.................................................................................................41
11.7.1. Medical Examination Requirements.............................................................................41
11.7.2. Exposure Monitoring....................................................................................................42
12.0 INCIDENT RESPONSE AND FIRST AID.............................................................................42
12.1. PERSONNEL ROLES,LINES OF AUTHORITY AND COMMUNICATION SYSTEM...................42
12.2. HOSPITAL DIRECTIONS.....................................................................................................43
12.3. EMERGENCY AND FIRST AID EQUIPMENT........................................................................43
MUR55 HASP 052114 acf 2 GTRS

12.4. ON-SITE EMERGENCY RESPONSE.....................................................................................44
12.5. COMMUNICATION SYSTEM...............................................................................................44
13.0 INCIDENT REPORTING, FOLLOW-UP,AND INVESTIGATION....................................44
14.0 RECORD KEEPING................................................................................................................45
List of Tables
Table1. Hazard Inventory......................................................................................................................9
Table 2. Summary of Project Information............................................................................................I I
Table 3. Site Specific Hazard Analysis................................................................................................13
Table 4. Safe Distance from Overhead Power Lines............................................................................23
Table5. Action Levels.........................................................................................................................29
Table 6. Emergency Contacts...............................................................................................................42
List of Figures
Figure 1. Murphy Medical Center-3990 East US Highway.................................................................7
Figure 2. Murphy Urgent Care Center 183 Ledford St.Murphy,NC 28906.........................................8
Figure3. Site Plan................................................................................................................................10
List of Appendices
Appendix A—HASP Training Documentation Form
Startup Checklist
ERH Restricted Zone Acknowledgement Form
Hot Work Permit
Heavy Equipment Inspection Form
Incident Reporting and Investigation Form
Safe Behavior Observation Form
Daily Tailgate Meeting Form
Appendix B—Activity Hazards Analysis
Appendix C—Standard Operating Procedure Compendium
1.1 Lockout Tagout
1.2 Electrical Application
1.3 Voltage Surveys
1.4 High Voltage Inspection
3.1 Hot Groundwater Sampling(Internal)
3.2 Hot Soil Sampling(Internal)
3.3 Vapor Sampling Post condenser
3.4 Vapor Sampling pre-condenser
3.6 SERT
4.3 External Hot Soil Sampling
4.7 External Hot Groundwater Sampling
MUR55 HASP 052114 ad 3 TRS

Appendix D—Respiratory Training and Fit Testing Procedures
Appendix E—Northrop Grumman Scope of Work—Exhibit
Abbreviations and Acronyms
ACGIH American Conference of Industrial Hygienists
AHA activity hazard analysis
ANSI American National Standards Institute
bgs below ground surface
CAS Chemical Abstracts Service
°C degrees Celsius
CFR Code of Federal Regulations
COC contaminant of concern
CRZ contaminant reduction zone
DCA 1, 1-dichloroethane
DCE 1,1-dichloroethene
cDCE cis-1, 2-dichloroethylene
DOT Department of Transportation
ERH electrical resistance heating
eV electron volt
E-stop Emergency-stop
EZ exclusion zone
OF degrees Fahrenheit
ft.bgs feet below ground surface
Freon-113 trifluorotrichloroethane
HASP Health and Safety Plan
HAZWOPER Hazardous Waste Operations and Emergency Response
HEPA high efficiency particulate air
HSO Corporate Health and Safety Officer
IDLH immediately dangerous to life and health
LOTO lockout/tagout
MSDS material safety data sheet
NFPA National Fire Protection Association
Northrup-
Grumman Northrup Grumman Guidance and Electronics Company, Inc.
OSHA Occupational Safety and Health Administration
PCE tetrachloroethylene
PCU power control unit
PEL permissible exposure limit
PID photoionization detector
PM Project Manager
MUR55 HASP 052114 ad 4 TRS

PPE personal protective equipment
ppm parts per million
ppmv parts per million by volume
PVC polyvinyl chloride
SBO Safe Behavior Observations
SHSO Site Health and Safety Officer
SOP Standard Operating Procedure
SOW Scope of Work
SUCL Start-up Check List
SZ support zone
TCA 1, 1, 1-trichloroethane
TCE trichloroethylene
TRS TRS Group,Inc.
TWA time weighted average
ug/l micrograms per liter
VOC volatile organic compound
VP Vice President
VR vapor recovery
MUR55 HASP 052114 ad 5 TRS

HEALTH AND SAFETY PLAN SUMMARY
Proiect Information:
Subcontract No: P 1084 Contract Date: March 25,2014
Client: Northrop Grumman Guidance and Electronics Company, Inc. (Northrop Grumman)
Client Address: 2980 Fairview Park Drive,Falls Church,VA 22042
Project Location: 1995 NC Hwy 141,Murphy,NC 28906-686
Project Objectives: Thermal remediation of trichloroethylene(TCE),tetrachloroethylene(PCE),
1,1,1-trichloroethane(TCA), 1,1-dichloroethene(DCE), 1,1-dichloroethane(1,1-DCA), cis 1,2-
dichloroethylene(cDCE),trifluorotrichloroethane(Freon 113)and 1,4-dioxane. In subsurface
groundwater from 27 to 78 feet below ground surface(ft. bgs)
Health and Safety Plan Preparation:
Prepared by: Robert Poulin
Reviewer/Approver: Michael Brown
Proiect Personnel:
Northrop Grumman Contact: Kurt Batsel Phone: [phone]
TRS Project Manager(PM): Drew Small Phone: [phone]
TRS Site Health and Safety Officer(SHSO): Steve Pistol Phone: [phone]
TRS Corporate Health and Safety Officer(HSO): Mick Brown Phone: [phone]
Nearest Local Hospital:
Hospital/Clinic:
Murphy Medical Center
3990 East Highway
[phone]
http://www.murphymedical.org
Driving directions to Murphy Medical Center
3990 US Highway Easy 64A,Murphy NC
Driving Distance: 4.9 miles,Approximate Drive Time: 8 minutes
• Depart Slow Creek Dr.toward NC-141 Private Road 46 ft.
• Turn right onto NC-141 4.2 mi
• Turn left onto E US-64-ALT 0.3 mi
• Keep straight onto Old Hwy 64 0.3 mi
• Turn left onto E US-64 315 ft.
• Arrive at 3990 E US-64,Murphy,NC 28906
MUR55 HASP 052114 ad 6 TRS

w�
Marble j
Grandview
Ehenexer
Tom wla - -
- -- - -
1 ~
Regal C �E E R K E E
Grape Creek - r _
12� _
- _ Pe htree -
129
- �7a� EUS, Mission
I
Yrfghway 64 CY
� Brasstown �
S vreerwarer Gap
h
i
�aa �
VVame ®20±41.1 icrosoftCwporafxn®2(]13Nokia
Figure 1.Murphy Medical Center-3990 East US Highway
Emergency Phone No.: 911
Paramedic: 911 Fire Dept.: 911 Police Dept.: 911
Emergency/Contingency Plans: Call 911 and then administer first aid
Nearest Occupational Health Center:
Urgent Care Center(Murphy Medical Center)
183 Ledford St.Murphy,NC 28906
[phone]
Hours of operation:
Monday—Saturday: 8:00 a.m.-8:00 p.m.
Sunday: 10:00 a.m.—6:00 p.m.
Closed for Thanksgiving,Christmas,New Year's Day and Easter
Driving directions to Urgent Care Center(Murphy Medical Center)
183 Ledford St.Murphy,NC 28906
Driving Distance: 7.1 miles, Approximate Drive Time: 10 minutes
MUR55 HASP 052114 ad 7 TRS

• Depart NC-141 toward Green lawn Cemetery Rd 2.0 mi
• Turn left onto E US-64-ALT 0.3 mi
• Keep straight onto Old Hwy 64 0.3 mi
• Turn right onto E US-64 4.1 mi
• Turn right onto US-19 N/US-74 E/US-129 N 0.3 mi
• Turn left onto Ledford St 394 ft
• Arrive at 183 Ledford St,Murphy,NC 28906
• If you reach Cross St,you've gone too far
,zs
r 191i
19 A-
t �rhtree
M:Ur 1
129; i E US-54-RLT #
Mission
r U&5 64
� Highway,
Figure 2.Murphy Urgent Care Center 183 Ledford St.Murphy,NC 28906
Site Control Measures: Only authorized personnel are permitted inside established exclusion zones
(EZs),contaminant reduction zones (CRZs) and support zones(SZs). During operations, only
authorized personnel are permitted in the electrical resistance heating(ERH)restricted zone and only
qualified persons are allowed within the ERH EZ as defined by TRS access requirements.
15 Minute Eyewash Required Fire Extinguisher Required First Aid Kit Required
Blood borne Pathogen Kit Required
Personal Decontamination Procedures: Thoroughly wash hands before eating.Use proper level of
personal protective equipment(PPE). The minimum PPE level for the project is Level D.
Table 1.Hazard Inventory summarizes chemical and physical hazards found on the Site,the level of
PPE required for Site work, and the health and safety monitoring equipment necessary for the project.
MUR55 HASP 052114 ad 8 GTRS

Table 1.Hazard Inventory
Summary of Chemical Hazards
Primary Expected Compounds: Chlorinated volatile organic compounds including: of TCE,PCE,TCA,DCE,
1,1-DCA,cDCE,Freon 113 and 1,4-dioxane.
Source Former above ground and underground storage tanks
Pathways Inhalation,skin and/or eye contact,and ingestion
Concentrations The maximum concentration of TCE found in the source area groundwater
was 520,000 micrograms/liter(µg/L)
Health Hazards irritation eyes,skin,nose,throat,respiratory system;nausea; flush face,neck;
dizziness,incoordination;headache,drowsiness; skin erythema(skin redness);
liver damage; [potential occupational carcinogen]
Summary of Physical Hazards
Y Heat Y Slip,Trip,Falls Y I Shallow Excavations/Trenching
P Cold Y Electrical Hazards Y Moving Equipment
Y Wet P Underground Hazards N Confined Space
Y Noise P Overhead Hazards Y Hydraulic Equipment
Y Lifting P Acids and Bases Y Rotating Equipment
P Steam Y Sharp and/or abrasive items Y Hand Held Power Tools
Summary PPE Requirements
R Hard Hat R Safety Eye gear Glasses with side protection
R Safety Boots A Respirator Half Face(A) Full Face(A)
R Orange Vest or Shirt A Filter Type Organic Vapor(A) HEPA(A)
A Hearing Protection R Gloves Work(A) Nitrile(A)
A Tyvek Coveralls A Gloves Neoprene(N) PVC(N)
A 5-Min.Escape Respirator
Summary of H&S Monitoring Equipment Requirements
Organic Vapor Photoionization detector(PID)with 11.7 electron volt(cV)lamp R
Organic Vapor Analyzer(flame ionization detector;FID) N
Oxygen Meter Exclusion Zone Air Monitoring A
Combustible Gas Meter Exclusion Zone Air Monitoring A
Passive Dosimeter N
Hydrogen Sulfide(1-12S)Meter N
Other Meters N
Notes:Y=Yes,N=No,P=Possible,A=As Needed,R=Required,N=Not Required,HEPA=High Efficiency Particulate
Air,PVC=Polyvinyl Chloride
MUR55 HASP 052114 acf 9 TRS

1.0 INTRODUCTION
The TRS Group,Inc. (TRS)has entered into a contract with Northrop Grumman for the remediation
of TCE,PCE,TCA,DCE,DCA, cDCE,Freon 113and 1,4-dioxane in groundwater located at 1995
NC Highway 141,Murphy,NC (the Site)by applying ERH technology. See Figure 3 for details of
the Site.
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Figure 3.Site Plan
This Health and Safety Plan(HASP)includes all work related to the installation, operation, and
demobilization of an ERH remediation system at the Site. Work to be performed under the scope of
this HASP includes; installation of electrodes and temperature monitoring points,near surface
trenching, assembly of vapor recovery(VR)system piping,placement of remediation system
components, operation of the ERH remediation system, and deconstruction/demobilization of ERH
related equipment. Activities associated with this project involve the installation of an electrode array
and VR system and the installation, operation, and demobilization of an ERH process/treatment
facility.
If significant changes in operation or site conditions occur,the HASP will be modified to reflect
changes. All staff associated with site operations will be notified following changes to the HASP.
On-site personnel working within the ERH area,ERH equipment compound or in the immediate
vicinity of the ERH treatment facility will comply with this HASP and any revisions made to the
plan. All site personnel are required to review this HASP and sign the HASP acknowledgement form
provided in Appendix A. A copy of the HASP will be maintained by the SHSO and kept readily
available at the Site for reference by all site workers.
MUR55 HASP 052114 ad 10 GTRS

Northrop Grumman provides health and safety orientation training for all workers at the site. All
TRS site personnel and TRS subcontractor personnel are required to complete the Northrop Grumman
health and safety orientation prior to performing work at the site. TRS will coordinate this training
with Northrop Grumman for all TRS site personnel and subcontractors.
TRS recognizes that potential hazards are inherent to the performance of site remediation using ERH.
TRS expects that all work related to the application of ERH will be conducted in a safe and healthful
manner.All project participants are responsible for conducting work in accordance with applicable
federal, state, and local regulations. Where there is concern that implementation of work could
compromise the safety or health of an individual, such concerns should immediately be brought to the
attention of the on-site TRS PM or SHSO.All TRS project personnel and subcontractors are
authorized to immediately stop work for any ERH related task or operation that poses unreasonable
risk to human health,the environment, or property.
Table 2.Summary of Project Information
Project Name Former Clifton Precision Facility
TRS Project Number MUS55
Site Location/Description The ERH remediation site at the Former Clifton Precision Facility
property is located at 1995 NC Hwy 141,Murphy NC
Current Status of Site The treatment area is presently covered with a combination of soil,
asphalt and concrete,and the remains of the foundations for the two
former site property buildings.
Suspected Chemical Hazards Chemicals of concern are: TCE,PCE,TCA,DCE,DCA,cDCE,Freon
113 and 1,4-dioxane
Known Physical Hazards Electricity,steam,heated water and contaminant vapors,trucks,heavy
machinery,hydraulic systems,rotating engines,power tools,pinch-
points,chemicals,extreme weather,lifting,trips and falls.
Field Activities Site preparation and equipment mobilization,subsurface electrode and
monitoring installations,piping,treatment facility construction,system
operations,process monitoring and sampling,equipment
deconstruction/demobilization, and waste disposal.
2.0 SITE INFORMATION
The Site is located at 3990 US Highway East 64A,Murphy NC. The contaminant source area that
will be treated using ERH technology is located within the foot print shown on Figure 2.
2.1. Site Description
Site soil stratigraphy in the remediation area consists of a mix of sands and silts. Groundwater is
reported at approximately 25 ft bgs based on historical site data,
The ERH treatment area measures approximately 23,045 square feet. TCE is the primary
contaminant of concern in the remediation area.Additional contaminants of concern(COCs)
identified in soil and groundwater in the treatment area is provided in Table 2.
Maximum concentrations of TCE in groundwater in the treatment volume have been reported at
520,000 µg/l based on historic site data. Based on data provided,TRS estimates that the treatment
volume contains approximately 7,882 pounds of COCs.
MUR55 HASP 052114 ad 11 GTRS

