FINAL WORK PLAN FOR TIME CRITICAL REMOVAL ACTION IN

FINAL WORK PLANfor the

TIME-CRITICAL REMOVAL ACTIONALONG THE PROPOSED WATER LINE

m the

VILLAGE OF BECKEMEYERBeckemeyer, Illinois

Prepared lorEPA Region V

On te ia ' f :'ASARCO

May 12, 1994

ENTACT

FINAL WORK PLAN

for the

TIME CRITICAL REMOVAL ACTIONALONG THE PROPOSED WATER LINE

in the

VILLAGE OF BECKEMEYERBECKEMEYER, ILLINOIS

PREPARED FOR

ERA REGION V

ON BEHALF OFASARCO

MAY 12, 1994

(214)580-1323 6025 Commerce *500FAX: (214) 550-7464 Las Colinas

METRO: (214) 751 0057 Irving, Texas "5063

TABLE OFCONTENTS

TABLE OF CONTENTS

1.0 BACKGROUND 1

1.1 Introduction 11.2 Project Objectives 21.3 Site History 21.4 Site Description 3

2.0 SITE MOBILIZATION 6

2.1 Site Specific Safety Plan for the Village of Beckemeyer 62.2 Pro-work Meeting 62.3 Site Control Measures 62.4 Office Trailer 62.5 Site Preparation 72.6 Personnel and Equipment Estimates 7

3.0 SAMPLING ACTIVITIES 9

3.1 Statement of Objectives 93.2 Sampling Activities Implementation Schedule 93.3 Sampling Procedures and Sampling Plan 93.4 Sample Shipping 173.5 Analysis 17

4.0 REMOVAL ACTIVITIES 18

4.1 Cleanup Criteria of Soils 194.2 Site Cleanup Activities • 194.3 Estimate of Time Required for Removal Activities 25

5.0 SITE RESTORATION/PROJECT CLOSEOUT ACTIVITIES 28

6.0 PROJECT MANAGEMENT AND PERSONNEL 29

6.1 Project Manager 296.2 Construction Superintendent 296.3 Construction Quality Assurance Officer 296.4 QA/QC Technicians 296.5 Regulatory Compliance 29

ENTACT, INC.

TABLE OF CONTENTS (cont.)31

6.6 Project Documentation and Record Keeping 316.7 Daily Activities Logs 316.8 Progress Reports 316.9 Record Keeping and Reporting

327.0 SITE CONSTRUCTION AND MEETINGS

327.1 Preconstruction Meeting 327.2 Pre-Final Inspection 327.3 Final Inspection 337.4 Final Report

ENTACT, INC.

SECTION I

V r i i a y e of BeckemeyerPipeline Proiect

Emergency Removal Work PlanPage '

1.0 BACKGROUND

7.7 Introduction

On Apri l 22. 1^4 an Adminis t ra t ive Order (ORDER) \\as issued b> the U S EPA (Docket NoVW-94-C-230) to the following parties for the purpose of requiring certain time critical removalactions at the Village of Beckemeyer site in Beckemeyer. Illinois:

• Circle Smelting CorporationASARCO, IncorporatedFederated Metals

This Work Plan will be utilized to conduct the work in compliance with requirements stated in theOrder. Work practices will also comply with applicable federal, state and local regulations.ENTACT. Inc. has been retained by ASARCO in order to comply with the Order and to prepareand initiate the Work Plan. The Order is provided as Appendix A to this Work Plan.

ENTACT, INC.

Village of BeckemeyerPipeline Project

Emergency Removal Work PlanPage 2

/. 2 Projec t Objec fives

The following objectives have been set for this time critical removal action:

EPA Issues Identified in the Order

Remove contaminated material potentially encountered during the Beckemeyer waterdistribution project;

Develop and implement a sampling and analytical program designed to identify contami-nated material along the water distribution line route;

Properly handle, store, and consolidate the contaminated material;

Provide adequate cover protection to consolidated contaminated material to preventexposure to the elements;

Provide dust suppression measures during removal of contaminated material and duringmanagement of the consolidated contaminated material; and

Develop a health and safety plan to prevent exposure to workers and local residents fromcontaminated material associated with the water distribution project.

Scope of Work

The scope of work for this time critical removal action is to excavate at least the uppertwo feet of the remaining length of the proposed water line route (48,000 feet). Theobjective of this scope of work is to remove contaminated material which will allow a saferoute for the water line to be placed. During excavation, the top and bottom of the trenchwill be field screened using an X-Ray Fluorescence (XRF) device to identify materialscontaining total lead concentrations in excess of 500 mg/kg (ppm). Identified contami-nated materials will be excavated and transported to the Circle Smelter for storage.

Duration of the Project

Excavation and identification of contaminated materials along the proposed water distri-bution line route is expected to be completed in 120 days. A detailed schedule is providedin Section 4 of this Work Plan.

1.3 Site History

The history of the Village of Beckemeyer and the Circle Smelter has been documented and isincluded in the Order attached as Appendix A of this Work Plan.

ENTACT, INC

1.0 BACKGROUND

7. 7 Introduction

i > ; ; \ ; - i , ; : : . ; ••••- ; an A J n i i m ^ r a t n c Order ( O R D E R ) âs issued h> the L S EPA ( D o c k e t V'\ \ \ - i M-( -2 .n l ) to the fo l lowing pa r t i e s tor the purpose of r e q u i r i n g certain t i m e c r i t i c a l r e m o v a lact ions at the Village of Bcckemc\cr s i t e in Bcckeme)cr. I l l inois

Circle Smelt ing CorporationASARCO. IncorporatedFederated Metals

Tins \ \ork P lan \ \ i l l be u t i l i z e d to conduct the uo rk in compliance u i t h requirements stated in UKOrder Work practices \ul! also comph \ \ i ih applicable federal, state and local regulationsENTACT. Inc has been retained b\ ASARCO in order to conipK u i t h the Order and to prepareand i n i t i a t e the Work P lan . The Order is p rov ided as Appendix A to this \Vork Plan

KNT-U T. I N C .



1.2 Project Objectives

The following objectives have been set for this time critical removal action.

EPA Issues Identified in the Order

Remove contaminated material potentially encountered during the Beckemeyer waterdistribution project;

Develop and implement a sampling and analytical program designed to identify contami-nated material along the water distribution tine route;

Properly handle, store, and consolidate the contaminated material;

Provide adequate cover protection to consolidated contaminated material to preventexposure to the elements;

Provide dust suppression measures during removal of contaminated material and duringmanagement of the consolidated contaminated material; and

Develop a health and safety plan to prevent exposure to workers and local residents fromcontaminated material associated with the water distribution project.

Scope of Work

The scope of work for this time critical removal action is to excavate at least the uppertwo feet of the remaining length of the proposed water line route (48,000 feet). Theobjective of this scope of work is to remove contaminated material which will allow a saferoute for the water line to be placed. During excavation, the top and bottom of the trenchwill be field screened using an X-Ray Fluorescence (XRF) device to identify materialscontaining total lead concentrations in excess of 500 mg/kg (ppm). Identified contami-nated materials will be excavated and transported to the Circle Smelter for storage.

Duration of the Project

Excavation and identification of contaminated materials along the proposed water distri-bution line route is expected to be completed in 120 days. A detailed schedule is providedin Section 4 of this Work Plan.

1.3 Site History

The history of the Village of Beckemeyer and the Circle Smelter has been documented and isincluded in the Order attached as Appendix A of this Work Plan.

ENTACT, INC.



1.4 Site Description

Site conditions, background, and environmental setting are detailed in the Order.

The general site location is provided in Figure I - I . As shown on the topographic map the Villageof Beckemeyer (elevation 455 feet MSL) is located on Old State Highway 50 approximately 2.5miles west of Carlyle in southern Illinois. Local topography slopes gently to the west towardBeaver Creek. East-west tributaries exist to the north and south of Beckemeyer and appear toaccept equal amounts of drainage from the Village.

Figure 1-2 is a map of the site which includes the Village of Beckemeyer as well as the CircleSmelter. The proposed path for the water line is also shown. It has been reported that wastematerials from the smelter were used as common fill material and structural subgrade throughoutthe Village of Beckemeyer. The focus of this time critical removal action is to provide a route freeof contaminated materials for the pipeline construction contractor. Therefore, excavation willoccur along the water line route shown in Figure 1-2.

ENTACT will excavate contaminated materials and transport them to the Circle Smelter forconsolidation and storage. The storage area at the Circle Smelter is also identified in Figure 1-2.This building has controlled access, a concrete floor and a competent structure that will protectthe contaminated material from the elements. This building will not be used for manufacturing,processing, or other industrial activities unless an appropriate protective barrier is placed betweenthe contaminated material and any proposed industrial activities.

ENTACT, INC.

Pipeimr Pfi ,. • ;Emergency Removal Wonc Plan

Page -i

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ENTACT, INC.

Figure 1 -1Topographic Map

Beckemeyer, IllinoisScale 1:13 333

IVILLAGE OFB E C K E M E Y E R NEW WATER LINE DIAGRAM

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SECTION II I

ut BeckemuyerPipeline Project


2.0 SITE MOBILIZATION

2.1 Site Specific Safety Plan for the Village of Beckemeyer

The site-specific Health and Safety Plan is presented in Appendix B.

2.2 Pre-work meeting

A pre-work meeting will be scheduled and an agenda arranged to provide information toASARCO, U.S. EPA On-Scene Coordinator, ENTACT, Village of Beckemeyer and other perti-nent contractors. Discussions will surround the details of the approved work plan. The partici-pants will each have the opportunity to read the approved plan and acknowledge the provisionsrelated to the Health and Safety Plan. Topics such as site organization, chain of command,channels of communication, emergency procedures, and evacuation routes will also be covered.

2.3 Site Control Measures

Work zones will be established and enforced near the work area. The safe zone will 'ot designatedas the area away from primary contamination and operations. This area will be designated assuch by the project manager. The Contamination Zone will be designated as the excavation.Additionally, the Exclusion Safety Zone will be established in the area surrounding the actualexcavation operations. Approximately fifty feet in front, fifty feet in rear, and twenty feet on eachside of the excavation equipment will be included in the Exclusion Safety Zone. The primaryreason for increased exclusion in this area is to prevent incidental entry into the path of theexcavation equipment. Decontamination zones will be established both for personnel and equip-ment. Personnel decontamination zones will be established to facilitate decontamination ofpersonnel after leaving the exclusion safety zone. Equipment decontamination zones will also beestablished to decontaminate equipment leaving the exclusion safety zone.

2.4 Office Trailer

ENTACT will establish an office trailer complete with electricity, phone, fax capabilities andcontrolled environment for computer terminals and printers. A work area will be provided for theEPA representative to facilitate interaction and communication. Restroom facilities will also belocated near the office trailer. The office trailer will be located adjacent to Village of BeckemeyerVillage Hall as shown previously on Figure 1-2.

ENTACT, INC.

Pipeline ProjectRemoval Work Plan

Page 7

2.5 Site Preparation

Care will be given to properly identify utilities and other possible hazards ENTACT will notifyall appropriate utilities prior to excavation. Additionally, residents in and near the work area willbe notified to allow for evacuation or other arrangements. Notification will consist of ENTACTconducting door-to-door visits to inform residents of excavation activities, schedules and neces-sary health and safety protocols. Engineering controls will be positioned and tested prior tobeginning excavation. Traffic barricades and a safety flagman will be used to control traffic.ENTACT vull also sweep the streets in the work area, as necessary

2.6 Personnel and Equipment Estimates

ENTACT is committing approximately five OSHA 29 CFR 1910.120 trained hazardous materialstechnicians to handle operations on site ENTACT participates in a RED CROSS CPR trainingprogram and several of the on-site personnel will be trained in first aid and CPR operationsEquipment will consist of excavators, front end loaders, street maintaining equipment, engineeringcontrols such as misters for dust suppression, dump trucks, and rubber tire backhoes. Additionalequipment \sill include XRF machines, sampling equipment, and decontamination equipment

ENTACT. INC.

Pipeline ProiectRemoval Wurk Plan

Page S

ENTACT, INC.

SECTION III



3.0 SAMPLING ACTIVITIES

3.1 Statement of Objectives

The following Sampling Activities Plan will be implemented at the Village of Beckemeyer in orderto delineate areas of contamination, guide Removal Action tasks, and verify that the action levelsfor the site have been achieved.

The remaining portion of the Village of Beckemeyer water main installation consists of approxi-mately 40,000 linear feet. This route will be excavated to a minimum of 2 feet by 2 feet. Theextent of the contamination along this zone has been delineated by several U.S. EPA samplingefforts and by a visual inspection performed by United Science Incorporated (USI). The results ofthese studies as well as the ENTACT sampling frequency that will be employed during thisremoval are shown on Figure 3-1.

In reference to Administrative Order Docket No. V-W-'94-C-230, the areas of concern identifiedin the Order were effected in part by the activities of the Circle Smelting facility located in thenortheast corner of the Village of Beckemeyer. Over the past 75 years, slag management practiceshave contributed to the contamination of the identified work site.

Lead contaminated material identified during the above mentioned sampling efforts have beendetermined by EPA to pose a potential "threat to public health, welfare, or the environment basedupon the factors set forth in section 300.415(b) (2) of the National Oil and Hazardous SubstancesPollution Contingency Plan, as amended ("NCP"), 40 CFR Part 300".

3.2 Sampling Activities Implementation Schedule

Sampling activities will commence on the first day of field activities following project mobiliza-tion. Sampling activities will continue for the duration of the project.

3.3 Sampling Procedures and Sampling Plan

The environmental sampling and analytical procedures outlined below are an overview of methodswhich will be implemented during the Removal Action Three types of samples will be collectedduring this project:

• Primary XRF Samples,QA/QC Laboratory Samples, and

• XRF Verification Samples.

The primary XRF Samples will be taken at 150 foot intervals along the waterline route to test thesoils at the surface and at the bottom of the trench Ten percent of these samples will be collectedand submitted for laboratory analysis (QA/QC Laboratory Samples). Finally, XRF verificationsampling will be conducted following removal of contaminated material. The sampling andtesting protocol is detailed on Figure 3-2. Samplmu jus t i f ica t ion and strategy is detailed inSection 4 of this report.

ENTACT, INC.

VILLAGE OFBECKEMEYER

PROPOSED WATER LINE ROUTE WITH EXISTING DATAABOVE 500 PPM LEAD AND PROPOSED SAMPLING LOCATIONS

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Emergency Removal Work PlanPage 1 1

Soil Sampling Identification System

A sampling identification system will be implemented in order to properly track sampling activi-ties. The sampling activities and identification coding system associated with each type are asfollowed:

Primary X-Ray Fluorescent Samples XRF-000QA/QC Laboratory Samples QA-000XRF Verification Samples V-000

All numbering sequences will begin with the number "001" and will continue upward by one unit(i.e., V-001, V-002, V-003, etc...) until the final samples for the Removal Action are collected.

Should any of the verification samples reflect total lead above the cleanup level (500 ppm), thearea will be excavated and a second sample will be collected in the same area and have a "B"affixed at the end of the number (Example: V-001B). This labeling system will continue until thearea meets the 500 ppm lead cleanup criteria.

Soil samples will be collected during various phases of the Removal Action. Representativesamples will be collected to address levels of lead contamination during the following activities:

XRF Field Screening Sampling for Total Lead

Post-excavation Verification Sampling for Total Lead

XRF Field Screening

An X-Ray Fluorescence Soils Analysis method will be used in determining the concentrations oflead in the soil during various tasks associated with the Removal Action. This method offersqualitative identification of lead. This sampling method analyzes total elemental concentrationsand cannot distinguish between valence or oxidation states. The primary objective for utilizing theXRF is to provide analytical data in a timely manner for guidance of ongoing work in the field.

The Spectrace 9000 energy dispersive X-Ray Fluorescence Analyzer will be the instrumentutilized for Removal Action tasks. The Spectrace 9000 utilizes three radioisotope sources. Eachsource emits a different energy (wavelength) of radiation which provides efficient analysis ofspecific ranges of elements. A thirty second scan time will be utilized for the duration of theRemoval Action. Only qualified analysts trained in the proper use, theory, and safety of XRFanalysis will operate this system.

ENTACT, INC.

VILLAGE OFBECKEMEYER SAMPLING AND TESTING PROTOCOL

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The principle of XRF analysis is based on electron excitation. Elemental atoms in a soil sampleare irradiated with a beam of X-Rays. Electrons in the atoms" lower lying energy levels areexcited to higher energy levels. The vacancies left in the inner electron orbitals make the atomunstable Relaxation to the ground state occurs, resulting in the emission of X-Rays characteris-tic of the excited elements Thus, by examining the energies of the X-Rays emitted by the irradi-ated soil sample, identification of elements present in the sample is possible. Comparing theintensities of the X-Rays emitted from a given sample to those emitted from reference standardswith known analyte concentrations allows quantization of the elements present in the samples

XRF Calibration

Prior to any on-site activities, the Spectrace ^000 w i l l be propcrK calibrated in order to allow foraccurate sample collection During on-site aetu ities. the XRF w i l l be standardized daily u t i l iz ingreferenced standards for quality assurance and qual i ty control

Addit ionalK. ENTACT w i l l collect at least ten samples from the site prior to excavation activitiesto ereate site specific standards These samples w i l l be analyzed by XRF as well as by EPAMethod 6010 (ICP) The XRF response wil l be compared to the laboratory data to evaluatepossible matrix interferences The soil samples will be stored for reanalysis by XRF on a weekhbasis in order to provide a secondary check on ins t rument calibration

FNTACT. INC.



XRF Sample Collection

XRF sample collection for both Primary and Verification Samples will be collected and performedin the following manner:

XRF sampling will be in-situ.The sampling surface will be smoothed and compacted such that theprobe face will be in direct contact with the soil to be analyzed.The sample will be exposed to each of the three radioactive sources. Theprimary lead indicating isotope, (Jadmium 109, will cycle for 30 seconds,iron for 5 seconds and americium for 5 seconds.The data results will be logged into the field data book including: XRFreading, soils description and location.The probe will be decontaminated with a distilled water rinse beforemoving to the next sampling location.

QA/QC Laboratory Sampling

To ensure that Quality Assurance/Quality Control procedures are followed during field samplingfor laboratory analysis, sampling methods, record keeping, and sample control will be continu-ously monitored.

Throughout the sampling efforts, samples will be collected to assist with data evaluation andvalidation and ensure that proper field QA/QC procedures are being followed. In order to insurethat the laboratory is meeting all Level II QA/QC requirements, ENTACT will submit the datapackage to the U.S. EPA OSC for the first five verification samples. The following is a descrip-tion of the laboratory samples which will be collected during the Removal Action.

To obtain analytical data to verify the XRF readings, samples will be collected at 10 percent ofthe 150 foot interval locations or at approximately 50 locations (see Figure 3-1). One duplicatesample for every 10 QA/QC Laboratory Samples will be collected and sent to the laboratory foranalysis. The objective of this sampling effort will be to verify the XRF results.

Verification samples will be obtained from depths of 0 - 2 inches below excavated grade. Thefollowing methods will be utilized during this phase of sampling:

a. A sampling team will be equipped with proper safety equipment and clothing inaccordance with the Health and Safety Plan.

b. Designated sampling locations wil l be identified and areas demarcated for futurereference. Photographs will be taken of representative sampling locations alongthe pipeline route.

c. Staging areas for sample collection will be established. Polyethylene sheeting willbe placed adjacent to the areas lo be sampled during sample collection. Thefollowing tools and supplies will be prepared for use:

ENTACT, INC.

Vi l l age of BeckemeyerPipeline Project


1 gallon sample bags

Stainless steel trowels.

Measuring tape.

Distilled water.

Disposable towels and gloves.

3 gallon buckets for decontamination liquids.

Sample location markers.

d. Field notes will be completed and will include identification of the soil beingsampled, soil color, condition and other pertinent information.

e. Chain-of-custody documents will be prepared and samples will be sealed in aplastic bag prior to shipment to an independent laboratory for analysis.

f. All sample containers will be labeled in accordance with the predeterminedsample numbering system and transported to Southern Spectrographic Laboratoryin Irving, Texas for total lead analysis.

g. All sampling equipment will be decontaminated utilizing a detergent wash andpotable water rinse, followed by a distilled water rinse and drying with disposabletowels between each sampling event. All disposable sampling media will beplaced into designated site containers.

h. Samples will be analyzed by EPA Method 6010 (ICP).

Water Sampling

Samples from decontamination rinse water will be collected from the final rinse from the equip-ment decontamination process. The sample will be collected from the distilled water rinse andpreserved with nitric acid to a pH of less than 2,

ENTACT, INC.