2.2. Scope of Work
TRS will design, supervise installation of subsurface components, construct, operate and monitor an
ERH treatment system, and demobilize ERH equipment at the Site.
ERH is an in situ process whereby soils and groundwater are heated by passing an electrical current
through the subsurface volume to be remediated. During ERH,the subsurface is heated just enough to
cause soil moisture and groundwater to boil and volatile organic compounds (VOCs)to convert to
vapors. The steam produced from this process acts as a carrier gas to sweep the contaminant vapors to
recovery wells where they are subsequently removed from the subsurface for surface treatment.
Active remediation by ERH will continue until the remedial goals are achieved. The remedial goal is
based on removing as much COC mass as possible during the allotted treatment time. The treatment
time and energy requirement were determined using a 99%average reduction of TCE in soil and
groundwater. During the remediation,concentrations of the daughter products of COCs will also be
reduced by an average of 99%in soil and groundwater.
3.0 HAZARD ANALYSIS
Before work begins at the site,TRS identified potential hazards during all phases of work at the Site
and developed this HASP to establish specific control measures to mitigate Site hazards. TRS
Activity Hazards Analyses(AHAs)are included in Appendix B that will be updated as AHAs are
utilized at the site during the course of the project. Site hazards and hazards resulting from
construction and operations activities are controlled using one or more of the control measures listed
below:
• Mitigate hazard through engineering/design.
Guard the hazard.
Utilize warning or alarm device to control hazard.
Obtain specialized training and follow specific procedures.
• Use of PPE.
3.1. Subsurface Utilities
Electric power lines,natural gas pipelines, communications lines and other utility services could exist
within a few feet of the ground surface. Digging into an underground electric line can cause power
outages and personal injury from shock or electrocution. A damaged gas pipeline or service to a
house can create an explosion hazard that potentially endangers both persons and property. These
underground utilities are not always located out in public areas and are likely to exist on private
property. The primary electrical service to the ERH area is below grade within the ERH treatment
area. There are likely other utilities located below grade within the treatment area. At least three
working days in advance of planned subsurface activities,including drilling,trenching and
excavation,TRS will contact the local underground utility service alert North Carolina 811 or at 800-
632-4949 to have local utility companies mark known subsurface features. If the public utility locate
is unable to identify subsurface features or if subsurface mark outs extend onto private property at the
Site,TRS will hire a utility survey specialist to perform the utility locate prior to any subsurface
work.
Based on the type and size of features present,the TRS PM and Project Engineer will determine the
need for any changes to the proposed locations of the subsurface ERH equipment to ensure safe
MUR55 HASP 052114 ad 12 GTRS

construction and maintain appropriate operational distances. The minimum offset for an ERH
subsurface component from an existing subsurface feature or associated mark-out is 2 feet.
3.2. Potential Chemical Hazards
Potential chemical hazards that may be encountered during site work include exposure to
uncharacterized waste in soil, surface water, groundwater,or air. Potential contaminants are primarily
associated with VOCs. The maximum detected concentrations of primary COCs and the associated
hazards are summarized in Table 3 below.
Table 3.Site-Specific Hazard Analysis
Chemical of Permissible Short- IDL Ionization Boiling Physical Route of Symptoms Target
Concern Exposure Term H Potential Point Properties Entry Organs
Limits(TWA) Exposure
Limit
TCE 100 ppm 100 ppm 1,000 9.45 eV 189°F Clear Inhalation Irritation Eyes,
(CAS#79-01-6) (ceiling at 300 (ACGIH) ppm colorless I eyes,skin; skin,
ppm) liquid; ingestion, headache, respirator
ethereal skin or visual y system,
(chlorofor eye disturbance heart,
m-like contact/ ,lassitude liver,
odor) absorptio (weakness, kidneys,
n exhaustion) central
,dizziness, nervous
tremor, system
drowsiness,
nausea,
vomiting
dermatitis,
cardiac
arrhythmia
s,
paresthesia;
liver
damage;
[potential
occupation
al
carcinogen]
MUR55 HASP 052114 acf 13 A TRS

Chemical of Permissible Short- IDL Ionization Boiling Physical Route of Symptoms Target
Concern Exposure Term H Potential Point Properties Entry Organs
Limits(TWA) Exposure
Limit
PCE 100 ppm 100 ppm 500 9.32 eV 250°F Clear inhalation irritation Eyes,
(CAS#127- (ceiling at 200 (ACGIH) ppm colorless ,skin eyes,skin, skin,
18-4) ppm) liquid; absorptio nose, respirator
(chlorofor n, throat, y system,
m-like ingestion, respiratory liver,
odor) skin system; kidneys,
and/or nausea; central
eye flush face, nervous
contact neck; system
dizziness,
incoordinat
ion;
headache,
drowsiness;
skin
erythema
(skin
redness);
liver
damage;
[potential
occupation
al
carcinogen]
1,1,1-TCA 350ppm 450ppm 700 11 eV 165°F Colorless inhalation irritation Eyes,
(CAS#71-55-6) ppm liquid with eyes,skin; skin,
a mild, ingestion, headache, central
chloroform skin lassitude nervous
-like odor and/or (weakness, system,
eye exhaustion) cardiovas
contact ,central cular
nervous system,
system liver
depression,
poor
equilibrium
dermatitis;
cardiac
arrhythmia
s;liver
damage
MUR55 HASP 052114 acf 14 TRS

Chemical of Permissible Short- IDL Ionization Boiling Physical Route of Symptoms Target
Concern Exposure Term H Potential Point Properties Entry Organs
Limits(TWA) Exposure
Limit
1,1-DCE 0.1 ppm 10.0 eV 89°F Colorless inhalation irritation Eyes,
(cas#75-35-4) liquid or ,skin eyes,skin, skin,
gas(above absorptio throat; respirator
89°F)with n, dizziness, y system,
a mild, ingestion, headache, central
sweet, skin nausea, nervous
chloroform and/or dyspnea system,
-like odor eye (breathing liver,
contact difficulty); kidneys
liver,
kidney
disturbance
pneumoniti
s
1,1-DCA 100 ppm 3,000 11.06 eV 135°F Colorless, inhalation irritation Skin,
(CAS#75-24- ppm oily liquid I skin; liver,
3) with a ingestion, central kidneys,
chloroform skin nervous lungs,
-like odor and/or system central
eye depression; nervous
contact liver, system
kidney,
lung
damage
Freon 113 1,000 ppm 1,250 2,000 11.99 eV 118°F Colorless inhalation irritation Skin,
(CAS#76-13- ppm ppm to water- I skin,throat, heart,
1) white ingestion, drowsiness, central
liquid with skin dermatitis; nervous
an odor and/or central system,
like carbon eye nervous cardiovas
tetrachlorid contact system cular
e at high depression; system
concentrati in animals:
ons cardiac
arrhythmia
s,narcosis
1,4-dioxane 100 ppm 500 9.13 eV 214°F Colorless inhalation irritation Eyes,
(CAS#123-91- ppm liquid or ,skin eyes,skin, skin,
1) solid absorptio nose, respirator
(below n, throat; y system,
53°F)with ingestion, drowsiness, liver,
a mild, skin headache; kidneys
ether-like and/or nausea,
odor eye vomiting;
contact liver
damage;
kidney
failure
cis-1,2-DCE 200 ppm N/A 1,000 9.65 eV 118- Colorless Inhalation Irritation Eyes,
(CAS#540-59- ppm 140°F liquid with eyes, respirator
0) a slightly ingestion, respiratory y system,
acrid, skin or system; central
chloroform eye central nervous
MUR55 HASP 052114 acf 15 GTRS

-like odor. contact/ nervous system
absorptio system,
n depression
Notes:TWA—time-weighted average;IDLH—immediately dangerous to life or health;CAS—Chemical Abstracts Service;ppm—parts
per million;°F—degrees Fahrenheit;ACGIH-American Conference of Industrial Hygienists.
3.3. Potential Physical and Biological Hazards
Potential physical hazards associated with this project include electricity, steam, heated water and
COC vapors,vehicles,rotating equipment,machinery,pinch-points, lifting, drum handling,power
tools,trips, falls,heat stress, and noise.
Small animals and rodents may be encountered on Site. Other potential biological hazards include
poisonous insects(spiders,ticks)and plants(poison ivy) in the materials lay down area. Precautions
should be taken to avoid direct contact with animals, insects, or plants. If a bite, sting, or skin
condition should occur, appropriate first aid and/or medical attention should be administered
immediately. All cuts received on site should be treated immediately.
3.4. ERH System Operational Hazards
3.4.1. Electrical Voltages
Dangerous voltages will be present in the subsurface of the ERH field during heating operations.
Startup and initial operation of the ERH power control until(PCU) are performed only when the ERH
Start-Up Checklist(SUCL)has been completed and approved by the appropriate TRS operations
personnel in accordance with TRS internal Standard Operating Procedure(SOP) 1-2,Application of
Electrical Power to ERH Sites. A copy of the SUCL is provided in Appendix A and a compendium
of TRS SOPS is provided in Appendix C. Copies of TRS SOPS will be maintained in a separate
binder at the Site.
In the treatment area,the region containing the electrode field will be a personnel restricted zone.
During start-up, a reduced voltage will be applied to the electrodes. Specially trained TRS personnel
will carefully survey and log locations within the electrode field and areas in the vicinity of the
electrode field for step-and-touch electrical voltage potential measurements in accordance with
Section 1.3 of the TRS internal SOP 1-3 for Voltage Surveys. Multiple points will be measured;
however, only points with greater than 1 volt will be logged. The measured step-and-touch voltage
potentials will be compared to TRS's internal policy limit.
The TRS electrical safety policy limit for exposed voltage is:
• High Exposure/Residential,5-Volt Step-and-Touch Survey and 10-Volt Extension Cord
Survey;
• Low Exposure/Industrial(where extension cord use is likely) 10-Volt Step—and—Touch
Inside and Outside Surveys, 10-Volt extension Cord Survey Inside, and 30-Volt
extension Cord Survey Outside;
• Low Exposure/Industrial(where extension cord use is not likely)30-Volt Step-and-
Touch Survey and No Extension Cord Survey;
• Restricted No Public Access,30-Volt Step-and-Touch Survey and 30-Volt Extension
Cord Survey.
MUR55 HASP 052114 acf 16 GTRS

As noted above, Step-and-Touch Voltage Surveys will be conducted on interior(inside) and exterior
(outside)portions of the Site based on the four different exposure areas that may be identified at the
Site. Additional Extension Cord Voltage Surveys will be conducted in any area of the site where an
electrical extension cord could likely be used by any person at the Site.
These limits provide a margin of safety beyond the 50-Volt limit established by the Occupational
Safety and Health Administration(OSHA). In general,the step-and-touch voltages increase in
proportion to the electrode voltage (a doubling of the applied electrode voltages will tend to double
the step-and-touch voltages previously recorded). If some surface-voltage potentials are marginal,
personnel can correct the problem by implementing the following engineering controls:
• Connect the subject voltage location to an electrically neutral location.
• Electrically insulate/isolate the subject voltage location so that personnel cannot make
contact with the location.
The above engineering controls are the preferred correction methods for mitigating surface voltage
potentials. In the case that engineering controls do not successfully mitigate potentials to meet TRS
voltage limits,the following administrative control may be implemented:
Create and ERH EZ to isolate a specific area of concern and prevent ANY personnel from
entering the area.
During start-up of the ERH system,the voltage applied to the electrodes will be slowly increased.
During this voltage ramp-up,the step-and-touch voltage surveys are completed repeatedly in
accordance with TRS SOPs 1-2 and 1-3. Special attention is directed toward metal objects located
within 50 feet of the electrode field.
3.4.2. High Temperatures
The application of ERH will increase subsurface soil and water temperatures and increase the
temperature of electrode and VR system components. Typically,the electrodes do not get any hotter
than the boiling point of the contaminant/water mix at depth. Electrodes are constructed inside PVC
over sleeves and caps at the ground surface that protect the operators from both hazardous voltages
and high temperatures during ERH operation. Following ERH shutdown, it may take several days or
weeks for the electrodes to cool below a safe handling temperature of 60 degrees Celsius(°C)or 140
'F. Severe burns may result from contact with these components without the use of proper PPE;
however,there are no planned activities that would require entering the over sleeves and touching the
casings while they are hot. Gloves providing protection from burns will be required to handle
groundwater monitoring well sampling and soil sampling equipment during this period(refer to TRS
SOP 3-1 for details on hot groundwater sampling and SOP 3-2 for hot soil sampling). Care should be
taken with regard to these temperatures for several weeks following shutdown of the ERH system.
3.4.3. Steam
Steam will be generated in the subsurface during operation of the ERH system and will be present
throughout the treatment area. In addition, steam may be present in the VR piping running from the
VR wells in the vicinity of the treatment area to the condenser, and within the condenser.
Steam that is below the water table will have a positive pressure equal to the hydrostatic pressure at
that depth. The subsurface will remain very hot immediately after an ERH shutdown and steam
MUR55 HASP 052114 ad 17 GTRS

generation can occur spontaneously if the hydrostatic head pressure is changed while groundwater is
at the hydrostatic head boiling point. This might occur during groundwater sampling, dewatering
activities, and/or soil sampling and related drilling activities.
Care must be taken to avoid exposing personnel to any source of steam. Field personnel will be
required to wear face shields, gloves, and heat resistant rain clothing as protection from burns when
opening any VR piping or conducting any sampling activity where steam may present a hazard
(including groundwater monitoring wells and soil borings in or adjacent to the electrode field).
3.5. Activity Hazards Analysis
The AHAs,to be included in Appendix B,defines each major work task and associated activities for
the ERH project at the Site. Each AHA identifies the sequence of work,the specific hazards
anticipated, and the control measures to be implemented to reduce,mitigate, or control each hazard to
an acceptable level. A major work task is defined as an operation involving a type of work presenting
hazards not experienced in previous operations or where a new subcontractor or work crew arrives on
site to begin a new segment of the project. The AHA for a specific task should be updated and made
"site-specific"as operations,procedures, site conditions, and equipment warrant during the project.
Site-specific AHAs will be added to the HASP as they are implemented and maintained on file at the
Site.
AHAs should be reviewed prior to performing a task with all staff that will be involved in that task.
AHAs are commonly reviewed during daily tailgate meetings or pre-task safety meetings conducted
at the Site. During these reviews, changes should be made to AHAs to reflect specifics at the site that
could change the hazards associated with the task and/or methods of hazard mitigation.
4.0 PERSONAL SAFETY, HAZARD CONTROL, AND INJURY
PREVENTION
Injury prevention is of the upmost importance to TRS. Injury prevention and personal safety will be
maintained through adherence to the following policies and good practice measures. TRS will
implement hazard mitigation throughout the project to minimize incidents at the site. Incidents are
defined as any personal injury, damage to equipment or property, and any unplanned release to the
environment.
4.1. Site Rules
All TRS personnel,TRS subcontractors,or others participating in on-site activities with TRS must
adhere to the instructions contained in this HASP.
Contact with contaminated or suspected contaminated surfaces and materials should be avoided.
Whenever possible,walking through puddles or discolored surfaces,kneeling on the ground, leaning,
sitting,or placing equipment on drums, containers, or the ground should be avoided.
Medicine, alcohol, and illegal drugs can increase the effects from exposure to toxic chemicals.
Personnel should not take prescribed drugs where the potential for adsorption, inhalation, or ingestion
of toxic substances may exist,unless specifically approved by a qualified physician. The possession
and intake of illegal drugs while on site is prohibited. The use of illegal drugs or alcoholic beverage
intake while on site or operating a company vehicle is prohibited.
MUR55 HASP 052114 ad 18 GTRS