-ig* .j* Be..<e"-(.'ve'Pipeline Proie>::

Removal \Aiurk PlanPage "5

Blanks

Blanks wi l l be collected even I Oth sampling day Field/equipment sample blanks are samplesuti l ized to identify possible sources of contamination during equipment decontamination, samplecollection, preservation and handling The field blank will consist of a water sample obtained byrinsing decontaminated sampling equipment \ \ i th analyte-free water which will be collected in asample container and handled as the other samples These samples will be collected to ensure thatcross-contamination was not present Field blanks \ \ i l l be analyzed for the same parameters assamples obtained from soil All samples \ \ i l l be collected in accordance with methods outlined inSection 3 3

Spikes

Matrix spikes and matrix spike duplicates (MS/MSD) are samples created at and by the labora-tory by spiking known concentrations of target analytes into a prepared portion of a sample pnorto analysis Spikes provide information on matr ix effects encountered during analysis. One MS/MSD u i l l be run for even, 20 samples sent to the laboratory during the course of this project.

ENTACT. INC.



3.4 Sample Shipping

For shipping, all samples will be packaged in such a manner as to prevent damage or breakageduring shipment or transport. Samples shipped through an overnight parcel service by samplingpersonnel will be placed into suitable containers, labeled and sealed in such a manner that tamper-ing with the seal would be obvious. All sample holding times will be tracked and a copy of theChain-of-Custody form will accompany the samples in a sealed plastic bag.

AH sample identification markings will be noted on a Chain-of-Custody form immediately aftercompletion of sampling procedures Sample identification numbers, appropriate analysis, preser-vation, date, and sample turnaround requests will be recorded on the Chain-of-Custody form.Signatures of individuals responsible for sample recordation and custody will also be noted on theform. The Chain-of-Custody form will accompany the associated samples at all times.

Copies of the Chain-of-Custody forms will be maintained on-site and signed copies from labora-tory personnel will be kept at the ENTACT corporate office in Irving, Texas while duplicates willbe made for the Final Report. Sample condition and pertinent laboratory information will beincluded on the signed copy. A sample Chain-of-Custody is included as Appendix C.

In order to maintain proper sample tracking and record keeping, documentation of sample posses-sion, analysis requests, storage and shipment will be required. To ensure valid sampling data,procedures for sample labeling, preservation, tracking and laboratory QA/QC methods will bereviewed periodically.

The Project Information and Data Coordinator will be responsible for maintaining complete andup-to-date sample records. All sampling teams will record pertinent sampling information (i.e.,time, date, location, sample media, ID #, etc.) in a sample field log. All information reflected inthis log will be transcribed into a portable computer system. This information will be kept on-siteand documented in the Final Report. Any additional relevant information that may be included indaily field notes will be referenced in the sample field log. All photographs taken will be dupli-cated for on-site records and for the Final Report.

3.5 Analysis

Southern Spectrographic Laboratory in Irving, Texas will be utilized for providing analyticalservices during the Removal Action. All laboratory analysis will be performed in accordance withthe Southern Spectrographic Laboratory Quality Assurance/Quality Control program, designed byGuidance in SW-846.

The XRF samples and verification samples will be analyzed for total lead concentrations.

U.S. EPA Method 6010 (SW-846) will be utilized to determine lead concentrations in all verifica-tions samples collected and shipped to Southern Spectrographic Laboratory.

ENTACT, INC.

Al NOIlD3i



4.0 REMOVAL ACTIVITIES

The time critical removal action mandated by the EPA Order specifies that contaminated materialspotentially encountered during construction of the Beckemeyer water line be removed and man-aged in a manner that is protective of human health and the environment. The scope of workdetailed in this Work Plan accomplishes this goal.

Considering existing data collected by U.S. EPA and the Village of Beckemeyer, ASARCO/ENTACT will excavate the remaining water line path to a minimum depth of two feet. Contami-nated materials will be identified by continuous visual excavation as well as XRF analysis(Spectrace 9000) at 150 foot intervals along the water line route. Ten percent of these sampleswill be submitted for laboratory analysis.

ASARCO/ENTACT have coordinated with the Village of Beckemeyer and the water line contrac-tor to plan the remedial effort to be as complimentary as possible. Prior to remedial excavation,the Village of Beckemeyer engineer and the contractor will walk the water line route and mark theexact path.

Where possible, man-made structures will not be excavated. It is under these man-made struc-tures that the majority of contaminated materials are believed to exist. The contractor will pushthe pipe under obstacles such as streets, railroad crossings, etc. Consequently, remedial excava-tion will not be conducted through the following areas:

-streets,-driveways,-sidewalks, and-railroad right of way.

By pushing the pipe through these zones, the opportunity to disturb contaminated materials isgreatly reduced. If slag or contaminated material exposed at the surface is in the path of thewaterline, it will be removed. If contaminated material was used as subgrade and is not exposedat the surface it will not be removed. The Contractor will push the pipe under the structure andassociated contaminated material.

Two water crossings will be encountered during construction of the water line. It is unclear ifthese tributaries maintain a constant flow Previous data indicates total lead concentrations inexcess of 1000 ppm in the stream sediments. ENTACT will coordinate closely with water linecontractor at these crossings to minimize suspending contaminated sediments during the construc-tion process. The following precautions will be taken:

* ENTACT will construct earthen berms to contain the water both up-stream and downstream of the crossing;

* Water collected on the upstream side of the berm will be pumped aroundthe excavation area beyond the down stream berm;

* ENTACT will excavate the trench for the contractor to total depth and

ENTACT, INC.



perform the necessan XRF testing to ensure a clean work zone; and

* Following installation of the water line. ENTACT \\ i l l backfill withappropriate imported backfill material.

Actual field conditions may require modifications to this Work Plan and all modifications will beagreed to in writing between ASARCO/ENTACT and the U.S. EPA On-Scene Coordinator. Theremainder of this section details activities required to support the Removal Activities.

4.1 Cleanup Criteria of Soils

U.S. EPA has mandated 500 ppm total lead as the cleanup level for this time-critical removalaction (see Figure 4-1). A portable XRF Analyzer will be utilized during all field activities todelineate the extent of excavation activities. Any soil, slag, furnace ash, or debris containinggreater than 500 ppm total lead will be excavated and transported to the Circle Smelting Corpora-tion Site to be consolidated and stored. Ail excavated soil found to contain less than 500 ppmtotal lead will be backfilled into the excavated trench.

4.2 Site Cleanup Activities

Excavation and Transport of Contaminated Materials

ENTACT wil l util ize a Caterpillar 110 or e q u i v a l e n t trackhoe weighing approximately 8.000pounds to excavate a 2 foot wide b> 2 foot deep trench approximately 40.000 linear feet along theproposed v\ater line route in order to ident i fy and remove any contaminated materials {see Figure4-2). Previous analytical data indicates thai oMiummation does not extend beyond a depth of

ENTACT. INC.

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t\\o feet In the e\ent that the XRF anaKzer indicates further contamination at a depth past of 2feet. ENTACT will continue to excavate until contaminated materials have been removed.

Contaminated materials will be loaded directly into a hazardous waste transport vehicle. Eachload will be covered before being transported to the Circle Smelting site for consolidation andstorage (sec Figure 4-3).

Soil sampling

The primary soil samp 1 ing/analytical technique to be used during this project will be the portableXRF analyzer (Spectrace 9000) (see Figure 4-1). Soils along the proposed water line route willbe analyzed at 150 foot intervals both at the surface of the excavation and at the two foot depth.Ten percent of these samples will be collected, containerized, labeled and shipped to the laboratoryfor verification analvsis.

Once a contaminated zone has been identified, the frequency of soil sampling with the XRF willbe conducted at a minimum interval of even five feet on each side of the initial "contaminated"reading until consecutive "clean" readings are encountered.

ENTACT, INC.

IVll.LAGF 01-BFt KEMFYFR

EXCA/Af .ON A.40 fESiV.3 OFCONTAMINATED SOU d PIPE. .1 f rt f, V

Known contaminated *reai will bo confirmed. delineated andexcavated. Additional XRF letting wttl b* p«rtorm«d an lh«

•! ISO FT Inlcivala

Ar«*« «( cenlMnkiaUon will to* d«Un*at*d during remedial •xciwatlonby •riclyzlni tt>« *««• •( S tool lnt*rw«U both torwwd and backward

Eicivatfon mm be 2 t«at wWe to • d«plh of e(th*f 2tt or to •load concentration In tho aoff of !••• than $00 pp«n whichovorto groalot.

Son ato«vo SOO pom lotol load mil be cue •••led, loaded, andIranapoflod lo tho arnoltor let itachptling In a protected atea

U«*d« «M bo covorotf for tranapocl lo »me4t»r

Mlstlna vriM be u UN ted to control •miaaloni during »oil movement

oicavaiton may bo required around •hallow uttfitie*.boo*, and ohrubo.

Air rnorWtotlng will bo porformod In tho word zone.

CKCAVATIO *W»

IVILLAGE OFBECK.FMEYFR TRANSPORTATION OF E X C A V A T E D SOn.S

CMTROLLEOACCCM TO

CMCU

EXCAVATE* MM.S MLL M TIAMMMTUTO MtfLTEl • MOKM.T UCCNWB VfMCLE*.LOAD* 1M.L M COWMft BUMMt

UNH TIWCK MCOMlAMHAItOMMMA 1O M MM*

TO SMELTER

MMTMG TO CCMtfRCHMJSt (MSStOMS

ENTACT

NO«TH£AST STORAGE BUILDINGAT THE CIRCLE SHEL TER

•UILDING DIHENSIOHS -- 20O X 80 X 20' UNOBSTRUCTED

CAN ACCOMODATE UP TO 10.000 CUBIC VAR0S

FiG1 Rr 43

Sampling of sediments in water

Two water crossings will be encountered during construction of the water line. Previous dataindicates total lead concentrations in excess of 1000 ppm in the stream sediments. ENTACT willredirect flow in these streams as necessary to create a dry work zone. XRF analyses will beconducted on the sediments to determine lead concentrations. ENTACT will coordinate with thepipeline contractor to provide all excavation at the water crossings. Once the contractor hasconstructed the water line through these areas, ENTACT will immediately provide and placeappropriate backfill.

Air monitoring and dust control

Due to the possibility of paniculate lead contaminants becoming airborne during excavationprocedures, engineering controls will be utilized. These will consist of continuous misting duringexcavation, loading, and unloading of contaminated materials. To ensure that engineering controlsare effective, air monitoring will be performed. Two forms of air monitoring will be implementedduring this project: ambient air monitoring for respirable dust and one personnel sampler in thework zone to monitor particulate lead concentrations.

All ambient air readings will be documented for recordation purposes and will be utilized to assessthe effectiveness of engineering controls in a "real time" fashion during excavation. In the eventthat respirable dust levels exceed 150 micrograms per cubic meter of air, additional engineeringcontrols will be implemented to further control emissions.

ENTACT, INC.

Personnel monitor samples will be collected daily and will be sent in for laboratory analysis everyfourth working day. The daily sample will also be sent in for laboratory analysis in the eventrespirable dust concentrations exceed 150 micrograms per cubic meter.

Handling and storage of decontamination rinsates, spent protective clothing, and ait otherwastes generated during the cleanup

All decontamination wastes and personal protective equipment generated during the course of theproject will be placed into 55 gallon open-top D.O.T. approved steel drums meeting all appropri-

ate labeling and packaging requirements. All drums will be staged along with the contaminatedCircle Smelting facility pending disposal by ASARCO at an approved facility.

4.3 Estimate of Time Required for Removal Activity

The project schedule is detailed in Figure 4-4. The schedule details mobilization, site preparation,e\:cavation. demobilization and final reporting. — •

ENTACT, INC.

IVILLAGE OFB E C K E M E Y E R

DESCRIPTION

1. Work Plan SubmitUl

2. Mobilization, Placement of Job Trailer,Phone/Pax and EUcUical Hoak-up. SiUHealth uid Safety Review. EaUblish SiUSecurity

3. Pre-construction HeeUnf. SIU Review

4. Site Preparation, Verification of ExcavationAreas. Utility Location and Harkinc. TrafficBarricade*. Circle SmtlUr Recei*in( AreaPreparation

cj En «V«UOD of ContaminanU U 500 ppm.TLHF ScjrejaUon of Soili. Deposit forB*. k f i l l or Transport U Smelter for LaterHandling. Verification Samplinf. Mivtinfto i ontrol EmiMiona

6 UiDim>l Excavation Area Restoration andCleao-Up

7. Secure Circle SmelUr Area

8. Pre-Final Inspection of Work SiU

0. Final Site Operations and Wrap-Up

10. Pinal Site Inspection

11. Demobilization

12. Final Draft Report

13. Final Report (AfUr KPA Conunenta)

PROJECTED SCHEDULE OF OPERATIONSENTACT

DAYS

60 120

FIGURE 4-4

Village of SeckemeyerPipeline Project

Etnergency Removal Work PlanPage 27

ENTACT, INC.

SECTION V



5.0 SITE RESTORATION/PROJECT CLOSEOUTACTIVITIES

The focus of this project is to remove contaminated materials that are in the path of the proposedwater line ERA has categorized this as a "time critical removal action." Concurrent with theactivities described in this Work Plan, the pipeline contractor will reopen the trench and beginconstruction of the new water line. Therefore, site restoration performed in this Work Plan willbe limited to backfill and compaction. Final restoration of the pipeline path is the responsibility ofthe pipeline contractor.

Prior to Demobilization Procedures, ENTACT will provide for the following:

-disposal of all decontamination wastes generated during the course of this project and

-maintain secure and adequate protection of storage pile to prevent exposure and migra-tion

ASARCO will provide for restoration of landscaping unexpectedly damaged during this project ona case-by-case basis.

It is not anticipated that future remedial actions conducted at this site \\ill impact the areasaddressed during this project. Following completion of this project, no future operation andmaintenance or monitoring efforts will be necessary.

ENTACT. INC.

SECTION VI



6.0 PROJECT MANAGEMENT AND PERSONNEL

ENTACT takes pride in the personnel assigned to every project, as they are responsible forensuring that the client receives a High Quality Product. Quality Assurance and Quality Controlare important issues at every level of the project. Every level of performance receives multiplepeer review prior to project completion. The organizational chart for this project is provided asFigure 6-1.

6.1 Project Manager

Dean Pisani will be project manager in charge of the work and final completion of the project. Heis responsible for ensuring that all materials construction procedures and workmanship conform toregulatory guidelines and accepted engineering practices. All work under his management must bescheduled to allow QA/QC testing personnel to perform their duties. The project manager willdelegate and over see site safety protocol and coordinate emergency responsibilities. Additionallythe project manager will be responsible for maintaining the project schedule or amending asrequired. All site construction personnel report to the project manager through the site superinten-dent.

6.2 Construct/on Superintendent

David Johnson will be construction superintendent in charge of equipment operators, materialshaulers, laborers, construction crews and subcontractors that will implement the approved projectplans. The construction superintendent will report to the project manager.

6.3 Construction Quality Assurance Officer

Tony Senna will be the CQA officer and will manage a planned system of inspections and testingprocedures to directly monitor and control the quality of the construction project. All tests andinspections will be completed by him, or a member of his QA/QC staff, outside testing services oranalytical laboratories. All daily activities reports, periodic summaries, measurements and otherpertinent activities will be scheduled and managed by him and aU information will be reported tothe Project Leader.

6.4 QA/QC Technicians

Chris O'Donnell will be the on site CQA technician and will assist the CQA officer in the perfor-manoe of his duties. His duties include taking field measurements, compiling results, reportingproblems and implementing corrective measures, daily site inspections of construction and materi-als installation, activities reporting, gathering soil samples and sending them for analytical testingand overseeing outside testing agencies during field work.

5.5 Regulatory Compliance

Sherry Pierce will be responsible for making sure all testing programs, project activities, QA/QCprocedures and guidelines that are proposed for the project are in compliance with current andproposed RCRA and state environmental regulations.

ENTACT, INC.

VILLAGE OFBECKEMEYER

PROJECTORGANIZATIONAL

CHART ENTACT

U.S. ERARepresentativeSamuel Berries

ASARCOClient Representative

Donald A. Bobbins

ENTACTProject Leader

Philip Pisani

ENTACTField Operations

LaboratorySouthern

Spectrographlc

ENTACTHazardous Materials

Technicians

HazardousWaste

TransportationSubcontractor

FIGURE 6-1



6.6 Project Documentation and Record Keeping

All activities with regard to QA/QC testing will be documented in association with excavation,soil and sampling, analytical testing and conformance specifications and adherence to regulatoryguidelines.

6.7 Daily Activities Logs

Daily field activities reports will be kept by the site project manager or assigned technician. Thedaily reports will include number and type of tests taken, date and time of tests, test locations anda written report of problems encountered with corrective measures taken. Daily reports willinclude notes of observations made by the site personnel. Additional documentation such asground photos, site entry and exit logs, aerial photos and video tape records of the work progresswill be taken and maintained at the discretion of the project manager. Daily communication withthe OSC or other designated representative will be provided to allow positive interaction andfeedback. Communication with the PRP will be established via the project manager and PhilPisani, both of ENTACT, to facilitate the passing of accurate and pertinent information.

6.8 Progress Reports

Progress reports will be submitted to the U.S. EPA on a monthly basis. The progress report willcontain a summary of operations recently completed with photo documentation. The progressreport will also contain a section outlining planned operations and provisions for anticipatedproblems. Copies of the report will be available to the PRP and other appropriate personnel.

6.9 Record keeping and Reporting

Written records of field tests, XRF results, photographs and video tape records will be kept on fileby the project manager. Chain of custody forms, analytical request forms and analysis reports willbe kept on file for the distribution to key project personnel.

ENTACT, INC.

SECTION VII



7.0 SITE CONSTRUCTION AND MEETINGS

7.1 Preconstruction Meeting

Prior to initiating site activities Dean Pisani of ENTACT will conduct a preconstruction meetingin which documentation methods, reporting and distribution of relevant data will be discussed. Ifchanges in project plans or methodology have occurred they will be addressed as will provisionsfor future changes in operations plans, procurement procedures, subcontracting requirements orschedule. Site specific items will be addressed such as site security and various protocols. At thetermination of the meeting a site walk through will be conducted in order to review all designcriteria and possible safety hazards.

7.2 Pro-Final Inspection

At the completion of the project ENTACT will notify the EPA in order to conduct a pre-final inspection of the project to determine if the project is complete and consistent with thecontract documents. Any deficiencies will be identified and noted as will actions needed to correctpossible deficiencies.

7.3 Final Inspection

Upon correction of all deficiencies noted in the pre final inspection the EPA will be notified inorder to conduct a final inspection of the project. A walk through will be conducted utilizing acheck list developed at the pre-final inspection.

ENTACT, INC.

of BeckemeyerPipeline Proiect


7.4 Final Report

A copy of the assembled Final Report outlining project activities and operations will be submittedto the U.S. EPA for final review and comment Following comment the required additions orchanges will be implemented and the report rcsubmitted

ENTACT. INC.

APPENDIX A ,r *•

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION V

\W94-C-230IN THE MATT3R OF: ) Docket No. ' *^ fc-^ W) ADMINISTRATIVE ORDER

CIRCLE SMELTING CORPORATION ) PURSUANT TO SECTION 106(a)RF:CR:EMEYER, ILLINOIS ) OP THE COMPREHENSIVE

) ENVIRONMENTAL RESPONSE,Respondents: ) COMPENSATION, AMD

} LIABILITY ACT OF 1980,CIRCLE SMELTING CORPORATION ) AS AMENDED, 42 U.S.C.FEDERATED METALS CORPORATION ) SECTION 9606(a)ASARCO, Inc.

I. JURISDICTION AMP GENgRAL PROVISIONS

This Order is issued pursuant to che authority vested in thePrceidcne of the United St<*tea by section 1U6(a) of theComprehensive Environmental Response, Compensation and LiabilityAct of 1980, « amended ("CBRCLA") , 42 u.S.C. 5 9606 (a) , anddelegated to the Administrator of the United States EnvironmentalProtection Agency ("BPA") by Executive Order No. 12580, January 23,1987, 52 Federal Register 2923, and further delegated to theRegional AdminisLi^Lura by EPA Delegation NQs. 14-3.4-A and 14-14-B,and to the Director, Waste Management Division/ Region V, byRegional DelegaLiuu NUB. 14-14-A and 14-14-B.

This Order pertains to lead-contaminated materials associated withthe property located at the Circle Smelting Corporation, OldIllinois state Highway 50 in northeast corner of the Village ofBeckemeyer, Illinois (the "Circle Smelting Site* or the "Site").This Order requires the Respondents to conduct removal activitiesdescribed herein to abate an imminent and substantial endangermentto the public health, welfare or the environment that may bepresented by the actual or threatened release of hazardoussubstances at or from cne Site.