4.1.1. General Housekeeping
Work zones will be cleaned and waste and debris will be removed daily. Tools and materials will not
be strewn about in a manner that may cause tripping or other hazards. Tools and materials will be
collected and returned to their storage area following the completion of tasks. Stored materials will
be placed and stacked in a manner that is stable and secured against sliding or collapse. All
slip/trip/fall hazards will be eliminated wherever possible.Where slip/trip/fall hazards cannot be
eliminated,the hazard will be guarded and warning signs will be used.
4.1.2. Fire Protection and Prevention
The appropriate number of 20A-80 B and or C rated fire extinguishers will be kept on site during
field activities. During operations, a minimum of one 10-pound dry chemical fire extinguisher and
one 15-pound carbon dioxide fire extinguisher will be kept on site near the PCU. Fire extinguishers
will be inspected monthly and certified by a qualified technician annually.
4.1.3. General Field Activities
The following list is provided as guidance for general field activities.
• All TRS personnel,TRS subcontractors,or others participating in on-site activities with
TRS must be adequately trained and thoroughly briefed on anticipated hazards,protective
equipment to be worn, safety practices to be followed, and emergency and communication
procedures.
• At no time during ERH power application shall any electrical extension cord be used within
the active treatment area(electrode field).
• Work areas for various construction and operational activities will be established, as
needed. Keep non-essential personnel out of the work area.
• A support zone will be maintained at all times.
• All personnel entering work zones must wear the designated PPE for the area.
• Loose-fitting clothing or loose, long hair is prohibited around moving machinery.
• All electrical equipment(power tools, extension cords, etc.) shall conform to Title 29 of the
CFR Part 1926.400(29 CFR 1926.400) Subpart K.
• Operation of corded electrical equipment and tools will use three-wire grounded extension
cords.
• All hand and power tools on site will be maintained in accordance with the manufacturer's
directions and specifications and visually inspected prior to use.
• Field personnel will inspect tools and moving equipment to ensure that parts are secured
and intact with no evidence of cracks or areas of weakness and that they are operating
according to manufacturer's specifications.
• Tools will be stored in clean, secure areas so that they will not be damaged, lost, or stolen.
• At the start of each day, field personnel will inspect brakes,hydraulic lines, light signals,
fire extinguishers,fluid levels,and steering on each piece of heavy equipment.
• Procedures defined in National Fire Protection Association(NFPA) 70E regulations for arc
flash and voltage protection will be followed.
4.1.4. Signs/Labels
Signs and labels will be used to clearly mark containerized waste materials, supplies, etc. Signs will
be used to clearly mark dangerous areas,restricted areas, and specific work zones. During operations,
MUR55 HASP 052114 ad 19 GTRS

hot surfaces and high voltage areas will be clearly identified and high voltage/no dig signs will be
posted around the perimeter of the ERH Restricted Zone. ERH equipment will have labels for arc
flash and voltage in accordance with NFPA 70E.
4.1.5. Eating/Drinking/Smoking
Eating,drinking, chewing gum or tobacco, smoking, or any practice that increases the probability of
hand-to-mouth transfer and ingestion of material is prohibited in any area that has been designated as
contaminated,designated Hazardous Operations and Emergency Response (HAZWOPER)EZ or
within the ERH treatment area and equipment compound.
4.1.6. Sanitation
Sanitary facilities will be provided for Site personnel near the ERH equipment compound. This
includes a hand wash sink(or suitable equipment for sanitizing hands) and toilet. Personnel will
thoroughly wash hands before eating, drinking, chewing gum or tobacco, smoking, or any practice
that increases the probability of hand-to-mouth transfer and ingestion of material.
Whenever decontamination procedures for outer garments are in effect,the entire body shall be
thoroughly washed as soon as possible after the protective garment is removed.
4.2. Site Control Measures
Due to the nature of the work to be performed and the hazards described in Section 3.0,the ERH
remediation Site has strict access control requirements. Access to the Site will be restricted to
authorized personnel from ERM,TRS, approved subcontractors, and visitors approved by the TRS
PM or Site Manager and the TRS SHSO. A log of personnel visiting, entering,or working on the Site
will be maintained by TRS.
During the construction phase, ERM with the help of TRS will maintain site control. The ERH area
will be enclosed by a fence with a gate and will be locked during construction and operations. The
fence will be unlocked during working hours and locked during off-duty hours.Unless specifically
arranged with ERM,work hours during the construction and demobilization phase will be restricted
to 7:00 a.m. to 5:00 p.m. daily,Monday through Friday, excluding federal holidays.
During the operational phase,no one may enter the restricted(remediation)zone or sample
monitoring wells until they have been trained by TRS and signed the associated Restricted Zone
Training Acknowledgement Form(Appendix A). Prior to performing work in the restricted zone that
could expose personnel to electrical current,trained personnel must lockout/tagout(LOTO)the ERH
PCU in accordance with TRS SOP 1-1 LOTO procedures.
4.2.1. Site Security
A chain-link,or similar, security fence will be installed to surround the portion of the electrode field
located outside of the Site building(s)prior to starting operations of the ERH equipment. This fence
will inhibit entrance by unauthorized personnel. Fencing will be located such that step-touch
electrical potential measured on the fence does not exceed the applicable voltage limit for that area as
defined in TRS SOP 1-3 Voltage Survey. TRS personnel will survey and document voltage at the
perimeter of the electrode field restricted zone.
To prevent injury to unauthorized personnel during operations, a motion detection security system
and a motion activated video system will be installed surrounding the ERH electrode field. As a
crucial site safety component,when any motion alarm is triggered, it will instantly de-energize the
electrode field via interlocks with the PCU. This component of the security system will protect a
MUR55 HASP 052114 ad 20 GTRS

possible intruder from injury associated with electrical shock. If unauthorized entry is detected and
the PCU is shut down,TRS personnel will be notified by a security vendor that the system was shut
down due to a security breach. If the shutdown was due to a false alarm,the system will be remotely
restarted following inspection using the security cameras and/or field personnel. If a true security
breach is observed,the local police department will be called to inspect the treatment area to ensure
the intruder is gone. Upon confirmation from the local police department, TRS can restart the system
via remote connection.
4.2.2. Construction and Sampling Work Zones
Decontamination of personnel,vehicles, and equipment is required prior to leaving the Site. Work
zones will be clearly identified for Site personnel and visitors. Work zones during construction and
sampling will consist of the following:
• EZ
• CRZ
• SZ
The SZ will be free of contamination or physical hazards. In the SZ,training and PPE requirements
will be equal to the lowest levels allowed on the Site. The TRS PM and SHSO will ensure that access
to the SZ is regulated at the perimeter fence line.
The EZs will be established to contain contaminated materials and to protect Site personnel and
visitors without proper training or PPE from exposure to chemical hazards. The TRS PM and SHSO
will ensure that access to the EZs is restricted to properly trained employees who need to enter the
zone and who are wearing proper PPE. It is anticipated that the areas around an active drill rig will be
the only established EZs. All EZs will be clearly demarcated using an appropriate combination of
caution tape,barriers, and signage.
The CRZs will be established between any EZs and the SZ. Personal decontamination will take place
in the CRZ. The TRS PM and SHSO will ensure that all employees,materials, supplies, and
equipment leaving an EZ pass through a CRZ and are properly decontaminated.All CRZs will be
clearly demarcated using an appropriate combination of caution tape,barriers, and signage.
Other areas of the Site may be demarcated as controlled access areas,but not EZs. These may include
haul routes,loading and off-loading areas, storage areas, and portions of the electrode field during
ERH system startup. These areas will be clearly demarcated using an appropriate combination of
caution tape,barriers, and signage.
4.3. Heat Stress
Heat stress is a major hazard especially for workers wearing protective clothing. Heat-related
illnesses range from heat stress to heat exhaustion and heat stroke. Careful training in the use of PPE
(including periods of acclimatization), frequent monitoring of personnel wearing protective clothing,
judicious scheduling of work and rest periods, and frequent replacement of fluids can protect against
this hazard.
Personnel will be monitored by the SHSO for the amount and frequency of liquid intake, frequency of
breaks, and the appearance of heat stress symptoms. The symptoms and/or warning signs for the early
stages of heat stress include rashes, cramps, discomfort,rapid pulse, drowsiness,and impaired
function. Treatment for early stages of heat stress includes rest in a cool setting and fluid intake.
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Continued heat stress could lead to heat stroke which can cause irreversible damage or even death.
The major symptom of heat stroke is dry,hot skin temperature, as the body's natural perspiring
mechanism has ceased to function properly. Thus,heat stroke requires immediate treatment,which
includes:
• Remove victim's protective clothing.
• Unless the victim is obviously contaminated, omit or minimize decontamination and begin
treatment immediately.
• Immediately cool the victim's body, especially the head and upper torso. This might
include moving the victim to a cool, shaded area and applying cool,wet towels.
When Site personnel are in Level D and C PPE,physiological monitoring shall commence when the
ambient temperature is above 29.5°C (85°F). This monitoring will be performed by the SHSO and co-
workers. The Physiological monitoring shall include:
• Watch for changes skin color,rashes, excessive sweating, or cessation of sweating.
• Ask personnel about rashes, cramps, and discomfort.
• Observe personnel for signs of drowsiness and impaired ability to think or function.
• Measure pulse and the time it takes for a rapid pulse to return to normal once stress has
been removed or reduced.
Monitoring frequency shall increase as the ambient temperature increases or as slow recovery rates
are observed. An adequate supply of cool drinking water shall be provided for the workers.
4.4. Cold Stress
Cold injury(frostbite and hypothermia) and impaired ability to work are dangers at low temperatures
or when the wind chill factor is high. Personnel will wear appropriate clothing,have warm shelter
readily available, schedule adequate work and rest periods, and will monitor their co-worker's
physical ability. Cold weather requirements:
• If wind chill is a factor at the work location,the cooling effect of the wind should be
reduced by shielding the work area or providing employees an outer garment to act as a
windbreak.
• Extremities,ears,toes, and noses will be protected from extreme cold by protective
clothing.
• Employees exposed to wet weather will wear a layer of clothing which is impermeable to
water.
• Workers will notify the SHSO if they are suffering from diseases or taking medication
which interferes with normal body temperature regulation or reduces tolerance to work in
cold environments. These workers will be excluded from work in cold(30°F or below).
4.5. Vehicle Safety
Cabs will be free of non-essential items and loose items will be secured. The rated load capacity of a
vehicle will not be exceeded. Heavy equipment will be inspected daily prior to use and documented in
the heavy equipment inspection form included in Appendix A. Personnel will confirm that all
appropriate guards are in working condition. These may include rollover protective structures, seat
belts, emergency shutoff in case of rollover, and backup warning lights and signals. Equipment
operators will report abnormalities such as equipment failure, oozing liquid,unusual odors,etc. to
their supervisor(s),the SHSO, or the PM. Blades and buckets will be lowered to the ground and
MUR55 HASP 052114 ad 22 GTRS

parking brakes set before vehicles are shut off. Wheels of construction vehicles will be chocked
when not in use for extended periods.
During construction and operations at the site,there will be instances when vehicles will be required
to maneuver off clearly marked roads or pathways.While maneuvering vehicles through these areas
of the Site, and any areas of limited visibility, a spotter will be implemented to provide the safe
mobility of the vehicle through the site. The driver and spotter will agree on verbal commands and
hand signals to be used during spotting prior to the activity. The spotter should remain visible to the
vehicle operator as long as the vehicle is in motion. If the operator loses visual contact with the
spotter during mobilization of the vehicle,the operator shall stop the motion of the vehicle until visual
contact with the spotter is re-established. Whenever possible,drivers will utilize spotters when
backing up vehicles at the site.
4.6. Equipment and Machine Guarding
Be certain that equipment has appropriate guards and engineering controls. Belts,gears, shafts,
pulleys, sprockets, spindles, flywheels, chains,or other reciprocating,rotating or moving parts of
equipment will be guarded if there is a possibility of human contact or when they otherwise create a
hazard. TRS and its subcontractors will adhere to other applicable provisions which require backup
alarms consistent with OSHA requirements.
4.7. Drilling
TRS personnel will be on site during drilling activities. The following list provides guidance to TRS
personnel:
• Head,hearing,hand, and eye protection will be worn by all TRS employees involved in
drilling activities, and by employees required to work in the immediate vicinity of drilling
activities.
• A high-visibility vest or shirt will be worn by personnel involved in or working in the
vicinity of drilling activities.
• Only trained and authorized personnel will operate the drill rig.
• At no time will employees be allowed to climb the mast of a drill rig while it is in the
upright position without appropriate fall protection and fall protection equipment training.
• Care will be taken to avoid slips/trips while working on uneven,wet,or plastic covered
surfaces.
• There will be no walking, standing, or crawling under a suspended load.
• All personnel will be trained on the location and function of the"kill switch"on the drill rig
prior to beginning drilling operations.
• TRS personnel will not approach an operating drill rig without establishing
communications with the drill rig operator.
• Routes of egress from drilling locations will be established prior to drilling at that location.
• The mast of the drill rig will be lowered prior to moving the equipment.
• When working around overhead power lines,heavy equipment and personnel will maintain
the minimum distances specified in Table 4.
Table 4. Safe Distance from Overhead Power Lines
Voltage of Power Line Minimum Distance to be Maintained
MUR55 HASP 052114 ad 23 GTRS