EPA has notified che state of Illinois of this action pursuant tosection 106(a) of CERCIA, 42 U.S.C. § 9606(a).

II. PARTIES BQOND

This Order applies to and is binding upon Respondents andRespondents' receivers, trustees, successors and assigns. Anychange in ownership or corporate status of Respondents including,but not limited to, any transfer of assets or real or personalproperty shall not alter such Respondents' responsibilities undertnis Order. Respondents are jointly and severally liable forcarrying out all activities required by this Order. Compliance ornoncompiiance by one or more Respondents with any provision of this

Order shall not excuse or justify noncompliance by any ncherRespondent;.

snalJ. ensure chat their contractors, subcontractors,and representatives comply with this Order. Respondent-.* shall beresponsible tor any noncompliance.

III. PIHDiygS OP PACT

aased on available information, including the Administrative Recordin this matter, U.S. EPA hereby finds that:

1. The Circle Smeltinq Corporation (CSC) plant-, sit* is located ona 28 -acre parcel of land situated along Illinois State Highway50 in the northeast corner cf the V-i 1 1 age of Beekemeycr,Cl inton County , ill inois . The CSC plant was original lyconstructed as a primary zinc smelter About 1904 and was laterconverted into a secondary zinc smelter around 1920.

2. The CSC plant site is presently owned and operated by CircleSmelt inq Corporation, an Illinois corporation. FederatedMetals Corporation, a division of ASARCO, Inc., a Delawarecorporation, is a past owner and operator of the plant site.

3. Beginning in the 1920s, lead -contaminated Blag material fromthe plant's smelters was disposed of on the plant property inthe form of a 17-arr* waste pile which ia ae muoh as fifteen(15) feet deep. Lead- contaminated slag material was also usedextensively within the Village of Beefcemeyer aa a surfacecover and fill material for walking paths, driveways, andalleys. Currant-ly, ic ic estimated that approximately 14,000linear faet (2600 cubic yards) of lead- contaminated slagmaterial and lead- contaminated ooilo (referred to aa"contaminated material*) are present and wholly or partiallyevposed throughout the Village of Beckemeyer.

4. The secondary zinc smelting processes employed by CircleSmelting Corporation and Federated Metals Corporationgenerated air •missions that contained lead.

5. On March 29, 1993, U.S. EPA conducted a site assessment of theVillage of Beckemeyer. Several areas of contaminated materialor area* of potential contaminated material, as indicated bystressed vegetation, were identified and sampled for analysis.A total of fourteen (14) sample a were collected and analyzedindicating the presence of high levels of lead contamination.Total lead levels were found to be &s high as 31,000 parts permillion (ppnO and toxic characteristic leachate procedure(TCLP) lead levels were &0 high as 210

6. Soil campling conducted on July 30, 1993 determined thatelevated levels cf lead contamination from the slag materialextended to approximately twenty-four (24) inches below thesurface of the slag material.

7. During the week of October 4, 1993 the U.S. EPA Remedialproject Manager collected 176 soil and slag material samplesfrom the perimeter of the pipeline route and residentialyards, while analyticctl results are still being compiled itappears that approximately 20% of the samples haveconcentrations of l««itl contamination greater than 500 ppm,Thus far sample results indicate lead concentrations of up to4300 ppm.

a. Presently, uhe village of BecKemeyer is replacing and updatingits municipal water distribution system because ofdistribution and health concerns. The current distributionsystem is in need of replacement to remedy pressure, capacity,

-righting, line creafc, and bacterial concerns.9. Ejtfuau£-« to contaminated material could occur during

excavation and trenching activities during emergency pipelinerepairs and during che water distribution project. The watermain replacement portion of the project will involve theinstallation of over 60,000 linear feet of water line and willresult in disturbing contaminated materials associated withtne Circle smelting Corporation site.

iv. cotrcLosioufl OP IAM AMPBased on tne Findings of ?act set forth above , and theAdministrative Record supporting these removal actions, SPAdetermines tnat:

1. Tne circle Smelting Site is a "facility" as defined by section101(9) of CERCIA, 42 U.S.C. § 9601(9).

2. Lead is a "hazardous substances" as defined by section ini(i4jof CERCIA, 42 U.S.C. § 9601(14).

3. Each Respondent is a "person" at defined by section 101 (21} ofCERCLA, 42 U.S.C. § 9601(21).

4. Respondent Circle Smelting Corporation is the pr«R«nt "owner"and "operator" of the Circle Smelting Site, as defined by section101(20) Of CBRCLA, 42 U.S.C. S 9601(20). Respondftnr.fi, federatedMetals Corporation and ASARCO are either persons who at the time oCdisposal of any hazardous substances owned or operated the circleSmelting Site, or who arranged for disposal or transport fordisposal of hazardous substances at r.h« Tirol* Smelting Sito.Respondents are therefore liable persona under section 107 (a) ofCERCLA, 42 U.S.C. S 9607 (a).

5. The conditions described in t-h»? Findings of Pact aboveconstitute an actual or threatened "release" into the "environment"as defined by sections 101(8) and (7.7.) of CSRC1A. 42 U.S.C. §59601(9) and (22) .

U-i -3

6. The conditions present at the Site constitute a threat to publichealth, »eiretre, or the environment based upon the factors setforth in section 300.415 (b) (2) of the National Oil and Hazardoussubstances Pollution Contingency Plan, as amended ("NCP") , 40 CFRFart 300. These factors include, but are not limited to, th*followiuy:

<*. actual or potential exposure to nearby human populations,animals, or the food chain from hazardous substances,pollutants or contaminants; this factor is present at the Sitedue to the existence of high levels of lead in samplescollected from locations within the village limits ofEecJcemeyer as documented by aite investigations conducted byibTA, U.S. EPA, and the TAT. Lead is considered a suspectedcarcinogen by the International Agency on Research for Cancer(IARC) . Lead is poisonous by ingestion, moderately toxic byintraperitoneal route, and poses ingestion and -inhalationnazards affecting the nervous system, blood system, andkidneys. The close proximity of residences and arhoola to thewater line project creates the potential for direct contact andexposure to lead-contaminated dust by adult-.* and childrenwithin the Village of Beckemeyer.

b. high levels of hazardous substances or pollutants orcontaminants in soils largely at or near rhe surface, that maymigrate; this factor is present at the Site due to theexistence of high levels of lead In *lag material that havebeen documented by site investigations which has beendeposited throughout the Village of T**ck«m*yer. increasedmigration of contaminants from excavation/trenching sites byairborne dust or storm run-off i« likely. If contaminatedmaterial is left in piles along the water line route it wouldbe subject to drying conditions incraasing th« potential forwindblown dust particulate or runpff during storm events.Migration from leaching Affects ie evident. Samplco collectedduring the March 29, 1993 site investigation indicate TCLPresults of slag mar.Rr-ial contain 210 ppm leachablc lead whichis well above the 5 ppm Resource Conservation and Recovery Actlevel. Total lead r.eincentrationg of up to 31,000 ppm lead iawell above the 500 ppm federal cleanup standard.

c. weather conditions that may cause hazardous substances orpollutants or contaminants to migrate or be released; thisfactor is present at the Site due to the existence ofprecipitation that could cause significant run-off of lead-contaminated soil and slag material into streets, alleys, andreaidnnrtAl property if haaardoua exc&vated material iu notaddressed properly. Dry weather conditions could lead to thespread nf contaminants through airborne dust particulate.

7. 7he actual or threatened release of hazardous substance* fromzhe site may present an imminent and substantial endangerraent tothe public health, welfare, or the environment within th« meaningot section 106(a) of CERCLA, 42 U.S.C. § 9606(a).

8. The removal actions required by this Order are necessary toprotect the public health, welfare, or the environment, and a.r» notinconsistent with the NCP and CERCLA.

V. QBSB&Based upon the foregoing Findings of Fact, Conclusions of Law,Determinations, and the Administrative Rer.ord for this Sit*, EPAhereby orders that Respondents perform the following actions:

1. Notice of Intent to Comply

Respondents shall notify EPA in writing within 3 business daysafter the effective date of this Orrtar of Respondent*' irrevocableintent to comply with this Order. Failure of each Respondent toprovide such notification within this tinw period cha.ll be aviolation of this Order.

2. Designation of Contractor. Project Coordinator, and Qn-SeeneCoorriMnat-m-

Raspondents shall pat-form the removal actions thcnaelvea or retain,a contractor to implement the removal actions. Respondents shallnotify EPA nf Respondents' qualifications or the name andqualifications of such contractor, whichever is applicable, within5 business days of the effective date of thio Order. Respondentsshall also notify EPA of the name and qualifications of any otheroonr.rartrors or subcontractors retained to perform work under LhiaOrder at least 5 business days prior to commencement of such work.RPfc retains the right to dieapprove of the Respondents uz: ttuy ofthe contractors and/or subcontractors retained by the Respondents.If EPA disapproves a selected contractor, Respondents ahull retaina different contractor within 2 business days following • EPA'sdisapproval and ohall notify BPA of that contractor* u name andqualifications within 3 business days of EPA's disapproval.

Within 5 business days after the effective date of this Order, theRespondents* shall designate a Project Coordinator who snail beresponsible for administration of all the Respondents' actionsrequired by the Order and submit the desicjudted coordinator's name,address, telephone number, and qualifications to EPA. To thegrcatcat extent possible, the Project, Coordinator snail be presenton site or readily available during site work. EPA retains theright co disapprove of any Project coordinator named by tneRespondents. If SPA disapproves a selected Project Coordinator.Rocpondcncs shall retain a different. Project Coordinator within 3business days following EPA'3 disapproval and shall notify EPA of

person'a name and gualific&Liuua within 4 business days ot

EPA's disapproval. Receipc by Respondents' Project Coordinator ofany notice or communication from EPA relating to this Order shallconstitute receipt by all Respondents.

The EPA has designated Samuel Borries of the Emergenry andEnforcement Response Branch, Region V, as its On-Scene Coordinator(OSC) . Respondents shall direct all submissions required by chicOrder to the OSC at Mail Code HSB-5J, 77 West Jackcon Blvd.,Chicago, Illinois 60604-3590, by certified or ftvprea* mail.Respondents shall also send a copy of all submissions toMary L. Fulghum, Assistant Regional Counsel, Ma-tl Coda CM-8T, 77West Jackson Blvd., Chicago, Illinois 60604-3590. All Respondentsare encouraged to make their submissions t-.n U.S. BPA on recycledpaper (which includes significant postconsumer waste paper contentwhere possible) and using two-sided cop-San.3 . Work to Be Performed

This time critical removal action will be conducted to stabilizecontaminated material associated with installation of the waterline project while preventing exposure to Beclcemeyer residanto andthe environment. Excavated soil will be secured and stored inanticipation of additional remediation. Respondents ehall perform,at a minimum, the following response activities:

a. Develop a Health and Safety Plan to prevent exposure toworkers and loral residence from contaminated materiel; and

b. Develop and -Implement a sampling and analytical programdesigned to identify potentially contaminated material alongthe war.ar distribution route i and

o. Provide dust tuppreeeion racaauree for excavacedcontaminated material to insure contaminated dust does notmigrate ; and

d. Remove contaminated material potentially encounteredduring excavation and trenching and properly handle, store,consolidate, and/or diopoac of the contaminated material; aud

e . Provide adequate cover protection to consolidatedcontaminated material to prevent exposure to the elements.

3 .1 Work Pj ft and

Within 10 business -days after the effective date of this Order, theRcopondcnta shall aubmit to EPA Coi: Approval a. draft Worfc Plan forperforming the removal activities set forth above. The draft WorkPlan shall provide a description of, and *u expeditious scheduleCor, the activities required by chis Order.

EPA may approve, disapprove, require revisions to, or modify thedraft Work Plan. If EPA requires revisions, Respondents snail

submit a revised draft Worlc Plan within 7 business days ofnotification. Respondents shall implement the Work Plan as finallyapproved in writing by EPA in accordance with the schedule approvedcy SPA. Once approved, or approved with modifications, the WorkFlan, the schedule, and any subsequent modifications shall b« fullyenforceable under this Order. Respondents shall notify EPA atleast 48 houre prior to performing any on-site work pursuant to theEPA approved work plan.

Respondents shall not commence or undertake any removal actions atche Site without prior EPA approval.3 .2 Health and Safety Plan

Within 10 business days after the effective dar.* of this Order, theRespondents shall submit a plan for EPA review and comment thatensures the protection of the public hnalt-.h and safety duringperformance of on-site work under chic Order. This plan shallcomply with applicable OccupaHnnal Safety and HealthAdministration (OSHA) regulations found at 29 CFR Part 1910. IfEPA determines it is appropriate, the plan shall also includecontingency planning. Respondents shall incorporate all changesto the plan recommended by EPA, and implement the plan during thependency of the removal action.3 .3 Quality Aflsuranee aqj Sampling

All sampling and analyses performed pursuant to this Order shallconform t-.o RPA direction, approval, and guidance regardingsampling, quality assurance/quality control (QA/QC), datavalidation, and chain of custody procedures. Respondent* shallensure that the laboratory used to perform the analysesparticipates in a QA/QC program that complies with UFA guidance.Upon request by EPA, Respondents shall have such a laboratoryanalyze samples submitted by EFA for quality assurance monitoring.Respondents shall provide to SPA che quality assurance/qualitycontrol procedures followed by all eaunpling teams and laboratoriesperforming data collection and/or analysis. Respondents shall alsoensure provision of analytical tracking information consistent wiLliOSWER Directive No* 9240.0-2B, "Extending the Tracking ofAnalytical Services to PRP Lead Superfund Sitee."

Upon requoot by EPA, Respondents shall allow EPA or it-a authorizedrepresentatives to take split and/or duplicate samples of anycamp lea collected by Respondents or their contractors or agentswhile performing work under this Order. Respondents shall notifyEFA not lese tham 3 business CUtyu Ixx advance of any samplecollection activity. EPA shall have the right to take anyadditional samples that It deems

3 .4 Reporting

Respondents shall submit: a monthly written progress report to EPAconcerning activities uiiUercalcen pursuant to cilia Order, beginning30 calendar days after the date of EPA's approval of the WorJc Plan,until tftrminALiua oC this Order, unless otherwise directed by theOSC. These reports shall describe all significant developmentsdut-uiy the preceding period, including the work perrormed and anyproblems encountered, analytical data received during the reportingperiod, and developments anticipated during tne next reportingperiod, including a schedule of work to be performed, anticipatedproblems, and planned resolutions or past or anticipated problems.

Any Respondent that owns any portion of the Site, and any successorin title shall, at least 30 days prior to the conveyance of anyinterest in real property at the Site, give written notice of thisOrder to the transferee and written notice of the proposedconveyance to KPA and the State. The notice to EPA and the Stateshall include the name and address of the transferee. The partyconveying such an interest shall require that the transferee willprovide access as described in Section V.4 (Access to Property andInformation) .

3.5 Final Report .

Within €0 calendar days after completion of all removal actionsrequired under this Order, the Respondents shall submit for EPAreview a final report summarizing the actions taken to comply withthis Order. The final report shall conform to the requirements setforth in section 300.165 of the NCP. The final report shall alsoinclude a good faith estimate of total coats incurred in complyingwith the Order, a listing of quantities and types of materialsremoved, a discussion of removal and disposal options consideredfor those materials, a listing of the ultimate destinations ofthose materials, a presentation of the analytical results of allsampling and analyses performed, and accompanying appendicescontaining all relevant documentation generated during the removalaction (e.g. . manifests, invoices, bills, contracts, and permits) .

The final report shall also include the following certificationsiqned by a person who supervised or directed the preparation ofthat report:

Under penalty of law, I certify that, to the best of myknowledge, after appropriate -inqniri** nf *11 relevant person*involved in the preparation of this report, the informationsubmitted is true, accurate, and

4 . Access CQ Property and

Respondents shall provide or obtain access as necessary t-.o t-.hA S-it-pand all appropriate off -site areas, and shall provide access to allrecords and documentation related r.n rhp rnnrtifions at the Site and

the activities conducted pursuant: to this Order. Such access shallbe provided to EPA employees, cGnurcictors, agencg, consultants,designees, representatives, and State cf Illinois representatives.These individuals shall be pexiiiiLLtfd to move freely at che Sice andappropriate off-site areas in order to conduct activities which EPAdetermines to fce nei-euudiy. Respondents shall sufcmit to UFA, uponrequest, the results of all sampling or testa and all other data9eu*-id. Led by Respondents or their contractors, or on theRespondents' behalf during implementation of this Order.

Where work under this Order is to be performed in areas owned by orin possession or someone other than Respondents, Respondents shallobtain all necessary access agreements within 14 calendar daysafter the effective date of this order, or as otherwise specifiedin writing by the OSC. Respondents shall immediately notify EPAif, arter using their best etrorts, they are unable to obtain suchagreements. Respondents shall describe in writing their efforts toobtain access, ifA may then assist Respondents in gaining access,to the extent necessary to effectuate the response activitiesdescribed nereln, using such means as EPA deems appropriate.

5. %JHC.O.r,4 Retention. DQcumen a.tj.on. Availability of Information

Respondents shall preserve all documents and information relatingto work performed under this Order, or relating to the hazardoussubstances found on or released from the Site, for six yearsfollowing completion of the removal actions required by this Order.At the end of this six year period and at least 60 days before anydocument or information is destroyed. Respondents shall notify EPAthat such documents and information are available to EPA forinspection, and upon request, shall provide the originals or copiesof such documents and information to EPA. In addition, Respondentssnail provide documents and information retained under this Sectionat any time before expiration of the six year period at the writtenrequest of EPA.6. Off-Site Shipments

All hazardous substances, pollutants or contaminants removed off-site pursuant to this Order for treatment, storage or disposalshall be treated, stored, or disposed of at a facility incompliance, as determined by EPA, with the EPA Revised Off-SitePolicy. OSWBR Directive Number 9834.11, November 13, 1987,promulgated pursuant to 42 U.S.C. S 9621(d)(3).

7. Compliance With Other Laws

All actions required pursuant to this Order shall be performed inaccordance with all applicable Inral, «at-.*t-.A, and federal lawg andregulations except as provided in CERCLA section 121 (e) and 40 CFRsection 300.4lS(i). In accordant with 40 CFP section 300.415(i),all on-site actions required pursuant to this Order shall, to theextent practicable, a« dat-AT-m-i ni?d by EPA, considering the

10

exigencies of the situation, attain applicable or relevant andappropriate requirements under reaerai environmencal or stateenvironmental or facility citing laws.

8 . Emergency Response and Notification _o_f Releases

If any incident, or change in Site conditions, during theactivities conducted pursuant to this Order causes or threatens tocause an additional release of hazardous substances from the Siteor an endangerment to the publ ic heal th , wel fare , or theenvironment, the Respondents shall immediately take all appropriateaction to prevent, abate or minimize such release, or endangermentcaused or threatened by the release. Respondents shall alsoimmediately notify the OSC or, in the event or his unavailability,shall notify the Regional Duty Officer, Emergency and EnforcementResponse Branch, Region V at (312) 353-2318, of the incident orSite conditions.

Respondents shall submit a written report co EPA within 7 businessdays after each release, setting forth the events that occurred andthe measures taken or to be taken to mitigate any release orendangerment caused or threatened by che release and to prevent thereoccurrence of such a release. Respondents shall also comply withany other notification requirements, including those in CBRCLAsection 103. 42 U.S.C. 5 9603, and section 304 of the EmergencyPlanning and Community Right-To-Know Act, 42 U.S.C. § 11004.

VI. AUTHORITY Q7 THB CTA Qtf-flCBTE

The OSC shall be responsible for overseeing the implementation ofthis Order. The OSC shall have the authority vested in an OSC bythe NCP, including the authority to halt, conduct, or direct anywnrV rftrjin'r«rf hy f.hlft Ord^r, or r.o direct any or.hAr response aoHorundertaken by EPA or Respondents at th* Site. Absence of the OSCfrom t-hfl Si t-B «hal 1 nnr. h* ran** for flr.nppagfl of worV unlessspecifically directed by the OSC.

EPA and Respondents shall have the right to change their designatedOSC or Project Coordinator. *PA shall notify the Respondents, andRespondents shall notify EPA, as early as possible before such achange ic made, but in no rase less than 24 hours before such achange. Notification may initially be made orally, but shall befollowed promptly by written notice.

viz. PPTALTIBS pon

Violation, of any provision o£ this Or dor may eubjact Respondents tocivil penalties of up to $25 f 000 per violation per day, as providedin section 106 (b) (1) of CBRCLA, 42 U.S.C. $ 9€06<b) (D •Responder.es may also be subject to punitive damages in an amount upco chree times the amount of any cost incurred by the united Statesas a result of such violation, as provided in section 107 (c) (3} ofCERCUV, -12 U.S.C. 5 9607(c)(3). Should Respondents violate this

A •*.-**• TAA tUO 0 ; iO ( -i o

11Order or any portion hereof, EPA may carry out the required actionsuiiild.Lerd.lly, pursuant co section 104 of CERCLiA, 4^ U.S.C. § 9604,and/or raay seek judicial enforcement of this Order pursuant tosection 106 Of CBRCLA, 42 U.S.C. § 9606.