from Power Line
<50kV 10 feet
200 kV 15 feet
350 kV 20 feet
500 kV 25 feet
650 kV 30 feet
800 kV 35 feet
Soils generated by drilling activities will be managed by TRS in accordance with the Northrop
Grumman Scope of Work(SOW)Exhibit B (Appendix E). Refer to section 4.11 for details
regarding soil management.
4.8. Confined Space Entry
According to the CFR 1910.146(b)"Confined space" is defined as a space that:
1. Is large enough and so configured that an employee can bodily enter and perform assigned
work; and
2. Has limited or restricted means for entry or exit(for example,tanks,vessels, silos, storage
bins,hoppers,vaults, and pits are spaces that may have limited means of entry.); and
3. Is not designed for continuous employee occupancy.
A"permit-required confined space"has the above characteristics,plus one or more of the following
characteristics:
1. Has the potential to contain a hazardous atmosphere.
2. Contains a material with the potential to engulf an entrant.
3. Has an internal configuration that might cause an entrant to become trapped or asphyxiated.
4. Contains other recognizable safety or health hazards.
The only known potential confined space at the site associated with the ERH equipment is the cooling
tower. This is a non-permit confined space. Confined space entry is not anticipated under this
contract. If a"permit-required confined space"is identified on site,then TRS will communicate this
requirement to employees, sub-contractors and visitors through the use of proper signage.
4.9. Fall Protection
In accordance with OSHA regulations outlined in 29 CFR 1926 Subpart M,each employee on a
walking/working surface(horizontal and vertical surface)with an unprotected side or edge which is 6
feet(1.8 m)or more above a lower level shall be protected from falling by the use of guardrail
systems, safety net systems, or personal fall arrest systems. Fall protection is not anticipated on this
project. However, should personnel require for certain, short term activities (e.g., access to crane or
drill derricks), only competent,trained personnel shall conduct the work activities. For activities
conducted at a height of 7.5 feet or greater above ground surface, each employee will wear a harness
and lanyard when appropriate(i.e.,when there is a reasonable and stable place to hook the lanyard).
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4.10. Hot Work
Hot work includes tasking involving electric or gas welding, cutting,brazing, or similar flame or
spark-producing operations. Heat shrinking activities are the only hot work anticipated under this
contract. Hot work is not anticipated under this contract. All activities associated with potential hot
work will require completion of the TRS hot work permit(Appendix A) and will follow the
appropriate safety protocols(i.e., fire extinguisher available nearby).
4.11. Excavation and Trenching
Any excavation and trenching work will not extend beyond a depth of 2 ft.bgs and the protective
systems requirements of OSHA Standard 1926.652 will not be required. All health and safety
practices for general construction will be followed including requirements for workspace
housecleaning and exposure to falling loads.
As part of the SOW,TRS is responsible for the management of excavated soils associated with
excavation,trenching, and drilling. TRS will conduct soil management in accordance with the
Northrop Grumman SOW Exhibit B (Appendix E),in particular, section 3.4.3 for VOC emissions
control. The following is a summary of the VOC emission control requirements presented in Section
3.4.3 of the Northrop Grumman SOW Exhibit B:
• The Contractor shall control potential VOC emissions during the work.
• Excavated soil shall not be spread or left open to the atmosphere.
• The Contractor shall supply and use a PID to monitor the excavated soil. PID measurements
shall be taken every 15 minutes within 3 inches of the soil surface. The PID shall be
calibrated per manufacturer requirements.
• If PID readings exceed 50 parts per million by volume (ppmv) above background,then
soil stockpiles, excavated surfaces, and other exposed soil surfaces shall be sprayed with
water or covered with plastic sheeting.
• Any soil exhibiting VOC emissions exceeding 50 ppmv(VOC-impacted soil) shall be
segregated and stockpiled separately.
• The Contractor shall cover with plastic sheeting any excavated soil at the end of each
working day or continuously during periods of existing or anticipated precipitation. The
plastic sheeting shall be new, 6-millimeter polyethylene plastic and shall be maintained
free of holes during the work. The plastic sheeting shall be fastened and secured over
the top of the soil in a manner that prevents wind from blowing the cover partially or
completely off the soil. A minimum overlap of 2 feet shall be maintained between sheets.
The plastic sheeting shall meet the approval of the Northrop Grumman Representative.
• If PID readings exceed 1,000 ppmv, then work shall cease until vapor emissions are
controlled and soil shall be immediately loaded into trucks or storage bins equipped with
covers. The Contractor shall immediately notify the Northrop Grumman representative.
4.12. Hoisting and Rigging
All hoisting and rigging operations will follow the guidelines set forth in CFR 1926.753, Safety and
Health Regulations for Construction,Hoisting and Rigging; OSHA Document 3072 (1996), Sling
Safety; and North Carolina requirements.
A lifting plan will be prepared and reviewed prior to initiating any critical lift. A critical lift is defined
as a lift that either exceeds 75 percent of the rated capacity of the crane or derrick or requires the use
of more than one crane or derrick. The TRS SHSO will determine if a critical lift exists and may also
MUR55 HASP 052114 ad 25 GTRS

require a lifting plan for other large or unusual loads. AHAs for crane work and lifting and lift plans
(if applicable)will be reviewed at a pre-task safety meeting with all personnel involved in hoisting
and rigging.
4.13. Material Handling
On-site personnel will observe the following protocols to prevent incidents of hazards and injury
related to lifting and moving of equipment and materials on the site:
1. Drums will be pumped prior to moving if the integrity of the drum skin is questionable.
2. Personnel will be trained in proper lifting and moving techniques and will only move items of
reasonable weight and dimension by hand.
3. Before moving anything with a forklift,the forklift operator will determine the most
appropriate sequence in which the various items should be moved.
4.13.1. Moving/Lifting
Employees performing repetitive motion tasks will take breaks to avoid injury. When lifting objects is
necessary, employees will follow safe lifting practices including: bending the knees,keeping the back
straight,keeping the object as close to the body as possible, and lifting with the legs. If the object is
large or awkward, employees will get help with lifting. Personnel will clear a pathway before moving
an object. When possible,personnel will use carts,hand trucks, or a push/pull technique to move
obj ects.
4.13.2. Spill Prevention and Containment
TRS and its subcontractors will store,handle and transfer fluids so as to prevent the release or spill of
oil or other hazardous materials. An adequately sized universal spill kit will be maintained at the Site.
Materials that are likely to be used in construction equipment include PVC glue and primer, gasoline,
diesel fuel,hydraulic fluid and lubricating oils.Materials that are likely to be used or stored on site
during operations include diesel fuel and drums or tanks containing waste material extracted from the
subsurface.
Separated storage areas will be created for the various types of waste and debris associated with the
removal. Signs and labels will be used to clearly mark containerized waste materials, supplies, etc.
Specifications for tanks and containers must meet generally approved standards (including but not
limited to suppliers' recommendations and specifications of the United States Department of
Transportation(DOT). In meeting these standards,TRS will ensure that tanks and containers maintain
their integrity and be of a condition acceptable for storage and transportation.
Secondary containment mechanisms will be placed under the ERH condensers. The secondary
containment system will have the capacity to hold all fluids contained within the ERH condensers.
4.13.3. Material Transfer Safety
Liquids and residues shall be removed from storage tanks using explosion-proof or air-driven pumps.
All pumps and transfer equipment requiring an electrical power source will be properly grounded
using Ground Fault Circuit Interrupters. Storage and temporary containers will also be grounded
during materials transfers.
Transferring liquids and refueling will occur only at approved locations that are at least 100 feet away
from any wetlands or surface waters, and 200 feet from any private,municipal or community water
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supply. Site personnel will have adequate spill response equipment available at the dispensing or
transfer location. Any liquids will be collected in suitable containers and appropriately disposed.
Transfer lines will not be left unattended when in use and will either be held or secured in place
throughout the transfer process.
Refueling of vehicles will be performed off-Site. In addition,only the qualified vendor providing
propane tanks (if used)will refuel these tanks on site.
TRS personnel shall contact the TRS PM and TRS SHSO for non-routine materials handling events.
The TRS SHSO will be responsible for developing the task-specific AHA.
5.0 PPE PROGRAM
5.1. Hearing Protection and Noise Control
The Site-wide hearing conservation program is based upon limiting the exposure of Site personnel
and visitors to excess noise. All Site personnel and visitors will be provided with protection against
the effects of hazardous noise exposure. Protection will include earplugs, earmuffs, or a combination
of both. Site personnel and visitors will be required to use hearing protection whenever sound-
pressure levels exceed 85 decibels steady-state expressed as a TWA. It will be assumed that this
sound pressure level is not exceeded if two people can engage in conversation using normal voices
while located a distance of three feet from the noise source.
5.2. Eye Protection
Airborne particulates, flying debris and chemical exposure can cause injury to eyes. Safety glasses
will be worn during all phases of work at the Site. All safety glasses used will meet American
National Standards Institute(ANSI)Z87.1-2010 standards. When work conditions warrant and as
determined by the TRS SHSO, full-face shields, goggles, or chemical goggles may be worn.
5.3. Dermal Protection
Protective clothing, such as Tyvek® suits and nitrile gloves will be worn when dermal exposure to
hazards warrants, as determined by the SHSO. Tyvek® suits are not required for the ERH project,but
Site personnel may elect to wear them during intrusive, subsurface activities such as drilling. Clothing
must be maintained and stored properly to prevent damage or malfunction due to exposure to dust,
moisture, sunlight, damaging chemicals, extreme temperatures,and impact. Tyvek® suits will not be
reused;they will be disposed of at the end of each workday at minimum or whenever necessary.
5.4. Construction Safety
Steel-toed boots or safety boots/shoes conforming to ANSI Z41.1-1991 and American Society for
Testing and Materials F 2412-05 and F2413-05 with chemical resistant soles will be worn during all
phases of work at the Site. A hard hat will be worn during any phase of Site work when overhead
obstructions exist. A high-visibility safety vest or an outermost layer of safety/reflective coloring will
be worn when heavy equipment is present at the Site and as site conditions warrant(and during all
phases of ERH operations). Gloves will be worn as appropriate.
MUR55 HASP 052114 ad 27 TRS

5.5. PPE Program-Respiratory
5.5.1. Anticipated Levels of Protection
The need for respiratory protection is not anticipated during ERH construction, operation, and
demobilization. Personnel will wear Level D PPE when on site. Level D PPE provides no respiratory
protection and minimal skin protection. Level D PPE should be used when the workplace atmosphere
contains less than regulatory limit and work functions preclude the potential for unexpected inhalation
of,or other contact with,hazardous levels of any chemical. For Level D PPE,the workplace
atmosphere must contain at least 19.5 percent oxygen.
Level C PPE provides respiratory protection when atmospheric conditions exceed the action level for
airborne contaminants (see Table 5 below). Level C PPE should be worn when the types of air
contaminants have been identified, concentrations measured, and a respirator filter cartridge is
available that can remove the contaminants of concern. Level C PPE should not be used if
atmospheric concentrations of any chemical exceed IDLH levels or if the workplace atmosphere
contains less than 19.5 percent oxygen. While not anticipated,Level C PPE at the Site will include
either a full or half-face air purified respirator with appropriately selected cartridges. During drilling
operations,this may require a combination HEPA and volatile organic filter cartridges. Any personnel
using a respirator will be trained in accordance with TRS respiratory training program(Appendix D).
Level B and Level A respiratory protection should be used when concentrations of chemicals in the
workplace atmosphere are above the regulatory limit. If this situation arises,work will cease until
appropriate training and equipment become available on Site.
5.5.2. Personal Monitoring
Exposure monitoring data from the Site will include: real time PID readings from the monitoring of
breathing zones,PID readings from ambient air monitoring, PID readings from subsurface samples
(during construction, sampling, and demobilization), and analytical data from the analyses of waste
materials. Depending upon monitoring and analytical results,personal TWA exposure calculations
may be performed for VOCs and selected compounds.
A PID equipped with a 10.2 eV lamp will be kept on site throughout construction, and operation. The
PID will be calibrated to an isobutylene equivalent according to manufacturer's recommendations.
The manual will be kept in the storage case with the PID for reference on calibration and use.
Experience gained from previous site activities indicates that a personal monitoring program based
upon the use of direct-reading field instruments will not put field personnel at a risk of exposure to
atmosphere concentrations of chemicals above regulatory limits or of exposure to unexpected
contaminants.
The level of personal monitoring during each site activity will be based upon known site
characteristics, observations of site conditions,the activity being performed, and any new
information/data collected during ERH construction and operations. The following guidelines are
provided for as minimum personnel air monitoring requirements during drilling operations if TRS
personnel are on site.
• The breathing zone will not be monitored during shallow invasive activities, such as
grading,trenching, and piping,unless liquids other than groundwater, stained soil cuttings,
or odors, or any suspected contaminants are encountered.
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• The PID will be used during drilling and other subsurface intrusive activities. Monitoring
will begin when the ground surface is broken at a borehole location, and continue until
drilling of the borehole is completed.
• PID readings will be taken periodically from the borehole opening,when the areas can
safely be accessed, or from recent soil cuttings.
• The worker breathing zones will be monitored in response to any PID readings at the
borehole opening which approach or exceed the action levels.
• Ambient air monitoring will be conducted with a PID prior to and during drilling
operations to ensure public safety.
During this project, drilling,trenching and electrode installation are the planned intrusive subsurface
activities that will require the periodic monitoring of breathing zones for personnel protection.
During operations of the ERH system,the vapor stream extracted from the subsurface will be
monitored for total VOC concentration using a PID and sampled for off-site laboratory analyses of
the concentrations of contaminants of concern VOCs. Details regarding the analytes to be measured,
the sampling methods, sampling frequency, and analytical protocols are in the Operation and
Maintenance Plan in Appendix 5 of the TRS Design Report. Data from these activities will continue
to provide guidance as to the possible chemical compounds personnel could be exposed to at the site.
5.5.3. Worker Exposure Limits
During the course of field activities,the upgrade of respiratory and skin protection requirements from
Level D PPE is not anticipated,but may be appropriate. The decision to upgrade levels of protection
will be made by the SHSO and the TRS PM based on exposure monitoring data collected with a PID
and any available analytical data(including waste material profile results). Depending upon
monitoring and analytical results,personal TWA exposure calculations may be performed for VOCs
and selected compounds.
This respiratory PPE program has been implemented to assure that no personnel are exposed to
airborne contaminant levels above the permissible exposure limits(PELs) listed in Table 5.A 5 ppm
limit has been established for this site as a conservative action level requirement based on the
potential presence of TCE,which has a PEL of 100 ppm. Air sampling per National Institute for
Occupational Safety and Health or OSHA guidelines will be performed if PID readings exceed 50
ppm in the breathing zone for 10 to 15 minutes.
When visible quantities of dust are in the ambient air,dust control techniques, such as wetting the
ground surface,will be employed, and the SHSO will be notified for guidance and recommendations
on whether to upgrade from Level D PPE to Level C PPE.
MUR55 HASP 052114 ad 29 TRS

Table 5.Action Levels
Contaminant Action Level Action PEL (TWA)
TCE 50 ppm* See Below* 100 ppm
cDCE 100 ppm* See Below* 200 ppm
PCE 50 PPM * See Below* 100 ppm
TCA 175 ppm See Below* 350 ppm
DCA 50 ppm See Below* 100 ppm
Freon 113 500 ppm See Below* 1,000 ppm
Dioxane 50 ppm See Below* 100 ppm
Dust in air Visible(prolonged) Institute engineering controls (i.e., dust
suppressant), dust masks, safety
glasses
* If sustained (30 seconds) real-time (instantaneous) measurements of organic vapor levels on the
PID exceed 1 ppmv in the breathing zone of affected personnel, corrective action will be taken
immediately to decrease the emissions, lower concentrations in the breathing zone, or prevent
worker exposure through the use of appropriate PPE.
5.5.4. Maintenance and Storage
All respirators will be inspected prior to use. The inspection will include a check of respirator
function,tightness of connections, and the condition of the various parts including,the face piece,
head straps,valves, connecting tube,and cartridges, canisters or filters and a check of elastomeric
parts for pliability and signs of deterioration.
The respirators will be cleaned and disinfected at the following intervals:
• Respirators issued for the exclusive use of an employee will be cleaned and disinfected as
often as necessary to be maintained in a sanitary condition.
• Respirators issued to more than one employee will be cleaned and disinfected before being
worn by different individuals.
• Respirators maintained for emergency use will be cleaned and disinfected after each use.
All respirators will be stored to protect them from damage, contamination, dust, sunlight,extreme
temperatures, excessive moisture,and damaging chemicals, and they will be packed or stored to
prevent deformation of the face piece and exhalation valve.
6.0 TRS ERH-SPECIFIC SAFETY PROCEDURES
All TRS personnel,TRS subcontractors, or others participating in on-site activities with TRS must be
familiar with standard operating safety procedures and any additional instructions and information
contained in this HASP. Copies of applicable TRS SOPS will be maintained on file at the site.
MUR55 HASP 052114 ad 30 GTRS

6.1. ERH System Operations
ERH System operations will be in accordance with TRS internal SOPS and equipment operating
standards.
6.1.1. ERH Start-Up
Dangerous voltages can be present in subsurface the ERH field during heating operations. Only
qualified,trained TRS personnel will conduct ERH start-up activities. ERH startup will be in
accordance with TRS internal SOPS 1-2 (ERH System Startup) and 1-3 (Voltage Surveys). Startup
and initial unattended operations of the ERH power control unit are performed only when the Site
SUCL has been completed and signed off by the appropriate TRS operations personnel. The Site
SUCL is included as Appendix A.
6.1.2. ERH Emergency System Shut Down
During ERH operations if an emergency condition should arise; any and all personnel have the
authority to depress the Emergency-stop (E-stop)button on the PCU which will de-energize the
electrode field. The E-stop button is located outside of the PCU, immediately adjacent to the control
room entrance. The procedure for emergency shutdown is as follows:
1. Press the E-stop button. A"clunk"will be heard as the output contactor(automatic switch)
opens.
2. Enter the PCU control room, depress the Output Switch, lock it in the depressed position,
hang a danger tag on the switch,and take personal possession of the key. This will prevent
any potential restart of the ERH system
3. Notify the TRS operator or TRS SHSO at the first available opportunity.
4. Once the emergency condition has been rectified,return the switch to the out-position
(normal)normal setting. Remove the danger tag from the output switch and unlock the
switch. The switch will normally spring return to the mid position; if it remains depressed,
gently pull it to the mid position.
5. Notify the TRS operator to restart the ERH system.
When the PCU is shut down,the subsurface becomes electrically safe instantly: there is no "residual
voltage".
6.2. ERH Operations Work Zones
Due to the hazards that exist on Site during ERH operations,TRS will establish an ERH Restricted
Zone. The ERH Restricted Zone is an area established to permit access to only authorized personnel
who have been properly trained or who are escorted by properly trained personnel and have signed
the ERH Restricted Zone Acknowledgement Form.
The ERH Restricted Zone will have a clearly defined boundary that restricts access,but may consist
of movable boundaries(such as temporary chain-link fencing) during operations. Proper signage
delineating the area shall be posted.
In the event that a hazardous condition exists within the site that cannot be eliminated with
engineering controls, an ERH EZ will be established to prevent access by all personnel while power is
applied to the subsurface. This zone will have a locked access point with immovable boundaries and
shall only be entered following LOTO procedures. Approval by the TRS Vice President(VP) of
Operations or Senior PM is required prior to access with power applied. Proper signage delineating
MUR55 HASP 052114 ad 31 GTRS

the area shall be posted. This area has the possibility of exceeding the administrative potential voltage
limit during ERH application.
6.3. Lockout/Tagout
Safe work practices will be used to safeguard employees from injury while they are working on or
near exposed electrical conductors or circuit paths that are, or can become, energized. The specific
safety-related work practice shall be consistent with the nature of and extent of the associated
potential energy hazards. Prior to performing work in the restricted zone that could expose personnel
to electrical current,trained personnel must lockout and tagout the ERH PCU. No one may perform
LOTO procedures until they have been trained by TRS personnel in accordance with SOP 1-1 LOTO,
have signed the associated Training Acknowledgement Form, and have been authorized by the TRS
PM.
Unless it can be demonstrated that de-energizing introduces additional or increased hazards or is
infeasible due to equipment design or operational limitations for specific tasking, exposed energized
electrical conductors or circuit paths to which an employee might be exposed will be put into an
electrically safe work condition before an employee works on or near them. Workers in the vicinity
of exposed and potentially live electrical conductors will follow procedures defined in NFPA 70E to
ensure personal safety.
Only authorized personnel experienced or trained to operate or perform maintenance on the ERH
remediation equipment or system support components are authorized to conduct the LOTO
procedures described in TRS SOP 1-1 Lockout/Tagout.
7.0 DECONTAMINATION
TRS employees and subcontractors shall implement work practices that minimize contact with
hazardous substances(e.g., do not walk through areas of obvious contamination; do not directly touch
potentially hazardous substances). All of TRS's site work will be performed in modified Level D
personal protection equipment. Should changes in site conditions cause an upgraded level of personal
protection,all impacted workers will be informed of the necessary equipment and decontamination
requirements.
7.1. Personal Decontamination Procedures
Personnel, clothing, equipment, and samples leaving the contaminated area of a Site must be
decontaminated to remove harmful chemicals or infectious organisms that may have adhered to them.
While in modified Level D personal protection equipment, any disposable protective clothing,
including nitrile gloves and Tyvek® (or equivalent) suits will be disposed of as general refuse. If
personal protection equipment has been in contact with subsurface soils or liquids,the protective
clothing will be disposed of in accordance with site waste management plans.
Potable water will be provided on site. Workers will wash hands and face before breaks, lunch,and
before leaving the job Site.Water, soap,and clean towels will be provided. Boots and hard hats will
be washed with detergent and rinsed with potable water as needed.
If an upgrade to Level C personal equipment occurs, all non-disposable protective equipment will be
cleaned in a specified contaminant reduction zone prior to leaving the site either for reuse or as trash.
If needed,respirators will be dismantled,washed,and disinfected after each use or as needed.
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Personnel will be trained in decontamination procedures to minimize contact with possible
contaminants and maximize worker protection. These procedures will be enforced throughout Site
operations.
7.2. Vehicle and Equipment Decontamination
A containment berm or decontamination pad will be constructed at a location that the TRS Site
Superintendent or SHSO feels is most adequate to perform decontamination for equipment and tools.
Decontamination will be performed on an as-needed basis. It is assumed that all equipment that
comes in contact with subsurface contamination will require on site decontamination. If necessary,
equipment and sampling tools will be decontaminated by scrubbing with detergent water using a
brush,followed by rinsing with water.
Drilling equipment will be decontaminated by pressure washer prior to arrival at the Site.
Decontamination of auger flights and equipment used for intrusive, subsurface activities will be
decontaminated via a high-pressure washer prior to arrival at the Site. Equipment that has come in
contact with subsurface soil will be decontaminated by pressure washer prior to leaving the Site.Any
decontamination water that collects in the containment berm will be pumped into DOT-approved 55-
gallon drums for temporary storage prior to disposal. Decontamination fluids will be handled and
contained in accordance with site-specific waste management plans.
7.3. Decontamination during Medical Emergencies
If emergency life-saving first aid and/or medical treatment are required, decontamination procedures
may be omitted at the professional emergency responder's direction. The appropriate Site personnel
and/or professional emergency responder will accompany contaminated victims to the medical
facility to advise them on matters involving decontamination.
Life-saving care will be instituted immediately without considering decontamination. The outer
garments can be removed if they do not cause delays,interfere with treatment, or aggravate the
problem. Protective clothing can be cut away. If the outer contaminated garments cannot be safely
removed,the individual can be wrapped in plastic to help prevent contaminating medical personnel.
No attempt need be made to wash or rinse the victim,unless it is known that the individual has been
contaminated with an extremely toxic or corrosive material,which could also cause severe injury or
loss of life. If it is at all possible,it is best to have a professional emergency responder make the
judgment and perform the above mentioned procedures. For minor medical problems or injuries,the
normal decontamination procedures will be followed.
For inhalation exposure cases,treatment can only be performed by a qualified physician.
If the contaminant is on the skin or in the eyes,water should be used to rinse the affected area with
water for 15 minutes. Portable eyewash stations containing potable water or eyewash solution will be
maintained at the Site for these emergencies.
8.0 HAZARD COMMUNICATION
The information and training employees receive must be tailored to the types of hazards and
exposures they encounter. The training program is designed for both new and experienced employees.
Hazard communication training will be provided for employees before and/or immediately when they
arrive on site.Additional training will be provided when a new chemical is brought into the
workplace. The following information will be given to employees with a potential for exposure:
MUR55 HASP 052114 ad 33 A TRS

• Chemicals present at the project Site,
• Physical and health effects of the hazardous chemicals,
• Methods and observation techniques used to determine the presence or release of hazardous
chemicals,
• Methods regarding minimizing or prevention of exposure to these hazardous chemicals
through the use of engineering and administrative controls and PPE,
• Steps the project team has taken to minimize or prevent exposure to these chemicals,
• Emergency procedures to follow if an individual is exposed to these chemicals,
• How to read labels and review material safety data sheets(MSDSs)to obtain appropriate
hazardous information(MSDS will be maintained in a separate file at the site), and
• Location of MSDS files and location of hazardous chemical lists.
8.1. Chemical Inventory List and MSDSs
The SHSO, or a designee,will prepare a chemical inventory list of chemicals brought to the Site(See
Appendix E). If new chemicals or hazardous substances are brought onto the job Site,employees
must inform the SHSO. The SHSO will be responsible for maintaining the MSDS compendium in the
TRS PCU. The MSDS files will be updated(added or removed from the compendium) as materials
are brought onto or no longer exist at the project site. Employees potentially exposed to the substance
will be advised of information contained in the MSDS for the substance.
8.2. Labeling Hazardous Chemical Containers
Each container entering the workplace will be checked for appropriate labeling, if applicable.
Container labels will include the following:
1. Identity of the hazardous chemical,
2. Appropriate hazard warning, and
3. Name and address of the chemical manufacturer.
Containers into which hazardous chemicals are transferred must be labeled,tagged, or marked with
the identity of the hazardous chemical(s) and appropriate hazard warnings.
9.OMEETINGS AND INSPECTIONS
9.1. Pre-Construction Safety Meeting
The TRS PM or his designee will conduct a preconstruction safety meeting before any work begins at
the Site and on the first day of mobilization in the field at the Site of new personnel. Every person
working in the field, including TRS employees and subcontractors,must attend a preconstruction
safety meeting. Meeting participants will review the HASP and the site-specific safety concerns. At a
minimum,the following topics will be covered in the preconstruction safety meeting:
• Team members and responsibilities,including SHSO.
• Location of on-site first aid equipment and spill containment equipment.
• Route/contact information for emergency medical services.
• Site security/visitor control.
• Contaminants of Concern and signs of exposure.
MUR55 HASP 052114 ad 34 TRS

• Personal protective equipment.
• Overhead power lines.
• Vehicle/heavy equipment.
• Fire Protection and location of extinguishers.
• LOTO.
• Permit requirements (e.g. hot work and confined spaces).
All personnel will document their understanding of this HASP and the preconstruction safety meeting
by signing the HASP Acknowledgement Form included in Appendix A.
9.2. Pre-Operations Safety Meeting
Prior to beginning ERH operations at the site,the TRS PM or his designee will hold a pre-operations
safety meeting. At a minimum,the following topics will be covered before personnel are permitted to
work within the ERH Restricted Zone during the system operational phase of work:
• Proper LOTO requirements to enter the electrode field.
• Proper PPE requirements.
• Site-specific training regarding potential hazards with ERH equipment. Training should
include(but not be limited to)hot surfaces,pinch points, slip,trip, and falls, confined
spaces, and contaminants of concern.
• Site-specific and task-specific training regarding site sampling requirements. Training
should include the potential hazards of sampling.
• Training on location and function of the E-stop. The E-stop will deactivate PCU and power
to electrodes but not vapor recovery or treatment. In the event of an emergency(fire,
electrical shock),press the red E-stop button to the right of the PCU door.
• On-site training for Emergency Response and the possible scenarios.
• Confirmation that all site personnel have completed project-specific reading assignments as
outlined by the TRS PM.
All personnel will document their understanding of topics addressed in the pre-operations safety
meeting by signing the ERH Restricted Zone Acknowledgement Form included in Appendix A.
9.3. Daily Tailgate Health and Safety Meetings
A daily tailgate meeting will be held each day when personnel are on site during all phases of the
ERH project. The PM,the SHSO, or a delegate of the SHSO will conduct these meetings. All Site
personnel will attend. The tailgate meetings will be conducted on site,prior to the commencement of
the daily activities. The agenda of the meeting may vary,but, at a minimum, it will cover the
activities planned for the day, including operations which may occur in other areas of the Site that
could potentially impact the planned work(e.g., site equipment of materials deliveries, expected
visitors,planned inspections), an overview of the known hazards,and methods to be used to mitigate
these hazards. Any near misses or incidents will be discussed as lessons learned. The SHSO will also
discuss any recently completed inspections and inspection findings. The daily tailgate meeting form
(Appendix A)will be completed and maintained on file at the site.
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9.4. General Site Safety Inspections
General site safety inspections will be conducted weekly,unannounced,at times selected by the
SHSO or his designee to ensure compliance with the HASP. The purpose of these general inspections
is to ensure that project health and safety procedures are being implemented in accordance with the
project safety plan, and to identify any issues which may require further evaluation,discussion or
actions. The results of these inspections will be discussed at the next Daily Tailgate Health and Safety
Meeting as discussed in Section 9.3.
9.5. Safe Behavior Observations
Safe Behavior Observations (SBO)will be made either by the SHSO or designated TRS personnel,
using the form contained in Appendix A. The goal of completing these evaluations is to reinforce
safe work practices and behaviors, identify and improve at-risk practices and acts,improve on
procedures,conditions and controls,make sure that the necessary tools and supplies are available, and
facilitate collaborative feedback. The SBO evaluations will provide real-time feedback on unsafe
actions and conditions, on a regular basis,to the work crews. Following the observation and feedback
session,the SBO form will be returned to the SHSO for evaluation and record keeping. Copies of all
SBO forms will also be submitted to the TRS HSO for review. These evaluations will be conducted
as site conditions and activities warrant. SBOs will not be completed when only one person is present
on the project site.
10.0 ROLES, RESPONSIBILITIES, AND AUTHORITY
TRS has established an organizational structure for providing technical direction and administrative
control to accomplish safety and quality-related goals on this project. The key health and safety
officers for the project are identified below:
• TRS PM: Drew Small
• TRS SHSO: Steve Pistol
• TRS Corporate HSO: Mick Brown
A copy of the HASP will be provided to subcontractors who will have personnel working on site. At
the time of mobilization to the Site,the SHSO will confirm that they understand the overall safety and
health objectives for the project. The SHSO will have the authority to ensure all personnel on site
follow the health and safety procedures set forth in the HASP.
10.1. Project Manager
The TRS PM has overall responsibility and authority to direct technical,management, and contractual
matters for those portions of the project under the supervision of TRS. The PM is required to
effectively communicate site risks and the requirements of the HASP to TRS's employees, TRS's
subcontractors,and those on-site personnel being supervised by TRS while they are performing
project-related activities.
The TRS PM has the following additional responsibilities:
• Serve as the primary contact with the client or the client's representative.
• Establish appropriate health and safety procedures for TRS's on-site activities.
MUR55 HASP 052114 ad 36 TRS