Respondents shall reimburse EPA, upon written demand, for allresponse costs incurred by the United States in overseeingRespondents' implementation of the requirements of this Order. EPAmay submit to Respondents on a periodic basis a bill for allr*spcr.se rosts incurred by the United States with respect to thisOrder. EPA's Itemized Cost Summary, or such other summary ascertified by SPA, shall serve as the basis for payment.Respondents shall, within 30 days of receipt of the bill, remit acashier's or certified check for the amount of those costs madepayable to the "Hazardous Substance Superfund," to the followingaddress:

U.S. Environmental Protection AgencySuperfund AccountingP.O. Box 70753Chicago, Illinois 60673

Respondents shall simultaneously transmit a copy of the check tothe Director, Waste Management Division, U.S. BPA Region V, 77West Jackson Blvd., Chicago, Illinois, 60604-3590. Payments shallbe designated as "Response Coats - Circle Smelting Site" pnd shallreference the payers' name and address, the EPA site identificationnumber (tfWJ), and the docket number of this Order.

Interest at a rate established by the Department of thepursuant to 31 U.S.C. 5 3717 and 4 CFR S 102.13 shall begin toaccrue on the unpaid balance from the day after th« axpSraHnn ofthe 30 day period notwithstanding any dispute or an objection toany portion of the costs.

IX. Pttg^TyM'TQH Off PTOHTfl

Nothing herein shall limit the pow*r anrt »iit:h<yH try of EPA or theUnited States to take, direct, or order all actions necessary topror.wcr. piihlln hmilf.h, wfllfare, or the environment or to prevent,abate, or minimize an accual or threatened release of hazardoussubstances, pollutant* or contaminants, or ha«ardou» or solid wasteon, at, or from the Site. Further, nothing herein shall preventKP& from «**V^ncf 1*3*1 or equitable relief to enforce the terms ofthis Order. EPA also reserves the right to take any other legal orequitable action a* it deems appropriate and nececcary, or torequire the Respondents in the future to perform additionalactivities pursuant to CHRCLA or any other applicable law.

12

X- OTHER CLAIMS

By issuance of this Order, the United States and EPA assume noliability for injuries or damages to persons or property resultingfrom any acts or omissions of Respondents. The .United States or EPAsnail not be a party or be held ouc as a party to any contractentered into by the Respondents their directors, officers,employees, agents, successors/ representatives, assigns,contractors, or consultants in carrying out activities pursuant tocnis ureter.This Order does not constitute a pre-authorization of funds undersection 111(a)(2) ot CERCLA, 42 u.s.C. S 96ll(a)(2).Nothing in this Order constitutes a satisfaction of or release fromany claim or cause of action against the Respondents or any personnoc a party to this Order, for any liability such person may haveunder CERCLA, other statutes, or the common law, including but notlimited to any claims of the United States for costs, damages andinterest under sections 106(a) or 107(a) of CSRCIA, 42 U.S.C.§§ 9606 (a), 9607(a).

XI. MODIFICATIONS

Modifications to any plan or schedule may be made in writing by theOSC or at the OSC'e oral direction. If the OSC makes an oralmodification, it will be memorialized in writing within 7 businessdays; however, the effective date of the modification shall be thedate of the OSC's oral direction. The rest of the Order, or anyother portion of the Order, may only be modified in writing bysignature of the Director, waste Management Division, Region V.

If Respondents seeks permission to deviate from any approved planor schedule. Respondents' Project: Coordinator shall submit awritten request to EPA for approval outlining the proposedmodification and its basis.No informal advice, guidance, suggestion, or comment by EPAregarding reports, plans, specifications, schedules, or any otherwriting submitted by the Respondents shall relieve Respondents oftheir obligations to obtain such formal approval as may be requiredby this Order, and to comply with all requirements of this Orderunless it is formally modified.

XII' KOTICK OF COMPLETION

After submission of the Final Report, Respondents may request thatKPa prnvirtp a WnMrn nf rrmtpl pM nn nf fhe wnrlc n»qm r*»rl hy thisOrder. If EPA determines, after EPA's review of the Final Report,rhst- all work ban h«f»n fu l ly perf onriftH In anr.mnrianr.ft vi f.h t-.Vri ROrder, except for certain continuing obligations required by thisOrrtpr f p . g . . rsrorri ret-.Anf.-icin) , FPA wll 1 prrnHdA noH r.A he r.h«Respondents. If EPA determines that any removal activities havenoc been completed in accordance with this Order, EPA will notify

13

the Respondents, provide a list of the deficiencies, and requirethat Respondents modify the Woirfc Plan to correct such deficiencies.The Respondents shall implement the modified and approved Work Planand shrill aubiuiL e± modified Final Report in accordance with the EFAnotice. Failure to implement the approved modified Work Plan shallbe a viuletLiyu u£ Llila Order.

XIII. ACCESS TO ADMINISTRATIVE KSCOKP

The Administrative Record supporting these removal actions isavailable for review during normal business hours in th« EPA Recordcenter, Kegion v, 77 w. JacJcson Blvd., Seventn Floor, Chicago,Illinois. Respondents may contact Mary L. Fulghura, Assistantregional Counsel, at (312) 886-7166 to arrange to review theAdminigcrative Record. An index of the Administrative Record isattached to this order.

XIV. OPPORTOHITT TO CQWKR

Within 3 business days after issuance ot tnis Order, Respondentsmay request a conference with EPA. Any such conference shall beheld within 3 business days from the date of the request, unlessextended by agreement of the parties. At any conference heldpursuant to the request, Respondents may appear in person or berepresented by an attorney or other representative.

If a conference is held, Respondents may present any .information,arguments or comments regarding this Order. Regardless of whethera conference is held. Respondents may submit any information,arguments or comments in writing to BPA within 2 business daysfollowing the conference, or within 7 business days of issuance ofthe Order if no conference is requested. This conference is not anevidentiary hearing, does not constitute a proceeding to challengethis Order, and does not give Respondents a right to seek review ofthis Order. Requests for a conference shall be directed to Mary L.Fulghum, Assistant Regional Counsel, at (312) 886-7166.Written submittals shall be directed as specified in Section V.2 ofthis Order.

XV.

If a court issues an order that invalidates any provision of thisOrder or finds that Respondents have sufficient cause not to complywith one or more provisions of this Order, Respondents shall remainbound to comply with all provisions of this Order not invalidatedby the court's order.

14

XVI. EFFECTIVE DATE

This Order shall be effective 10 business days following issuanceunless & conterence is requested as provided herein. it aconference is requested, this Order shall be effective 5 businessdays after the day ot the conference.

IT IS SO ORDERED

BY wL. . DATErectorivigion

William 6. Mono,Waste ManagementUnited StatesSnvironmental Protection Agency

Region V

APPENDIX B

of BeckemeyerPipeline Project

Site Specific Safety PlanPage 1

SITE SPECIFIC SAFETY PLAN for the VILLAGE OFBECKEMEYER

The health and safety aspects presented in this plan are in accordance with OSHA 29 CFR, Part1910 as required by EPA Region V and are also in accordance with ENTACTs Safety PolicyManual which is a separated document to this plan. Figure 1 is provided to illustrate site-specificaspects of this plan.

I. GENERAL INFORMATION

A. Project Name: Village of BeckemeyerB. Location: Beckemeyer, IllinoisC. ENTACT Project Number; 669D. Client: ASARCO

II. PROJECT ORGANIZATION

A. Project Leader: Phil PisaniB. Field Project Manager: Dean PisaniC. Site Health & Safety Officer: Dean PisaniD. Information/Data Coordinator: Tony SennaE. Technical/Engineering Support: Reagan RorschachF. Regulatory Support: Sherry PierceG. Client Representative: Donald A. Robbins

III. SITE SAFETY PLAN PREPARATIONA. Prepared by: David Johnson and Reagan RorschachB. Reviewed by: Troy Butt, WSO # 014518C. Amended by: David Johnson and Reagan RorschachD. Approved by: Troy Butt, WSO # 014518

IV. SITE HISTORY AND DESCRIPTIONSite history has been documented in the EPA order located in Appendix A.

V SITE ORGANIZATION AND CONTROLThe project organization chart is provided as Figure 2.

VI. JOB ACTIVITIES IN WORK PLAN

A. Type of activities planned:

* Proper delineation of lead contaminated areas of soil. An effective sam-pling plan will produce a more efficient soil removal process.

* Preparation of the work areas for remedial activities. Vegetative growthwill be removed where necessary to enhance decontamination andexcavation procedures.

ENTACT, INC

IVILLAGE OFB E C K i " T V E R HEALTH AND SAFETY ASPECTS

ENTAa

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I «C, uSt^M ZOMt

HIHI

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FIRST STREETM**MMMM_mm ••flHTT

HHIHI

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SECOND STREET

Î•W l*«»UHa MOM•OTTOW or iKC»*tN

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UTN.ITV DCAlCHAIIOH. LOCATION A .lW KACt M C»« OF l>NOC«ClliH,h(>

ENClNEEMNG COMTflOl* FOR*i**tO*

COOMOlltATION

FiG'JRE 1

V I L L A G E OFR r C K E \ f E Y F R

PROJECORGANZA fi

ENTAa

,s EFARepresentat iveSamuel Borries

A S A R C OClient Representative

Donald A. Robbins

ENTACTProject Leader

Philip Pisani

ENTACTField Operations

LaboratorySoutnern

Spectrographic

E N T A C THazardous Materials

Technicians

HazardousWaste

TransportationSubcontractor

FIGURE 2

Vil lage of BeckemeyerPipeline Project


Gross contamination will be removed in an environmentally safe manner Miscel-laneous materials will be transported and stored at the Circle Smelter facility.

Excavation of contaminated soil with level exceeding 500 ppm will betransported to the Circle Smelter storage area.

Restoration of the work areas. Upon receipt of verification analyses,excavated areas will be backfilled with appropriate fill materials.

B. Comments:

VII. EDUCATION AND TRAINING

A. Site specific training: 29 CFR 1910.120 (e)B. Type of training: 40 hour classroom training with infield supervision

VIII. MEDICAL SURVEILLANCE

A. Medical monitoring

* An annual medical surveillance program is established for allfield personnel and includes the following: Blood test for HeavyMetals (lead, cadmium, chrome and mercury), physician's exami-nation including pulmonary function test, chest X-ray, and drugscreen.

I.. AMBIENT AIR MONITORING

A. Specific requirements:

To insure that engineering controls are effective and that dustemissions do not represent a significant exposure pathway, ambient airmonitoring will be performed. ENTACT will implement the air monitor-ing program described below:

* Random air monitoring will be performed in the work zone with amini-ram a minimum of three times a day. This includes a readingat the beginning of the work day to obtain a base line concentra-tion. Each monitoring event will last 20 minutes.

* A Sensidine BDX 530 Personnel Air Sampling Pump will be employed tocollect air samples from the work zone to record ambient air conditionsduring excavation operations. Every 4th day the personnel sample will besubmitted for analysis, or in the event that the Random Air Monitorindicates >150 micrograms per cubic meter respirable dust.

* All readings w i l l be documented for recordation p u r -poses and will be u t i l ized to assess the effective-

ENTACT, INC.



ness of engineering controls. In the event that random air monitor resultsexceeds 150 micrograms per cubic meter of air, additional misting proce-dures will be implemented to further control emissions and additionalmonitoring devices will be utilized if necessary.

B, Equipment requirements: Furnished by independent accreditedindustrial hygiene firm.

X. SAFETY MEETINGS

A. ENTACT conduct daily safety sign in and tailgate safety meetings.Safety Sign in and Tailgate Safety Meetings will begin the start of eachwork day to remind, outline and discuss any new or old activities that willbe conducted. An example of ENTACTs Tailgate Safety Meeting formis located in Appendix C.

XI. OPEN TRENCH SAFETY

A. As per Occupational Safety and Health Administration (OSHA), EN-TACT adheres to its Construction Standards for Excavations, 29 CFRpart 1926, Subpart P. ENTACT recognizes the importance of Trenchsafety, with this in mind ENTACT enrolls its field personnel in OSHAapproved Open Trench Safety classes. Under close supervision, allexcavation will be handled with caution.

XH. EXCLUSION ZONE

A. For the safety of the residents in the community, ENTACT per-sonnel will design and construct temporary barriers. The barrierswill include traffic cones, caution tape, and painted plywood orlike materials. Additionally the Exclusion Safety Zone will beestablished in the area surrounding the actual excavation opera-tions. Approximately fifty (50) feet in front of, and to the rear of,the excavation equipment and twenty (20) feet on each side willbe included in the Exclusion Zone. The primary reason for in-creased exclusion in this area is to prevent incidental entry intothe path of the excavation equipment.

XIII. TRAFFIC CONTROL

ENTACT knows the importance of proper traffic control. Keepingthis in perspective, all areas including posting of warning signs,flagmen, safety cones and caution tape will be addressed. Inaddition flags will be tied to all outermost swing points of theequipment and operating Machinery.

XIV. PERSONNEL PROTECTION REQUIREMENTS AT EACH JOB ACTIVITY

ENTACT, INC.



A. Site preparation performed in level C: Hard hats, TYVEK suits withhoods and boots, rubber work boots, gloves, safety glasses and, 3-Mnegative pressure half-face respirators with High Efficiency PaniculateAir (HEPA) FILTERS.

B. Soil sampling will be performed in Level C: Hard hats, TYVEKsuits with hoods and boots, rubber work boots, gloves, safetyglasses and, 3-M negative pressure half-face respirators with(HEPA) filters will be utilized.

C. Soil excavation and loading will be performed in Level C: hardhat, work boots, gloves, safety glasses, hearing protection (ifnecessary), and 3-M half face negative pressure respirators with(HEPA) filters and TYVEK suits will be utilized.

D. Site cleanup/restoration will be performed in Level C: Hard hats,TYVEK, work boots, gloves, and safety glasses will be worn.

XV. XRF PRECAUTIONS

A. Spectrace 9000 X-Ray Fluorescence Analyzer

The Spectrace 9000 Field Portable X-Ray Fluorescence Analyzerutilizes three (3) radioactive isotopes with the following activities:

SOURCE ACTIVITY

Cadmium-10 5 millicuriesAmericium-241 5 millicuriesIron-55 50 millicuries

Each isotope is tested for leakage and/or contamination every sixmonths in accordance with the Regulations for Control of Radia-tion. In the event that the leak test reveals the presence of 0.05microcurie or more of leakage or contamination obtained from ateletherapy or a gamma irradiator source of 0.0005 microcurie or more ofleakage or contamination obtained from an}' other type source, theanalyst shall immediately withdraw the source(s) from use and shallpackage it with the appropriate safety covers and packaging to betransported for decontamination and/or repair.

A report, describing the equipment involved, the test results, andthe corrective action taken shall be filed with:

Director, Division of Compliance and InspectionIllinois Department of Nuclear Safety1035 Outer Park Drive

ENTACT, INC.

Village of BeckemeverPipeline Project


Springfield, Illinois 62704

The above Actions will also pertain to any operational malfunction of theXRF that would prohibit the isotopes from being mechanically placedwithin the internal safety shield (i.e., the probe fails to place the isotopesinto the 'safe position').

XVI. SAFETY EQUIPMENT LIST

A. First aid:

Portable first aid kits will be located in central administrationoffice. Small first aid kits may be placed and secured on heavyequipment.

B. Fire protection:

ABC type fire extinguisher will be located in the central adminis-tration office and on each piece of heavy equipment.

C. Communications:

Warning signs will be posted along perimeter barricade fences,and 2-way radio communications will be established between allheavy equipment operators and ground support personnel.

D. PPE;

Work boots, hard hats, TYVEK, safety glasses, half-face respira-tors, and gloves will be worn at all times while working insidespecific work zones.

E. Decon. Equip.:

Boot wash and hand wash stations will be utilized for personnelcleaning before lunch breaks and leaving the work site.

F. Sanitation:

A portable sanitation system will be located on site near centraladministration office

G. PPE Disposal:

Spent PPE will be placed and stored in DOT approved containersstored on site for later handling by ASARCO.

ENTACT, INC.

Village oi BeckemeverPipeline Project


XVII. DECONTAMINATION PROCEDURES

A. Work activities:

Site preparation, excavation, and loading will be performed inLevel C PPE. Hand and boot wash stations will be utilized beforeleaving the job site. All personnel will thoroughly wash hands, arms, faceand boots with water and mild soap. After thoroughly rinsing, disposablehand towels will be used to dry off. All towels and wash water will becollected, sampled and properly disposed.

Upon completion of Removal Action activities, heavy equipment will be decontami-nated in predetermined decon areas for wash water collection. High pressure washingequipment will be utilized to remove residual dust, mud, etc. from heavy equipment.

XVIII. CONTINGENCY PLANS

A. Local sources of assistance:

Posted in on-site central administration office. Local police,hospital, fire, and emergency medical phone numbers will bepositioned near decontamination areas and supply trailer.

B. Emergency Response Agencies

Beckemeyer Fire Dept. 911 or (618) 227-8500Beckemeyer City Police 911 or (618) 227-8500Clinton County Sheriff (618) 594-4555Illinois State Police (618) 346-3990

C. Site phone number (pending)

D. National or regional sources of assistance:

ENTACT 1-214-580-1323EPA-RPM 1-312-886-7503EPA-OSC 1-312-353-2886EPA Region VEmergency 24 Hour Spill Line 1-312-353-2318

E. Evacuation Procedures

To be posted for each i nd iv idua l phase of the

ENTACT, INC.



project. Workers to be instructed prior to start up of each phase of work.Also, escape or exit routes to be clearly marked in each phase.

F. Hospital :

St. Joseph Hospital 1-618-526-4511Emergency 1-618-526-4511Ambulance 1-618-526-4511Fire Dept. 1-618-227-8500

**Note: St. Joseph will be informed of activities that will beperformed on-site. ENTACT will establish a SafetyControl Area to decontaminate victims. St. Joseph hasa Safety Control for dealing with contaminated wasteand victims. Directions to hospital will be determined andposted upon arrival on- site.

G. Utilities

Midwest Cable 1-800-322-6835Illinois Power/Gas 1-800-755-5000Amtech (phone) 1-800-698-4200Digg (line locate) 1-800-892-0123

This site specific Health and Safety Plan is based on information available at the time ofpreparation. Unexpected conditions may arise. It is important that personal protectivemeasures be thoroughly assessed prior to and during the planned activities. Unplannedactivities and/or changes in the hazard status should ini t iate a reviewof major changes in this plan.

Changes in field activities or hazards: _______________________

Proposed Amendments:__

Site Safety Plan Written by:

Site Safety Plan Accepted by:___

Site Safety Plan Approved by:____

ENTACT, INC.

APPENDIX C

eENTACT

I Ml

6025 Commerce 4500LMCOUUM

living, Texas 75Q63214/580-13231-800-788-8897

FAX: 214/550-7464

>IOENTACT P.O. No.:.

Sampler: ____

ENTACT Contact:

Samples Received By:

Samples Relinquished By:

Samples Received By: —


Samples Received By: _


Date

Date

Date

Date

Date

Date

A=.

B =

C =

D =

E =

Job No.:

Dai j: _

Sample No. Type of Sample Description/Remarks Pres arvative

.

Analysis

ANALYSIS

J =

DISTRIBUTION:

Original — To Customer w/Final Report2nd Copy — To Job File3rd Copy — To Lab

eTAILGATE SAFETY MEETING ENTACT

Facility: Date:Job:Gust:

Type of Work:

Chemicals used: ______________________________

SAFETY TOPICS PRESENTED

ATTENDEES

NAME PRINTED SIGNATURE

Meeting Conducted by:

CDMFIOEKTIAL IMfORMATIOH Of EMTACT. IMC.

This document and the information contained herein is the exclusive property of ENTACI, Inc. ENTACT regardsthe document and the ideas in this document as its trade secrets. EHTACT claims Copyright as an unpublishedwork. This document is not to be reproduced in whole or in part without the express written permission ofEHTACT. The information, ideas and expressions contained in this document are not to be disclosed, copied orused in whole or in part without the express written authorization of EMTACT. Any violation uill be enforcedunder the Texas trade secret laws and the Federal Copyright Laws. Copyright EHTACT, Inc. 1994. All rightsreserved.

Documents

FINAL WORK PLAN FOR TIME CRITICAL REMOVAL ACTION IN