• Ensure that project staff is properly trained.
• Enforce health and safety requirements, and determine disciplinary actions for violations of
the plan.
• Ensure that necessary permits for TRS's activities have been obtained prior to starting field
work.
• Ensure that required field personnel attend health and safety briefings and tailgate
meetings.
• Review and update the HASP.
• Participating in incident investigations.
10.2. Site Health and Safety Officer
The TRS SHSO is responsible for documenting that the designated procedures of this HASP are
implemented in the field by TRS employees,TRS subcontractors, and others participating with TRS
in the completion of project tasks under the management of TRS. In some cases the SHSO role may
be filled by the TRS PM.
The TRS SHSO will serve as the on-site point of contact for all health and safety matters related to
work being performed, or supervised by, TRS. The TRS SHSO will provide technical information
regarding health and safety to site personnel. The TRS SHSO will also oversee TRS's site activities
with respect to Health and Safety issues and will stop work if conditions are determined to be
detrimental to site personnel or the environment.
The TRS SHSO has the following responsibilities for site activities under the direction or supervision
of TRS:
• Ensure that all known tasks assigned to TRS,the hazards associated with those tasks, and
protective controls required for those tasks have been identified.
• Ensure that only personnel qualified in accordance with applicable health and safety
requirements are allowed to perform field work.
• Ensure that only qualified individuals are allowed access to site locations or operations
where potential hazards exist.
• Conduct documented inspections of TRS's work activities.
• Stop work and remove personnel from the field if personnel or the environment are
jeopardized by work activities.
• Provide project-specific training to new employees and visitors.
• As required,participate in daily tailgate health and safety meetings.
• Ensure that employees know the location of safety equipment, such as fire extinguishers
and first aid kits, and that this equipment is kept current.
• Ensure that proper chemical and safety postings are in place and legible.
• Ensure that all operations are conducted in a manner to mitigate adverse environmental
impacts.
• Ensure that work practices promote behavior based safety including the performance of
SBOs,recognition and correction of unsafe behaviors, and reporting of near-miss and
incident events.
• Post and keep current all employee right-to-know information.
MUR55 HASP 052114 ad 37 GTRS

• Establish and maintain the hazard communications program, including MSDS and training
materials.
• Evaluate the site for any hazards not identified in the HASP and initiate safety measures to
protect personnel, including appropriate revisions to health and safety documents.
• Immediately report incidents in accordance with this HASP and TRS procedures.
• Coordinate with off-site emergency responders and medical service organizations to
establish required emergency services and verify that emergency phone numbers and
addresses are current and accurate.
10.3. Field Personnel
Field personnel are responsible for performing work in a safe and healthful manner. They are
responsible for abiding by the requirements of the HASP, and for fulfilling and maintaining their
individual training and medical surveillance programs. If there are concerns that implementation of
work orders or health and safety requirements would unreasonably compromise the safety or health of
an individual or the environment, such concerns should be brought to the attention of an immediate
supervisor or the SHSO. Field personnel are responsible for the following:
• Abide by the requirements of this HASP.
• Take all reasonable precautions to prevent injury to themselves and to their fellow
employees;being alert to potentially harmful situations.
• Perform only those tasks for which they have been trained and believe they can do safely,
and immediately report any accidents,near misses, and/or unsafe conditions to the SHSO.
• Notify the SHSO of any special medical conditions(i.e., allergies, contact lenses,
pregnancy, diabetes, etc.) and, if necessary, ensure that all on-site personnel are aware of
the condition.
• Prevent spillage to the extent possible. If a spill occurs, contain the spillage and clean-up
immediately using safe cleanup measures as directed by the SHSO.
• Practice good housekeeping at all times.
• Immediately report all injuries.
10.4. Subcontractors
Subcontractors are responsible for establishing, implementing, and maintaining a health and safety
program for their employees. Subcontractors are responsible for performing work activities in a safe
and healthful manner in accordance with both the subcontractor's health and safety program and this
HASP. In the event that the event that the subcontractor health and safety program conflicts or differs
from this HASP,the SHSO and PM will review the program components with the subcontractor's
safety representative and develop the best approach to project tasking.
10.5. Stop Work Orders
When any employee observes a condition of"imminent danger"or unsafe work conditions at the
work site,that employee can exercise Stop Work Authority. Imminent danger means a condition or
hazard that would reasonably be expected to cause death or serious harm to workers or members of
the public,damage to equipment or property, or result in an unplanned release to the environment.
Examples of unsafe work conditions can include,but are not limited to:
MUR55 HASP 052114 ad 38 GTRS

• Operation of drill rig too close to overhead power lines.
• Air monitoring detection at or above OSHA 8-hr TWA or IDLH limits.
• Unsafe operation of heavy equipment.
• Failure of workers to wear proper safety equipment.
Should an employee exercise Stop Work Authority,the TRS SHSO will be notified immediately.
11.0 TRAINING
Due to the nature of the work to be performed on site, special training will be required based on the
activity performed. Training records for all Site personnel will be maintained in the on-site copy of
the HASP as Appendix E.
11.1. General Hazardous Waste Operations Training
To protect site personnel from exposure to chemical hazards, it is possible that EZs will be
established to contain contaminated materials and will be in place during the duration of each phase
of the project. Before Site personnel or visitors may enter an EZ or complete subsurface invasive
work activities or perform tasking which has the potential for contact with hazardous materials,they
will be required to have successfully completed the following training:
• Initial 40 hours of HAZWOPER training as required under 29 CFR 1910.120.
• Eight hours of HAZWOPER refresher training annually as required by 29 CFR 1910.120.
• Three days actual field experience under the direct supervision of a trained, experienced
supervisor.
Visitors and site personnel, such as surveyors and electricians,who must enter the site but will not be
entering EZs or performing any subsurface invasive work will not require HAZWOPER training in
accordance with 29 CFR 1910.120.
Before a site worker or visitor may enter an EZ,their employer must provide the SHSO with a
certification showing that the worker or visitor has completed their HAZWOPER initial and refresher
training. These certifications will be maintained in an on-site file and be available for review.
The SHSO understands TRS's safety and health program and will be trained in TRS's PPE,ERH
operations, LOTO procedures, spill containment,hot media sampling procedures,and health hazard
monitoring procedures and techniques.
11.2. Electrical Safety Training
Prior to working on site during TRS ERH operations,TRS personnel who intend to enter the ERH
restricted zone must complete the following electrical safety requirements:
• Read and understand the TRS Electrical Safety Policy.
• Read and understand the TRS Working Alone Policy.
• Complete Electrical Safety NFPA 70E Arc Flash Training.
• Complete TRS training on LOTO procedures as described in SOP 1-1.
MUR55 HASP 052114 ad 39 TRS

• All on-site personnel involved with ERH operations will receive site-specific LOTO
training. This training will include emergency ERH shutdown procedures.
• Complete the site-specific TRS ERH electrical restricted zone training and sign the
acknowledgement form included in Appendix A.
No TRS personnel shall work within high voltage panels(greater than 600 volts) at any time.
11.3. Crane and Lift Truck Operator Training
Only appropriately trained heavy equipment operators may operate heavy equipment,this includes lift
trucks. Specific to tasking anticipated at the Site,only operators trained and certified in accordance
with 29 CFR 1926.1427 shall operate a crane. Only personnel trained in accordance with 29 CFR
1910.178 will operate lift trucks. Crane and lift truck operators must present copies of training
documentation to the TRS SHSO prior to commencing any lift.
11.4. Respiratory Training
Any personnel using a respirator will be trained and fit tested in accordance with TRS respiratory
training program included as Appendix D of this document.
11.5. Competent Person Training
Certain activities or safety procedures at a construction site require design, inspection or supervision
by a competent person. The OSHA Construction Standard defines a competent person as someone
who is capable of:
1. Identifying existing and predictable hazards in the surroundings, or
2. Identifying working conditions which are unsanitary,hazardous,or dangerous to employees,
and
3. Authorizing the implementation of prompt corrective measures to eliminate hazards.
Unless otherwise noted in the Daily Tailgate Health and Safety Meeting,the SHSO will serve as the
Competent/Qualified Person to complete the following health and safety requirements:
• General safety and health.
• Safety training.
• Fire protection and prevention.
• PPE.
• Noise exposure.
• Gases,vapors, dusts, and mists.
• Hazard communication.
• HAZWOPER.
• Waste disposal.
• General electrical.
• Lockout/Tagout.
• Fall protection and ladder safety.
• Motor vehicle safety.
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During the Daily Tailgate Health and Safety Meeting,TRS and on-site subcontractors will identify
the site-specific competent persons required to complete daily tasking. Competent persons are
required for the following anticipated Site activities:
• Rigging.
• Electrical.
• Aerial lifts.
• Cranes or hoists.
• Powered industrial trucks(forklifts).
• Excavations.
• First aid and medical.
• Signaling.
11.6. Other Training
Personnel involved in the transportation of hazardous material will be trained in accordance with 49
CFR 172 Subpart H.
All personnel operating electric and or pneumatic tools will receive training on their use.
11.7. Medical Surveillance
The expected duration of the project is estimated to be nine to twelve months. Exclusion zones will be
established to contain contaminated materials and to protect Site personnel and visitors from exposure
to chemical hazards. It is possible that these zones will be in place during the duration of the project.
Personnel working on this project who enter such EZs will be required to participate in a medical
monitoring program that meets the requirements of 29 CFR 1910.
11.7.1. Medical Examination Requirements
OSHA suggests that a baseline medical monitoring program contain the components listed below.
• Medical History/Physical.
• Audiometry.
• Respirometry.
• Vision by Machine.
• Urinalysis.
• Blood Chemistries.
The employer of each site personnel or visitor who enters an EZ will be required to provide the SHSO
with a signed letter stating that the employee currently participates in a medical monitoring plan that
meets the requirements of 29 CFR 1910 and has passed a respirator fit test within the last 12 months.
The employer will also provide the SHSO with a letter or certificate signed by physician or other
licensed healthcare professional stating that the employee is physically fit to perform the work duties
assigned to him or her and has medical clearance to use a respirator. These documents must be
provided to the SHSO and filed for review before the employee will be allowed to enter an EZ.
Copies of TRS site personnel medical clearance documents are provided in Appendix E.
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11.7.2. Exposure Monitoring
Any person exposed to high levels of hazardous substances will be required to undergo a repeat
medical surveillance examination at, or if necessary,before the conclusion of the project. Such an
examination will help determine the medical implications of the exposure. The type of surveillance
examination will be determined by the SHSO and TRS corporate HSO based on the exposure. Any
person suffering a lost-time injury or illness must have medical approval prior to returning to work on
site.
12.0 INCIDENT RESPONSE AND FIRST AID
In the event of an accident or emergency,the appropriate response is critical to minimize impact of
the event. Proper preparation by maintaining the emergency call list and first aid supplies are vital to
providing the appropriate response.
12.1. Personnel Roles,Lines of Authority and Communication System
A list of emergency and site contacts is contained in Table 4. The list of emergency contacts will be
kept on site with the acting SHSO and posted inside the PCU office.A cellular phone will be kept on
site with the PM or the SHSO for emergency situations.
Table 6.Emergency Contacts.
Situation Response Agency Telephone Number
Emergency Fire/Police/Rescue 911
Police(Non-emergency) Murphy Police Department [phone]
Fire(Non-emergency) Murphy Fire Department [phone]
Medical Murphy Medical Center [phone]
Poison Control Carolinas Poison Control 1-[phone]
Chemical Release National Response Center [phone]
Company Name Telephone Number
Northrop Project Manager Kurt Batsel [phone]
TRS VP of Operations Tim Warner [phone]
TRS HSO Mick Brown [phone]
TRS Sr.PM Chris Blundy [phone]
TRS PM Drew Small [phone]
TRS SHSO Steve Pistol [phone]
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12.2. Hospital Directions
The directions to the hospital are provided in the HASP summary at the beginning of this document,
on Figure 1, and below.
Directions to the Medical Facility(Figure 1): Murphy Medical Center,Driving Distance: 4.9 miles,
Approximate Drive Time: 8 minutes
• Depart Slow Creek Dr.toward NC-141 Private • 46 ft.
Road
• Turn right onto NC-141 • 4.2 mi
• Turn left onto E US-64-ALT • 0.3 mi
• Keep straight onto Old Hwy 64 • 0.3 mi
• Turn left onto E US-64 • 315 ft.
• Arrive at 3990 E US-64,Murphy,NC 28906
12.3. Emergency and First Aid Equipment
Maintaining the proper emergency equipment and first aid supplies on site during construction and
operations are essential in preserving employee, sub-contractor and visitor health and safety.
A list of health and safety equipment to be kept on site is provided below:
One 10-pound dry chemical ABC rated fire extinguisher.
One 15-pound carbon dioxide fire extinguisher.
Air horn.
15-minute eyewash or portable eyewash bottles.
Potable water.
Safety glasses.
Eye goggles
Face Shields
Ear plugs.
Tyvek® suits.
Hard hats
Gloves-Nitrile.
Gloves—Neoprene
Spill kit
First aid kits stocked in accordance with ANSI Z308.1-2003:
At least one 32-square inch absorbent At least six applications of burn treatments,
compress(no side smaller than 4 0.5 grams (0.14 fluid ounces)
inches) Two or more pairs of medical exam gloves
At least 16 lx3 inch adhesive bandages, (latex or non-latex)
One roll of adhesive tape, 5 yards total At least four 3x3 inch sterile pads, One
At least ten packets of antiseptic, 0.5grams 40x4Ox56 inch triangular bandage
(0.14 fluid ounces)applications Additional(but optional)items include:
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Four 2x2 inch bandage compresses One 4x5 inch chemical cold pack
Two 30 inch bandage compresses Two 2-inch-wide roller bandages
One 4x4 inch bandage compresses One 3-inch-wide roller bandage
One eye patch CPR barrier device
One ounce of eye wash Red biohazard bags
12.4. On-Site Emergency Response
A first aid kit will be located on site and maintained by the SHSO. If an injured individual requires
attention beyond first aid,the individual will immediately be transported to the nearest emergency
medical facility. A map illustrating the route to Murphy Medical Center is shown in Figure 1.
Injuries,regardless of severity,will be reported immediately to the SHSO and TRS senior
management. Documentation of the incident will be completed in writing and submitted to the TRS
Corporate HSO within 24 hours.
12.5. Communication System
hi the event of an emergency, a blast from an air or vehicle horn(one blast, 5 seconds in duration)
will alert field personnel to stop work activities and meet at the Site construction/operations office.
Workers will be aware of and trained to alternate strategies when communication is reduced in high-
noise areas.
In the event of an injury, a member of the respective crew will contact the SHSO or PM directly or by
mobile telephone. The SHSO or PM will then contact the appropriate authority for medical care.
Internal communication will be used for the following:
• Alert team members to emergencies.
• Pass along safety information.
• Communicate changes in the work to be accomplished.
• Maintain site control.
Pre-arranged hand signals will be used for communication to employees wearing PPE,respirators,
etc. These hand signals will be interpreted as follows:
• Thumbs up -all clear.
• Grabbing wrist of personnel—evacuate.
• Hands on throat-help and/or choking.
Off-site sources may need to be contacted to get assistance or to inform officials regarding hazardous
conditions that may affect public or environmental safety(See Table 4 for Emergency Contacts).
13.0 INCIDENT REPORTING, FOLLOW-UP, AND INVESTIGATION
Site personnel and visitors will report all injuries, illnesses,property damage, spills/release to the
environment, and near misses,no matter how minor,to the SHSO immediately. To prevent
recurrence,every incident and"near miss"event must be investigated as soon as possible to find the
primary and contributing causes. A"near miss"is an unplanned event,which does not result in
personal injury, environmental release, or property damage but,in similar circumstances,likely could.
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If the conditions permitting the"near miss"or"close call"are not eliminated,they will continue to
contribute to the potential for future employee injury,property damage,or environmental release.
The following actions and reporting must be completed following an incident occurring at the project
site:
• Immediately secure the situation to prevent further damage and/or future incidents
• The SHSO will report the incident verbally to the PM and Corporate HSO as soon as it is
safe to do so.
• Within 24 hours of the incident,the TRS PM will notify the client PM of any injuries,
illnesses, spills, or property damage that occurred at the project site.
• Within 48 hours of the incident,the TRS PM will confirm that the TRS incident reporting
and investigation form has been completed. As most accidents involve unsafe conditions
and/or unsafe acts, it is the responsibility of the investigators to uncover the root causes of
the incident and develop action items to minimize the possibility of re-occurrence.
• Accidents that are recordable per OSHA requirements will be placed on the OSHA 300
logs of the appropriate company within six working days by the TRS HSO
• Government agencies will be notified as required. For example, if there have been any
fatalities or three or more hospitalizations,the TRS HSO will notify OHSA.
• The TRS HSO will ensure that any new incident that occurred at a TRS project site will be
reviewed by employees during division meetings and OSHA refresher courses.
14.0 RECORD KEEPING
TRS and its subcontractors must comply with OSHA record keeping requirements and standard TRS
record keeping. The following records and documentation will be maintained by TRS:
• On-site training documentation.
• Incident and near miss documentations/investigations.
• Inspections and audits.
• Heavy equipment inspections.
• Daily tailgate meetings
• Daily construction reports.
• Daily operations log.
• TRS Near Miss and Incident Reports
• The corporate HSO from each company involved in the project will maintain a Log and
Summary of Occupational Injuries and Illness on OSHA Form 300 for annual posting.
Relevant cases include:
• An occupational death.
• An occupational illness.
• An occupational injury that involves the following.
• Medical treatment other than first aid.
• Loss of consciousness.
• Restriction of work or motion.
MUR55 HASP 052114 ad 45 TRS

• Temporary assignment to another job.
• Days away from work other than the day of injury.
MUR55 HASP 052114 acf 46 TRS

Appendices
MUR55 HASP 052114 acf 47 TRS

TRS
Accelerating Value
Quality Assurance/Quality
Control (QA/QC) Plan
Electrical Resistance Heating
Former Clifton Precision Facility
Murphy, North Carolina
Issued: May 2014
TRS Group, Inc.
O Box 737
Longview,WA 98632 .n
www.thermalrs.corn —��� —

TABLE OF CONTENTS
1.0 INTRODUCTION......................................................................................................................3
2.0 BACKGROUND AND PROJECT TASK REQUIREMENTS.................................................4
3.0 DATA QUALITY OBJECTIVES..............................................................................................5
3.1.1 INTENDED USERS OF DATA......................................................................................................5
3.1.2 INTENDED USES OF ACQUIRED DATA......................................................................................5
3.1.3 DATA QUALITY INDICATORS...................................................................................................5
4.0 PROJECT ORGANIZATION AND RESPONSIBILITIES......................................................8
5.0 DATA GENERATION AND ACQUISITION..........................................................................9
5.1.1 FIELD DATA COLLECTION.......................................................................................................9
5.1.2 LABORATORY DATA COLLECTION........................................................................................10
5.1.3 GROUNDWATER SAMPLING...................................................................................................10
5.1.4 SOIL SAMPLING......................................................................................................................11
5.1.5 VAPOR SAMPLING..................................................................................................................11
6.0 TRS TRAINING REQUIREMENTS.......................................................................................11
7.0 PROJECT DOCUMENTATION AND RECORDS................................................................11
7.1.1 SITE ACTIVITY RECORD KEEPING.........................................................................................12
7.1.2 FIELD DATA FORMS...............................................................................................................12
7.1.3 CALIBRATION RECORDS........................................................................................................12
8.0 REFERENCES.........................................................................................................................12
List of Tables
Table 1. System Operations and Monitoring Schedule..........................................................................9
List of Figures
Figure1. Site Location Plan...................................................................................................................3
List of Appendices
Appendix A. Standard Operating Procedures
3.1 Internal Hot Groundwater Sampling
3.2 Internal Soil and Groundwater Sampling
3.3 Vapor Sampling Post Condenser
4.3 External Hot Soil Sampling
4.7 External Hot Groundwater Sampling
Appendix B. Health and Safety Plan
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Appendix C. 2011-0214-Murphy-Final QAPP Submittal
Abbreviations and Acronyms
AHA Activity Hazard Analysis
APM Assistant Project Manager
COC chain-of-custody
CRA Conestoga-Rovers and Associates
DNAPL dense non-aqueous liquid
ERH electrical resistance heating
FSK Field Sampling Key
GC/MS Gas Chromatography/Mass Spectrometry
Northorp Grumman Northrop Grumman Guidance and Electronics Company, Inc.
HASP Health and Safety Plan
PCU Power Control Unit
PM Project Manager
ppb parts per billion
QA Quality Assurance
QC Quality Control
RPD Relative Percent Difference
SHSO Site Health and Safety Officer
SPM Senior Project Manager
SOP Standard Operating Procedure
SRL Sample Reporting Limit
SSOW Simplified Scope of Work
TRS TRS Group,Inc.
USEPA United States Environmental Protection Agency
VOC volatile organic compound
LOINTRODUCTION
The TRS Group, Inc. (TRS)has entered into a contract with Northrop Grumman Guidance and
Electronics Company,Inc. (Northrop Grumman)to perform Electrical Resistance Heating(ERH) in
the source area at Waste Management Unit WMU-B of the Former Clifton Precision Facility located
in Murphy,North Carolina. ERH is an in situ thermal process for the remedial treatment of volatile
organic compounds(VOCs)in soil and groundwater.
This Quality Assurance/Quality Control Plan(QA/QC Plan)has been developed to provide the
methodology and procedures for training, system monitoring, sampling, and data management of an
ERH system at the Former Clifton Precision Facility(herein referred to as the "Site").
MUR55 QAQC 051914 ad 3 GTRS

This QA/QC Plan provides a comprehensive framework for obtaining analytical and field
measurement data of known quality during the ERH project. The overall objective of this QA/QC
Plan is to insure collection of appropriate data to allow timely evaluations and decisions regarding
project progress and ERH system operations. The QA/QC Plan is required reading for all staff
participating in ERH field activities at the site. The QA/QC plan is intended for ERH system specific
data collection and is a supplement to the 2011-0214-Murphy-Final QAPP Submittal document. The
QAPP submittal will take priority over the QA/QC plan for any overlapping information, guidelines,
restrictions or instructions.
2.0 BACKGROUND AND PROJECT TASK REQUIREMENTS
The Site is located in Murphy,North Carolina. Figure 1 is a general vicinity map showing the Site
location.
SUE
� P
SITE LOCATION MAP M
Figure 1.
Detailed descriptions of the site-specific investigation and remediation activities including the project
objective, sampling locations,number and frequency of samples, and schedules of planned activities
will be included in the Design Report prior to field implementation.
The scope of services to be performed by TRS during the project will include,but is not limited to:
• Design site-specific ERH treatment systems based on treatment volume and remedial goals.
• Prepare Design Report and Project Schedule, Site-Specific Health and Safety Plan (HASP)
and QA/QC Plan for submittal.
• Provide technical oversight for installation of ERH subsurface and surface components.
• Complete surface installation of ERH treatment system.
• Ensure system readiness through system shakedown and startup evaluation.
MUR55 QAQC 051914 ad 4 GTRS

• Monitor ERH system parameters daily and optimize system as necessary.
• Provide technical guidance and assistance as needed with sampling and analysis of soil,
groundwater, condensate, and air.
• Quality control of field activities.
• Decommissioning of ERH treatment system.
• Preparation of reports.
3.0 DATA QUALITY OBJECTIVES
Data Quality Objectives are qualitative and quantitative statements that clarify technical and quality
objectives describe the intended use of the data, define the appropriate type of data needed to support
project decisions,identify the conditions under which the data should be collected, and specify the
tolerable levels of decision errors due to uncertainty in the data.
3.1.1 Intended Users of Data
The laboratory data and field screening data gathered during all phases of this project will be a
collaborative effort of the project team which includes;Winter Environmental,TRS, and the
analytical laboratory. Data collected for this ERH project will be posted to an electronic repository.
Both the TRS project team and oversight team will have access to analytical data and field screening
data including subsurface temperature data,groundwater measurement data, and ERH system
operational data that includes voltage, current,power, and energy data. This data will be delivered to
the oversight team via weekly status reports.
3.1.2 Intended Uses of Acquired Data
TRS will analyze air samples to measure the composition and mass of VOCs removed from the
subsurface during remediation in order to determine the point of diminishing returns at the condenser
effluent line.Air discharge stack effluent samples will be analyzed to test for regulatory compliance
of the air emissions abatement equipment. The inlet and effluent air streams will be monitored weekly
during ERH operations.
The analytical laboratory will analyze soil and groundwater samples to measure the composition and
mass of VOCs removed from the subsurface and confirm that remedial goals defined in the Design
Report have been met. All samples will be sent to a laboratory specified by Conestoga-Rovers and
Associates(CRA),who serves as Northrop Grumman's laboratory and database mangement
company.All samples will be analyzed as described in the 2011-0214-Murphy-Final QAPP Submittal
document.
Subsurface temperature data and ERH system operational data will be reviewed daily by TRS
personnel to determine system operational efficiency. Data will be used to determine modifications
required to optimize heating throughout the treatment volume. Data will also be used to optimize the
recovery and treatment of steam and contaminant vapors.
3.1.3 Data Quality Indicators
The measurement data must be of a type that can comply with the project-specific and task-specific
tolerances for precision, accuracy,representativeness,comparability, completeness, sensitivity, and
selectivity. The project-specific data quality indicators are not intended as absolute standards used to
MUR55 QAQC 051914 ad 5 GTRS

accept or reject analytical data,but rather to establish a standard for complete and unqualified
usability, and to allow identification of data that must be qualified to identify limitations in usability.
Data analysis will involve use of data from an off-site laboratory and collection of on-site data using
meters, instruments, and other hand-held or automatic measuring devices.
Precision
Precision is a measurement of random error expressed in terms of analytical variability and may be
used to assess both analytical and sampling contributions to overall error. Precision is also affected by
natural matrix variation and the distribution of a constituent within the sample matrix. For chemical
analyses that do not allow for sample homogenization prior to analytical sub-sampling(e.g.,volatile
organic analysis),precision values must be interpreted with an understanding that the result is
representative of a single point in space and time, and may not be reflective of the true average
concentration. In order to assess the effect of matrix heterogeneity or sample handling procedures, the
collection of replicate samples may be necessary for both field and laboratory samples. Alternately,
collection of a larger number of primary field samples may help to reduce error in the estimated
mean.
Accuracy
Accuracy is used as a synonym for bias, or systematic error, and is the amount of agreement between
a measured value and the true value. Accuracy includes a combination of random error and systemic
error components that result from sampling and analytical operations. Accuracy can be improved by
following good sampling and measurement practices. Accuracy for analytical samples will be
assessed by the analytical laboratory through determination of percent recoveries for laboratory
control samples as described in 2011-0214-Murphy-Final QAPP Submittal document. Accuracy in
the field will be ensured by following all standard operating procedures (SOPS) for hot soil and
groundwater sampling procedures.
Representativeness
Representativeness is the degree to which data accurately and precisely represents a parameter
variation at a sampling point or an environmental condition. Samples that are not properly collected
or preserved or are analyzed beyond acceptable holding times may not provide representative data.
Representativeness is a parameter that is primarily concerned with the proper design of the sampling
program and an assessment of representativeness would include an evaluation of precision in the field
and laboratory duplicate samples. Representativeness can also be improved by collection of a larger
number of samples.
The representativeness criterion is best satisfied in the laboratory by making certain that all sub-
samples taken from a given sample are representative of the sample as a whole. This includes sample
premixing/homogenization prior to and during aliquot procedures. All sampling procedures are
discussed in the 2011-0214-Murphy-Final QAPP Submittal document.
Comparability
Comparability is the degree to which data from one study can be compared with data from other
similar studies,reference values (such as background),reference materials, and screening values.
Comparability of laboratory results will be achieved by using the standard techniques to collect and
analyze representative samples,by reporting analytical results in appropriate units,using traceable
reference materials,using Class A volumetric glassware or correctly calibrated pipettes for volumetric
MUR55 QAQC 051914 ad 6 GTRS

procedures,using correctly calibrated balances for gravimetric procedures, and following good
laboratory practices.
There will be strict adherence to method QC and procedural requirements or proper documentation of
any deviations from the analytical methods. If undocumented method deviations are discovered
during data quality review,the QC officer(laboratory)will evaluate the potential effect on data
usability and comparability and will contact the laboratory for corrective action.Notification of
corrective action will also be made to the appropriate project staff.
When performance-based methods such as field analytical techniques are employed, comparability
becomes a critical data quality indicator. If comparability between standard methods and
performance-based methods has not been demonstrated, a project-specific percentage of duplicate
(split) samples for analysis by the standard reference method should be included. This allows an
assessment of comparability between data sets by calculating the relative percent difference(RPD)
and determining the usability of the performance-based method in supporting project decision-
making. These data items are intended for internal project use.
During groundwater sampling events conducted at the Site, all methods will adhere to the protocol as
described in the 2011-0214-Murphy-Final QAPP Submittal document.
From a data collection standpoint, staff familiar with the specifics of this project and previous data
collection techniques will be utilized when possible. This will further limit another variable and allow
the comparability of the data to be maximized.
Completeness
Completeness is defined as the percentage of usable data out of the total amount of data generated.
Analytical completeness is a measure of the number of overall accepted analytical results (valid
results), including estimated values,compared to the total number of analytical results requested on
samples submitted for analysis after review of the analytical data. Less than 100 percent completeness
could result if sufficient chemical concentrations exist to require sample dilutions,resulting in an
increase in project-required detection/quantitation limits for some parameters. Highly contaminated
environments can also be sufficiently heterogeneous to prevent the achievement of specified precision
and accuracy criteria.
Rejection of data due to severe matrix interference is sometimes unavoidable. The project contract
laboratory and the QC officer(laboratory)will make every effort to minimize matrix interference
problems by selection of additional cleanup procedures or alternate analytical procedures if possible.
The project laboratory is expected to pay careful attention to analytical procedures and method
requirements, and to implement corrective actions to avoid rejection of results.
Sensitivity
As used in this context, sensitivity refers to the ability of project analytical procedures to identify and
quantify target analytes at concentrations low enough to meet project data needs. A specific indicator
of sensitivity in analytical measurements is the sample reporting limit(SRL).
The SRL represents the lowest concentration of an analyte that can be reported with reasonable
quantitative accuracy in a particular sample. Examples of the laboratory reporting limit for
tetrachloroethene,trichloroethene,1,1,1-trichloroethane;1,1-dichloroethene,1,1-dichloroethane and
MUR55 QAQC 051914 ad 7 GTRS

cis-1,2-dichloroethene is 0.5 parts per billion(ppb). The laboratory reporting limit for Freon-113,
Freon-12 and 1,4-dioxane is 5 ppb. The reporting limit for acetone is 50 ppb.
Selectivity
Selectivity is the ability of an analytical procedure to accurately identify an analyte and to distinguish
that analyte from interferences. In order to ensure that project data needs are met,the analytical
laboratory will typically use gas chromatography/mass spectrometry(GC/MS),which eliminates the
need for second column confirmation analysis,to analyze the air and water samples for organic
compounds. The project laboratory must also maintain their analytical systems in proper working
procedure by following the preventative maintenance schedules outlined in their individual Quality
Systems Manuals, and that method requirements for confirmation are strictly followed. Proper
compound identification will be monitored during data validation and the project laboratories will be
required to provide additional explanation for any questionable compound identification. It is
expected and required that the laboratory will appropriately flag the data generated from a response
that does not meet the required identification criteria as being only presumptively identified.
4.0 PROJECT ORGANIZATION AND RESPONSIBILITIES
TRS has established an organizational structure to provide overall technical and administrative
management control to accomplish project tasks and related quality objectives. The organizational
structure for the project,and descriptions of team members various responsibilities are summarized
below:
Project Manager(PM): Drew Small,the PM, is responsible for the safe completion of all work
performed to achieve the desired results of the contract specifications related to the implementation
and execution of ERH at the site. The PM will develop, approve, and implement the site-specific
design report. The PM is responsible for the overall remediation activities at the site and ensuring
personnel safety throughout all phases of ERH activities. The PM will also provide technical
guidance to the project team and manage the preparation of all project deliverables. The PM reports
directly to the Senior Project Manager(SPM) and serves as the primary TRS contact to Northrop
Grumman.
Assistant Project Manager(APM): The APM is responsible for supporting the Project Manager in
achieving the desired results of the contract specifications and the overall remediation activities at the
site. The APM reports directly to the PM on all project-related matters.
Senior Project Manager(SPM): Chris Blundy is the SPM for this ERH project and reports to the
Vice President of Operations for TRS. Mr. Blundy is responsible for all administrative and technical
aspects of the project.
Vice President of Operations: Tim Warner is Vice President of Operations for TRS and is
ultimately responsible for TRS performance and overall remediation activities at the site.
Project Engineer: Jake Seeman is responsible for the design of the in-situ ERH system and will
support the PM to ensure that all treatment related goals of the contract specifications are attained.
Mr. Seeman works directly with the PM and reports to the Principal Engineer.
Principal Engineer: Greg Beyke is responsible for the overall design of the in-situ ERH system, and
will ensure that all treatment related goals of the contract specifications are attained.
MUR55 QAQC 051914 ad 8 GTRS

Site Health and Safety Officer(SHSO): The SHSO is responsible for assisting the PM with the
development of safe approaches to project tasking and determining personnel training expectations
have been met for all aspects of ERH activities,including electrode construction,installation, and
operation. The SHSO reports to the PM and also to the Corporate Health and Safety Officer(HSO)
regarding matters of Health and Safety.
Corporate Health and Safety Officer(HSO): Mick Brown,the HSO, is responsible for
implementing the TRS corporate Health and Safety Program. This includes review of site-specific
HASPS,review of SOPS,maintaining employee training records, and oversees incident reporting and
investigating.
Laboratory Requirements: Laboratory data will be produced using rigorous preparatory and
analytical methods such as U.S. Environmental Protection Agency(USEPA)reference methods.
Analyte presence and quantitation are confirmed through extensive QC procedures performed at the
laboratory. To generate data of sufficient quality for monitoring and quality,protocols have been set
forth in the 2011-0214-Murphy-Final QAPP Submittal document.
5.0 DATA GENERATION AND ACQUISITION
5.1.1 Field Data Collection
Some information may be collected electronically using data loggers and/or analog meters and
totalizers. Temperature data from the thermocouples will be collected electronically on a daily basis
and transferred to project databases. Pressure or vacuum data will be collected both manually.
Manual collection and recording of key data parameters will be monitored and measured during the
operation of the ERH system. These parameters will be used to ensure proper operation of the ERH
system and to assess overall performance. Personnel will evaluate the data each day to confirm
accurate data collection and determine operational efficiency.
During operations, TRS personnel will be on site to perform routine equipment maintenance and
review system performance. Routine system checks and a preliminary monitoring schedule are shown
in Table 1.
Tablel. System Operations and Monitoring Schedule
Operation/Maintenance Item Performance Schedule Performed By
Subsurface Temperatures Daily TRS
ERH Voltage, Current, and Power Daily TRS
Energy Input Daily TRS
Vapor Stream Concentration Weekly TRS
Applied Vacuum Daily TRS
Total VR System Airflow Daily TRS
Individual Electrode Currents Daily during start up and weekly TRS
Hours of operation thereafter TRS
MUR55 QAQC 051914 ad 9 GTRS

System Uptime Daily TRS
Groundwater levels Weekly TRS
Groundwater extraction rate 3 Times weekly TRS
Recovered DNAPL quantity When applicable TRS
Influent samples/soil Weekly TRS
gas/groundwater
Note: TRS may elect to contract with an environmental vendor for compliance sampling.
DNAPL—dense non-aqueous phase liquid
5.1.2 Laboratory Data Collection
The field sampler is personally responsible for collection and handling of all samples until they are
transferred to the laboratory or courier.As few people as possible should handle the samples. Sample
container labels will clearly identify the particular sample, and should include the following:
• Facility name and sample ID
• Time and date sample was taken
• Sample preservation
Analysis requested
• Matrix
Field sample identification numbers for the project will be established in consultation with Northrop
Grumman oversight team. Where possible, adhesive-backed labels for sample containers and chain of
custody forms will be pre-printed by the laboratory, and submitted to the site with the empty sample
containers,coolers and shipping materials. TRS will coordinate with CRA at least 14 days in advance
of sample activities. A Simplified Scope of Work(SSOW)will be submitted to CRA 14 days prior to
sampling. CRA will then establish a project-specific purchase order with the selected analytical
laboratory based on the SSOW. Sample information that has not been pre-printed on the label will be
completed for each sample using indelible ink. Within 5 business days of sample collection, a field
sampling key(FSK)will be submitted to CRA. The FSK is part of CRA's database management
protocol for documenting analytical sampling data.
Sample coolers will be shipped from the field and dispatched to the appropriate laboratory for
analysis,with a separate signed chain-of-custody(COC)record enclosed inside a bag and secured to
the inside lid of each cooler. TRS will maintain a copy of the COC in the power control unit(PCU)
office files.
Liquid and solid samples requiring temperature preservation will be properly packaged in insulated
coolers with sufficient wet ice to maintain the preservation temperature at 4 degrees Celsius(°C)f
2°C during shipment to the laboratory. Temperature bottle blanks will be supplied by the laboratory
and placed in each cooler(for samples requiring temperature preservation)prior to shipment to the
laboratory to provide a mechanism for measuring the temperature of the samples upon receipt at the
laboratory.
5.1.3 Groundwater Sampling
Groundwater sampling will be conducted prior to ERH, during ERH operations, and following the
completion of ERH operations to determine remedial progress and goal completion. TRS has
developed a hot groundwater sampling technique that is primarily based on low-flow purge and
MUR55 QAQC 051914 ad 10 OTRS

sample method. The hot groundwater sampling technique developed by TRS is described in the SOP
document provided in Appendix A. TRS SOP 4.7 provides technical guidance for non-TRS personnel
conducting hot groundwater sampling. TRS personnel directly performing hot groundwater sampling
will be trained in accordance with TRS internal SOP 3.1.
5.1.4 Soil Sampling
Soil sampling may be conducted of the heated subsurface during ERH operations and following the
completion of ERH operations to determine remedial progress and goal completion. Soil samples may
be collected using a variety of methods, including a hand auger, GeoprobeO sampler,hollow-stem
auger, split-spoon sampler,or direct from an excavator bucket.
TRS SOP 4.3 provides technical guidance for non-TRS personnel conducting hot soil sampling. TRS
personnel directly performing hot soil sampling will be trained in accordance with TRS internal SOP
3.2.
5.1.5 Vapor Sampling
Vapor sampling will be performed to evaluate system performance and mass removal. TRS personnel
directly performing vapor sampling will be trained in accordance with TRS internal SOP 3.3.
6.0 TRS TRAINING REQUIREMENTS
In addition to standard ERH operations training, TRS requires each person working on-site to read the
TRS Site-Specific HASP and be trained in accordance with the ERH restricted zone training
acknowledgment form. These forms are provided in Appendix A of the TRS HASP.
TRS SOPs are provided to every TRS employee during his first three days of on-site training under a
trained Site Supervisor. Site-specific Activity Hazard Analysis(AHA) are provided to every
employee on their first day of work at a site.All employees are given time to read and ask questions
with regards to the SOPS and AHAs before any assigned work. TRS also requires their employees to
review the SOPS and AHAs when the employee switches task while working on the site. TRS has
empowered their employees to stop work and address any unsafe situation that may arise during
construction and operation of the ERH system. Copies of the Gates Perforating Company Facility
AHAs related to ERH tasking have been provided in Appendix B of the HASP.
7.0 PROJECT DOCUMENTATION AND RECORDS
TRS will monitor system performance,using a PC interfaced to the PCU. Based on the collected data,
TRS can adjust the applied voltage to the electrodes as needed to meet the remedial goals in the most
energy-efficient manner. The PCUs will be monitored and controlled locally during site visits and
remotely by an internet connection when TRS personnel are away from the site. This allows system
adjustments to be made in real-time, even if TRS personnel are not on site.
In addition to monitoring the operating parameters of the PCU, subsurface temperature measurements
are a valuable performance metric during heat-up and operational phases of the project. Subsurface
temperatures are recorded at least once per day throughout the operations portion of the project. The
data is then used to develop subsurface temperature profiles to show temperature versus time and
temperature versus depth.
MUR55 QAQC 051914 ad 11 GTRS

Power,temperature, and operation data are recorded daily in an electronic database which is saved on
a central server. The database is reviewed by the SPM,the PM, and Project Engineer. Records of
applied power, energy, and subsurface temperatures are essential to the effective evaluation of system
performance and will be used to optimize the system performance throughout the project.
TRS is responsible for providing the appropriate equipment and data forms for the specific
operational tasks. The forms will be up-to-date with respect to parameters to be monitored, identify
the monitoring locations, and operating requirements.
7.1.1 Site Activity Record Keeping
Notes regarding site operations will be a key source of documenting the field activities,although the
actual data collection might be done on a data form or electronically. TRS commonly utilizes
electronic format for record keeping of notes documenting site activities. TRS will update site notes
daily and save them electronically with other daily site data.
Information included in the site activity notes may include,but not be limited to,the following items:
Field observations relevant to the operation of the ERH systems;
Observations of site activities not covered under regular activities, including presence of
persons on-site not related to the sampling activities(subcontractors, agency representatives,
members of the press, and others), and actions by those people affecting task performance;
Information relevant to a change in scope or change in procedure;
Type and/or level of health and safety equipment used;
References to information on other field forms;
The site activity notes will be primarily used by the PM to complete status reports.
7.1.2 Field Data Forms
Data collected in the field will be recorded manually on paper. The field data to be collected will be
listed on the form and will be filled out as directed with the correct information. Field forms will be
submitted to the PM who will ensure that project personnel enter information into appropriate project
databases. The PM will also make sure that field information is kept on file at the Site as required by
the specifications for the project. Field Data Forms are contained as attachments to the site-specific
documents.
7.1.3 Calibration Records
All field screening instruments used by TRS in the field will have records of standard preparation and
instrument calibration data maintained. Calibration notes will either be maintained on field data
sheets prior to data collection or in the site-specific field notes.
8.0REFERENCES
TRS Group,Inc., May 2014 Design Report, Electrical Resistance Heating, Former Clifton Precision
Facility,Murphy, NC
TRS Group, Inc., MAY 2014.Health and Safety Plan (HASP), Electrical Resistance Heating,
Former Clifton Precision Facility,Murphy, NC
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Conestoga-Rovers and Associates, Quality Assurance Project Plan, 2011-0214 Murphy-Final QAPP
Submittal
MUR55 QAQC 051914 acf 13 TRS